Privacy Policy

1) Introduction: this privacy policy ("Policy") describes how the personally identifiable information ("Personal Information") you may provide on the www.kaizenner.eu website ("Website" or "Service") and any of its related products and services (collectively, "Services") is collected, protected and used. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy is a legally binding agreement between you ("User", "you" or "your") and this Website operator ("Operator", "we", "us" or "our"). By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Agreement. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

 

2) Automatic collection of information: our top priority is customer data security, which is why we process only minimal user data, only as much as it is absolutely necessary to maintain the Website and Services. These user data are mainly technical data (e.g. Internet browser, operating system or the Internet protocol (IP) address) and is collected automatically as soon as you are entering the website. The information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

 

3) Collection of personal information: you can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Website, you may be asked to provide certain Personal Information (for example, your name or your e-mail address). We receive and store any information you knowingly provide to us when you fill any online forms on the Website. When required, this information may include the following:

 

  • Personal details such as name, country of residence, etc.

  • Contact information such as email address, phone, etc.

 

Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as public databases and our joint marketing partners. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.

 

4) Use and processing of collected information: in order to make the Website and Services available to you, or to meet a legal obligation, we need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:

 

  • Send administrative information

  • Respond to inquiries and offer support

  • Improve user experience

  • Enforce terms and conditions and policies

  • Protect from abuse and malicious users

  • Respond to legal requests and prevent harm

  • Run and operate the Website and Services

 

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

 

Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

5) Privacy policy for Wix.com: this website was created with Wix.com [40 Ltd. Namal, 6350671 Tel Aviv, Israel] ("Wix") and is also hosted on their servers. Wix uses physical, electronic, and procedural safeguards to protect the personal information of its users and site visitors. Wix is a global company that respects the laws of the jurisdictions in which it operates. The processing of the user's customer data may take place in the territory of the European Union, Israel or a third country, territory or one or more specific sectors within this third country, which the European Commission has decided to ensure an adequate system level of protection (transfer based on an adequacy finding). Any transfer to a third country outside the European Union which, according to the European Commission, does not ensure an adequate level of protection, will be made in accordance with the standard contractual clauses (2010/87/EU) in Annex 1 of the Wix Data Processing Agreement. Wix also collects statistical data about the visit of this website. Among the access data are: Name of the accessed website, file, date and time of access, transferred data volume, message about successful access, browser type and version, the operating system of the user, referrer URL (the previously visited site), IP address and the requesting provider. Wix uses the log data for statistical evaluations for the purpose of operation, security and optimization of the offer and these are also available to us as the operator of this website. We have concluded an order processing contract with WIX. This is a contract under data protection law, which guarantees that WIX will process the personal data of our website visitors only according to our instructions and in compliance with the GDPR. Before sending us a message, please also read the privacy policy of Wix, which can be found at http://de.wix.com/about/privacy.

 

6) Disclosure of information: depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

 

7) Retention of information: we will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

 

8) Transfer of information: Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section. Our website also includes tools from companies based in the USA. If these tools are active, your personal data can be sent to the US servers of the respective companies be passed on. We would like to point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to send personal data to the security authorities, without you as the person concerned being able to take legal action against this. Therefore, it cannot be ruled out that US authorities (e.g. secret services) may find your data stored on US servers for monitoring purposes, evaluate and permanently store the data. We have no influence on these processing activities.

 

9) The rights of users: You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

 

10) The right to object to processing: where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.

 

11) Data protection rights under GDPR: if you are a resident of the European Economic Area (EEA), you have certain data protection rights and the Operator aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

 

  • You have the right at any time and free of charge to request information about the origin, recipient and purpose of your stored Personal Information that we store and have the ability to access your Personal Information.

  • You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request us to complete the Personal Information you believe is incomplete.

  • You have the right to request the erase your Personal Information under certain conditions of this Policy.

  • You have the right to object to our processing of your Personal Information.

  • You have the right to seek restrictions on the processing of your Personal Information. When you restrict the processing of your Personal Information, we may store it but will not process it further.

  • You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • You also have the right to withdraw your consent at any time where the Operator relied on your consent to process your Personal Information.

 

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

12) Right to object to data collection in special cases and to Direct advertising (Art 21 GDPR): IF THE DATA PROCESSING IS BASED ON ART 6(1) E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR SPECIFIC SITUATION, INCLUDING PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN PROVE THAT THERE ARE COMPELLING REASONS FOR PROCESSING WHICH ARE WORTHY OF PROTECTION AND WHICH OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION ACCORDING TO ART 21(1) GDPR. IF YOUR PERSONAL DATA ARE PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING, INCLUDING PROFILING, INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION BASED ON ART 21(2) GDPR).

 

13) California privacy rights: in addition to the rights as explained in this Policy, California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.

14) How to exercise these rights: Any requests to exercise your rights can be directed to the Operator through the contact details provided in this document. Please note that Personal Information is collected when contacting us (e.g. via contact form). Which data is collected in the case of a contact form can be seen from the respective contact form. These data are stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. Your data will be deleted after the final processing of your request. This is the case if it can be concluded from the circumstances that the matter in question has been finally clarified and provided that there are no legal obligations to retain data. Furthermore, please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

 

15) Privacy of children: By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site. We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us. You must also be at least 16 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).


16) Cookies: see our Cookie Policy.

17) Third-party services: Wix has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement and data optimization services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”). Such Third-Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

 

18) Do Not Track signals: Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your personal information.

 

19) Links to other resources: The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information. This Privacy Policy does not apply to such linked third-party websites and services.

 

20) In particular links to LinkedIn and Twitter: The website links to both social media providers. You can recognize them by their logo or by the explicit reference. We do not collect any personal data in this regard, nor have any influence on what data the linked social media providers collect or use. At present, it must be assumed that a direct connection to the provider's services is established and at least the IP address and device-related information is collected and used. It is also possible that the service providers will attempt to store cookies on the computer used. Please refer to the data protection information of the respective service provider to find out which specific data is collected and how it is used.

21) Use of social media

  • Social Media Plugins with Shariff: this website uses plugins from social media (especially Twitter, LinkedIn). You can usually recognize these plugins by the respective social media logos. In order to guarantee data protection on this website, we only use these plugins in combination with the so-called "Shariff" solution. This application prevents the plugins integrated on this website from transferring data to the respective provider as soon as you enter the site for the first time. Only when you activate the respective plugin by clicking the corresponding button, a direct connection to the provider's server is established (consent). As soon as you activate the plugin, the respective provider receives the information that you have visited this website with your IP address. If you are at the same time logged in to your respective social media account (e.g. Twitter), the respective provider can assign the visit to this website to your user account. Activating the plugin constitutes consent within the meaning of the GDPR. You can revoke this consent at any time with effect for the future.

  • Twitter and LinkedIn Plugins: there are functions of the services Twitter and LinkedIn integrated on this website. These functions are offered by Twitter International Company (One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland) and LinkedIn Ireland Unlimited Company (Wilton Place, Dublin 2, Ireland). By using Twitter / LinkedIn and the respective function "Re-Tweet" / "Share", the visited website will be linked to your Twitter or LinkedIn account and will be announced to other users. In this process, data is also transferred to Twitter / LinkedIn. We would like to point out that we have no knowledge of the content of the transmitted data or its use by Twitter / LinkedIn. For further information, please refer to the privacy policy of Twitter (https://twitter.com/de/privacy) or LinkedIn (https://www.linkedin.com/legal/privacy-policy). The use of the Twitter or LinkedIn plugin is based on our legitimate interest in the widest possible visibility in social media. If the appropriate consent has been given, the processing is carried out exclusively on this basis, but can be revoked at any time. Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here, for example for Twitter at https://gdpr.twitter.com/en/controller-to-controller-transfers.html. You can also change your privacy settings; for example on Twitter in the account settings via https://twitter.com/account/settings.

  • Twitterfeed (POWr): our website uses a Twitterfeed plugin operated by POWr. The operator of the plugin is POWr HQ, 340 Pine Street, San Francisco, California 94104. The plugin provides you with an overview of our recent twitter posts. If you visit one of our pages equipped with a POWr plugin, a connection to the servers of POWr will be made. This tells the POWr server which of our pages you have visited. POWr is used in the interest of an attractive presentation of our online services and an increased reach of our social media activities. This represents a legitimate interest in the sense of Article 6(1) 1 lit. f GDPR. Further information on the handling of user data can be found in the POWr data protection declaration at: https://www.powr.io/privacy.

22) Newsletter: To receive the newsletter offered on our website, you can register using the respective form. However, we use the so-called double opt-in procedure, which means that you will - after using the form - receive a confirmation email with a  final request for a confirmation. The registration only becomes effective if you click on the activation link contained in this confirmation email. We only collect data when you register for the newsletter. These collected data (name and email address) are used exclusively to send the newsletter, which may contain information or offers. The data is generally not transmitted to third parties. However, we use Ascend from WIX to create and send the newsletter. Your data will therefore also be transmitted to WIX, although WIX is prohibited from using the data for purposes other than sending the newsletter. Passing on or selling the data is also not permitted. You can revoke your consent to the storage of the data and its use for sending the newsletter at any time, e.g. via the unsubscribe link in the newsletter or by email. The legality of the data processing operations already carried out remains unaffected by the revocation. The data you have stored with us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to exist. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the framework of our legitimate interest.

 

23) Information security: We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. Wix has in addition also implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts. We therefore encourage you to avoid providing us with any sensitive information which you believe its disclosure could cause you substantial or irreparable harm.

 

24) Data breach: In the event we become aware that the security of the Website and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website.

 

25) Changes and amendments: We reserve the right to modify this Policy or its terms relating to the Website and Services from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will revise the updated date at the bottom of this page. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected. This policy was created with https://www.WebsitePolicies.com.

 

26) Acceptance of this policy: You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

 

27) Contacting us: If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact form, by sending an email to kai.zenner@ep.europa.eu or writing a letter to Kai Zenner, 60 Rue Wiertz, 1047 Brussels, Belgium.

 

This section was last updated on 10 March 2022​.