Privacy policy
1. Data protection at a glance
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.
Data collection on this website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. Their contact details can be found in the section “Information on the responsible body” in this privacy policy.
How do we collect your data?
Your data is collected when you provide it to us. This may include, for example, data that you enter in a contact form.
Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g. internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyse your user behaviour.
What rights do you have regarding your data?
You have the right to obtain information about the origin, recipient and purpose of your stored personal data at any time and free of charge. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
Please feel free to contact us at any time if you have any further questions on this or other data protection issues.
Analytical tools and third-party tools
When you visit this website, your surfing behaviour may be statistically evaluated. This is primarily done using so-called analysis programmes.
Detailed information about these analysis programmes can be found in the following privacy policy.
2. Hosting
We host the content of our website with the following provider:
External hosting
This website is hosted externally. The personal data collected on this website is stored on the servers of the host/hosts. This may include IP addresses, contact enquiries, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.
External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) DSGVO) and in the interest of secure, fast and efficient provision of our online services by a professional provider (Art. 6(1)(f) DSGVO). If consent has been requested, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
Our host(s) will only process your data to the extent necessary to fulfil their service obligations and will follow our instructions regarding this data.
We use the following host(s):
manitu GmbH
Welvertstraße 2
66606 St. Wendel
Deutschland
3. General information and mandatory information
data protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We would like to point out that data transmission over the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.
Note on the responsible body
The responsible body for data processing on this website is:
Aron Brocher
Revenite UG (haftungsbeschränkt)
Welscher Heide 19
51429 Bergisch Gladbach
Deutschland
Telefon: +491729575008
E-Mail: aron.brocher@comeback-tracker.de
The responsible body is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).
storage period
Unless a more specific storage period is specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, deletion will take place once these reasons no longer apply.
General information on the legal basis for data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) DSGVO or Art. 9(2)(a) DSGVO, if special categories of data are processed in accordance with Art. 9(1) DSGVO. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) DSGVO. If you have consented to the storage of cookies or access to information on your end device (e.g. via device fingerprinting), data processing is also carried out on the basis of Section 25(1) TTDSG. Consent can be revoked at any time. If your data is necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 (1) lit. b DSGVO. Furthermore, we process your data if it is necessary to fulfil a legal obligation on the basis of Art. 6 (1) lit. c DSGVO. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 (1) lit. f DSGVO. The relevant legal basis in each individual case is explained in the following paragraphs of this privacy policy.
Note on data transfer to the USA and other third countries
Among other things, we use tools from companies based in the United States or other third countries that are not secure in terms of data protection. When these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that these countries cannot guarantee a level of data protection comparable to that of the EU. For example, US companies are obliged to disclose personal data to security authorities without you, as the data subject, being able to take legal action against this. It cannot therefore be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data located on US servers for surveillance purposes. We have no influence on these processing activities.
Withdrawal of your consent to data processing
Many data processing operations are only possible with your express consent. You may revoke any consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to object to data collection in specific cases and to direct marketing (Art. 21 DSGVO)
If data processing is carried out on the basis of Article 6(1)(e) or (f) of the DSGVO, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation; this also applies to 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 demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims (objection pursuant to Article 21(1) DSGVO).
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will no longer be used for direct marketing purposes (objection pursuant to Art. 21(2) DSGVO).
Right of appeal to the competent supervisory authority
In the event of violations of the DSGVO, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done if it is technically feasible.
Information, deletion and correction
Within the framework of the applicable legal provisions, you have the right to obtain information free of charge at any time about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correct or delete this data. You can contact us at any time with any questions you may have on this subject or on the subject of personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do so. The right to restriction of processing applies in the following cases:
If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.
If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
If you have lodged an objection pursuant to Art. 21(1) DSGVO, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may – apart from its storage – only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site 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.
Objection to advertising emails
We hereby object to the use of contact details published within the scope of the legal notice obligation for sending unsolicited advertising and information materials. The operators of the website expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, for example via spam emails.
4. Data collection on this website
Cookies
Our websites use so-called “cookies”. Cookies are small data packets and do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser automatically deletes them.
In some cases, cookies from third-party companies may also be stored on your device when you visit our website (third-party cookies). These enable us or you to use certain services provided by the third-party company (e.g. cookies for processing payment services).
Cookies have various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies are used to evaluate user behaviour or display advertising.
Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. for the shopping basket function) or to optimise the website (e.g. cookies for measuring the web audience) are stored on the basis of Art. 6 para. 1 lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG); consent can be revoked at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.
If cookies are used by third-party companies or for analysis purposes, we will inform you separately in this privacy policy and, if necessary, ask for your consent.
server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- Operating system used
Referrer URL - Host name of the accessing computer
- Time of the server request
- IP address
This data is not merged with other data sources.
This data is collected on the basis of Art. 6(1)(f) DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be collected.
contact form
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 (1) (b) DSGVO, provided that your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6(1)(f) DSGVO) or on your consent (Art. 6(1)(a) DSGVO) if this has been requested; consent can be revoked at any time.
The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.
Enquiry by e-mail, telephone or fax
If you contact us by email, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of processing your request. For the purpose of rectifying app-related errors and processing technical support enquiries, we are entitled to pass on the necessary data, such as account data, the IMEI of the Comeback GPS tracker used in this account, and activation data to our partner Smartdings GmbH.
This data is processed on the basis of Art. 6 (1) (b) DSGVO, provided that your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6(1)(f) DSGVO) or on your consent (Art. 6(1)(a) DSGVO) if this has been requested; consent can be revoked at any time.
The data you send us via contact enquiries will remain with us until you request us to delete it, revoke your consent to its storage or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.
5. Social media
This website incorporates features of the Instagram service. These features are provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
When the social media element is active, a direct connection is established between your device and the Instagram server. Instagram thereby receives information about your visit to this website.
If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to this website with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by Instagram.
If consent has been obtained, the use of the above-mentioned service is based on Art. 6 para. 1 lit. a DSGVO and § 25 TTDSG. Consent can be revoked at any time. If no consent has been obtained, the use of the service is based on our legitimate interest in achieving the widest possible visibility on social media.
Insofar as personal data is collected on our website using the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 DSGVO). Joint responsibility is limited exclusively to the collection of data and its transfer to Facebook or Instagram. The processing by Facebook or Instagram after the transfer is not part of the joint responsibility. The obligations incumbent upon us jointly have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data protection information when using the Facebook or Instagram tool and for the secure implementation of the tool on our website in accordance with data protection law. Facebook is responsible for the data security of Facebook or Instagram products. You can assert your rights as a data subject (e.g. requests for information) regarding the data processed by Facebook or Instagram directly with Facebook. If you assert your rights as a data subject with us, we are obliged to forward them to Facebook.
Data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875 and https://de-de.facebook.com/help/566994660333381.
Further information can be found in Instagram’s privacy policy: https://instagram.com/about/legal/privacy/.
6. Newsletter
Newsletter data
If you would like to subscribe to the newsletter offered on the website, we require your email address and information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter.
Further data is not collected or is collected on a voluntary basis only. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of data, your email address and its use for sending the newsletter at any time, for example via the “Unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
The data you provide us with 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 ceases to apply. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6 (1) lit. f DSGVO.
Data stored by us for other purposes remains unaffected by this.
After you unsubscribe from the newsletter distribution list, your email address will be stored by us or the newsletter service provider in a blacklist, if necessary, in order to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interests and our interests in complying with the legal requirements for sending newsletters (legitimate interest within the meaning of Art. 6 (1) (f) DSGVO). There is no time limit for storage in the blacklist. You can object to the storage if your interests outweigh our legitimate interest.
7) Data processing for contract execution
7.1 Use of special service providers for contract processing and execution
– Billbee GmbH
We use the following provider for order processing: Bilbee GmbH Arolser Straße 10, 34477 Twistetal, Germany.
Your name, address and, where applicable, other personal data will be passed on to the provider in accordance with Art. 6 (1) (b) DSGVO exclusively for the purpose of processing your online order. Your data will only be passed on to the extent that this is actually necessary for the processing of your order.
7.2 – Amazon Pay
If you select the payment method “Amazon Pay”, payment processing will be carried out by the payment service provider Amazon Payments Europe s.c.a., 38 avenue J.F. Kennedy, L-1855 Luxembourg (hereinafter: “Amazon Payments”), to whom we will forward the information you provided during the ordering process along with the information about your order in accordance with Art. 6 (1) (b) DSGVO. Your data will only be forwarded to the payment service provider Amazon Payments for the purpose of payment processing and only to the extent necessary for this purpose. If cookies, i.e. small text files that are stored on your device, are set when using Amazon Pay, this is done exclusively on the basis of your express consent in accordance with Art. 6 (1) (a) DSGVO. This consent can be revoked at any time via the “Cookie Consent Tool” implemented on the website. Further information about Amazon Payments’ privacy policy is available at the following internet address: https://pay.amazon.com/de/help/201751600.
– Apple Pay
If you choose the “Apple Pay” payment method from Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, payment will be processed via the “Apple Pay” function on your iOS, watchOS or macOS device by debiting a payment card stored with “Apple Pay”. Apple Pay uses security features built into your device’s hardware and software to protect your transactions. To authorise a payment, you must enter a code that you have previously set and verify your identity using the Face ID or Touch ID feature on your device.
For the purpose of payment processing, the information you provide during the ordering process, together with the information about your order, is transmitted to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay for the payment to be made. The encryption ensures that only the website through which the purchase was made can access the payment data. After the payment has been made, Apple sends your device account number and a transaction-specific, dynamic security code to the originating website to confirm that the payment was successful.
If personal data is processed during the transfers described above, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 (1) (b) DSGVO. Apple stores anonymised transaction data, including the approximate purchase amount, the approximate date and time, and whether the transaction was successfully completed. Anonymisation completely excludes any personal reference. Apple uses the anonymised data to improve Apple Pay and other Apple products and services.
When you use Apple Pay on your iPhone or Apple Watch to complete a purchase you made using Safari on your Mac, your Mac and the authorisation device communicate via an encrypted channel on Apple’s servers. Apple does not process or store any of this information in a format that can be used to identify you. You can disable the ability to use Apple Pay on your Mac in your iPhone settings. Go to Wallet & Apple Pay and disable Allow Payments on Mac.
Further information on data protection at Apple Pay can be found at the following Internet address: https://support.apple.com/de-de/HT203027
– Google Pay
If you choose the payment method “Google Pay” from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), payment will be processed via the “Google Pay” application on your mobile device running at least Android 4.4 (“KitKat”) and equipped with NFC functionality by debiting a payment card stored with Google Pay or a payment system verified there (e.g. PayPal). To authorise a payment via Google Pay in excess of €25, you must first unlock your mobile device using the verification method you have set up (e.g. facial recognition, password, fingerprint or pattern).
For the purpose of payment processing, the information you provide during the ordering process, together with information about your order, will be passed on to Google. Google will then transmit your payment information stored in Google Pay to the originating website in the form of a unique transaction number, which is used to verify that payment has been made. This transaction number does not contain any information about the actual payment details of your payment method stored in Google Pay, but is created and transmitted as a one-time valid numerical token. For all transactions via Google Pay, Google acts solely as an intermediary for processing the payment. The transaction is carried out exclusively between the user and the originating website by debiting the payment method stored in Google Pay.
If personal data is processed during the transfers described above, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 (1) (b) DSGVO. Google reserves the right to collect, store and evaluate certain transaction-specific information for each transaction made via Google Pay. This includes the date, time and amount of the transaction, the merchant’s location and description, a description of the goods or services purchased provided by the merchant, photos you have attached to the transaction, the name and email address of the seller and buyer or sender and recipient, the payment method used, your description of the reason for the transaction and, if applicable, the offer associated with the transaction.
According to Google, this processing is carried out exclusively on the basis of Art. 6 (1) lit. f DSGVO on the basis of the legitimate interest in proper accounting, verification of transaction data and the optimisation and maintenance of the Google Pay service. Google also reserves the right to combine the processed transaction data with other information collected and stored by Google when using other Google services.
The terms of use for Google Pay can be found here: https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=googlepaytos&ldl=de
Further information on data protection at Google Pay can be found at the following internet address: https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=de
– Paypal
One or more online payment methods from the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg.
If you select a payment method from the provider that requires advance payment, your payment details provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) (b) DSGVO. In this case, your data will only be passed on for the purpose of processing the payment with the provider and only to the extent necessary for this purpose.
If you select a payment method for which we make advance payments, you will also be asked to provide certain personal data (first and last name, street, house number, postcode, city, date of birth, email address, telephone number, and, if applicable, details of an alternative payment method) during the ordering process.
In such cases, in order to protect our legitimate interest in determining your solvency, we will forward this data to the provider for the purpose of a credit check in accordance with Art. 6 (1) lit. f DSGVO. The provider checks whether the payment option you have selected can be granted with regard to payment and/or default risks on the basis of the personal data you have provided and other data (such as shopping basket, invoice amount, order history, payment history).
The credit assessment may contain probability values (so-called score values). Insofar as score values are included in the result of the credit assessment, they are based on a scientifically recognised mathematical-statistical procedure. Address data, among other things, but not exclusively, are included in the calculation of the score values.
You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for contractual payment processing.
– Stripe
If you choose a payment method offered by the payment service provider Stripe, payment processing will be handled by the payment service provider Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we will pass on the information you provided during the ordering process together with the information about your order (name, address, account number, bank code, credit card number if applicable, invoice amount, currency and transaction number) in accordance with Art. 6 (1) lit. b DSGVO. Your data will only be passed on for the purpose of payment processing with the payment service provider Stripe Payments Europe Ltd. and only to the extent necessary for this purpose. For more information on Stripe’s data protection policy, please visit https://stripe.com/de/privacy#translation.
