PRIVACY POLICY CHAPTR Gmbh

Status: 05/2024

I. Data Protection Is a Matter of Trust

Data protection is a matter of trust and your trust is important to us. We fully comply with all legal requirements and, in order for you to feel comfortable when visiting our website, we would like to inform you transparently about our use of your data. We want you to know when we collect and store which data, and how and for what purposes we use it. The following data protection information summarises for you the data processing in our company. It applies to all websites, apps as well as other services and features offered by us.

We only use personal data within the framework of these provisions and its use is governed by the provisions of the EU General Data Protection Regulation (GDPR), the German Act on Data Protection (BDSG), the German Telemedia Act as well as the German Act on Telecommunications, Teleservices and Data Protection (TTDSG).

We make the greatest possible efforts to protect your data from unauthorised access, loss, misuse or destruction. We also take procedural and electronic protection measures to protect your personal data in accordance with the requirements of Art. 32 GDPR and § 19 German TTDSG.

If you have any questions about this Privacy Policy or about data protection at our company, you can contact our data protection team at data@chaptr.xyz. Further information can be found in sections III. Your Data Subject Rights and V. Contact.

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1. Data Controller

The data controller within the meaning of the General Data Protection Regulation(GDPR)  and the German Act on Data Protection (BDSG) is:

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CHAPTR GmbH

Waldemarstraße 33a

10999 Berlin, Germany

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2. Scope of Processing Personal Data

In principle, we only process personal data insofar as this is necessary for the provision of a functional website as well as for providing our content and services. Depending on how you contact us and which services you use, various data from different sources may be collected. Much of the data we process is provided by you by giving your consent, for example when registering for one of the services we provide and therefore submitting your name or e-mail address or postal address. An exception applies in those cases where the processing of data is permitted by legal regulations.

Statistical data which we collect, for example, when visiting our website and which cannot be linked to you personally are not included here. For example, these are statistics about which pages of the content offered are particularly popular or how many users visit/retrieve certain pages/content.

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3. Data Deletion and Storage Time

Unless an explicit storage time is specified below for the processing operations carried out by us, your personal data will be deleted or made anonymous as soon as the purpose or legal basis for the storage ceases to apply. In principle, your data will only be stored on our servers in Germany and the EU, subject to any transfer that may take place in accordance with the regulations in section II. 9. Data Transfer to Third Countries.

In addition, storage may take place if this is required by the European or national legislator regarding EU regulations, laws or other provisions to which we are subject as the responsible party (e.g. § 257 HGB, § 147 AO). If the storage time prescribed by the statutory provisions expires, the personal data will be anonymised or deleted unless further storage by us is necessary and there is a legal basis for this.

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II. Your Visit to Our Website / Usage Analysis

1. Creation of Log Files

Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer (so-called log files), which your browser transmits to us:

• Information about the browser type and version used
• The operating system of the user
• The user's internet service provider
• The IP address of the user
• Date and time of access

The data collected is used for data security purposes, in particular to defend against attempted attacks, to stabilise operational security and for statistical analysis. They are deleted or anonymised after 7 days at the latest. In the case of anonymisation, the IP addresses are changed in such a way that individual details about personal or factual circumstances can no longer be attributed to a specific or identifiable natural person. The log files are neither used to create individual user profiles nor passed on to any third parties.

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You may also upload content to the platform as part of using our services (content data), which we process to provide the service to you.

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f GDPR or § 25 para. 2 no. 2 TTDSG.

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2. Pseudonymised Usage Profiles

We and our partners may analyse usage profiles using a pseudonym for the offers on our website, for advertising, market and opinion research and to improve our services (Pseudonymised Usage Data), unless you have exercised your right to object to this use of your data via the consent management tool provided by us. Such usage profiles are generated, for example, by means of so-called cookies (see 4. Cookies & Analysis Tools). By analysing and evaluating this information, we are able to improve our website and our services and to make our advertising more suitable and interesting for you.

Legal basis: The legal basis for data processing for the purposes described above is Art. 6 para. 1 lit. a GDPR or § 25 para.1 TTDSG (consent).

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3. Market and Opinion research

In addition, we may also use your data for market and opinion research, e.g. by conducting surveys. Of course, we only use this data anonymously for internal statistical purposes (cf. conditions for participation for the relevant survey).

Legal basis: The legal basis for the data processing is Art. 6 para. 1 lit. a GDPR or § 25 para.1 TTDSG (consent).

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4. Cookies & Analysis tools

On the one hand, cookies are necessary so that you can navigate through the website and use essential functions. These "necessary" cookies may be set without consent according to Art. 6 para. 1 p. 1 lit. f GDPR, § 25 para. 2 No. 2 TTDSG. On the other hand, cookies allow us to personalise the website and make it easier for you to use the website, as well as to evaluate usage data for the purpose of improving our services. These cookies require your consent according to Art. 6 para. 1 p. 1 lit. a GDPR, § 25 para. 1 TTDSG or Art. 49 para. 1 a GDPR, § 25 para. 1 TTDSG when using applications where the transfer of personal data to any third country takes place.

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To obtain consent, we use our Consent Management Tool and thus offer you the option of agreeing to or rejecting the use of cookies when visiting our website. In addition, you have the possibility to inform yourself about the cookies used at any time via the Consent Management Tool and to subsequently adjust the decision you have made there. Cookies that are necessary for the provision of the web service cannot be rejected.

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We use the following types of cookies:

Session cookies: Most of the cookies we store are deleted again at the end of the browser session (so-called session cookies). This allows us to optimise our website, improve content or any personalisation and to simplify use. Session cookies may be set without consent according to Art. 6 para. 1 p. 1 lit. f GDPR, § 25 para. 2 no. 2 TTDSG.

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Persistent cookies: These cookies remain on your hard drive and enable us to recognise your computer on your next visit. The duration depends on the lifetime of the specific cookie and can extend into automatic or manual deletion (e.g. in your browser settings). In particular, these cookies enable you to enter certain details (for example, your password or language settings when logging in) only once and not have to keep re-entering them. These cookies require your consent according to Art. 6 para. 1 p. 1 lit. a GDPR, § 25 para. 1 TTDSG.

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Overview of all Cookies / Objection and Removal Options

For an overview of all cookies used, please

Cookies are stored on the user's computer and transmitted by it. Therefore, you as a user also have full control over the use of cookies. If you do not wish to accept cookies or comparable tools, you can also reject them in the security settings of your browser even beyond the possibilities of the Consent Management Tool. In the security settings of your browser, you can allow or prohibit temporary and permanent cookies independently of each other. If you disable cookies, certain features on our website may not be available to you and some content may not be displayed properly.

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5. Newsletter

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By registering for the newsletter, you agree to receive current information and offers from us. We,  as the responsible party, will process the personal data you provide exclusively for the purpose of sending the newsletter.

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1. Procedure

To verify your email address for newsletter subscription purposes, we employ a so-called double opt-in procedure. This means we will only send you a newsletter via email if you have explicitly confirmed beforehand that you wish to receive it and that the email address you have provided belongs to you. To do this, we will send you a notification email asking you to confirm ownership of the email address by clicking a link within that email for confirmation.

Upon registration for the newsletter, we will also process, record and store your IP address and the date and time of your registration. This data is used to prevent misuse of your email address or our services. Your personal data we collect and process for sending the newsletter will not be disclosed to third parties.

Only individuals with full legal capacity or those who have obtained the consent of their legal guardians may subscribe to the newsletter.

Furthermore, if we receive your email address in connection with concluding a contract or the provision of our services and you have not opted out, we reserve the right to regularly send you current information for that service or offers for similar products or services from our portfolio via email. You may object to the use of your email address for this purpose at any time by sending a message to the contact details provided below or by using the link provided in the promotional email. This will not incur any costs other than the transmission costs according to the basic rates.If at any time you decide to unsubscribe from our newsletter, you may do so effective immediately by sending a notification in text form to the contact details below (e.g., email or letter) to: marketing@chaptr.xyz, Publisher: CHAPTR GmbH.

Additionally, you can always find an unsubscribe link in every newsletter.

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2. Rapidmail

For sending our newsletter, we use the newsletter tool “rapidmail”. Rapidmail is used inter alia, to organise and analyse the dispatch of our newsletters. The data you enter for the purpose of receiving the newsletter is stored on rapidmail's servers in Germany. If you do not accept any analysis by rapidmail, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter sent to you. For the purpose of analysis, the e-mails sent with rapidmail contain a so-called tracking pixel, which connects to the servers of rapidmail when you open the e-mail. That way we can determine whether a newsletter sent to you has been opened or whether and which links within have been clicked. Optionally, links in the e-mail can be set as tracking links with which your clicks can be counted.

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Recipient: the recipient of the data is rapidmail GmbH, Wentzingerstraße 21, 79106 Freiburg im Breisgau, Germany.

Transmission to third countries: No data will be transferred to any third countries.

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Duration: Your data will be stored until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of rapidmail respectively, after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g. e-mail addresses for the use of our products and surveys) remain unaffected by this.

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Further data protection information:

You can find rapidmail's privacy policy here.

For more details on the analysis functions of rapidmail, please refer to the following link: https://www.rapidmail.de/wissen-und-hilfe

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Legal basis: Insofar as data processing takes place after registration for the newsletter, the legal basis is Art. 6 para. 1 lit. a GDPR (consent). The legal basis for sending advertising messages as a result of the sale of goods or services is Art. 6 para. 1 lit. f GDPR, Sect. 7 para 3 UWG.

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6. Social Media Plugins

In addition to our publishing website, we also maintain public profiles on several social networks (such as Instagram, Twitter, Discord and LinkedIn). Your visit to these profiles initiates various data processing procedures. However, the respective pictogram of the platform only establishes direct contact between you and the social network when you actively click on the button ("1-click solution"). When you visit one of our social media profiles, we can only view the information stored in your public profile. The social networks reached via this button each process your data under their own responsibility.

By activating the social media plug-in or the link via the pictogram (Art. 6 para. 1 lit a) GDPR), the following data may be transmitted to the social media providers: IP address, browser information, operating system, screen resolution, installed browser plug-ins, or visited websites (previous and current).

Further information on social media plug-ins, the scope and specific purposes of the respective data processing can be found in the data policies of the relevant controller.

If you use our profiles in the social networks to contact us (e.g. by creating posts or comments, responding to our posts or by sending us private messages), the data you provide us with will be processed exclusively for the purpose in order to contact you. The legal basis for this is Art. 6 para. 1 lit. a and b GDPR. We delete stored data as soon as the storage is no longer necessary or you request us to delete it; in the case of statutory retention obligations, we limit the processing of the stored data accordingly.

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7. Contacting Us

You have the option of contacting us via email. For this purpose, we process your email address and, if applicable, your first and last name. We use this data exclusively to process your request. After clarifying your request, we delete your email address from our systems.

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8. Data Transfer to Third Countries

Data processing within the scope of our business relationships generally takes place in Germany or in other European countries. If, in exceptional cases, a transfer to countries outside the European Union or the EEA (in so-called third countries) takes place, this may result in your data being transferred to a country with a lower data protection standard than in the European Union.

In these cases, we ensure that your data is only processed in third countries if certain measures are taken to ensure that an adequate level of data protection exists (e.g. Adequacy Decision of the EU Commission or so-called suitable guarantees pursuant to Art. 44 et seq. of the GDPR, such as the conclusion of standard contractual clauses or certifications).

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III. Your Data Subject Rights

You have the following rights under the EU General Data Protection Regulation:

Right of access, Art. 15 GDPR

You can request information about the following:

• the purposes for which the personal data are processed;
• the categories of personal data which are processed;
• the recipients or categories of recipients to whom your personal data has been or will be disclosed;
• the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage duration;
• the existence of a right to rectify or delete personal data relating to you, a right to have its processing restricted for the controller or a right to object to such processing;
• the existence of a right of appeal to a supervisory authority;
• any available information on the origin of the data if the personal data is not collected from the individual data subject;
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information on whether personal data relating to you is transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards that we have agreed upon in relation to the recipient of your data and which are related to the transfer.

If you wish to exercise your right to information, please send your request by e-mail or by postal service, clearly identifying yourself, to data@chaptr.xyz or CHAPTR GmbH, Waldemarstraße 33a, 10999 Berlin, Germany.

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Right to rectification, Art. 16 GDPR

You have the right to rectification and/or completion if the personal data processed relating to you is inaccurate or incomplete.

If you wish to exercise your right to rectification, please send your request by e-mail or by postal service, clearly identifying yourself, to data@chaptr.xyz or CHAPTR GmbH, Waldemarstraße 33a, 10999 Berlin, Germany.

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Right to restriction of processing, Art. 18 GDPR

You may request the restriction of the processing of your personal data under the following conditions:

• if you contest the accuracy of the personal data relating to you for a period enabling the controller to verify the accuracy of the personal data;
• if the processing is unlawful and you refuse to delete the personal data and instead request the restriction of the use of the personal data;
• if the controller no longer needs the personal data for the purposes of processing, but you need it for the assertion, exercise or defence of legal claims, or
• if you have objected to the processing and it has not yet been determined whether the legitimate grounds on our side outweigh your grounds.

Where the processing of personal data relating to you has been restricted, we may process such data, other than for storage, only 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 substantial public interest of the Union or a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by us before any restriction is lifted.

If you wish to exercise your right to restrict processing, please send your request by e-mail or by postal service, clearly identifying yourself, to data@chaptr.xyz or CHAPTR GmbH, Waldemarstraße 33a, 10999 Berlin, Germany.

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Right to deletion, Art. 17 GDPR

You have the right to have personal data relating to you deleted without delay if one of the following reasons applies:

• The personal data relating to you is no longer necessary for the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing of your data was based and there is no other legal basis for the processing.
• You object to the processing and there are no other legitimate grounds for the processing.
• The personal data relating to you has been processed unlawfully.
• The deletion of the personal data relating to you is necessary for the compliance with a legal obligation under Union or Member State law to which we are subject.
• The personal data relating to you has been collected in relation to services offered by information society.

The right to deletion does not exist insofar as the processing is necessary.

• to exercise the right to freedom of expression and information;
• for the compliance with a legal obligation which requires processing under Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in order to exercise an official authority vested in us;
• for reasons of public interest in the field of public health;
• for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, or
• for the assertion, exercise or defence of legal claims.

Insofar as this does not conflict with any statutory retention obligations, your personal data will be deleted if you have asserted a claim for deletion, if the data is no longer required to fulfil the purpose for which it was stored or if its storage is inadmissible for other legal reasons.

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Please note that data that you delete yourself may only be blocked at first, and then ultimately deleted after a time delay in order to prevent accidental deletion or any possible delibarate damages.

If you wish to exercise your right to deletion, please send your request by e-mail or by postal service, clearly identifying yourself, to data@chaptr.xyz or CHAPTR GmbH, Waldemarstraße 33a, 10999 Berlin, Germany.

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Right to information, Art. 19 GDPR

If you have asserted the right to rectification, deletion or restriction of processing of your personal data against us, we will notify all recipients to whom we have disclosed the personal data relating to you of this rectification or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You also have the right to be informed about these recipients.

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Right to Data Portability, Art. 20 GDPR

You have the right to receive the personal data relating to you and that you have provided to us in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us, provided that

• the processing is based on consent or on a contract and
• the processing is carried out by means of automated procedures.

In exercising this right, you also have the right to have the personal data relating to you transferred directly from us to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in order to exercise an official authority vested in us.

If you wish to exercise your right to data portability, please send your request by e-mail or by postal service, clearly identifying yourself to data@chaptr.xyz or CHAPTR GmbH, Waldemarstraße 33a, 10999 Berlin, Germany.

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Right to objection, Art. 21 GDPR

You have the right to object at any time to the processing of personal data relating to you. In this case, we will no longer process the personal data relating to you unless we can demonstrate compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

If the personal data relating to you is processed for market and opinion research purposes or for direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.

If you wish to object to the collection, processing or use of your data by us in accordance with these data protection provisions, either in whole or for individual measures, you can send your objection to the above address or by e-mail to data@chaptr.xyz or CHAPTR GmbH, Waldemarstraße 33a, 10999 Berlin, Germany.

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Right to revoke the declaration of consent under data protection law, Art. 7 (3) GDPR

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent shall not affect the lawfulness of the processing carried out by virtue of the consent granted until the revocation.

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Right to complain to a supervisory authority, Art. 77 GDPR

Notwithstanding any other administrative or judicial remedy, you have the right to lodge a complaint with the relevant supervisory authority if you consider that the processing of personal data relating to you infringes the EU General Data Protection Regulation and/or the German Act on Data Protection (BDSG).

Should you make use of this right, please contact the Berlin Commissioner for Data Protection and Freedom of Information.

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IV. Miscellaneous

We reserve the right to change our privacy policy if this should be necessary due to new technologies or for legal reasons. Please ensure that you have the latest version. If fundamental changes are made to this privacy policy, we will announce these changes on our website.

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V. Contact

If you have any concerns about data protection or the enforcement of your data subject rights, you can contact our data protection officer at data@chaptr.xyz at any time.

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