Your privacy is important to us. This document describes what data is collected, how your data is used and your rights of withdrawal. By using feedbackr, you agree to the processing of the data and the procedures and processes described below. With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Name/Company: Carrot & Company GmbH
Street Nr.: Sparbersbachgasse 26
ZIP, City, Country: 8010, Graz, Österreich
CEO: DI Christian Haintz, DI Karin Pichler
Phone number: +43 316 37 50 14
Email address: firstname.lastname@example.org
We want to keep feedbackr as simple and uncomplicated as possible. Therefore, we do not store and process any personal data that is not necessarily needed to provide you with our services.
Your data will not be passed on. The only exceptions to this principle are compliance with the law, the protection of our rights, the further development of our product and the operation of our services.
We respect your privacy with respect to all personal information collected during your visit to our website and when you register with feedbackr. In order to protect the rights of young people, it is not allowed to create a user account for young people under the age of 14.
Types of data processed
- Inventory data (name, address)
- Contact information (e-mail address)
- Content data
- Contract data
- Usage data
- Meta/communication data
- Payment data
Both registered users and participants will have their IP addresses stored for 7 days based on our legitimate interests (Art. 6 Abs. 1 lit. f. GDPR) .
No special categories of data are processed.
Categories of data subjects
Visitors and users of the online offer, customers, interested persons.
Purpose of processing
- Provide the online offer, its contents and functions
- Contractual services, customer care and support
- Answering contact inquiries and communication with users
- Marketing, advertising and market research
- Safety procedures
1. Relevant legal principles
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.
3. Security precautions
We shall take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, in accordance with Article 32 GDPR, taking into account the state of the technology, the costs of implementation and the nature, scope, circumstances and purposes of processing and the different likelihood of occurrence and severity of the risk to the rights and freedoms of natural persons; the measures shall include in particular ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and their separation. Furthermore, we have established procedures that guarantee the rights of data subjects, deletion of data and reaction to data risks. 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 presettings (Art. 25 GDPR).
The security measures include in particular the encrypted transmission of data between your browser and our server.
4. Cooperation with contract processors and third parties
If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transmit it to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 lit. b GDPR for contract fulfilment is necessary), if you have consented, if 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 “Data Processing Agreement”, this is done on the basis of Art. 28 GDPR.
5. Transfers to third party countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of 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. We only process or leave the data in a third country if the special requirements of Art. 44 ff. Process GDPR. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
6. Rights of data subjects
You have the right to request confirmation as to whether the data are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have the right to request that the data concerning you be completed or incorrect data concerning you be corrected (Art 16 GDPR).
In accordance with Art. 17 GDPR, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 GDPR.
You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request its transmission to other persons responsible.
In accordance with Art. 77 GDPR, you also have the right to file a complaint with the competent supervisory authority.
7. Right of withdrawal
You have the right to withdraw consents granted according to Art. 7 para. 3 GDPR with future effect.
8. Right of objection
You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection may be made in particular against processing for direct marketing purposes.
9. Cookies and right of objection in direct advertising
10. Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with Articles 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 legal storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
The data of registered users are automatically deleted after 24 months of inactivity.
Application documents are stored for 7 months. Afterwards, all documents will be deleted, except applicants wishing us to keep the data for further job offers. If the documents have been deleted, the names and birthdays of the applicants are saved for economic interests.
11. The provision of contractual services
We process inventory data (e.g., names and addresses as well as contact data of users), 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. GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.
Users can create a user account with which they can manage surveys with feedbackr. During the registration process, the necessary information that is collected is communicated to the user. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is necessary for commercial or tax reasons (Art. 6 Abs. 1 lit. c GDPR). It is the user’s responsibility to save their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
When registering, re-registering and using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 Abs. 1 lit. c GDPR.
We process usage data (e.g., the visited websites of our online offer, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile in order to show the user e.g. product information based on their previously used services.
The deletion takes place after the expiration of statutory warranty and comparable obligations, the necessity of the storage of the data is checked every two years; in the case of statutory archiving obligations the deletion takes place after their expiration (end of commercial law (6 years) and tax law (10 years) storage obligation); details in the customer account remain up to its deletion.
12. Establishing contacts
When contacting us (via contact form or e-mail), the user’s details are used for the processing of the contact request and its handling in accordance with Art. 6 Para. 1 lit. b) GDPR.
User information can be stored in our Customer Relationship Management System (“CRM System”) or comparable system.
We use the CRM system “Pipedrive Inc, 460 Park Ave South, New York, NY 10016, USA and Intercom, Inc. a Delaware corporation with offices at 55 2nd Street, 4th Fl., San Francisco, CA 94105, USA based on our legitimate interests (efficient and fast processing of user requests). Pipedrive as well as Intercom is certified under the Privacy Shield Agreement and thus offers an additional guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzX1AAK&status=Active).
We delete the requests if they are no longer necessary. We review the requirement every two years; requests from customers who have a user account at feedbackr are stored permanently and are referred to the customer account details for deletion. In the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).
13. Comments and contributions
If users leave comments or other contributions, their IP addresses will be used on the basis of our legitimate interests within the meaning of Art. 6 (1) (f). GDPR for 7 days.
This takes place for our safety, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
14. Akismet Anti-Spam Check
Our website uses the “Akismet” service provided by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments of real people are distinguished from spam comments. All comment information is sent to a server in the USA, where it is analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored after this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used, the computer system and the time of entry.
Automattic is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
Users are welcome to use pseudonyms. You can completely prevent the transfer of data by not using our comment system. That would be a pity, but unfortunately we see no other alternatives that work just as effectively.
15. Collection of access data and log files
We collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider. Furthermore, errors that occur in the web application are sent to the server with meta information and stored.
Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.
16. Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
17. Cookies & range measurement
Cookies are information that is transferred from our web server or third party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.
We use “cookies” or the local storage of the browser (e.g. to store your login status so that we can even use our online offer). A randomly generated unique identification number is stored in our cookies or local storage, a so-called session ID, but also settings that affect our web application. A cookie also contains information about its origin and the storage period. Session cookies are partially deleted when you have finished using our online offer and log out, for example.
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. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
18. Google Analytics
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles of users can be created from the processed data.
We use Google Analytics to display the ads placed by Google and its partners within advertising services only to users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are determined by the web pages visited) that we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences we would also like to ensure that our ads correspond to the potential interest of the users and are not annoying.
We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Further information on data use by Google, possible settings and objections can be found on Google’s websites:
https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when using our partners’ websites or apps”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information that Google uses to show you advertising”).
19. Google-Re/Marketing Services
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the marketing and remarketing services (“Google Marketing Services” for short) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
The Google marketing services allow us to target ads for and on our site in order to present users only with ads that potentially match their interests. For example, if a user sees ads for products he has been interested in on other websites, this is referred to as “remarketing”. For these purposes, when our and other websites on which Google marketing services are active are accessed, Google directly executes a code from Google and (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file it is noted which websites the user visits, which contents he is interested in and which offers he has clicked on, furthermore technical information about the browser and operating system, referring websites, visiting time as well as further information about the use of the online offer. The IP address of the users is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other signatory states of the European Economic Area Agreement and only in exceptional cases completely transmitted to a Google server in the USA and shortened there. The IP address is not combined with the user’s data within other Google offers. The above information may also be linked by Google to such information from other sources. If the user then visits other websites, the ads tailored to his interests can be displayed.
Users’ data is processed pseudonymously within the framework of Google marketing services. This means that Google does not store and process, for example, the names or e-mail addresses of users, but processes the relevant data cookie-related within pseudonymous user profiles. This means from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
We can also use the “Google Optimizer” service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) within the framework of so-called “A/B testing”. Cookies are stored on the user’s devices for these test purposes. Only pseudonymous user data is processed.
We can also use the “Google Tag Manager” to integrate and manage Google analysis and marketing services into our website.
If you wish to object to interest-based advertising by Google marketing services, you can use the setting and opt-out options provided by Google: https://adssettings.google.com/authenticated.
20. Facebook, custom audiences and Facebook marketing services
Due to our legitimate interests in the analysis, optimisation and economic operation of our online offer and for these purposes the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used within our online offer.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads we post only to Facebook users who have also shown an interest in our online offering or who have certain features (e.g. interests in certain topics or products that are determined by the websites visited) that we transmit to Facebook (so-called “custom audiences”). We also want to use the Facebook pixel to ensure that our Facebook ads meet the potential interest of users and are not a annoying experience. The Facebook pixel also helps us understand the effectiveness of Facebook ads for statistical and market research purposes by showing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion”).
You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set what types of ads you see within Facebook, you can visit the page set up by Facebook and follow the instructions on usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
21. payment provider Stripe
Our credit card payments are made through the payment provider Stripe, Inc, 185 Berry Street, Suite 550, San Francisco, CA 94107, USA. Users using the paid version of feedbackr via credit card will send the following information to our payment provider “(Stripe”):
- credit card details
22. customer support: Intercom
One of our goals is, besides our product, to provide the best possible support and assistance. For this purpose we use an external service provider who offers a support platform: Intercom, Inc., a Delaware corporation with offices at 55 2nd Street, 4th Fl., San Francisco, CA 94105, USA. The following personal information is stored at Intercom:
- Browser and browser version
- operating system
- language settings
- interaction with feedbackr – user behavior (which functions were used)
- time of last login
- date of registration
- communication history (sent e-mail traffic)
Occasionally we send e-mails to all registered users. In terms of content, these are innovations within the product and related offers. The following information is collected when you interact with the emails:
- If the e-mail has been opened
- If a link was opened/clicked in the e-mail
- Has an e-mail been answered?
- E-mail dispatch failed
23. Infrastructure: Amazon Web Services & Hetzner
The infrastructure for feedbackr is hosted at Amazon Web Services. The infrastructure is located in Ireland and is therefore also subject to EU data protection legislation. All data necessary for the operation of the application is stored there:
- email address
- IP address
- billing details
Application data arising from the use of feedbackr (questions, answers of participants, etc.)
Amazon Web Services is certified under the US-EU data protection agreement “Privacy Shield” and thus undertakes to comply with EU data protection regulations.
Our data backups are stored on a physical server in Germany, at Hetzner Hetzner Online GmbH Industriestr. 25 91710 Gunzenhausen Germany. All data generated during the operation of feedbackr is stored there as a backup. This concerns the same data that is stored on Amazon Web Services:
- email address
- IP address
- billing details
- Application data arising from the use of feedbackr (questions, answers of participants, etc.)
24. Email sending via Mailgun
The sending of e-mails within the application (registration confirmation, password reset, password forgotten, etc.) is done by our e-mail dispatch service provider Mailgun Technologies, Inc. 535 Mission St. San Francisco, CA 94105 . The following data is sent to Mailgun for sending e-mails:
- email address
- contents of the e-mail
25. Document management with Google
We use Google LLC (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA for our internal administration of support requests and answers as well as for our e-mail dispatch. E-mail traffic data, support requests and data exports are stored.
26. Spinbackup backup system
Our documents and e-mails are stored by our document backup service provider Spinbackup Inc, 1426 Fillmore Street, Suite 300, San Francisco, CA 94115, USA.
27. CRM Pipedrive
All customer relationships that arise in addition to registered users are recorded in our CRM by Pipedrive Inc, 460 Park Ave South, New York, NY 10016, USA. The following data is stored:
- contact details (e-mail address, telephone number, website)
- VAT ID
- communication flow
Pipedrive is certified under the US-EU data protection agreement “Privacy Shield” and thus undertakes to comply with EU data protection regulations. You can view Pipedrive’s data protection declaration at the following link: https://www.pipedrive.com/en/privacy
28. Internal communication: Slack
For the internal communication Slack Technologies Limited 4th Floor, One Park Place Hatch Street Upper Dublin 2, Ireland is used. Slack is certified under the US-EU data protection agreement “Privacy Shield” and thus undertakes to comply with EU data protection regulations. You can view Slack’s data protection declaration at the following link: https://slack.com/privacy-policy
29. Anonymity of your audience and prohibition to collect personal data
The answers of your participants are 100% anonymous. We have no way of assigning answers given to individual persons. IMPORTANT: it is forbidden to collect personal data of your participants with feedbackr which allows conclusions to the respective person. Personal data includes information that your participants can identify (such as name, e-mail address, etc)
With the following details we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By registering with feedbackr you express an interest to be informed about our products. In addition, our newsletters contain information about our products, offers, promotions and our company.
Furthermore, the shipping service provider can use this data in pseudonymous form, i.e. without assignment to a user, to optimise or improve its own services, e.g. for technical optimisation of the dispatch and presentation of the newsletter or for statistical purposes in order to determine from which countries the recipients come. However, the shipping service does not use the data of our newsletter recipients to write them down or pass them on to third parties.
Success measurement – The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the mail-order company’s server when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or 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 the individual newsletter recipients. However, it is not our intention, nor that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
The dispatch of the newsletter and the performance measurement are carried out on the basis of Art. 6 para. 1 lit. b, in conjunction with § 107 para. 2 TKG or on the basis of the legal permission pursuant to § 107 para. 2 and 3 TKG.
Cancellation/Revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. The data will not be deleted at this time. Data will only be deleted if you delete your user account.
31. Integration of third-party services and content
Within our online offer, we use based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offerings of third parties to incorporate their content and 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 users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include 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 may be linked to such information from other sources.
The following presentation provides an overview of third-party providers and their contents, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):