This Privacy Policy explains the processing of your personal data if you visit the website https://www.vay.io/ (the "Website") by Vay Technology GmbH, c/o The Drivery, Mariendorfer Damm 1, 12099 Berlin ("we" or "Vay") as controller (Art. 4 (7) GDPR) and your rights under the GDPR.

1. Why do we use your personal data?

1.1. Registration & communication

We use your personal data to provide you with the services on our Website, for example when you register, log in, participate in training courses and events or send us messages. For example, if you use the contact form, we process your personal data for the purpose of responding to your inquiry. The same applies if you contact us by other means, such as e-mail, messenger services or telephone. The legal basis is Art. 6 (1) b) GDPR.

Our contact form uses the service "MailChimp", a newsletter service of our service provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE Suite 5000, Atlanta, GA 30308, USA. MailChimp acts as our processor (Art. 28 GDPR). We have concluded the EU standard contractual clauses approved by the European Commission with MailChimp to provide adequate safeguards in case of transfers to third countries (esp. the USA).

1.2. Log data

When you visit the website, we receive log data sent by your browser (e.g., IP address, previous website visited, time and date, displayed contents, information regarding the browser and operating system). Collecting log data is technically required to enable you to use our website (the legal basis is Art. 6 (1) b) GDPR). The log files are stored for as long as is necessary for the respective purpose, generally no longer than 30 days.

1.3. Cookies

For our use of Cookies see our Cookie Policy.

1.4. Google Analytics

We use Google Analytics with your consent (Art. 6 (1) a GDPR) to better understand your interests and to continuously improve our website. This service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics allows us to analyse traffic and usage patterns of individual users (without further identifying them) or groups (which webpages you visit, how often you return, how long you stay, etc.). Google acts as a processor (Art. 28 GDPR).

1.5. Google Tag Manager

Google Tag Manager is a tag management system provided by Google that we use on our websites. Google Tag Manager allows us to add code snippets, pixels or similar, to our websites. Google will only process your IP address as a processor (Art. 28 GDPR). Google will not combine your IP address with personal information from other sources. The legal basis is Art. 6 (1) f) GDPR.

1.6. Embedded Content

We use third party providers to embed content on our Website (e.g., videos) with your consent (Art. 6 (1) a GDPR). We embed YouTube videos on our websites. Therefore, Google as the provider of YouTube can access data sent by your browser (e.g., IP address, previous website visited, time and date, displayed contents, information regarding the browser and operating system) and use it for its own purposes.

1.7. Other Purposes for Which We Process Your Personal Data

Furthermore, we process your personal data to:

• meet our legitimate interests (Art. 6 (1) f) GDPR), including the following:

• to complete corporate transactions (e.g., restructuring, asset deals, mergers); and
• to exercise and defend our legal claims.

• comply with our legal obligations, court orders or other binding decisions. The legal basis is Art. 6 (1) c) GDPR.
• with your consent (Art. 6 (1) a) GDPR) for other purposes, such as subscription to a newsletter; in this case, you can revoke your consent at any time.

2. Who Will We Share Your Personal Data With?

In addition to the recipients of data mentioned under section 1, we also use other companies to process personal data on our behalf, such as for sending newsletters or for analysis and advertising purposes. Such service providers only process the data on our behalf in accordance with this privacy policy as so-called processors (Art. 28 GDPR). 

Furthermore, we transmit personal data to third parties if required by law or necessary to exercise or defend legal claims or if third parties provide certain services for us (e.g., lawyers, tax consultants).

Insofar as we transfer personal data to third countries outside of the EU (including the other member states of the EEA), we ensure an appropriate level of data protection through contractual measures (i.e., Standard Contractual Clauses approved by the European Commission). You have the right to receive copies of these contracts. 

3. How Long Do We Store Your Personal Data?

Unless a specific retention period is specified in this privacy policy, we will only process your data for as long as is necessary for the respective purposes or for as long as there are legal retention obligations. After the respective processing purpose is fulfilled and the legal retention periods have ended, your data will be routinely deleted.

4. Your Rights

You can request information about our processing of personal data and a copy of your stored personal data. If you have provided personal data based on a contract or consent, you have the right to receive this personal data in a commonly used and machine-readable format.

In addition, you can also request the deletion, rectification or restriction of the processing of your personal data.

You can revoke your consent at any time (with effect for the future).

Information about your Right of Objection under Article 21 of the GDPR

You have the right, for reasons arising from your particular situation to object to the processing of your personal data, that we process based on legitimate interests as described in Section 1 above. If you file an objection, we will, based on the information provided re-evaluate the grounds for the processing and whether they outweigh your interests, rights and freedoms or the processing, e.g., where the processing is necessary to assert, exercise, or defend legal claims or to fulfill a legal obligation, and, if possible, stop further processing and delete your data if this is not the case.

5. Contact; Complaint to Supervisory Authority

Please address your questions or concerns in connection with the processing of your personal data to our data protection officer:

Vay Technology GmbH c/o The Drivery
– Data Protection Officer –
Mariendorfer Damm 1
12099 Berlin
[email protected]

In case of questions and in case of possible concerns about the data processing, you can also contact a supervisory authority. The responsible supervisory authority for Vay is: 

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin
Germany
[email protected]