PRIVACY

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BASIC INFORMATION ON DATA PROCESSING AND LEGAL BASIS

This data protection declaration informs you about the type, scope and purpose of the processing of personal data within our online offer and the websites, functions and content connected to it (hereinafter jointly referred to as “online offer”). The privacy policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) used on which the online offer is executed.

The terms used, such as “personal data” or their “processing” we refer to the definitions in Article 4 of the General Data Protection Regulation (DSGVO).

The personal data of users processed within the scope of this online offer includes inventory data (e.g., e-mail address, names and addresses of users), contract data (e.g., services used, names of clerks, payment information), usage data (e.g., the visited web pages of our online offer) and content data (e.g., details of escrow payment, chat messages, images).

The term “user” includes all categories of data subjects. They include our business partners, customers, interested parties and other users of our online offer. The terms used, such as “user”, are to be understood as gender-neutral.

We process users’ personal data only in compliance with the relevant data protection provisions. This means that user data will only be processed if a legal permission exists. I.e., in particular if the data processing is necessary for the provision of our contractual services as well as online services, or is required by law, a consent of the user is available, as well as due to our legitimate interests (i.e. interest in the analysis, optimization and economic operation and security of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO, in particular in the case of range measurement, creation of profiles for advertising and marketing purposes, and collection of access data and use of third-party services.

We point out that the legal basis of the consents Art. 6 para. 1 lit. a. and Art. 7 DSGVO, the legal basis for processing for the performance of our services and implementation of contractual measures Art. 6 para. 1 lit. b. DSGVO, the legal basis for processing to fulfill our legal obligations Art. 6 para. 1 lit. c. DSGVO, and the legal basis for processing to protect our legitimate interests Art. 6 para. 1 lit. f. DSGVO is.

SECURITY MEASURES

We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

The security measures include in particular the encrypted transmission of data between your browser and our server.

TRANSFER OF DATA TO THIRD PARTIES AND THIRD-PARTY PROVIDERS

Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, on the basis of Art. 6 para. 1 lit. b) DSGVO for contractual purposes or on the basis of legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO in the economic and effective operation of our business.

If we use subcontractors to provide our services, we take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal provisions.

If content, tools or other means from other providers (hereinafter collectively referred to as “third party providers”) are used within the scope of this data protection declaration and their named registered office is located in a third country, it is to be assumed that a data transfer to the third party providers’ countries of domicile takes place. Third countries are countries in which the GDPR is not directly applicable law, i.e. basically countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if there is an adequate level of data protection, user consent or otherwise legal permission.

PROVISION OF CONTRACTUAL SERVICES

We process inventory data (e.g., names and addresses as well as contact data), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. DSGVO.

Website visitors can create a user account on our website, with which they can in particular create, view and manage their trust payments. For the opening of the user account as well as for the disbursement of the funds, the following personal data are collected:

Name, first name

e-mail address

Password

Date of birth

Nationality

Address (street, house number, postal code, city, country)

Mobile number

Bank details (e.g. IBAN, BIC)

For so-called business accounts, the following data is also collected:

Name of the company

Sales tax identification number or tax number

Address of the company

For registration we use the so-called double-opt-in procedure. This means that registration is not completed until the user confirms registration by clicking a link in a verification e-mail sent for this purpose.

The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention being necessary for reasons of commercial or tax law in accordance with Art. 6 para. 1 lit. c DSGVO.

For the purpose of carrying out trustee payments, personal data will be processed as follows

First and last name

Status of identification (identification open / identification completed)

Chat messages

as well as information and status messages on the escrow payments are exchanged between the parties involved.