Privacy Policy
1. Introduction
In the following, we provide information about the collection of personal data when using
● our website jokr.it
● our profiles in social media.
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
1.1. Contact details
The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is JOKR Services GmbH, Große Hamburger Straße 17, 10115 Berlin, Germany, email: privacy@jokr.it. We are legally represented by Sven Grajetzki, Konstantin Sorger, Benjamin Bauer.
Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.
1.2. Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
● Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
● Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
● Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
● Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.
1.3. Data processing outside the EEA
Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).
If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
1.4. Storage duration
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
1.5. Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:
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Right of access,
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Right to correction or deletion,
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Right to limit processing,
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Right to object to the processing,
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Right to data transferability,
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Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.
1.6. Obligation to provide data
Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.
1.7. No automatic decision making in individual cases
As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.
1.8. Making contact
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
1.9. Customer surveys
From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.
2. Newsletter
We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.
Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.
Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.
We send newsletters with the tool Braze of the provider Braze, Inc., 330 W 34th St 18th floor, New York, NY 10001, USA (privacy policy: https://www.braze.com/company/legal/privacy). The provider processes content, usage, meta/communication data and contact data in the process in the EU.
3. Data processing on our website
3.1. Informative use of our website
During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
These data are:
● IP address
● Date and time of the request
● Time zone difference to Greenwich Mean Time (GMT)
● Content of the request (specific page)
● Access status/HTTP status code
● Amount of data transferred in each case
● Website from which the request comes
● Browser
● Operating system and its interface
● Language and version of the browser software.
This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.
3.2. Web hosting and provision of the website
Our website is hosted by Wix.com Ltd., Nemal St. 40, 6350671 Tel Aviv, Israel (privacy policy: https://www.weebly.com/de/privacy/) and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland, in the EU and USA. The provider thereby process the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
We use a content delivery network to help provide our website. The provider is Akamai Technologies GmbH, Parkring 20 - 22, 85748 Garching, Germany (privacy policy: https://www.akamai.com/de/de/multimedia/documents/akamai/akamai-privacy-statement.pdf). The provider thereby processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
3.3. Offer of goods
We do not offer goods via our website. In order to enter into a business relationship with JOKR, customers are required to download the JOKR application. In this case, the privacy policy of the corresponding JOKR application will govern the relationship between the parties.
3.4. Third-party tools
3.4.1. Adjust
We use Adjust for analytics. The provider is Adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.adjust.com/terms/privacy-policy/.
3.4.2. Intercom
We use Intercom for improvement of user engagement. The provider is R&D Unlimited Company 2nd Floor, Stephen Court, 18-21 St. Stephen's Green, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times), contact data (e.g. e-mail addresses, telephone numbers), and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in optimizing the interaction with our website visitors.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://www.intercom.com/legal/privacy.
3.4.3. Facebook Custom Audiences
We use Facebook Custom Audiences for advertising. The provider is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://www.facebook.com/policy.php.
3.4.4. Google Marketing Platform
We use Google Marketing Platform for analytics and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.
3.4.5. Google Maps
We use Google Maps for maps on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are consents.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.
3.4.6. Zapier
We use Zapier for automatization between applications. The provider is Zapier, Inc., 548 Market St. #62411, San Francisco, CA 94104-5401, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in easily connecting the applications in our company to optimize the way we work.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://zapier.com/privacy.
3.4.7. Facebook Conversion API
We use Facebook Conversion API for analytics. The provider is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.facebook.com/policy.php.
4. Data processing on social media platforms
We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.
If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
4.1. Facebook
We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly. More information is available here https://www.facebook.com/legal/terms/page_controller_addendum.
4.2. Instagram
We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.
4.3. LinkedIn
We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
5. Changes to this privacy policy
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
6. Questions and comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.