Privacy Policy
We are very pleased that you are interested in our company. Data protection is of particular importance to the management of Flowtify GmbH. Use of the Flowtify GmbH website is generally possible without providing any personal data. However, if a data subject wishes to use specific services of our company through our website, the processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and the country-specific data protection regulations applicable to Flowtify GmbH. By means of this Privacy Policy, our company would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Data subjects are also informed of the rights to which they are entitled.
As the controller, Flowtify GmbH has implemented numerous technical and organizational measures to ensure the most complete protection possible of the personal data processed through this website. Nevertheless, internet-based data transmissions can in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
1. Definitions
This Privacy Policy is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our Privacy Policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
We use the following terms in this Privacy Policy, among others:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person ("data subject"). 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.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing
Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting its future processing.
e) Profiling
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 analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
f) Pseudonymization
Pseudonymization means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or person responsible for processing
Controller or person responsible for processing means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient means a natural or legal person, public authority, agency, or other body to which 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 are not regarded as recipients.
j) Third party
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 authorized to process personal data.
k) Consent
Consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.
2. Name and address of the controller
The controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in Member States of the European Union, and other provisions related to data protection is:
Flowtify GmbH
Ehrenfeldgürtel 76
50823 Cologne
Germany
Phone: +49 (0)221 64306225
Email: info [at] flowtify.de
Website: www.flowtify.de
For data protection inquiries, you can reach us at: datenschutz [at] flowtify.de
3. Supervisory authority
The data protection supervisory authority responsible for Flowtify GmbH is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2-4
40213 Düsseldorf, Germany
Phone: +49 211 38424-0
Email: poststelle [at] ldi.nrw.de
Website: www.ldi.nrw.de
4. Cookies
The websites of Flowtify GmbH use cookies. Cookies are text files that are stored on a computer system via an internet browser.
Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified through the unique cookie ID.
By using cookies, Flowtify GmbH can provide users of this website with more user-friendly services that would not be possible without cookies.
The data subject can prevent the setting of cookies through our website at any time by means of a corresponding setting of the internet browser used and can thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
A detailed overview of the cookies we use, their purpose and storage duration, as well as information on third-party cookies, can be found in our Cookie Policy. You can adjust or revoke your consent at any time via the cookie banner.
The legal basis for processing personal data when using technically necessary cookies is Art. 6(1)(f) GDPR (legitimate interest in the reliable operation of the website). For all other cookies, processing is based on your consent pursuant to Art. 6(1)(a) GDPR.
5. Collection of general data and information
Each time the website is accessed by a data subject or an automated system, the Flowtify GmbH website collects a series of general data and information. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-pages accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information used to defend against attacks on our information technology systems.
When using this general data and information, Flowtify GmbH does not draw any conclusions about the data subject. This information is needed to (1) deliver the contents of our website correctly, (2) optimize the contents of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by Flowtify GmbH statistically and with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from any personal data provided by a data subject.
Server log files are stored for a period of seven days and then automatically deleted, unless longer storage is required in individual cases for security purposes or to investigate a specific incident.
6. Hosting
We host our website on Microsoft Azure. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland ("Microsoft").
Processing takes place in data centers operated by Microsoft within the European Union. When you access our website, technically necessary connection data is processed (in particular IP address, date and time of the request, requested URL, transferred data volume, HTTP status code) in order to deliver the website reliably and to protect it against misuse.
The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the reliable, secure, and performant provision of our website. A data processing agreement pursuant to Art. 28 GDPR has been concluded with Microsoft.
For more information on Microsoft's data processing, please refer to Microsoft's privacy statement at https://privacy.microsoft.com/en-us/privacystatement.
7. SSL/TLS encryption
For security reasons and to protect the transmission of confidential content, this website uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser bar.
When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
8. Locally hosted fonts
This website uses the "Inter" font for the consistent display of typefaces. The font files are loaded exclusively locally from our own servers. There is no connection to external providers such as Google Fonts. No data is transmitted to third parties.
The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in a uniform and appealing presentation of our website.
9. Routine deletion and blocking of personal data
The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage, or as required by the European legislator or any other legislator in laws or regulations to which the controller is subject.
If the purpose of storage no longer applies, or if a storage period prescribed by the European legislator or any other competent legislator expires, the personal data is routinely blocked or deleted in accordance with the legal provisions.
10. Rights of the data subject
a) Right to confirmation
Each data subject has the right to obtain confirmation from the controller as to whether or not personal data concerning them is being processed. To exercise this right, a data subject may contact an employee of the controller at any time.
b) Right of access
Each data subject has the right to obtain free information about their stored personal data and a copy of this information from the controller at any time. Furthermore, the data subject has the right to information about the purposes of processing, the categories of personal data concerned, the recipients or categories of recipients, the envisaged storage period, the existence of the right to rectification, erasure, restriction of processing, or objection, the right to lodge a complaint with a supervisory authority, the source of the data, and the existence of automated decision-making including profiling. To exercise this right, a data subject may contact an employee of the controller at any time.
c) Right to rectification
Each data subject has the right to obtain the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by providing a supplementary statement, taking into account the purposes of the processing. To exercise this right, a data subject may contact an employee of the controller at any time.
d) Right to erasure (right to be forgotten)
Each data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the legally specified grounds applies and processing is not necessary. If one of these grounds applies and a data subject wishes to request the erasure of personal data stored at Flowtify GmbH, they may contact an employee of the controller at any time. The Flowtify GmbH employee will ensure that the erasure request is complied with without undue delay.
e) Right to restriction of processing
Each data subject has the right to obtain from the controller the restriction of processing where the accuracy of the personal data is contested, the processing is unlawful, the controller no longer needs the data but the data subject requires it for the establishment, exercise, or defense of legal claims, or the data subject has objected to processing. If one of these conditions applies and a data subject wishes to request the restriction of personal data, they may contact an employee of the controller at any time.
f) Right to data portability
Each data subject has the right to receive personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, where processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and processing is carried out by automated means. To exercise the right to data portability, the data subject may contact an employee of Flowtify GmbH at any time.
g) Right to object
Each data subject has the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions. In the event of an objection, Flowtify GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims. To exercise the right to object, the data subject may contact an employee of Flowtify GmbH at any time.
h) Automated individual decision-making, including profiling
Each data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision is necessary for entering into or performing a contract between the data subject and the controller, is authorized by Union or Member State law, or is based on the data subject's explicit consent. To exercise rights related to automated decisions, the data subject may contact an employee of the controller at any time.
i) Right to withdraw data protection consent
Each data subject has the right to withdraw consent to the processing of personal data at any time. To exercise the right to withdraw consent, the data subject may contact an employee of the controller at any time.
j) Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a data protection supervisory authority regarding our processing of your personal data. The supervisory authority responsible for us is named in Section 3 of this Privacy Policy.
11. Contact via the website
Due to legal regulations, the Flowtify GmbH website contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general email address. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data, transmitted on a voluntary basis by a data subject to the controller, is stored for the purposes of processing or contacting the data subject.
We use the CRM platform Salesforce for our contact form. The provider is Salesforce.com Germany GmbH, Erika-Mann-Straße 31, 80636 Munich, Germany, with corporate ties to salesforce.com, inc., 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA.
The data entered in the contact form (in particular name, email address, telephone number, and any other information provided in the form) is transmitted to Salesforce and stored there for the processing of your inquiry. Transmission to the USA is possible within the corporate structure.
The legal basis is your consent pursuant to Art. 6(1)(a) GDPR and Art. 6(1)(b) GDPR, insofar as your inquiry is aimed at concluding a contract or carrying out pre-contractual measures. A data processing agreement pursuant to Art. 28 GDPR has been concluded with Salesforce. For data transfer to the USA, we rely on the EU-US Data Privacy Framework and additionally on standard contractual clauses pursuant to Art. 46(2)(c) GDPR.
For more information on data processing by Salesforce, please refer to https://www.salesforce.com/company/privacy/.
The data you provide in the contact form is stored by us until you request its deletion, withdraw your consent, or the purpose for storing the data ceases to apply (e.g., after your inquiry has been processed). Mandatory legal provisions, in particular retention periods, remain unaffected.
12. Spam protection via Google reCAPTCHA
To protect our contact form against automated requests (spam), we use the "reCAPTCHA" service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
reCAPTCHA is used to determine whether data entry on our website is performed by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of website visitors based on various characteristics. This analysis begins automatically as soon as you use the contact form. For analysis, reCAPTCHA evaluates in particular the IP address, the time spent on the website, and mouse movements made by the user. The data collected is transmitted to Google.
We integrate reCAPTCHA in such a way that the associated scripts are loaded only when you actively interact with the contact form. No data is transmitted to Google before this point.
The legal basis is your consent pursuant to Art. 6(1)(a) GDPR and our legitimate interest in protection against spam and misuse pursuant to Art. 6(1)(f) GDPR. Transmission to the USA is possible. We rely on the EU-US Data Privacy Framework for this.
For more information on Google reCAPTCHA and Google's privacy policy, please visit https://policies.google.com/privacy and https://www.google.com/recaptcha/about/.
13. Online appointment booking via Acuity Scheduling
On our consultation booking page, we offer the option to book an appointment online. We use the "Acuity Scheduling" service for this. The provider is Squarespace, Inc., 225 Varick Street, 12th Floor, New York, NY 10014, USA ("Squarespace").
The booking widget is not loaded automatically. It is only loaded after you have actively clicked the corresponding button and thereby given your consent to the data processing. Before this, no connection to Squarespace is established.
Once you load the booking widget, data is transmitted to Squarespace. This includes in particular your IP address, technical information about your browser and device, and any data you provide during the booking process (e.g., name, email address, telephone number, requested appointment).
The legal basis is your consent pursuant to Art. 6(1)(a) GDPR by actively loading the booking widget. Transmission to the USA is possible. We rely on the EU-US Data Privacy Framework for this.
For more information on data processing by Squarespace, please refer to their privacy policy at https://www.squarespace.com/privacy.
14. Web analytics with Google Analytics
This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
Google Analytics enables us to analyze the behavior of our website visitors. We receive various usage data, such as page views, time spent on the page, operating system used, and the user's origin. This data is summarized in a user ID and assigned to the respective end-device session of the website visitor.
We use Google Analytics with IP anonymization activated. Your IP address is shortened by Google within Member States of the European Union or other contracting states of the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
Google Analytics sets cookies that enable an analysis of your use of the website (in particular _ga and _ga_<container_id>). These cookies have a storage duration of up to two years.
The legal basis is your consent pursuant to Art. 6(1)(a) GDPR. You can withdraw your consent at any time via the cookie banner or the Cookie Policy. A data processing agreement pursuant to Art. 28 GDPR has been concluded with Google. Transmission to the USA is possible. We rely on the EU-US Data Privacy Framework for this.
For more information on data processing by Google Analytics, please refer to Google's privacy policy at https://policies.google.com/privacy.
15. Use of AI-generated images
All images used on this website were created using artificial intelligence. They are exclusively synthetically generated representations that do not depict real people, places, or brands. Any similarities to living or deceased persons are unintentional and coincidental. The use of these images does not affect any personality rights, image rights, or trademark rights.
16. Legal basis for processing
Art. 6(1)(a) GDPR serves as the legal basis for processing operations for 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 the data subject is a party, as is the case, for example, with processing operations necessary for the supply of goods or the provision of any other service or consideration, processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfillment of tax obligations, processing is based on Art. 6(1)(c) GDPR. Finally, processing operations may be based on Art. 6(1)(f) GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases, where processing is necessary for the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests, fundamental rights, or fundamental freedoms of the data subject.
17. Legitimate interests pursued by the controller or a third party
Where processing of personal data is based on Art. 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and shareholders.
18. Period for which personal data is stored
The criterion for the duration of storage of personal data is the respective statutory retention period. After the period has expired, the corresponding data is routinely deleted, provided it is no longer required for contract performance or contract initiation.
19. Statutory or contractual provisions on the provision of personal data
We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information about the contractual partner). It may sometimes be necessary for the conclusion of a contract that a data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.
20. Existence of automated decision-making
As a responsible company, we do not use automated decision-making or profiling.
21. Updates to this Privacy Policy
We reserve the right to adapt this Privacy Policy from time to time so that it always complies with current legal requirements or to reflect changes to our services in the Privacy Policy, for example when introducing new services. The new Privacy Policy will then apply to your next visit.