Privacy policy

§ 1 Information on the collection of personal data

(1) In the following we inform about the collection of personal data when using our website. Personal data are all data that are personally identifiable to you, e.g. name, address, e-mail addresses, user behaviour.

(2) The person responsible pursuant to Art. 4 VII DS-GVO is twoplus Ifran & Horvath GbR, represented by Fernando Ifran and Leticia Horvath, Mainzer Str. 24, 10247 Berlin, Germany; Email: hello@wearetwoplus.com. (see our legal notices).

(3) When you contact us via e-mail or a contact form, the data you provide (your e-mail address, if applicable your name and your telephone number) will be stored by us in order to answer your questions. We delete the data arising in this context after the storage is no longer necessary, or limit the processing if statutory retention obligations exist.

(4) If we make use of contracted service providers for individual functions of our offer or would like to use your data for advertising purposes, we will inform you in detail about the respective processes below. We also specify the defined criteria for the storage period.

§ 2 Your rights

(1) You have the following rights towards us with regard to personal data concerning you:

  • Right of information,
  • Right of correction or deletion,
  • Right of limitation of processing,
  • Right of opposition to the data processing,
  • Right to data Transferability.

(2) You also have the right to complain to a data protection supervisory authority about our processing of your personal data.

§ 3 Collection of personal data when visiting our website

(1) When using the website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which are technically necessary for us to display our website to you and to guarantee stability and security (legal basis is Art. 6 Para. 1 S. 1 lit. f DS-GVO):

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • The amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive assigned to the browser you use and through which certain information flows to the place that sets the cookie (here by us). Cookies cannot run programs or transmit viruses to your computer. They serve to make the Internet offer more user-friendly and effective overall.

(3) Use of cookies:

a) This website uses the following types of cookies, the scope and functioning of which are explained below:

Transient cookies (see b)

Persistent cookies (see c)

b) Transient cookies are automatically deleted when you close your browser. This includes in particular the session cookies. These store a so-called session ID, with which different requests of your browser can be assigned to the common session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close your browser.

c) Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser.

d) You can configure your browser settings according to your wishes and, for example, refuse the acceptance of third party cookies or all cookies. Please note that you may not be able to use all functions of this website.

e) We use cookies to identify you for follow-up visits if you have an account with us. Otherwise you will have to log in again for each visit.

Manage cookies preferences

§ 4 Facebook Custom Audiences & Facebook Pixel

We use the remarketing function "Custom Audiences" and the visitor action pixel "Facebook Pixel" from Facebook. Provider is Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").

The Facebook pixel allows Facebook to identify visitors to our online service as a target group for displaying ads (so-called "Facebook ads"). This enables us to define that the Facebook ads placed by us are only displayed to Facebook users who have an interest in our online service or who have interests/characteristics defined by us (so-called "custom audiences"). In addition, the Facebook pixel enables us to analyze the effectiveness of Facebook advertisements for statistical and market research purposes.

Further information and details about the Facebook pixel and how it works can be found here: https://www.facebook.com/business/help/651294705016616. You can object to the collection and use of your data and/or change your settings at https://www.facebook.com/settings?tab=ads. In addition, you may opt-out of the use of cookies, which are used to track reach and serve advertising purposes, via the Network Advertising Initiative opt-out page (http://optout.networkadvertising.org/), via the U.S. website (http://www.aboutads.info/choices), or via the European website (http://www.youronlinechoices.com/uk/your-ad-choices/). Facebook is certified under the Privacy Shield Agreement and thereby provides a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

The legal basis for the processing of your data is a legitimate interest pursuant to Art. 6 Para. 1 S. 1 lit. f DS-GVO. Further information on data processing by Facebook can be found at https://www.facebook.com/about/privacy.

§ 5 Newsletter

(1) With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers. The advertised goods and services are named in the declaration of consent.

(2) We use the double opt-in procedure to subscribe to our newsletter. This means that after your registration we will send you an e-mail to the specified e-mail address in which we ask you to confirm that you would like the newsletter to be sent. If you do not confirm your registration within [24 hours], your information will be blocked and automatically deleted after one month. In addition, we store your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

(3) The only required information for sending the newsletter are your e-mail address and your name. The indication of further, separately marked data is voluntary and is used to be able to address you personally. After your confirmation, we will save your e-mail address for the purpose of sending you the newsletter. The legal basis is Art. 6 I 1 a) DS-GVO.

(4) You can revoke your consent to the sending of the newsletter at any time and cancel the newsletter. You can declare your revocation by clicking on the link provided in every newsletter e-mail, by e-mail to support@holabrief.com or by sending a message to the contact details stated in the imprint.

§ 6 Google Analytics

(1) This website uses Google Analytics, a web analysis service of Google Inc. "("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with further services associated with website and Internet use.

(2) The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

(3) You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

(4) This website uses Google Analytics with the extension "_anonymizeIp()". As a result, IP addresses are further processed in abbreviated form to exclude an affiliation to people. As far as the data collected about you is personal, it will be excluded immediately and the personal data will be deleted immediately.

(5) We use Google Analytics to analyze and regularly improve the use of our website. We can improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 I 1 f) DS-GVO.

(6) Third Party Information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User conditions: http://www.google.com/analytics/terms/de.html, Übersicht zum Datenschutz: http://www.google.com/intl/de/analytics/learn/privacy.html, sowie die Datenschutzerklärung: http://www.google.de/intl/de/policies/privacy.

§ 7 Autopilot

Newsletters are sent via the "Autopilot" mailing service, a marketing automation platform of the US provider AutopilotHQ, Inc. 149 New Montgomery St, 4th Floor, Suite 631, San Francisco, CA, 94105, USA. The privacy policy of the mail service provider can be found here: https://www.autopilothq.com/legal/privacy-policy. AutopilotHQ, Inc. is certified under the Privacy Shield Agreement, thereby providing a guarantee of compliance with the European level of data protection ( https://www.privacyshield.gov/participant?id=a2zt0000000TRfOAAW ). The mail service provider is used on the basis of our legitimate interests according to Art. 6 para. 1 lit. f DS-GVO and an order processing contract according to Art. 28 para. 3 p. 1 DS-GVO. The mail service provider may use the recipient's data in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of the dispatch and presentation of the newsletters or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

§ 8 Hotjar

Our website uses the Hotjar web analytics service provided by Hotjar Ltd (Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe, Tel: +1 (855) 464-6788).

Hotjar analyzes usage behavior on our website by tracking movements such as your mouse and scroll movements and clicks. Hotjar can also determine how long you stayed with the mouse pointer in a certain place, how long you were on our website and when you left it. Hotjar uses this information to create so-called heat maps, which can be used to determine which areas of the website are preferred by you as website visitor. We can also determine at which point you have interrupted your entries in a contact form (so-called conversion tunnels). Finally, we can obtain direct feedback from Hotjar. With these functions we can make our website more user-friendly, more valuable and easier for the end users to use.

With Hotjar, we can track which buttons are clicked, the course of the mouse, how far it scrolls, the screen size of the device, device type and browser information, geographic location (country only) and the preferred language to display our website. Areas of the websites in which personal data from you or third parties is displayed are automatically hidden by Hotjar and can therefore not be traced at any time. In order to exclude the possibility of direct personal references, IP addresses are only stored and processed anonymously.

However, we would like to point out that Hotjar uses various services from third-party providers such as Google Analytics and Optimizely. It may therefore be the case that these services collect data that is transmitted by your browser as part of web page requests. These would be cookies or your IP address, for example. In these exceptional cases, this processing is carried out in accordance with Art. 6 para. 1 lit. a DSGVO on the basis of the consent you have given for the purpose of statistical analysis of user behaviour for optimisation and marketing purposes.

If you wish to disable Hotjar's data collection, click on the following link and follow the instructions there: https://www.hotjar.com/legal/compliance/opt-out/.

For more information about Hotjar Ltd. and the Hotjar tool, please visit https://www.hotjar.com. The Hotjar Ltd. privacy policy can be found at: https://www.hotjar.com/privacy/.

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