1. Introduction

We would like to use the information below to provide you “data subject” with an overview of our processing of your personal data and your rights under data protection law. It is generally possible to use our website without entering personal data. However, if you wish to make use of special services offered by our company through our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we will generally obtain your consent. Personal data, such as your name, address or email address, is always processed in accordance with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the “Seventh Signal (CY) Ltd.”. The aim of this Privacy Notice is to inform you about the scope and purpose of the personal data we collect, use and process. As the data controller, we have implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, as a rule, internet-based data transmissions may have security gaps, and we are unable to guarantee absolute protection. Because of this, you are free to send us personal data by alternative means, for example by telephone or post.

2. Data controller

The data controller, as defined by the GDPR, is:

Seventh Signal (CY) Ltd.
Arsakeiou 19, 2045 Strovolos, Cyprus

Phone: +357 24 020210

Email: info@seventhsignal.eu

3. Data protection officer

You can reach the data protection officer as follows:

Seventh Signal (CY) Ltd.
ATTN: Data Protection Officer
Arsakeiou 19, 2045 Strovolos, Cyprus

Email: dpo@seventhsignal.eu

You may contact our data protection officer directly at any time if you have any questions or suggestions regarding data protection.

4. Definitions

This Privacy Notice uses terms based on those used by European lawmakers in adopting the General Data Protection Regulation (GDPR). Our Privacy Notice should be easy for the public as well as our customers and business partners to read and understand. To ensure this is the case, we would like to explain the terms used in advance. We use the following terms in this Privacy Notice, among others:

1. Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Data subject A data subject is any identified or identifiable natural person whose personal data is processed by the data controller (our company).
3. Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
4. Restriction to processing Restriction to the processing means marking stored personal data with the aim of limiting its processing in future.
5. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
6. Pseudonymisation Pseudonymisation is the processing of personal data in such a way that the data can no longer be assigned to a specific data subject without additional information being provided, given that such additional information is kept separate and subject to appropriate technical and organisational measures that ensure that personal data cannot be attributed to an identified or identifiable natural person.
7. Data processor The processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
8. Recipient means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
9. Third parties Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
10. Consent Consent is any unambiguous voluntary declaration of consent given by the data subject for a specific case in an informed manner in the form of a statement or other action clearly confirming consent (ticking a box) with which the data subject indicates their agreement to their personal data being processed.

5. Legal basis for processing

Article 6 Paragraph 1(a) GDPR serves as our company’s legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Article 6 Paragraph 1(b) GDPR. The same applies to those processing operations required to carry out pre-contractual measures, such as in cases of queries regarding our products or services. If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Article 6 Paragraph 1(c) GDPR. In rare cases, processing personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if someone visiting our business were to be injured and their name, age, health insurance data or other vital information needed to be disclosed to a doctor, hospital or another third party. Processing would then be based on Article 6 Paragraph 1(d) GDPR. Finally, processing operations could be based on Article 6 Paragraph 1(f) GDPR. Processing operations not based on any of the above-mentioned legal bases may be carried out on the basis of Article 6 Paragraph 1(f) GDPR if the processing is necessary to safeguard the legitimate interests of our company or those of a third party, provided the interests and fundamental rights and freedoms of the data subject do not take precedence. We are permitted to engage in such processing operations in particular because they have been specifically mentioned in European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47 Sentence 2 GDPR).

6. Technology

6.1 SSL/TLS encryption

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login details or contact requests that you send to us as the website operator. You can recognise an encrypted connection by your browser’s address bar reading “https://” instead of “http://” and the lock symbol in the browser bar. If SSL or TLS encryption is activated, the data you send us cannot be read by third parties.

6.2 Data collection when visiting the website

If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (in what is known as “server log files”). Our website collects a range of general data and information each time you access a website or an automated system. This general data and information is stored in the server’s log files. The browser

1. types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system accesses our website (called a referrer),
4. the sub-pages accessed via an accessing system on our website,
5. the date and time the website is accessed,
6. a truncated internet protocol address (anonymised IP address) and
7. the accessing system’s internet service provider may be collected.

No conclusions are drawn about you when using this general data and information. Instead, this information is needed

1. to properly deliver our website content,
2. to optimise the content of our website as well as to advertise it,
3. to ensure the continued functioning of our IT systems and our website’s technology
4. as well as to provide the information necessary for law enforcement authorities to prosecute in the event of a cyber attack.

This collected data and information is therefore statistically analysed and further analysed by us with the aim of increasing data protection and data security within our company to ultimately ensure an optimum level of protection for the personal data being processed by us. The anonymous data from the server log files is stored separately from all personal data provided by a data subject. The legal basis for data processing is Article 6 Paragraph 1 Sentence 1(f) GDPR. Our legitimate interest is based on the purposes listed above for the collection of data.

7. Cookies

7.1 General information about cookies

We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not harm your device and do not contain viruses, trojan horses or other malware. Information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity. The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are erased automatically when you leave our website. We also use temporary cookies to optimise user-friendliness. These cookies are stored on your device for a specific period of time. If you return to our website to use our services, cookies allow us to automatically recognise that you have visited our website previously and remember the inputs and settings you have made so that you do not have to enter them again. We also use cookies to statistically record the use of our website and analyse it for the purpose of optimising our services. These cookies allow us to automatically recognise that you have already visited our website when you visit our website again. These cookies are automatically erased after a defined period of time. The processing of data through cookies for the purposes stated above is necessary in order to safeguard our legitimate interests pursuant to Article 6 Paragraph 1 Sentence 1(f) GDPR. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or so a message is always displayed before a new cookie is created. However, if you disable cookies completely, you may not be able to use all the features on our website.

7.2 Cookie Opt-in

In accordance with Article 6 Paragraph 1(a) GDPR, you have given your consent to this through our opt-in cookie banner.

8. Contents of our website

8.1 Data processing when opening a customer account and for contract execution

Pursuant to Article 6 Paragraph 1(b) GDPR, personal data is collected and processed if you provide it to us for the execution of a contract or when opening a customer account. The data collected is shown in each input form. You may erase your customer account at any time by sending a message to the data controller’s address as stated above. We store and use the data you provide to execute contracts. After complete execution of the contract or erasure of your customer account, your data will be blocked, taking into account tax and commercial retention periods, and erased once these periods have expired unless you have expressly consented to the further use of your data or we are legally permitted to further use your data, about which we will inform you below.

8.2 Data processing for order processing

The personal data we collect is disclosed to the transport company hired to deliver goods under the scope of contract execution, provided this is necessary for the delivery of the goods. We disclose your payment details to the bank commissioned as part of payment processing, provided this is necessary for payment processing. If payment service providers are used, we will explicitly inform you about this below. The legal basis for this transfer of data is Article 6 Paragraph 1(b) GDPR.

8.3 Contact/contact form

Personal data is collected when you contact us (e.g. using our contact form or by email). If you use a contact form to get in touch with us, the contact form you use will indicate the data being collected. This data is stored and used exclusively for the purpose of responding to your query or establishing contact and the associated technical administration. The legal basis for data processing is our legitimate interest in responding to your request pursuant to Article 6 Paragraph 1(f)f GDPR. If the aim of you contacting us is to conclude a contract, processing is also legally based on Article 6 Paragraph 1(b) GDPR. Your data will be erased once we have finished processing your query. This is the case when it can be inferred from the circumstances that the relevant facts have been clarified in a conclusive manner and there are no statutory retention obligations in place that prevent its erasure.

8.4 Comment function on the blog

We offer users the opportunity to leave individual comments on individual blog posts on a blog located on our website. A blog is a portal maintained on a website, usually open to the public, in which one or more people called bloggers or web bloggers can post articles or write thoughts in what are termed blog posts. Blog posts can usually be commented on by third parties. If you leave a comment on the blog published on this website, your comments will be stored and published, as will information about the date and time of posting the comment and your chosen user name (pseudonym). The IP address assigned by your Internet Service Provider (ISP) is also logged. IP addresses are stored for security reasons and in the event that you have violated the rights of third parties or posted illegal content through a comment. The storage of this personal data is therefore in our own interest so that we can exculpate ourselves in the event of a violation of the law. This represents a legitimate interest within the meaning of Article 6 Paragraph 1(f) GDPR. Personal data collected will not be disclosed to third parties unless such disclosure is required by law or serves our legal defence.

9. Newsletters

9.1 Newsletter for regular customers

If you have provided us with your email address when purchasing goods or services, we reserve the right to send you regular emails with offers on products or services from our collection similar to those you have already purchased. We do not require your specific consent for such purposes as per article 7, paragraph 3 of the UWG (Unfair Competition Act). The sole basis for the data processing is our legitimate interest in personalised direct marketing in line with article 6, paragraph 1 lit. f GDPR. We will not send you any emails should you expressly object to the use of your email address for that purpose. You are entitled to object to the use of your email address for the aforementioned purpose at any time with immediate effect by notifying the data controllers listed in the opening of this statement. By taking this action, you will incur submission fees only in line with basic rates. After receipt of your objection, your email address will immediately be removed for marketing purposes.

9.2 Marketing newsletter

You can subscribe to our newsletter via our website. The input screen determines which personal data are shared with us when subscribing to the newsletter. We use our newsletter to regularly communicate our offers to our customers and business partners. You can, therefore, only receive our company’s newsletter if

1. you have a valid email address and
2. have registered for the newsletter.

For legal reasons, as part of the double opt-in procedure a confirmation email will be sent to the email address you provided when registering for the newsletter. This confirmation email is sent to check if you are the holder of the email address and have authorised the newsletter. When you register for the newsletter we also save the IP address used by your IT system at the time of registration, which is issued by your Internet Service Provider (ISP) as well as the date and time of registration. We must collect this data to investigate any (possible) misuse of your email address at a later stage and it is therefore lawful for the purposes of our security. The personal data collected during registration are used solely for sending our newsletter. Furthermore, subscribers to the newsletter may receive information via email if this is required in order to administer the newsletter service for registration purposes, which may be the case if our newsletter is amended or technical circumstances change. Personal data collected for our newsletter service are not shared with third parties. You may terminate your subscription to our newsletter at any time. You can at any time withdraw your consent to the storage of the personal data you shared during registration. A link is provided in each newsletter to allow you to withdraw your consent. It is also possible to unsubscribe from our newsletter directly through the website or to contact us in another manner. The legal basis for data processing for the purposes of sending a newsletter is article 6, paragraph 1 lit. a GDPR.

9.3 Mailchimp

Our email newsletters are sent via the technical service provider The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (https://www.mailchimp.com/), to whom we forward the data you provided when registering for the newsletter. This disclosure is made in accordance with Article 6 Paragraph 1(f) GDPR and serves our legitimate interest in the use of an effective, secure and user-friendly newsletter system. Please note that your data is usually transferred to a MailChimp server in the US and stored there. MailChimp uses this information to send and statistically analyse our newsletter on our behalf. For analysis purposes, the emails sent contain what are known as web beacons or tracking pixels, which are one-pixel image files stored on our website. This allows us to see whether a newsletter email has been opened and what links have been clicked. Technical information is also recorded (e.g. date and time of access, IP address, browser type and operating system). This data is exclusively collected on a pseudonymous basis and will not be linked to your other personal data. It is not possible to use the data collected to identify you. This data is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to the interests of recipients. If you wish to object to the analysis of data for statistical evaluation purposes, you must unsubscribe from the newsletter. Furthermore, MailChimp may use this data itself in accordance with Article 6 Paragraph 1(f) GDPR on the basis of its own legitimate interest in designing a service commensurate with market needs and optimising the service as well as for market research purposes in order to determine, for example, the countries from which newsletter recipients come. However, MailChimp does not use our newsletter recipients’ data to address them directly, nor does it disclose their data to third parties. To protect your data in the US, we have concluded a data processing agreement (“Data Processing Agreement”) with MailChimp based on the standard contractual clauses of the European Commission to enable the transfer of your personal data to MailChimp. If interested, this Data Processing Agreement is available online at the following link: https://mailchimp.com/legal/forms/data-processing-agreement/. In addition, MailChimp is certified under the “Privacy Shield”, a US-European data protection agreement, and is therefore bound to compliance with EU data protection regulations. You can view MailChimp’s privacy policy here: https://mailchimp.com/legal/privacy/

10. Our activities in social networks

To allow us to communicate with you on social networks and inform you about our services, we run our own pages on these social networks. We are not the original provider (data controller) of these pages, but only use them within the scope of the options offered to us by the respective providers We would therefore like to point out as a precautionary measure that your data may also be processed outside of the European Union or the European Economic Area. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your rights to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behaviour by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behaviour may be assigned directly to your own member profile on the respective social network (if you are logged in). The processing operations of personal data described are carried out in accordance with Article 6 Paragraph 1(f) GDPR on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you have to grant your consent to the respective providers to process your data as a user, the legal basis for this processing is Article 6 Paragraph 1(a) GDPR in conjunction with Article 7 GDPR. Since we have no access to these providers’ databases, we would like to point out that you would be best placed to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider. More information on the processing of your data on social networks and your options for exercising your right to object or your right of revocation (opt out) is listed below for each of the social network providers we use:

10.1 Facebook

Data controller responsible for data processing in Europe: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland Privacy Notice (Data Policy): https://www.facebook.com/about/privacy Opt-out and advertising settings: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen Facebook has joined the EU-US Privacy Shield Agreement: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active https://facebook.com/about/privacy/

10.2 LinkedIn

Data controller responsible for data processing in Europe: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland Privacy Notice: https://www.linkedin.com/legal/privacy-policy Opt-out and advertising settings: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out LinkedIn has joined the EU-US Privacy Shield Agreement: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active

10.3 Twitter

Data controller responsible for data processing in Europe: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland Privacy Notice: https://twitter.com/en/privacy Information about your data: https://twitter.com/settings/your_twitter_dataOpt-out and advertising settings: https://twitter.com/personalization

11. Web analytics

11.1 Matomo

On this website we have integrated the component Matomo of the supplier InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand. Matomo is a software tool for web analysis, ie for the collection, collection and analysis of data on the behaviour of visitors to websites. Among other things, data are collected on which website an affected person has come to a website (the so-called referrer), which subpages of the website were accessed or how often and for which length of stay a subpage was viewed. This is used to optimize the website and cost-benefit analysis of Internet advertising. The purpose of the Matomo component is to analyse the flow of visitors to our website. Among other things, we use the data and information obtained to evaluate the use of this website and to compile online reports for us that show activity on our website. Matomo sets a cookie on your IT system. By setting the cookie, we are enabled to analyze the use of our website. Each time you visit one of the pages on this website, the Internet browser on your IT system automatically causes the Matomo component to submit data to our server for online analysis. In the course of this technical process, we gain knowledge of personal data, such as the IP address of the person concerned, which among other things serves to help us understand the origin of visitors and clicks. The cookie stores personal information, such as access time, the place from which access was made, and the frequency of visits to our website. Each time you visit our website, this personal information, including the IP address of the Internet connection you use, is transmitted to our server. These personal data are stored by us. We do not share this personal information with third parties. You can prevent the setting of cookies through our website at any time by means of a corresponding setting of the Internet browser used and thus permanently contradict the setting of cookies. Such a setting of the Internet browser used would also prevent Matomo from setting a cookie on your IT system. In addition, a cookie already set by Matomo can be deleted at any time via an internet browser or other software programs. You also have the option of objecting to and preventing the collection of the data generated by Matomo relating to the use of this website. You need to set an opt-out cookie to do this. If your IT system is later erased, formatted or reinstalled, the data subject will need to set an opt-out cookie again. However, setting an opt-out cookie may result in you being unable to make full use of our website. These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR.

12. Your rights as a data subject

12.1 Right to confirmation

You have the right to request confirmation from us as to whether personal data relating to you will be processed.

12.2 Right to information (Article 15 GDPR)

You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us.

12.3 Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

12.4 Erasure (Article 17 GDPR)

You have the right to request that we erase your personal data, provided one of the reasons stipulated by law applies and if processing is not necessary.

12.5 Restriction to processing (Article 18 GDPR)

You have the right to request that we restrict the processing of your data if one of the legal requirements is met.

12.6 Data transferability (Article 20 GDPR)

You have the right obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 Paragraph 1(a) GDPR or Article 9 Paragraph 2(a) GDPR or on a contract pursuant to Article 6 Paragraph 1(b) GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us. Furthermore, when exercising your right to data transferability pursuant to Article 20 Paragraph 1 GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.

12.7 Objection (Article 21 GDPR)

You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1(e) (data processing in the public interest) or (f) (data processing on the basis of the weighing of legitimate interests) GDPR. This also applies to profiling based on these provisions pursuant to Article 4 Number 4 GDPR. Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims. In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose. In addition, you have the right to object to our processing of your personal data for scientific or historical research purposes or for statistical purposes pursuant to Article 89 Paragraph 1 GDPR for reasons arising from your particular situation, unless such processing is necessary for the performance of a task in the public interest. You are free to exercise your right to lodge an objection in relation to the use of information society services, Directive 2002/58/EC notwithstanding, by means of automated procedures using technical specifications.

12.8 Revocation of consent regarding data protection

You have the right to revoke any consent to the processing of personal data at any time with future effect.

12.9 Lodging a complaint with a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

13. Duration of storage of personal data

The criterion for the duration of the retention of personal data is the respective legal retention period. Once this period expires, the data in question will be routinely erased, provided it is no longer required for the fulfilment or initiation of the contract.

14. Version and amendments to the Privacy Notice

This Privacy Notice is currently valid and was last updated on January 2020. It may be necessary for us to amend this Privacy Notice in the process of further developing our website and the services we offer through our website or due to changes in legal or regulatory requirements.

You can view and print our current Privacy Notice on the website at any time by visiting “https://www.seventhsignal.eu/privacy-notice”.

This privacy statement has been prepared with the assistance of the privacy software: audatis MANAGER.