Privacy Policy

Privacy Policy

We operate our websites in accordance with the principles set out below:

We undertake to comply with the statutory provisions on data protection and endeavour to always observe the principles of data avoidance and data minimisation.

1. Name and contact details of the responsible person

a) The controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states of the European Union as well as other data protection regulations is:

Eye-Able® Web Inclusion GmbH

Gartenstraße 12c

97276 Margetshöchheim

Phone number: +49 176 64103397

Email address: info@eye-able.com

However, the data controller may vary depending on the offer or purpose of the processing, and another of our Eye-Able® companies may therefore be the data controller. A list of our Eye-Able® companies can be found here.

We, Eye-Able® Web Inclusion GmbH, have agreed with Eye-Able® B.V. and Eye-Able S.r.l. to share responsibility for our marketing and recruitment activities. We will be happy to provide you with this information on request. In this case, please contact our data protection officer.

b) The data protection officer

You can contact the data protection officer of the controller as follows:

Head of Legal & Compliance

Mr Björn Holeschak

Gartenstraße 12c

97276 Margetshöchheim

Email: datenschutz@eye-able.com

c) The competent supervisory authority

The supervisory authority responsible for the company is the Bavarian State Office for Data Protection Supervision.

Postal address:

Postfach 1349

91504 Ansbach

Germany

Website: https://www.lda.bayern.de/de/kontakt.html

Alternatively, you can contact the supervisory authority responsible for your location in your home country.

2. Explanation of terms

We have designed our privacy policy in accordance with the principles of clarity and transparency. However, if you are still unclear about the use of certain terms, you can find the relevant definitions here.

3. Legal basis for data processing

a) Processing of personal data in accordance with the GDPR

We only process your personal data, such as your first and last name, your email address and IP address, etc., if there is a legal basis for doing so. In accordance with the General Data Protection Regulation, the provisions of Art. 6 (1) ff. GDPRapply in particular.

However, we will always inform you again at the relevant points in this privacy policy about the exact legal basis on which your personal data is processed.

b) Consent of legal guardians pursuant to Art. 8 (1) sentence 2 alternative 2 GDPR

A legal guardian must consent to all data processing within the scope of this website for which the consent of a minor under the age of 16 is required.

Information on the individual data processing operations, their purposes and the categories of data concerned for which the consent of the data subject is required can be found in the privacy policy.

You can withdraw your consent at any time by sending a written statement of withdrawal to the contact details of the controller. Processing remains lawful until withdrawal.

c) Processing of information in accordance with country-specific requirements

a. Processing in accordance with Section 25(1) TDDDG (specific to Germany)

We also process information in accordance with Section 25(1) TDDDG by storing information on your end device or accessing information that is already stored on your end device. This may include both personal information and non-personal data, e.g. cookies, browser fingerprints, advertising IDs, MAC addresses and IMEI numbers. An end device is any device directly or indirectly connected to the interface of a public telecommunications network for the purpose of transmitting, processing or receiving messages, Section 2 (2) No. 6 TDDDG.

We usually process this information on the basis of your consent, Section 25 (1) TDDDG.

If an exception under Section 25(2)(1) and (2) TDDDG applies, we do not require your consent. Such an exception applies if we access or store the information exclusively for the purpose of transmitting a message via a public telecommunications network or if this is absolutely necessary in order to provide a telemedia service that you have expressly requested. You can revoke your consent at any time.

We hereby inform you that the revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

4. Transfer of personal data

The transfer of personal data also constitutes processing within the meaning of section 3 above. However, we would like to take this opportunity to inform you separately about the transfer of data to third parties. The protection of your personal data is very important to us. For this reason, we are particularly careful when it comes to passing on your data to third parties.

Data will therefore only be passed on to third parties if there is a legal basis for processing. For example, we pass on personal data to persons or companies who act as processors for us in accordance with Art. 28 GDPR. A processor is anyone who processes personal data on our behalf – i.e. in particular in a relationship of instruction and control with us.

In accordance with the provisions of the GDPR, we conclude a contract with each of our processors to oblige them to comply with data protection regulations and thus to guarantee comprehensive protection for your data.

5. Storage period and deletion

We will delete your personal data if it is no longer necessary for the purposes for which it was collected or otherwise processed, if processing is not necessary for the exercise of the right to freedom of expression and information, for the fulfilment of a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims.

6. SSL or TLS encryption

This website uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as the enquiries you send to us as the website operator. You can recognise 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 line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

7. Cookies

We use cookies on our website. Cookies are small data packets that your browser automatically creates and stores on your device when you visit our website. These cookies are used to store information related to the device you are using.

When using cookies, a distinction is made between technically necessary cookies and ‘additional’ cookies. Technically necessary cookies are those that are strictly necessary to provide an information society service that you have expressly requested.

a) Technically necessary cookies

In order to make the use of our website more pleasant for you, we use technically necessary cookies. These may be so-called session cookies (e.g. language and font selection, shopping basket, etc.), consent cookies, cookies to ensure server stability and security, or similar. The legal basis for the cookies is Art. 6 para. 1 sentence 1 lit. f) GDPR, our legitimate interest in the error-free operation of the website and our interest in providing you with optimised services.

b) Other cookies

Other cookies include cookies for statistical, analysis, marketing and retargeting purposes.

We use these cookies on the basis of your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR.

You can revoke your consent to the use of cookies at any time.

We would like to inform you that the revocation of your consent does not affect the lawfulness of the processing carried out on the basis of your consent until the revocation.

To do this, you can either edit your cookie settings on our website, deactivate the use of cookies in your browser settings (which may also restrict the functionality of the online offer) or opt out of the relevant service on a case-by-case basis.

We will inform you of the legal basis on which this data is processed in the respective services within the privacy policy.

8. Cookie banner / consent management

To obtain consent for the cookies we use, we use the CCM19 cookie banner from the service provider Papoo Software & Media GmbH, Auguststr. 4, 53229, Bonn. This banner sets a so-called consent cookie to query and process the respective consent status. This consent cookie is technically necessary and is therefore used on the basis of our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR, § 25 para. 1 TDDDG.

For the use of some services of the Google/Alphabet group, we use the so-called Google Consent Mode V2 in Basic Mode. Details about this consent mode can be found on Google's website at https://developers.google.com/tag-platform/security/guides/consent?hl=de&consentmode=advanced

The use of Consent Mode is technically necessary and is therefore used on the basis of our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR.

9.Collection and storage of personal data and the nature and purpose of its use

a) Hosting of the website

Our website is hosted on servers belonging to Hetzner AG. This means that all personal data collected on our website runs through the dedicated logical server at Hetzner. This may include your IP address, your email address, communication data or similar information. You can find out exactly what personal data this is in the individual functions and services described below.

If we use an external service provided by a third party, this will be clearly indicated in the description of the respective service or tool. We would like to point out in particular that our shop page is hosted externally. Further information on this can be found in the following paragraph.

As hosting is carried out on our own servers, responsibility for data processing lies entirely with us and is carried out exclusively for the purposes described in this privacy policy.

b) Shop system and hosting of the shop page

To offer our services, we use the shop and hosting system of Shopify International Limited, 2nd Floor, 1-2 Victoria Buildings Haddington Road Dublin 4. D04XN32, Ireland on shop.eye-able.de.

The data you provide will therefore also be processed by our shop provider in the context of operating the shop system and hosting. In addition, the shop system may set further cookies.

For this reason, we have concluded a contract for order data processing/standard contractual clauses with them.

When you visit our shop website, information is automatically sent to Shopify's server. This information is temporarily stored in a so-called log file. The following information is collected without your intervention and stored until it is automatically deleted:

• IP address of the requesting computer

• Date and time of access

• Name and URL of the file accessed

• Website from which access is made (referrer URL)

• Browser used and, if applicable, the operating system of your computer and the name of your access provider

We process the aforementioned data for the following purposes:

• Ensuring a smooth connection to the website

• Ensuring the comfortable use of our website

• Evaluating system security and stability

• Error analysis

• For other administrative purposes

The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the purposes listed above for data collection. Under no circumstances will we use the data collected for the purpose of drawing conclusions about your person.

Further information on data protection can be found at:

https://www.shopify.com/de/legal/datenschutz.

c) Contractual relationship

(1) Conclusion of contract

Within the framework of establishing the contractual relationship, only personal data that is absolutely necessary for the execution of the contract will be processed in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.

If you provide additional voluntary information, this will only be processed on the basis of your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. We use this voluntary information to offer a customer-friendly service and to continuously improve it.

(2) Credit card payment

If you make a credit card payment on our website, we collect and process your necessary personal data and forward it to the card-issuing institution for payment processing and to fulfil legal requirements, such as customer authentication in accordance with the EU Payment Services Directive PSD2.

This data is forwarded for payment processing in accordance with Art. 6 para. 1 sentence 1 lit. b) GDPR and to fulfil our legal obligation to carry out strong customer authentication in accordance with Art. 6 para. 1 sentence 1 lit. c) GDPR in conjunction with Directive EU 2015/2366 (PSD 2) and the Payment Services Supervision Act (ZAG) for the purpose of combating money laundering and criminal prosecution.

The technical processing of credit card payments is carried out by Shopify Payments, Shopify Inc., 151 O'Connor Street, Ground floor, Ottawa. This company has been commissioned for the technical control of payment transactions, including the implementation of the 3D Secure 2.0 procedure in accordance with Art. 28 GDPR. Other recipients of the data are the banks involved (on the one hand, the card-issuing bank – the issuer – and, on the other hand, the merchant's credit card-accepting bank – the acquirer).

The Shopify Payments privacy policy can be found at https://www.shopify.com/de/legal/datenschutz.

d) Newsletter

Contents of the newsletter and registration data

Our newsletter will only be sent to you, statistical surveys and analyses will only be carried out and the registration process will only be logged if you order this from us and have given your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR, § 25 para. 1 TDDDG.

The content of the newsletter is described in detail when you subscribe to the newsletter. Your email address is sufficient to subscribe to the newsletter. If you provide further voluntary information, such as your name and/or gender, this will be used exclusively to personalise the newsletter sent to you.

Double opt-in and logging

For security reasons, we use the double opt-in procedure for registration for our newsletter so that no one can register with someone else's email address. After registering for our newsletter, you will therefore first receive an email asking you to confirm your registration. Your registration will only become effective once you have confirmed it.

Furthermore, your registration for the newsletter will be logged. The logging includes the storage of the time of registration and confirmation, the data you provided and your IP address. If you make changes to your data, these changes will also be logged.

Revocation

If you no longer wish to receive our newsletter, you can revoke your consent at any time with future effect. To do this, you can click on the link to unsubscribe from the newsletter at the end of each newsletter or send us an email to the following email address: datenschutz@eye-able.com

The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

Please ensure that you are really using self-hosting and not a rented server.

Please check your contract documents with Shopify to ensure that this is the correct company.

Please check whether this corresponds to the log file procedure at Shopify. You will also need to find out how long Shopify stores this data and what access you have to these log files.

We recommend that you also check with your payment service provider to see whether any additional data is processed in connection with credit card payments.

If the provider can provide you with precise information about the data that is processed, you can enter this information here.

Use of ‘HubSpot’

Registration is carried out using the newsletter service ‘HubSpot’, which is provided by HubSpot Inc. (25 First Street, Cambridge, MA 02141 USA).

The email addresses of our prospective customers and any other data described in this notice are stored on HubSpot's servers in the USA. HubSpot uses this information to send and evaluate the participation links on our behalf. Furthermore, HubSpot may use this data to optimise or improve its own services, e.g. for technical optimisation of the sending and presentation of the invitation or for economic purposes to determine the countries from which the recipients come. However, HubSpot does not use the data of our prospective customers to contact them itself or pass it on to third parties.

We have concluded the standard contractual clauses with HubSpot. HubSpot does not obtain any right to pass on your data.

You can find HubSpot's privacy policy here.

Use of ActiveCampaign

We send our newsletter using the newsletter service ‘ActiveCampaign’, which is operated by ActiveCampaign, LLC (1 North Dearborn St, 5th Floor, Chicago, IL 60602, USA).

The email addresses of our newsletter recipients, as well as other data described in this notice, are stored on ActiveCampaign's servers in the United States. ActiveCampaign uses this information to send and evaluate the newsletter on our behalf.

Furthermore, ActiveCampaign may, according to its own information, use this data in pseudonymous form, i.e. without assignment to a user, for the optimisation or improvement of its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletter or for statistical purposes to determine the countries from which the recipients come. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or pass it on to third parties.

We have concluded the standard contractual clauses with Active Campaign.

You can find ActiveCampaign's privacy policy here: https://www.activecampaign.com/legal/privacy-policy

Statistical surveys and analyses

The newsletters sent via AcitveCampaign contain a so-called ‘web beacon’, i.e. a pixel-sized file that is retrieved from the server of the shipping service provider when the newsletter is opened. During this retrieval, technical information such as information about your browser and your system, as well as your IP address and the time of retrieval, are collected.

This information is used to improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval location (which can be determined using the IP address) or the access times.

The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of ActiveCampaign to monitor individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

a) Appointment

On our website, we offer you the option of making an appointment for a consultation with us directly. A calendar with available appointments will be displayed for this purpose. After selecting a suitable appointment, you will be asked to enter your first and last name, your email address and your telephone number so that we can reserve the appointment for you and send you a confirmation. You will also be asked to provide information about your company (company domain and size), your job description and the subject of your enquiry. This data will be processed for the purpose of conducting the consultation.

We use the calendly tool from Calendly LLC, 271, 17th St NW, 10th Floor, Atlanta, Georgia 30363, USA, with whom we have concluded a data processing agreement.

We process your personal data in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR for the purpose of carrying out pre-contractual measures taken at your request.

You can find more information about data protection at Calendly at https://calendly.com/legal/privacy-notice.

a) Free WCAG test

We offer a free WCAG test for your website on our website. To use this service, you must provide your full name, business email address, telephone number, job title, company domain, company size and the nature of your enquiry. We process this data in order to carry out the WCAG test, send you the test report by email and create a test licence in the Eye-Able Dashboard.

This processing is carried out on the basis of Art. 6 para. 1 sentence 1 lit. b and f GDPR for the implementation of pre-contractual measures taken at your request or for the pursuit of our legitimate interest, namely the exercise of our business activities.

b) Contact form

We provide a form on our website so that you can contact us at any time. To use the contact form, you must provide a name for personal address and a valid email address so that we know who the enquiry comes from and can process it.

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there and your IP address, will be processed in accordance with Art. 6 para. 1 sentence 1 lit. b and f GDPR for the purpose of implementing pre-contractual measures taken at your request or for the purpose of pursuing our legitimate interest, namely the performance of our business activities.

The enquiries and the associated data will be deleted no later than 3 months after receipt, unless they are required for a further contractual relationship.

c) Application form

We provide a form on our website that you can use to apply for a job with us. Your personal data from the application will be processed in accordance with our privacy policy for applicants.

This form is used in our legitimate interest in the simple and secure transmission of your application documents, Art. 6 para. 1 sentence 1 lit. f) GDPR.

We use the provider Personio SE & Co. KG, Rundfunkplatz 4, 80335 Munich, Germany, for this purpose. We have concluded a contract with this provider for order processing.

The data protection information for the processing of personal data by us within the framework of the application process and by Personio itself through the provision of the application tool can be found at

https://eye-able.jobs.personio.de/privacy-policy?language=de.

d) Google Tag Manager

We use Google Tag Manager from Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) on our website. Google Tag Manager is an administration and management tool in which other tracking and/or statistics tools can be centrally managed and played.

When you visit our website, Google Tag Manager collects and processes your IP address, which may also be transferred to the United States. However, Google Tag Manager does not create a user profile or perform any analyses itself.

The use of Google Tag Manager is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR.

We have concluded a contract with Google for order processing.

The Google privacy policy can be found here. [https://www.google.com/policies/privacy/?hl=de]

10. Analysis and tracking tools

We use the analysis and tracking tools listed below on our website. These serve to ensure the ongoing optimisation of our website and to tailor it to your needs.

We use these tools on the basis of your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. You can revoke your consent at any time by changing your cookie settings. Processing remains lawful until revocation.

The respective data processing purposes and data categories can be found in the corresponding tools. We would like to point out that we have no influence on whether and to what extent the service providers carry out further data processing.

a) Google Analytics

We use Google Analytics, a web analytics service provided by Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, hereinafter referred to as ‘Google’), on our website.

Google Analytics uses cookies for this purpose (see section 7). The information generated by the cookie about your use of this website, such as

· Name and version of the browser used

· Operating system of your computer

· Website from which access is made (referrer URL)

· IP address of the requesting computer

· Time of the server request are usually transferred to a Google server in the USA and stored there.

Your IP address is automatically anonymised by Google before it is recorded via EU domains and servers. Your IP address is therefore not logged or stored.

On our behalf, Google will use this information to evaluate your use of our website, to compile reports on website activity and to provide us with other services related to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.

We have concluded a contract with Google for order processing.

Please click here for an overview of Google's privacy policy. [https://support.google.com/analytics/answer/6004245]

b) Google Remarketing

We use the remarketing function of Google Analytics to target advertising campaigns, including Google AdWords campaigns, to visitors to our website.

Based on your previous visits to our website, you will be presented with relevant advertisements when you visit other websites in the Google Display Network.

The DoubleClick cookie enables Google to display targeted advertising to us and other third-party providers that corresponds to your interests based on your previous visits to our website and/or other websites. This advertising may be displayed on websites belonging to Google and/or other operators of the Google advertising network. We also use Google Analytics advertising functions to analyse the effectiveness of our own advertising campaigns.

If you have agreed in your Google account that your web and app browsing history may be linked to your Google account and that information from your Google account may be used to personalise ads, Google will use data about you together with Google Analytics data to create target audience lists for cross-device remarketing. To do this, Google Analytics first collects Google-authenticated IDs for you as a user on our website, which are linked to your Google account. Google Analytics then temporarily links these IDs to Google Analytics data to optimise our target groups.

We have concluded a contract with Google for order processing.

Please click here for an overview of Google's privacy policy. [https://support.google.com/analytics/answer/6004245]

c) Google Ads Conversion Tracking

We use Google Ads, an online advertising programme from Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), on our website. Conversion tracking is also used for this purpose. With this tool, Google Ads places a cookie on your device when you visit our website via a Google advertisement.

The cookie does not serve any personal tracking purposes. If you visit our website as a user and the cookie is still active, we and Google can recognise that you clicked on the ad and were redirected to our site. Each Google Ads customer is assigned a different cookie. Cookies cannot be tracked across the websites of Ads customers.

The data collected by conversion cookies is used to create conversion statistics for Ads customers. As a Google Ads customer, we thus learn the total number of users who responded to our ad and were then redirected to a website that has been tagged with a conversion tracking tag. This allows us to recognise the success of individual advertising measures. We do not receive any information that could be used to personally identify you as a user during this process.

When using Google Ads, your browser automatically establishes a direct connection to the Google server and, if you have a Google account and are logged in, can associate the visit with your account. If you do not have a Google account, Google will assign you a unique ID. We have no influence on what further data Google collects and stores.

We have implemented Google's ‘extended conversions’ feature on our website. This means that data collected by us, such as your email address, name, address or telephone number, is recorded in conversion tracking tags. These are then sent in hashed form to Google, where they are used to match our existing customers with Google accounts. For more information about this feature, please visit https://ads.google.com/intl/de_de/home/privacy/solutions/enhanced-conversions-for-web/

We have entered into a contract with Google for order processing.

For more information about Google's privacy policy, please visit http://www.google.de/policies/privacy/.

d) Google AdSense

We use the Google AdSense service provided by Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) on our website to integrate advertisements.

Google AdSense uses cookies. These are files that are stored on your device and enable Google to analyse your use of our website. Google AdSense also uses web beacons, which are invisible graphics that enable Google to analyse clicks on our website, traffic on our website and similar information.

The information obtained via cookies and web beacons, your IP address and the delivery of advertising formats are transmitted to a Google server in the USA and stored there. Google may transfer this collected information to third parties if required by law or if Google commissions third parties to process the data. However, Google will not merge your IP address with other stored data.

We have concluded a contract with Google for order processing.

You can find more information about Google's privacy policy at

http://www.google.de/policies/privacy/.

e) Google Double Click

We have integrated components from DoubleClick by Google into our website. DoubleClick is a brand of Google, under which special online marketing solutions are primarily marketed to advertising agencies and publishers. DoubleClick by Google transfers data to the DoubleClick server with every impression, click or other activity.

Each of these data transfers triggers a cookie request to the browser of the person concerned. If the browser accepts this request, DoubleClick sets a cookie in your browser.

DoubleClick uses a cookie ID that is necessary for the technical process. The cookie ID is required, for example, to display an advertisement in a browser. DoubleClick can also use the cookie ID to record which advertisements have already been displayed in a browser in order to avoid duplicate placements. Furthermore, the cookie ID enables DoubleClick to record conversions. Conversions are recorded, for example, when a user has previously seen a DoubleClick advertisement and subsequently makes a purchase on the advertiser's website using the same Internet browser.

The cookie is used, among other things, to place and display advertisements relevant to the user and to create or improve reports on advertising campaigns. The cookie also serves to prevent the same advertisement from being displayed multiple times. Each time you visit one of the individual pages of our website on which a DoubleClick component has been integrated, your browser is automatically prompted by the respective DoubleClick component to transmit data to Google for the purpose of online advertising and commission settlement.

A DoubleClick cookie does not contain any personal data, but may contain additional campaign identifiers. A campaign identifier is used to identify campaigns with which you have already come into contact on other websites. As part of this service, Google obtains data that Google also uses to generate commission statements. Among other things, Google can track that you have clicked on certain links on our website. In this case, your data will be transferred to the operator of DoubleClick, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Further information and the applicable privacy policy of DoubleClick by Google can be found at https://policies.google.com/privacy.

We process your data with the help of the DoubleClick cookie for the purpose of optimising and displaying advertising.

f) Hubspot

We work with Hubspot CRM software from HubSpot Inc. (25 First Street, 2nd Floor, Cambridge, MA 02141, USA), which enables us to manage our customer data and conduct online marketing. Among other things, landing pages are analysed and reports are generated for this purpose. So-called ‘web beacons’ and cookies are used in this process. In this context, the following personal data may be processed:

• IP address,

• geographical location,

• type of browser,

• duration of visit,

• pages accessed,

• visitor sources using Utm parameters.

As a rule, the IP address is processed on Hubspot's European servers and only stored in a shortened form. Only in exceptional cases will the IP address be transferred to a HubSpot server in the USA and shortened there.

We use the information collected to continuously optimise and improve our website and make it more user-friendly for you. In addition, we use this information to analyse which services of our company are of interest to customers, users and newsletter subscribers in order to contact them for advertising purposes.

We have concluded the standard contractual clauses with HubSpot. HubSpot does not obtain any right to pass on your data.

You can find HubSpot's privacy policy here.

g)   Microsoft Clarity

We use the analysis service ‘Microsoft Clarity’ provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052 USA, on our website.

Here, usage and user-related information, such as your IP address, location, time or frequency of your visit to our website, is transferred to a Microsoft server in the USA and stored there. We have activated the anonymisation function with Microsoft so that your IP address is only processed in abbreviated form.

This data is used to evaluate your visit to our website and your usage behaviour so that we can improve and optimise our services.

We have agreed on the standard contractual clauses with Microsoft. Further information on data protection at Microsoft can be found at https://privacy.microsoft.com/de-de/privacystatement

h) Matomo (formerly ‘Piwik’)

We use the Matomo analysis service (InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand), which uses cookies. These are stored on your computer and enable us to analyse the use of our website.

The cookies contain usage information and transfer this to our server, where it is stored for usage analysis purposes and helps us to optimise our website. The usage information also includes your IP address, but this is shortened so that it is anonymised and you remain anonymous as a user.

We have concluded a contract with Matomo for order processing.

Further information on data protection at Matomo can be found at:

https://matomo.org/privacy-policy/

We do not pass on the information generated by the cookie to third parties.

i) Facebook Conversion Pixel

We use the ‘conversion pixel’ or visitor action pixel from Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). When this pixel is called up from your browser, Meta Platforms can subsequently recognise whether a Facebook advertisement was successful, e.g. whether it led to an online purchase.

We only receive statistical data from Meta Platforms that is not related to any specific person. This allows us to measure the effectiveness of Facebook ads for statistical and market research purposes. In particular, if you are registered with Facebook, we refer you to their privacy policy at https://www.facebook.com/about/privacy/.

j) LinkedIn Conversion Tracking

We use the conversion tracking function of LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) on our website. This allows us to target you with advertisements after you have visited our website. In addition, LinkedIn provides reports on how successful our advertisements are and how users interact with our website in general. If you are logged in to LinkedIn before visiting our website, this will be recognised as part of conversion tracking and you will be associated with your LinkedIn account as a visitor to our website.

We have concluded a contract with LinkedIn for order processing.

Further information can be found in LinkedIn's privacy policy:

https://www.linkedin.com/legal/privacy-policy?_l=de_DE

You also have the option of opting out of interest-based advertising via LinkedIn. This can be done via the following link:

https://www.linkedin.com/psettings/enhanced-advertising

k) Microsoft Advertising Conversion Tracking

We use the Microsoft Advertising advertising programme on our website, which is provided and operated by Microsoft Ireland Operations Limited, One Microsoft Place, South Country Business Park, Leopardstown, Dublin, Ireland 18, D18 P521 (‘Microsoft’).

The Microsoft Advertising advertising programme enables us to place advertisements in various search engines and networks. In order to recognise which advertisement or keyword brought you to our website, we have implemented Universal Event Tracking (UET) on our site. This is a conversion tracking tag that allows us to learn more about your user behaviour on our websites. We use this information to optimise our advertisements and offers and tailor them better to your needs.

Microsoft collects, processes and uses information via the cookie to create usage profiles using pseudonyms. These usage profiles are used to analyse visitor behaviour and are used to display advertisements. No personal information about the identity of the user is processed.

Microsoft Advertising may collect the following information, among other things:

• Information about the browser you are using and the device you are using

• Identifiers (tags) assigned by Microsoft

• Website or advertisement from which access is made (referrer URL)

• IP address of the requesting computer

• Access duration and time

We have entered into a contract with Microsoft for order processing, which ensures that your data will be processed in accordance with European data protection standards.

It cannot be ruled out that personal data may also be processed by the service provider in the USA, as the parent company Microsoft Corporation has its headquarters in the USA.

Further information on data protection and the cookies used by Microsoft can be found on the Microsoft website https://privacy.microsoft.com/de-de/privacystatement.

l) Hotjar

Our website uses the Hotjar analysis software from Hotjar Ltd. (Hotjar Ltd, Level 2, St Julians Business Centre,3, Elia Zammit Street,St Julians STJ 1000, Malta, Europe). This software enables us to analyse the usage behaviour of our website visitors by measuring and evaluating clicks, mouse movements and similar behaviour on our website. The purpose of this software is to identify areas for improvement on our website.

Hotjar uses cookies that are stored on your device and enable an analysis of your use of the website. To prevent direct personal references, IP addresses are only stored and processed in anonymised form. In addition, information about the operating system, browser, incoming and outgoing references (links), geographical origin and resolution and type of device is evaluated for statistical purposes. This information is not personal and is not passed on to third parties by us or Hotjar.

You can prevent the storage of cookies by adjusting your browser software settings accordingly. However, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.

We have concluded a contract with Hotjar for order processing.

Further information on data protection at Hotjar can be found at:

https://www.hotjar.com/legal/policies/privacy

In addition, you can prevent or reactivate recording by following the instructions at https://www.hotjar.com/opt-out

11. Image, audio and video integration

a) YouTube

We embed videos from YouTube, which is operated by Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), into our website using iFrame and/or a plug-in. When embedding the videos, we have activated YouTube's extended data protection mode.

If you play a YouTube video during your visit, a connection to the YouTube servers is established and the YouTube server is informed which of our pages you have visited. This allows YouTube to associate your surfing behaviour directly with your personal profile. You can prevent this by logging out of your member account before visiting our website. In addition, YouTube sets various cookies when the service is started in order to improve the services it offers and prevent misuse, according to its own statements.

Further information on the handling of user data and the cookies set can be found in YouTube's privacy policy at: https://www.google.de/intl/de/policies/privacy

By integrating YouTube, Google Fonts are also dynamically reloaded without the website operator or visitor actively determining this. These web fonts are integrated via a server call, usually a Google server in the USA. This may result in the following information being transmitted to the server and stored by Google:

· Name and version of the browser used

· Website from which the request was triggered (referrer URL)

· Operating system of your computer

· Screen resolution of your computer

· IP address of the requesting computer

· Language settings of the browser or operating system used by the user

Further information can be found in Google's privacy policy, which you can access here:

www.google.com/policies/privacy/

The legal basis is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. You can revoke your consent at any time by changing the cookie settings on our website.

12. Rights of the data subject

You have the following rights:

a) Information

In accordance with Art. 15 GDPR, you have the right to request information about your personal data processed by us. This right to information includes information about

· the purposes of processing

· the categories of personal data

· the recipients or categories of recipients to whom your data has been or will be disclosed

· the planned storage period or, at least, the criteria for determining the storage period

· the existence of a right to rectification, erasure, restriction of processing or objection

· the existence of a right to lodge a complaint with a supervisory authority

· the origin of your personal data, if it was not collected by us

· the existence of automated decision-making, including profiling, and, if applicable, meaningful information about the details thereof

b) Rectification

According to Art. 16 GDPR, you have the right to obtain from us the rectification of inaccurate or incomplete personal data stored by us without undue delay.

c) Deletion

Pursuant to Art. 17 GDPR, you have the right to request the immediate deletion of your personal data stored by us, unless further processing is necessary for one of the following reasons:

· the personal data is still necessary for the purposes for which it was collected or otherwise processed

· for exercising the right of freedom of expression and information

· for compliance with a legal obligation which requires processing in accordance with the law of the European Union or of the Member States to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

· for reasons of public interest in the area of public health pursuant to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 GDPR

· for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of this processing

· for the assertion, exercise or defence of legal claims

d) Restriction of processing

You may request the restriction of the processing of your personal data for one of the following reasons in accordance with Art. 18 GDPR:

· You dispute the accuracy of your personal data.

· The processing is unlawful and you refuse to have the personal data deleted.

· We no longer need the personal data for the purposes of processing, but you require it for the assertion, exercise or defence of legal claims.

· You object to the processing pursuant to Art. 21 para. 1 GDPR.

e) Notification

If you have requested the correction or deletion of your personal data or a restriction of processing in accordance with Art. 16, Art. 17 or Art. 18 GDPR, we will inform all recipients to whom your personal data has been disclosed, unless this proves impossible or involves disproportionate effort. You can request that we inform you of these recipients.

f) Transfer

You have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format.

You also have the right to request the transfer of this data to a third party, provided that the processing was carried out using automated procedures and is based on consent pursuant to Art. 6 para. 1 sentence 1 lit. a or Art. 9 para. 2 lit. a or on a contract pursuant to Art. 6 para. 1 sentence 1 lit. b GDPR.

g) Revocation

In accordance with Art. 7 para. 3 GDPR, you have the right to revoke your consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. In future, we may no longer continue the data processing based on your revoked consent.

h) Complaint

You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates the GDPR. To do so, please contact the data protection authority named in section 1.c.

i) Objection

If your personal data is processed on the basis of legitimate interests pursuant to Art. 6 (1) sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right to object, which we will implement without specifying your particular situation. If you wish to exercise your right of revocation or objection, simply send an email to datenschutz@eye-able.com.

j) Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

i. is necessary for the conclusion or performance of a contract between you and us

ii. is authorised by European Union or Member State law to which we are subject and that law provides for appropriate measures to safeguard your rights and freedoms and legitimate interests

iii. is based on your explicit consent

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) lit. a or g GDPR applies and appropriate measures to protect your rights and freedoms and your legitimate interests have been taken.

With regard to the cases referred to in i) and iii), we take appropriate measures to safeguard your rights and freedoms and your legitimate interests, including at least the right to obtain intervention by us, to express your point of view and to contest the decision.

13. Changes to the privacy policy

If we change the privacy policy, this will be indicated on the website.

Status: 02.07.2025