Data protection declaration Converto AG

May 23, 2018 release.

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In this data protection declaration, we, Converto AG, (hereinafter  Converto,  weather  or  us), how we collect and otherwise process personal data. This is not an exhaustive description; if necessary, other data protection declarations regulate specific issues. Personal data is understood to mean all information that relates to a specific or identifiable person.

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1. Responsible

Converto AG, Firststrasse 3a, 8835 Feusisberg is responsible for the data processing that we describe here. If you have any concerns about data protection law, you can send them to us at the following contact address:  privacy@converto.com

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2. Collection and processing of personal data

We primarily process the personal data that we receive from these and other people involved in our business relationship with our customers and other business partners or that we collect from their users when operating our websites, apps and other applications.

As far as this is permitted, we also take certain data from publicly accessible sources (e.g. debt enforcement registers, land registers, commercial register, press, internet) or receive such data from authorities and other third parties. In addition to the data from you that you give us directly, the categories of personal data that we receive about you from third parties, in particular information from public registers, information that we learn in connection with official and judicial proceedings, are information in connection with yours professional functions and activities (so that we can, for example, conclude and process business with your employer with your help), information about you in correspondence and meetings with third parties, credit information (insofar as we do business with you personally), information about you who represent us Give to your environment (family, consultant, legal representative, etc.) so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as anti-money laundering and export restrictions , Information from banks, insurance companies, sales and other ver contract partners of ours for the use or provision of services by you (e.g. payments made, purchases made), information from the media and the Internet about you (as far as this is indicated in a specific case, e.g. in the context of an application, press review, marketing / sales, etc. .), Your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of visit, pages and content accessed, functions used, referring website, location information).

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3. Purposes of data processing and legal bases

We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of cooperation with our customers and the purchase of products and services from our suppliers and subcontractors, as well as to meet our legal obligations to comply at home and abroad. If you work for such a customer or business partner, you can of course also be affected in this role with your personal data.
In addition, we process personal data from you and other persons, as far as permitted and it appears to us to be appropriate, also for the following purposes in which we (and sometimes also third parties) have a legitimate interest corresponding to the purpose:

• Offer and further development of our offers, services and websites, apps and other platforms on which we are present;

• Communication with third parties and processing of their inquiries (e.g. applications, media inquiries);

• Examination and optimization of procedures for needs analysis for the purpose of direct customer contact as well as collection of personal data from publicly accessible sources for the purpose of customer acquisition;

• Advertising and marketing (including holding events), unless you have objected to the use of your data (if we send you advertising as an existing customer of ours, you can object to this at any time, we will then put you on a blacklist against further advertising mailings);

• Market and opinion research, media monitoring;

• Assertion of legal claims and defense in connection with legal disputes and official proceedings;

• Prevention and investigation of criminal offenses and other misconduct (e.g. carrying out internal investigations, data analyzes to combat fraud);

• Warranties of our operations, in particular IT, our websites, apps and other platforms;

• Other measures for IT, building and plant security and protection of our employees and other people and values entrusted to us (such as access controls, network and mail scanners);

• Acquisition and sale of business areas, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and, if applicable, for compliance with legal and regulatory obligations and internal regulations of Converto.

Insofar as you have given us your consent to process your personal data for certain purposes (for example when you register to receive newsletters or carry out a background check), we will process your persons within the framework of and based on this consent, unless we have any other legal basis and we need one. A given consent can be withdrawn at any time, but this has no effect on data processing that has already taken place.

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4. Cookies / tracking and other technologies in connection with the use of our website

We use "cookies" and similar technologies on our websites, with which your browser or your device can be identified. A cookie is a small file that is sent to your computer or automatically saved on your computer or mobile device by the web browser used when you visit our website. If you visit this website again, we will be able to recognize you, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the website ("session cookies"), cookies can also be used to save user settings and other information for a certain period of time (e.g. two years) ("permanent cookies" ").

However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that you can save user settings (e.g. language, autologin, so that we can better understand how you use our offers and content, and so that we can show you offers and advertisements tailored to you (which can also happen on the websites of other companies; However, they will not find out who you are from us, if we even know, because they only see that the same user is on their website who was also on a certain page on our website). Certain of the cookies are set by us , certain also from contractual partners with whom we work. If you block cookies, it is possible that certain functionalities (such as language selection, shopping cart, order processes) no longer work.

In our newsletters and other marketing e-mails, we sometimes and as far as permitted also incorporate visible and invisible image elements, which we can retrieve from our servers to determine whether and when you have opened the e-mail, so that we can also measure here and understand better how you can use our offers and tailor them to you. You can block this in your e-mail program; most are preset to do this.

By using our website and consenting to receive newsletters and other marketing emails, you consent to the use of these technologies. If you do not want this, you have to set your browser or your e-mail program accordingly.

We use Google Analytics and comparable services on our websites. This is a service provided by third parties that may be located in any country in the world (in the case of Google Analytics, it is Google LLC in the USA, www.google.com), with which we measure the use of the website (non-personal) and can evaluate. Permanent cookies, which the service provider sets, are also used for this purpose. The service provider does not receive any personal data from us (and does not store any IP addresses), but can track your use of the website, combine this information with data from other websites that you have visited and which are also tracked by the service provider, and this information use it for your own purposes (e.g. controlling advertising). If you have registered yourself with the service provider, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection regulations. The service provider only tells us how our respective website is used (no information about you personally).

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5. Data transfer and data transfer abroad

As part of our business activities and for the purposes according to Clause C, we also disclose to third parties, insofar as this is permitted and it appears appropriate to us, either because they process them for us, or because they want to use them for their own purposes . In particular, it concerns the following positions:

• Service providers from us (such as banks, insurance companies), including order processors (such as IT providers);

• Dealers, suppliers, subcontractors and other business partners;

• Customers;

• domestic and foreign authorities, authorities or courts;

• Media;

• The public, including visitors to websites and social media;

• Competitors, industry organizations, associations, organizations and other bodies;

• Acquirers or interested parties in the acquisition of business areas;

• other parties in possible or actual legal proceedings;

• all together recipients.

Some of these recipients are in Germany, but they can be anywhere on earth. In particular, you must expect your data to be transmitted to all countries, to countries in Europe and the USA, where the service providers we use are located (such as Microsoft, Amazon, Körbler, Zedo, WordPress, Google). If we transfer data to a country without adequate statutory data protection, we ensure, as required by law, by means of appropriate contracts (namely on the basis of the so-called standard contractual clauses of the European Commission, the  here  here  and  here  are available) or so-called binding corporate rules for an appropriate level of protection or are based on the statutory exceptions of consent, contract processing, the determination, exercise or enforcement of legal claims, overriding public interests, the published personal data or because it is to protect the integrity of the affected persons is necessary.

You can obtain a copy of the mentioned contractual guarantees at any time from the contact person named under Section A, unless already stated above. However, we reserve the right to blacken copies or only to deliver extracts for reasons of data protection or confidentiality.

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6. Duration of retention of personal data

We process and store your personal data as long as it is necessary for the fulfillment of our contractual and legal obligations or for other purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as in accordance with the statutory retention and documentation obligations. It is possible that personal data is stored for the time in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized as far as possible. For operational data (e.g. system protocols, logs), generally shorter retention periods of twelve months or less apply.

7. Data security

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, controls.

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8. Obligation to provide personal data

As part of our business relationship, you must provide the personal data that is required for the establishment and implementation of a business relationship and the fulfillment of the related contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will usually not be able to conclude or process a contract with you (or the office or person you represent). The website cannot be used either if certain information to secure data traffic (such as IP address) is not disclosed.

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9. Profiling

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to be able to provide you with targeted information and advice on products. We use evaluation tools that enable us to communicate and advertise according to our needs, including market and opinion research.

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10. Rights of the data subject

Within the scope of the data protection law applicable to you and as provided therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing and to surrender certain personal data for the purpose of transfer to another place (so-called data portability). Please note, however, that we reserve the right to enforce the statutory restrictions on our part, for example if we are obliged to store or process certain data, have an overriding interest in it (insofar as we can refer to it) or if we are required to assert Need claims. If you have any costs, we will inform you in advance. We have already informed you about the possibility of revoking your consent in Section C. Please note that the exercise of these rights can conflict with contractual agreements and this can have consequences such as premature termination of the contract or cost consequences. In this case, we will inform you in advance, where this is not already contractually regulated.

The exercise of such rights usually requires that you clearly prove your identity (e.g. by means of a copy of your ID, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in Section A.

Each person concerned also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The responsible data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

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11. Changes

We can adjust this data protection declaration at any time without prior notice. The current version published on our website applies. Insofar as the data protection declaration is part of an agreement with you, we will inform you of the change in the event of an update by e-mail or in another suitable manner.