This privacy policy explains the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "person responsible", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
SDCH Handelslösungen UG (haftungsbeschränkt)
c/o Digital Hub Logistics
Am Sandtorkai 32
20457 Hamburg
Managing Director: Ricardo Henriquez
+49 174 4767013
ricardo @ tradeledge.com
- Inventory data (e.g., names, addresses).
- Contact details (e.g., email, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g. websites visited, interest in content, access times).
- Meta / communication data (e.g. device information, IP addresses).
Visitors and users of the online offer (in the following we also refer to the persons concerned as "users").
- Provision of the online offer, its functions and content.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach measurement / marketing.
"Personal data" is all information that relates to an identified or identifiable
natural person (hereinafter “data subject”); A natural person is regarded as identifiable who can be identified
directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number,
location data, an online identifier (e.g. cookie) or one or more special features, which express the physical, physiological,
genetic, psychological, economic, cultural or social identity of this natural person.
“Processing” is any process carried out with or without the aid of automated
processes or any such series of processes in connection with personal data. The term is broad and includes practically
every handling of data.
"Pseudonymisation" is the processing of personal data in such a way that the
personal data can no longer be assigned to a specific data subject without the use of additional information, provided
that this additional information is stored separately and is subject to technical and organizational measures that ensure
that the personal data cannot be assigned to an identified or identifiable natural person.
“Profiling” means any type of automated processing of personal data that
consists of using this personal data to evaluate certain personal aspects that relate to a natural person, in
particular aspects relating to work performance, economic situation, health, personal To analyze or predict the
preferences, interests, reliability, behavior, whereabouts or relocation of this natural person.
"Person responsible” is the natural or legal person, authority, institution
or other body that alone or jointly with others decides on the purposes and means of processing personal data.
"Processor" means a natural or legal person, authority, institution or other
body that processes personal data on behalf of the person responsible.
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing to safeguard our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as the legal basis.
In accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the type, scope,
circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk for
the rights and freedoms of natural persons, we make suitable technical and organizational measures to ensure a level of
protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical
access to the data, as well as the access, input, forwarding, ensuring availability and their separation. Furthermore, we have
set up procedures that ensure that data subjects' rights are exercised, that data are deleted and that data are responded to at
risk. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software
and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default
settings (Art. 25 GDPR).
If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing,
transmit them to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if
the data is transmitted to third parties, such as to payment service providers, according to Art. 6 Para. 1 lit. b GDPR is
required to fulfill the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate
interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done
on the basis of Art. 28 GDPR.
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it happens to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
You have the right to request confirmation as to whether the data in question is being processed and to request information
about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have according to Art. 16 GDPR the right to request the completion of the data concerning you or the correction
of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or,
alternatively, in accordance with Art. 18 GDPR, to request a restriction on the processing of the data.
You have the right to request that you receive the data concerning you that you have provided to us in accordance
with Art. 20 GDPR and to request that it be transmitted to other responsible parties.
You also have, pursuant to Art. 77 GDPR, the right to lodge a complaint with the competent supervisory authority.
You have the right to revoke your consent in accordance with Art. 7 Para. 3 GDPR with effect for the future.
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection can in particular be made against processing for direct marketing purposes.
"Cookies" are small files that are stored on the users' computers. Various information can be stored within the cookies.
A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or
after their visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that
are deleted after a user leaves an online offer and closes his browser. The contents of a shopping cart in an online
shop or a login status can be stored in such a cookie. Cookies are referred to as "permanent" or "persistent" and remain
stored even after the browser is closed. For example, the login status can be saved if users visit it after several days.
The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing
purposes. "Third-party cookies" are cookies that are offered by providers other than the person responsible for
operating the online offer (otherwise, if it is only their cookies, they are referred to as "first-party cookies").
We can use temporary and permanent cookies and clarify this as part of our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option
in the system settings of their browser.
Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional
restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be made for a large number of services,
especially in the case of tracking, on the US website https://optout.aboutads.info/ or the EU website
https://www.youronlinechoices.com/ explained. Furthermore, cookies can be saved by deactivating them in the browser
settings. Please note that you may then not be able to use all the functions of this online offer.
The data processed by us will be deleted or restricted in their processing in accordance with Art. 17 and 18 GDPR. Unless expressly
stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended
purpose and the deletion does not conflict with any statutory retention requirements. If the data is not deleted because it is required
for other legally permissible purposes, its processing will be restricted. In other words, the data is blocked and not processed for
other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1
Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, more relevant for taxation Documents,
etc.) and 6 years according to § 257 Paragraph 1 No. 2 and 3, Paragraph 4 HGB (commercial letters).
According to legal requirements in Austria, the storage takes place in particular for 7 years in accordance with § 132 para. 1 BAO
(accounting documents, receipts / invoices, accounts, receipts, business papers, list of income and expenses, etc.), for 22 years
in connection with land and for 10 years for documents in connection with electronically provided services, telecommunications,
radio and television services that are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
We process the data of our customers as part of our contractual services, which include conceptual and strategic advice, campaign planning,
software and design development / advice or maintenance, implementation of campaigns and processes / handling, server administration,
data analysis / consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data
(e.g., text entries, photographs, videos), contract data (e.g., subject of the contract, term), payment data (e.g., Bank details, payment history),
usage and metadata (e.g. in the context of evaluating and measuring the success of marketing measures). In principle, we do not process special
categories of personal data, unless these are part of a commissioned processing. Those affected include our customers, interested parties and their
customers, users, website visitors or employees as well as third parties. The purpose of processing is to provide contractual services, billing and
our customer service. The legal basis for processing results from Art. 6 Para. 1 lit. b GDPR (contractual services), Art. 6 Para. 1 lit. f GDPR
(analysis, statistics, optimization, security measures). We process data that are necessary for the establishment and fulfillment of the contractual
services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of an
order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements
for order processing in accordance with. Art. 28 GDPR and do not process the data for any purposes other than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. the necessity of data retention is reviewed every three years.
In the case of the statutory archiving obligations, the deletion takes place after their expiry (6 years, according to § 257 paragraph 1 HGB, 10 years,
according to § 147 paragraph 1 AO). In the case of data that has been disclosed to us in the context of an order by the client, we delete the data in
accordance with the specifications of the order, generally after the end of the order.
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners
(uniformly referred to as "contractual partners") in accordance with Art. 6 Para. 1 lit. b. GDPR in order to provide you with our contractual or
pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying
contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact details (e.g. e-mail addresses and
telephone numbers) as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons)
and payment data (e.g., Bank details, payment history).
As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned or contractual processing.
We process data that are required for the establishment and fulfillment of the contractual services and point out the necessity of their disclosure,
if this is not evident for the contractual partner. Disclosure to external persons or companies only takes place if it is required in the context of
a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements.
When using our online services, we can save the IP address and the time of the respective user action. The storage takes
place on the basis of our legitimate interests, as well as the interests of the users in protection against misuse and other
unauthorized use. A transfer of this data to third parties does not take place, unless it is to pursue our claims acc.
Art. 6 para. 1 lit. f. GDPR required or there is a legal obligation to do so in accordance with. Art. 6 para. 1 lit. c. GDPR.
The data will be deleted when the data is no longer required to fulfill contractual or statutory duties of care and to deal
with any warranty or comparable obligations, whereby the need to store the data is checked every three years; Otherwise,
the statutory retention requirements apply.
We process data in the context of administrative tasks as well as the organization of our operations, financial accounting
and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the
context of providing our contractual services. The processing bases are Art. 6 Para. 1 lit. c. GDPR, Art. 6 Para. 1 lit. f. GDPR.
Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest
in processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to
maintain our business activities, perform our tasks and provide our services. The deletion of the data with regard to contractual
services and contractual communication corresponds to the information given for these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax consultants or auditors, as well as other
fee offices and payment service providers.
Furthermore, on the basis of our business interests, we store information on suppliers, organizers and other business partners,
e.g. for the purpose of later contact. We generally store this mostly company-related data permanently.
When contacting us (e.g. via the contact form, email, telephone or via social media), the information provided by the user
is used to process the contact request and to process it in accordance with. Art. 6 para. 1 lit. b. (within the framework
of contractual / pre-contractual relationships), Art. 6 Para. 1 lit. f. (other inquiries) GDPR processed. The user information
can be stored in a customer relationship management system (“CRM system”) or a comparable inquiry organization.
We delete the requests if they are no longer required. We review the requirement every two years.
The statutory archiving obligations also apply.
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer. We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer based on our legitimate interests in an efficient and secure provision of this online offer in accordance with. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of an order processing contract).
We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and
communication data from customers, interested parties and visitors to this online offer based on our legitimate
interests in an efficient and secure provision of this online offer in accordance with. Art. 6 para. 1 lit. f GDPR
in conjunction with Art. 28 GDPR (conclusion of an order processing contract).
For security reasons (e.g. to investigate acts of abuse or fraud), log file information is stored for a maximum
of 7 days and then deleted. Data, the further storage of which is necessary for evidence purposes, are excluded
from deletion until the respective incident has been finally clarified.
We maintain an online presence within social networks and platforms in order to be able to communicate with the customers,
interested parties and users active there and to inform them about our services. When calling up the respective networks
and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of the users if they communicate
with us within the social networks and platforms, e.g. write articles on our online presence or send us messages.
We use content or service offers from third-party providers within our online offer based on our legitimate interests
(i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6
Para. 1 lit. f GDPR). Integrate services such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the user, since
they would not be able to send the content to their browser without the IP address. The IP address is therefore
required to display this content. We strive to only use content whose respective providers only use the IP address
to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as
“web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as
visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the
user's device and contain, among other things, technical information about the browser and operating system,
referring websites, visiting time and other information about the use of our online offer, as well as being
linked to such information from other sources.
We integrate the fonts (“Google Fonts”) from the provider Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043,
USA. Data protection declaration:
https://www.google.com/policies/privacy/, Opt-Out:
https://adssettings.google.com/authenticated.