Privacy Policy

This is an English translation provided for your convenience. The legally binding version of this privacy policy is the German version („Datenschutzerklärung"). In the event of any discrepancy between the German and English versions, the German version shall prevail.

1. Privacy 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 by which you can be personally identified. For detailed information on data protection, please refer to our privacy policy set out 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. You can find the operator's contact details in the section „Information on the Controller" in this privacy policy.

How do we collect your data?

Your data is collected, on the one hand, by you providing it to us. This may, for example, be data you enter into a form.

Other data is collected automatically or with your consent when you visit the website, by means of our IT systems. This is primarily technical data (e.g. internet browser, operating system, or time of the page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected in order to ensure the website is provided without errors. Other data may be used to analyse your user behaviour. Insofar as contracts can be concluded or initiated via the website, the transmitted data is also processed for contract offers, orders, or other enquiries.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipients, and purpose of your stored personal data free of charge at any time. You also have a right to request the rectification or erasure of this data. If you have given consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the subject of data protection.

2. Hosting

We host the content of our website with the following provider:

Amazon Web Services (AWS)

The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter AWS).

When you visit our website, your personal data is processed on servers operated by AWS. Processing takes place in an AWS data centre within the European Union (Frankfurt am Main region, Germany). However, it cannot be ruled out that, in the course of providing the service, personal data may be transferred to AWS's US parent company or that US authorities may assert access to the data on the basis of the US CLOUD Act. Any transfer of data to the USA, insofar as it occurs, is based on the EU Standard Contractual Clauses. You can find details here: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/.

For further information, please refer to AWS's privacy policy: https://aws.amazon.com/de/privacy/?nc1=f_pr.

The use of AWS is based on Art. 6(1)(f) GDPR. We have a legitimate interest in presenting our website as reliably as possible.

The company is certified under the „EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov/participant/5776.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law, which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

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 by which you can be personally identified. 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 point out that data transmission over the internet (e.g. when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Information on the Controller

The controller responsible for data processing on this website is:

Modular Minds GmbH
Andreas-Gayk-Strasse 13
24103 Kiel, Germany

Email: info@modular-minds.com

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, or similar).

Storage Period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for erasure or withdraw your consent to data processing, your data will be erased, unless we have other legally permissible grounds for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, erasure will take place after these grounds no longer apply.

General Information on the Legal Bases for Data Processing on This Website

If you have consented to the data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, insofar as special categories of data within the meaning of Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is additionally based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your terminal equipment (e.g. via device fingerprinting), the data processing is additionally based on Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG). Consent can be withdrawn at any time. If your data is required 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)(b) GDPR. Furthermore, we process your data insofar as it is necessary for compliance with a legal obligation, on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the respective legal bases relevant in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we cooperate with various external parties. This sometimes also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary in the context of the performance of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in passing it on, or if another legal basis permits the data to be passed on. When using processors, we pass on personal data of our customers only on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; 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 CONCERNED, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged breach. This right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in performance 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 insofar as it is technically feasible.

Information, Rectification, and Erasure

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of the data processing and, if applicable, a right to rectification or erasure of this data. You can contact us at any time regarding this and other questions 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 for this purpose. The right to restriction of processing exists 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) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined 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 being stored – only be processed with your consent or for the establishment, 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.

4. Data Collection on This Website

Cookies

Our web pages use so-called „cookies". Cookies are small data packets and do not cause any damage to your terminal equipment. They are stored on your terminal equipment either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your terminal equipment until you delete them yourself or until they are automatically deleted by your web browser.

We use exclusively technically necessary cookies. These are required to ensure the operation and basic functions of our website as well as its security. We do not use cookies for the analysis of user behaviour or for advertising purposes, nor do we use cookies from third-party companies (third-party cookies).

Since these are exclusively technically necessary cookies, they are stored on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Consent to the storage of these cookies is not required.

You can set your browser so that you are informed about the setting of cookies and allow cookies only 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 limited.

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) GDPR. 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.

The server log files are automatically deleted after 14 days at the latest. Any storage beyond this period takes place only insofar as it is necessary for the investigation or prevention of a specific security-related incident; in this case, the affected log files are retained until the incident has been conclusively resolved.

Contact Form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR, insofar as your enquiry is connected with the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this was requested; consent can be withdrawn at any time.

The data you enter in the contact form will remain with us until you request its erasure, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Enquiry by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your enquiry, including all personal data arising from it (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The data you send us via contact enquiries will remain with us until you request its erasure, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Web Analytics and Reach Measurement

Matomo (cookieless)

This website uses the open-source web analytics service Matomo for the statistical evaluation of visitor access. Matomo is self-hosted by us and operated on our own infrastructure. The data collected is not transferred to third parties.

Matomo is configured by us in such a way that no cookies are set and no information is stored on or read from your terminal equipment. In particular, the recognition of browser characteristics is deactivated, so that no access to information in your terminal equipment within the meaning of Section 25 TDDDG takes place. Only data that your browser transmits technically in any case when using the website is evaluated.

The IP addresses collected in this process are shortened or anonymised before each evaluation. Individual visitors are not identified, nor are personal user profiles created. This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the statistical, data-minimising analysis of user behaviour in order to optimise its offering. Since no access to your terminal equipment takes place, no consent is required for this.

Own Reach Measurement

For the statistical evaluation of access to this website, we additionally use a reach measurement solution developed by us ourselves. Processing takes place exclusively on our own infrastructure; the data is not transferred to third parties.

This reach measurement uses exclusively data that your browser transmits technically in any case with each request, namely the IP address, the browser identifier (user agent), and the language setting (Accept-Language). No cookies are set and no information is stored on or read from your terminal equipment. Access to information in your terminal equipment within the meaning of Section 25 TDDDG therefore does not take place.

The aforementioned data is immediately aggregated and encrypted by means of a non-reversible procedure (hashing) using an additional secret (salt). The unshortened IP address is not stored. Identification of individual visitors and recognition of returning visitors beyond the respective session are not possible; the evaluation is carried out exclusively in aggregated, anonymous form. Insofar as a personal reference should nevertheless exist, the processing is based on Art. 6(1)(f) GDPR; the website operator has a legitimate interest in the data-minimising statistical evaluation of access in order to optimise its offering. Since no access to your terminal equipment takes place, no consent is required for this.

6. Newsletter and Email Dispatch

If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you consent to receiving the newsletter. No further data is collected, or only on a voluntary basis. We use the service provider described below to handle the newsletter.

Registration for our newsletter takes place using a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Newsletter registrations are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the service provider are also logged.

The processing of the data entered during newsletter registration is based exclusively on your consent (Art. 6(1)(a) GDPR). You can withdraw your consent to the storage of the data, the email address, and their use for sending the newsletter at any time, for example via the „unsubscribe" link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the withdrawal.

To evaluate and optimise our newsletters, we record whether and when the emails sent are opened and which links contained therein are clicked (performance measurement). This statistical evaluation is covered by your consent. The following also applies here: when you withdraw your consent or unsubscribe from the newsletter, the performance measurement ends.

The data you store with us for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted after you unsubscribe from the newsletter. Data stored with us for other purposes remains unaffected by this.

Transactional and Notification Emails

Independently of the newsletter, in the course of providing our services we send emails with functional or contract-related content, for example system and status notifications, confirmations, or messages relating to the administration of your account. The data required for this (in particular your email address) is processed on the basis of Art. 6(1)(b) GDPR, insofar as the dispatch serves the performance of a contract or the implementation of pre-contractual measures, and otherwise on the basis of our legitimate interest in the reliable and secure operation of our services (Art. 6(1)(f) GDPR). These emails cannot be unsubscribed from as long as the underlying contractual or usage relationship exists, as they are necessary for its performance.

Dispatch Service Provider Mailjet

For the technical dispatch of both our newsletter and our transactional and notification emails, we use the Mailjet service. The provider is Mailjet GmbH, Alt-Moabit 2, 10557 Berlin, Germany, a company of the Sinch group.

On our behalf, Mailjet processes the data required for dispatch, in particular the email addresses of the recipients as well as the data arising in connection with the dispatch and performance measurement. Processing takes place primarily in data centres within the European Union. Due to the corporate group structure of the provider, it cannot be ruled out that personal data may be transferred to group companies in a third country, in particular in the USA, or that access from a third country may occur. Any such transfer, insofar as it occurs, is safeguarded by appropriate guarantees within the meaning of Art. 46 GDPR – in particular EU Standard Contractual Clauses – as well as supplementary protective measures.

The use of Mailjet takes place within the framework of a processing relationship; a data processing agreement (DPA) pursuant to Art. 28 GDPR has been concluded with the provider. Further information on data protection at Mailjet can be found at https://www.mailjet.com/de/rechtliches/datenschutzerklaerung/.