Privacy Policy

  1. Controller
  2. Processing of Personal Data
  3. Protection of Your Personal Data
  4. Purposes for Processing Personal Data
  5. Data Collected Automatically When Visiting Our Website
  6. Cookies
  7. Use of Google Analytics
  8. Use of Google DoubleClick Cookies
  9. Children and Young People
  10. Security
  11. Changes to Our Privacy Policy
  12. Consent
  13. Contact Form
  14. Application Process
  15. Data Subject Rights
  16. Right to Object
  17. Questions, Suggestions, Complaints to the External Data Protection Officer
  18. Right to Submit a Complaint to a Supervisory Authority

1. Controller

As the operator of this website (www.turnfriendly.com), TurnFriendly Software GmbH, Schillstraße 4, 90491 Nuremberg, Germany, is the controller in the sense of the EU General Data Protection Regulation (GDPR) who individually or jointly makes decisions on the purposes and means of the processing of personal data, hereafter referred to as “data”.

2. Processing of Personal Data

According to the General Data Protection Regulation, personal data is any information concerning an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier (such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Use of our website does not require you to provide data. However, in certain cases, we will need your name, address and additional information to perform your requested services.

The same applies to, e.g., the sending of information material and ordered goods and to responses to individual inquiries. We will notify you when required. Furthermore, we only process data you provide to us voluntarily and data that is collected automatically when our website is visited (e.g., your IP address and the names of the pages you opened, your browser and operating system, time and date of access, search engines used or names of downloaded files).

If you request our services, usually only the data required for us to perform the service will be collected. Any additional data we may request may be provided voluntarily.

Data will only be processed to perform requested services and to safeguard our legitimate business interests.

3. Protection of Your Personal Data

Thank you for your interest in our company and our products and services. We want you to feel safe about your data when visiting our website. We take the protection of your data very seriously and strictly adhere to the General Data Protection Regulation and the German Federal Data Protection Act [Bundesdatenschutzgesetz, BDSG] in its respectively valid form.

We implemented technical and organizational measures to ensure compliance with data protection regulations by both us and our commissioned external service providers. We require our employees and commissioned service providers to maintain confidentiality and adhere to the General Data Protection Regulation and the German Federal Data Protection Act in its respectively valid form.

As part of our obligation to provide information, we want this Privacy Policy to be as transparent as possible and will explain the purposes for processing your data and use of tracking/analysis tools, cookies and social media plugins hereafter.

4. Purposes for Processing Personal Data

We will process the data you provide in accordance with the principles of data economy and purpose limitation. The principle of purpose limitation states that data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes is not considered to be incompatible with the initial purposes.

We only process your data to answer inquiries, handle your orders and provide access to certain information or offers to you. Maintaining customer relationships may also require us or a commissioned service provider to use this data to inform you about product offers or to conduct online surveys to fulfill the tasks and requirements set by our customers.

We will only process the data you provide online for the stated purposes. Your data will not be transferred to third parties without your express consent.

Data will only be collected or transmitted to authorized state institutions and officials in accordance with applicable laws or if we are required to do so due to a court order.

We respect that you may not wish to provide your data to support our customer relationship (especially not for direct marketing or market research purposes). We will not sell your data to third parties or otherwise market your data without your consent.

5. Data Collected Automatically When Visiting Our Website

When using our website, the following data may be processed for technical and organizational reasons: The names of the pages you opened, your browser and operating system, time and date of access, search engines used or names of downloaded files and your IP address.

6. Cookies

When you visit our website, we may save information on your computer in form of a (session) cookie. Cookies are small text files transmitted by a web server to your browser and saved on your computer's hard disk.

Except for your IP address, no personal user data will be saved. This information allows you to be automatically recognized during your next visit to our website and makes navigation easier. Cookies enable us to, e.g., adjust our website to your interests and to save your password so that you won't have to re-enter it every time you visit our website.

You may also view our website without cookies. If you do not want us to recognize your computer, you may prevent cookies from being saved on your hard disk by setting your browser to "Disable cookies." For detailed instructions, please see your browser's help function. However, please note that disabling cookies may prevent you from fully using every function of our offers.

7. Use of Google Analytics

Our website uses Google Analytics, a web analysis service of Google Inc. ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. Google Analytics uses so-called cookies, text files saved onto your computer that allow your use of the website to be analyzed.

The information on your website use generated by the cookie is generally transmitted to a Google server in the USA where it is saved. If IP-anonymization is activated on our website, your IP address will be shortened by Google within a Member state of the European Union or in another state party to the European Economic Area Agreement (so-called IP masking).

Only in exceptions will your full IP address be transferred to a Google server in the US and shortened there. On behalf of the operators of this website, Google will use this information to assess your use of this website, to compile reports about website activity and to perform additional services related to use of the website and the Internet for the website operators.

The IP address transmitted by your browser through Google Analytics will not be merged with other Google data. You can prevent cookie storage through your browser settings at any time. However, please note that you may not be able to use every function of this website. Furthermore, you can prevent the collection of cookie-generated data (including your IP address) on your use of the website and the processing of this data by Google by downloading and installing the browser plug-in provided under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser plugin and on browsers on mobile devices, you may also prevent data collection by Google Analytics by activating the following link which will install an opt-out cookie that will block any future collection of your data when visiting our website. Please note that this link must be activated again if you delete your cookies.

For Google's Privacy Policy, please see https://policies.google.com/privacy?hl=en. For the Google Terms of Service, please see https://policies.google.com/terms?hl=en (German).

8. Use of Google DoubleClick Cookies

Our website uses cookies of Google DoubleClick, an analysis service of Google Inc. ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. DoubleClick uses cookies to optimize advertisements to display relevant advertisements to users, improve advertising campaign reports and to prevent users from repeatedly being displayed the same advertisements.

DoubleClick cookies are used to assess use of this website. For this, reports are prepared about your activities on our website to allow us to adjust our Internet offer to your needs. DoubleClick cookies do not contain personal data, but may occasionally include additional anonymized identifiers to identify campaigns with which the user previously came into contact. This prevents web activities from being assigned to a specific person. DoubleClick cookies used a pseudonymous identification number assigned to your browser to review advertisement clicks and displays. This enables Google and its partner pages to display advertisements based on previous visits to our website or to other websites. Google will transmit the information generated by DoubleClick cookies to servers in the US where it will be saved. By using our website, you agree to the use of the above-stated data and its described processing by Google.

You may refuse this tracking web-analysis or disable DoubleClick cookies at any time. You may download and install the according browser extensions from the respective Google websites. When using several devices or browsers, the opt-out must be installed on each device or browser.

Opt out: Google Analytics: https://tools.google.com/dlpage/gaoptout.

If you do not want to install this browser extension or if you access our website through a mobile device or if you want to disable Google Analytics merely for our website, you can also prevent tracking on our pages by Google Analytics through a cookie. To do so, please click on the following link to have a script determine whether the opt-out cookie was installed when you return our website. If so, data collection will be disabled. However, please note that this solution will only apply to one device and only for our website. If you visit our website on several devices (PC, smartphone, etc.), the cookie must be installed on each device.

Click here for an opt-out cookie from Google Analytics
Disable Google Analytics

Please note that Google Analytics was extended by the code "anonymizeIp" on our website to ensure anonymous collection of IP addresses (so-called IP masking).

9. Children and Young People

Our website is aimed exclusively at potential applicants, customers, business partners and media representatives.

Persons under 16 years of age should not transmit data to us without the permission of a parent or guardian. We do not request data from children or youths who have not yet completed their sixteenth year of life. We do not collect such data or provide such data to third parties.

10. Security

We implemented technical and operational protective measures in accordance with the applicable legal regulations to protect your data from, loss, destruction, manipulation and unauthorized access. Our security measures are reviewed regularly and adjusted to technological advances. All our employees and all persons participating in data processing are required to adhere to the General Data Protection Regulation, the German Federal Data Processing Act in its respectively valid form and other laws relevant for data protection and must treat data confidentially.

Furthermore, we conclude according agreements with any external service providers we commission.

Our security measures are regularly reviewed and adjusted in accordance with technological advances.

11. Changes to Our Privacy Policy

We reserve the right to make changes to our security and data protection measures if required due to technical developments. In such cases, we will also adjust our Privacy Policy. Therefore, please note the respectively current version of our Privacy Policy.

12. Consent

Should the processing of your data require your consent, we will obtain it from you and use your data for the stated purposes for which we requested your consent. Your consent will be documented digitally.

You may revoke your consent at any time with future effect. To do so, please write us at Marco Rothberg or email us at hello@turnfriendly.com.

13. Contact Form

If you contact us through our contact form, we will request personal information. A valid email address is required to respond to your inquiry. Additional personal information may be provided voluntarily.

Your information will be processed further by email. Information submitted through the contact form is transmitted through end-to-end encryption.

Your data will be saved on secure servers in Germany under adherence to data protection regulations.

Data for contacting us is processed on the basis of your voluntary consent. By activating the "Send" button, you agree to our processing of your contact information for the above-stated purposes. If you do not agree, you must abort this process. No information will then be transmitted through our contact form and no data will be processed.

You may revoke your consent at any time with future effect.

We only use your data to the extent required for handling your inquiry and for further correspondence with you. We save data collected through your use of our contact form to process your inquiry and for subsequent questions and will delete your data in accordance with data protection regulations after completing your request, unless other legal storage obligations apply.

14. Application Process

By transmitting your applicant data, you consent to the processing of your data for the respective application process. You may revoke your consent at any time with future effect.

15. Data Subject Rights

If we process your data, you are entitled the following extensive rights as a data subject:

a) Right to Information

Under Art. 15 of the General Data Protection Regulation, you have the right to information about the data processed by us.
You may especially obtain information about the purposes of the processing, the categories of personal data concerned, the categories of possible recipients and the envisaged period for which the personal data will be stored.

Please submit information requests to Mr. Marco Rothberg or by email to hello@turnfriendly.com

b) Right to Rectification

Under Art. 16 of the General Data Protection Regulation, you have the right to obtain rectification or completion of your data from us.

You may exercise this right by contacting the above-stated addresses.

c) Right to Erasure

Under Art. 17 of the General Data Protection Regulation, you have the right to obtain erasure of personal data concerning you if storage of the data is no longer required and if there is no other legal ground for its processing. You may also obtain erasure if you object to the processing and there are no overriding legitimate grounds for the processing and if your data was processed unlawfully or if the personal data must be erased for compliance with a legal obligation under EU or national law.

You may exercise this right by contacting the above-stated addresses.

d) Right to Restriction of Processing

Under Art. 18 of the General Data Protection Regulation, you have the right to obtain the restriction of processing if you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of your personal data; if the processing is unlawful, but you oppose the erasure of your personal data; the purposes for the processing cease to apply, but the data is required for the establishment, exercise or defense of legal claims or if you objected in accordance with Art. 21 of the General Data Protection Regulation and if whether the legitimate grounds of the controller outweigh your interests has not yet been determined.

You may exercise this right by contacting the above-stated addresses.

e) Right to Data Portability

Under Art. 20 of the General Data Protection Regulation, you have the right receive your personal data in a structured, commonly used and machine-readable format (data portability). In addition, under certain circumstances, you may also receive your data directly from a controller if technically possible.

You may exercise this right by contacting the above-stated addresses.

16. Right to Object

You have the right to object to use of your data for the above-stated purposes at any time (Art. 21 of the General Data Protection Regulation). This is possible for objections to direct marketing or on grounds relating to your particular personal situation. If you object to direct marketing, we will implement your general objection right without information about your particular personal situation.

To exercise your right to object, please write us at Marco Rothberg or email us at hello@turnfriendly.com

17. Questions, Suggestions, Complaints to the External Data Protection Officer

Should you have any questions about our Privacy Policy, data protection or the processing of your personal data, please contact our data protection officer directly:

Attorney at Law Thomas P. Costard
Rechtsanwaltskanzlei Costard
Kanzlei für IT-Recht und Datenschutz
Bayreuther Straße 11
90409 Nuremberg, Germany
Tel.: 0911/790 30 34, Fax: 0911/790 30 35,
Email: costard@it-rechtsberater.de
www.it-rechtsberater.de

Information requests, suggestions and complaints may also be submitted to the data protection officer.

18. Right to Submit a Complaint to a Supervisory Authority

Please also note that, irrespective of other administrative or legal remedies, you have the right to submit complaints to supervisory authorities, especially in the Member state of your habitual residence, place of work or place of the alleged infringement if you believe that the processing of your personal data infringes on the General Data Protection Regulation.

A list of (non-public sector) supervisory authorities and their addresses is provided (in German) at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Contact us

Questions? Contact us!

Our team is happy to answer your questions.