Zenhomes GmbH attaches great importance to the protection of your data and complies with the legal provisions at all times.
Thank you for your interest in our online presence. The protection of your personal data is very important to us. Zenhomes GmbH (hereafter “Zenhomes”, “Vermietet.de”, “Hausio”, “we” or “us”) takes the protection of personal data very seriously.
This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our social media profile (hereinafter referred to collectively as “online offer”). With regard to the terms used, e.g. “processing” or “person responsible”, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).
“Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable 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 (e.g. a cookie) or 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 upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
“pseudonymisation” shall mean the processing of personal data in such a way that the personal data cannot be related to a specific data subject without the inclusion of supplementary information, provided that this supplementary information is kept separate and is subject to technical and organisational measures ensuring that the personal data is not related to an identified or identifiable natural person.
“profiling” means any automated processing of personal data carried out with a view to evaluating certain personal aspects relating in particular to the performance of work, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or change of location of a natural person.
“Responsible person” shall mean the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
processor” shall mean any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
You can reach us at 0800 72 34 942 or firstname.lastname@example.org
Mollstr. 31, 10249 Berlin, Germany
E-mail address: email@example.com
telephone number: +49 800 7234942
Managing Director: Jannes Fischer
Link to the imprint: www.zenhomes.com/de/impressum
Contact data protection officer: firstname.lastname@example.org
If you have any data protection concerns, please contact us and provide us with sufficient information to individualise your person (e.g. name, e-mail address).
Categories of persons concerned
Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as “users”).
Note for children and young people
Persons under 18 years of age are unfortunately not allowed to use our service.
Types of data processed
When visiting the online offers of the Zenhomes, such as Vermietet.de, you remain anonymous.
You can visit our websites and obtain information without having to provide personal details. During your visit to our website you will then remain anonymous and the connection data transmitted by your Internet browser each time you call up a page, such as the date, the length of stay or the name of your Internet service provider, will be used by us without personal reference.
If you register, we take the liberty of storing some data, such as contact details and bank details.
You provide personal information voluntarily, for example, when you use the services offered on our websites, make a booking/order, register for our website, order a newsletter and especially when you provide the user’s access data to his bank accounts.
This personal information may include
Name, address and other user data are stored by us in the context of the contract fulfilment.
First name, surname, address, telephone number, date of birth, e-mail address, account details (name of bank, IBAN, BIC). These data are collected, processed, stored and used by Zenhomes in the context of the fulfilment of the contract.
Access data for bank accounts
Your online banking access data is stored by finAPI GmbH.
Account numbers and PINs of all integrated bank accounts. These data are stored by finAPI GmbH (see below under “external service providers”) to be able to prepare the transaction history always up-to-date in all services. For this purpose the access for future connections is saved when connecting the bank account. The user explicitly agrees to this by connecting a personal bank account.
Transaction data of the payment history and identified savings
We collect, process, store and use transaction data from the payment history within the framework of the fulfilment of the contract.
Payee in the case of direct debits (customer data, such as contract number, customer number, first name, last name), payment sender in the case of credits (first name, last name, bank data), amounts, purpose, date of the respective transaction, frequency of payments, IBAN, SEPA creditor ID, purpose, standing orders, account balances as well as collected information on the savings potential in the case of executed bills of exchange (amount of savings in the first year of delivery, date of savings). These data are collected, processed, stored and used by Zenhomes in the context of the fulfilment of the contract.
Special types of personal data
Sometimes we have to collect special types of personal data under the highest security standards. However, we never pass these on to third parties.
In the course of processing and providing transaction history, it may be necessary for Zenhomes to process special types of personal data. Special types of personal data are data that may include information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health and sex life. Such data may appear in the purpose of use, for example in connection with referrals to/from political parties, trade unions, doctors or certain associations. Zenhomes uses this information solely to provide services related to a bank account. All data will be processed under the highest security standards and under no circumstances will it be disclosed to third parties. The user must explicitly consent to the processing of special types of personal data so that they can be processed by Zenhomes for the purpose of the services. Since it is not technically possible to exclude transfers and the like relating to special types of personal data from the extraction of transaction history, consent is required to use the services of Zenhomes. You will find more information on consent below in the section “Consent”.
We would like to know when and how you use our offers, which is why we store your usage behaviour.
In the course of using the services of Zenhomes, Zenhomes processes and stores usage data that is intended to provide information on how and when users use the service. This includes, above all, log data, which shows when the user has logged on to the service or carried out activities such as a change of contract. In addition, Zenhomes stores data during the conclusion of contracts, which should provide information about the product type, the product partner, contract modalities and change status.
Purpose of processing
We need your data so that we can offer you our services in the best possible way. The protection of this data is carried out according to the highest possible standards.
Without providing the information described in the section “Types of data processed”, various services can only be used to a limited extent. For this reason, Zenhomes grants the users of its services the highest possible standard of data protection. The collection, processing, storage and use of the generated data is exclusively for the purposes specified here.
We may have to pass on your data to third parties in order to provide our services. However, these are obliged to protect your data.
We use this data to fulfil your booking in accordance with the contract or to provide you with the requested service. For this purpose, it may be necessary to pass on your personal data to companies that we use or procure to provide the service or to process the contract. These are for example service providers. These only receive the necessary data from us and are in turn obliged to protect your personal data. We need your e-mail address so that we can confirm receipt of your order and communicate with you (e.g. to send you an order confirmation or a newsletter you have ordered). For services that do not directly serve the provision of services requested by users, such as hosting or the implementation of marketing measures, external service providers can also be used, which may have their headquarters outside the European Union. In such cases, information will be passed on to these companies or individuals to enable them to process your request. The relevant companies can be found in the following sections, in particular “Newsletter” and “External service providers”. The relevant service providers are carefully selected by us, bound by legally compliant contracts and regularly reviewed. The service providers may only use the data for the purposes specified by Zenhomes.
We use your e-mail address to send you information in connection with our services and, upon request, to send you our newsletter.
If you have registered for our newsletter with your e-mail address, we will use your e-mail address for our own advertising purposes beyond the execution of the contract until you unsubscribe from the newsletter. In addition, the e-mail address is used exclusively for the purpose of sending e-mails to the user in connection with services such as summaries, reminders, information about news and the like. The user may object to the sending of any emails at any time by sending an informal objection to Zenhomes contact details.
Your user account allows you to use our services quickly and conveniently.
When you register on our site, your data will be stored to create a user account, to enable you to use your account more quickly and conveniently in the future and to enable you to take advantage of other services on the site.
We will use your data only for the purpose for which it is intended and confidentially and will only pass it on to third parties within the scope of the services you have requested.
We observe the principle of purpose-related data use and collect, process and store your personal data only for the purposes you have requested. Your personal data will not be passed on to third parties without your express consent, unless this is necessary for the provision of the service or the execution of the contract. Also, the transmission to state institutions and authorities entitled to receive information is only carried out within the scope of the legal obligations to provide information or if we are obliged to provide information by a court decision.
You can revoke your consent to data storage at any time.
As far as we use data for a purpose which requires your consent according to the legal regulations, we will ask you for your explicit consent in each case. You can revoke your consent once given at any time and/or object to future uses of your data.
Should we ever evaluate your data, then it will be anonymised.
Within the framework of the legal provisions, we may evaluate user profiles under a pseudonym for the purposes of advertising, market research and to improve our services, but only insofar as you have not exercised your legal right to object to this use of your data.
Applicable legal basis
The legal basis for our data processing is primarily the DSGVO, which will apply throughout the EU from 25 May 2018.
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 letter d DSGVO serves as the legal basis.
In accordance with Art. 32 DSGVO and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
Such measures shall include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical access to data, as well as access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and we respond to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly presettings (Art. 25 DSGVO).
Cooperation with contract processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this is only done on the basis of a legal authorisation (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 letter b DSGVO for the fulfilment of the contract), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called “contract processing agreement”, this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. DSGVO. This means that the processing is carried out in compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of the data subjects
You have the right of confirmation, information, completion, correction, deletion and transmission of your data as well as the right to complain.
You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information on such data, as well as further information and a copy of the data in accordance with Art. 15 DSGVO.
You have accordingly. Art. 16 DSGVO the right to request the completion of data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 DSGVO, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with Art. 18 DSGVO, to demand that the processing of the data be restricted.
You have the right to obtain the data concerning you which you have provided us with in accordance with Art. 20 DSGVO and to demand that it be passed on to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
Right of withdrawal
You can revoke your consent.
You have the right to revoke consents granted in accordance with Art. 7 Para. 3 DSGVO with effect for the future
Right of objection
You can object to future processing.
You may object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. In particular, you may object to processing for the purposes of direct advertising.
Cookies and right of objection for direct advertising
Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the person responsible for the online offer (otherwise, if it is only their cookies, it is called “first-party cookies”).
You can restrict the storage of cookies on your computer and delete them.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
We will delete all your data on request. Simply write to us at email@example.com or via our chat.
The data processed by us will be deleted or restricted in their processing in accordance with articles 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, the storage is in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, trading books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
We process contract and payment data for the provision of contractual services.
Additionally we process
– Contract data (e.g., subject matter of the contract, duration, customer category).
– Payment data (e.g., bank details, payment history)
from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as the organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process within the scope of providing our contractual services. The basis for processing is Art. 6 Par. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose of and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
We disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee agencies and payment service providers.
Furthermore, we store information on suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store these mostly company-related data permanently.
Business management analyses and market research
The analysis of the data available to us is essential for the profitability of our company.
In order to run our business economically, to be able to identify market trends, the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries etc. We process inventory data, communication data, contract data, payment data, usage data, meta data on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with details, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimise our offer and for business management purposes. The analyses serve only us and are not disclosed externally, unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they will be deleted or made anonymous when the user terminates the contract, otherwise after two years from the end of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
Participation in affiliate partner programs
In the context of affiliate programs, we need to be able to track whether the users referred by affiliates actually take advantage of our offers.
Within our online offering, we use tracking measures customary in the industry on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering) in accordance with Art. 6 para. 1 lit. f DSGVO, insofar as these are necessary for the operation of the affiliate system. In the following, we explain the technical background to the users.
The services offered by us and our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if, for example, links or services of third parties are offered after the conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.
In summary, it is necessary for our online offer to be able to track whether users who are interested in affiliate links and/or the offers available from us subsequently take up the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values that can be set as part of the link or otherwise, e.g. in a cookie. These values include in particular the initial website (referrer), time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user, as well as tracking specific values such as advertising material ID, partner ID and categorizations.
The online IDs of the users used by us are pseudonymous values. This means that the online IDs themselves do not contain any personal data such as names or e-mail addresses. They only help us to determine whether the same user who clicked on an affiliate link or was interested in an offer via our online service has taken advantage of the offer, i.e. has concluded a contract with the provider, for example. However, the online identification is personal insofar as the online identification is available to the partner company and also to us, together with other user data. Only in this way can the partner company inform us whether the user has taken advantage of the offer and we can pay out the bonus, for example.
The data recorded in your user account is always yours. If you have cancelled your user account, your data will be completely deleted.
Users can create a user account. As part of the registration process, the required mandatory data is provided to users and processed for the purposes of providing the user account on the basis of Art. 6 para. 1 lit. b DSGVO. The processed data includes in particular the login information (e-mail address and password). The data entered during registration is used for the purposes of the use of the user account and its purpose.
Users can be informed by e-mail about information relevant to their user account, such as technical changes. If users have cancelled their user account, their data with regard to the user account will be deleted, subject to a legal obligation to keep records. It is the responsibility of users to save their data before the end of the contract if they have terminated their user account. We are entitled to irretrievably delete all user data stored during the contract period.
Within the scope of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s need for protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO. The IP addresses are anonymised or deleted after 90 days at the latest.
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO. The user’s details may be stored in a customer relationship management system (“CRM system”) or in comparable inquiry organisations.
We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
We regularly send out a free newsletter to inform you about new features or activities related to your properties.
With the following notes we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your right of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.
To avoid misuse and to be able to prove the registration process, we store your newsletter registration data.
Double-Opt-In and logging: The registration for our newsletter is done in a so-called Double-Opt-In procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name for personal contact in the newsletter.
The dispatch of the newsletter and the associated measurement of success is based on the consent of the recipients in accordance with Art. 6 Para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 Para. 2 No. 3 UWG or on the basis of the legal permission in accordance with § 7 Para. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests as well as meeting the expectations of the users and also allows us to provide proof of consent.
You can unsubscribe from the newsletter service at any time.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter – Mailchimp incl. Mandrill
We send our newsletter via the service MailChimp, which stores your newsletter, registration & interaction data.
The mail-order service provider may use the recipient’s data in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of the dispatch and presentation of newsletters or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Newsletter – measurement of success
The main purpose of measuring the success of the newsletter is to provide our customers only with the information they want to read.
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or from the server of a mailing service provider if we use one. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and time of retrieval are initially collected.
This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined by means of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients, but it is neither our nor the dispatch service provider’s intention to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
External service providers
External service providers commissioned by us comply with European data protection standards without exception.
Zenhomes uses the following external service providers to help optimize the service. Insofar as these service providers process data on behalf of Zenhomes, appropriate agreements have been concluded with them that define the European data protection standards as binding and in particular prohibit the use of the data for other purposes.
Our German partner finAPI provides transaction data as part of the account information service under supervision and exclusively according to the instructions of Zenhomes.
For the provision of transaction data in the context of the account information service we use the external service provider finAPI GmbH, Ainmillerstraße 11, 80801 Munich (“finAPI”), which processes the data under supervision and exclusively according to the instructions of Zenhomes. finAPI never uses the data directly, but only forwards them to Zenhomes.
Access to and use of this data is only possible with explicit consent in accordance with Art. 6 para. 1 lit. a DSGVO in conjunction with Art. 9 para. 2 lit. a DSGVO (see section “Consent” above).
We host our online offers with hosting providers with whom we have concluded a contract.
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of contract processing agreement).
Collection of access data and log files
Log file information is stored for security reasons and deleted after a short time.
We, or our hosting provider, collect log file information on the basis of our legitimate interests as defined in Art. 6 Par. 1 lit. f. DSGVO collects data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.
For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum period of 90 days and then deleted. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
We store some of our data on Google Cloud.
Zenhomes stores some of its data on Google Cloud. Google Cloud is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). All data is secured with 256-bit encryption and maintains the same security standards as a variety of other Google services. The accounts of Zenhomes employees who have access to Google Cloud are regularly audited to ensure the highest level of security for your data.
The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimization of our online services in accordance with Art. 6 paragraph 1 lit. f. DSGVO.
We transfer the data to Google on the basis of the EU standard contract clauses. Google does not use this data itself under any circumstances, but only performs data processing and data storage services on our behalf.
You can find more detailed information on data protection in Google Cloud at https://cloud.google.com/security/.
Google’s content delivery network
We use the Google content delivery network to speed up the development of our websites and the download of files.
We use a Content Delivery Network (CDN) provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
A CDN is a service that helps us to deliver content from our online offering, especially large media files such as graphics or scripts, more quickly with the help of regionally distributed servers connected via the Internet. User data is processed solely for the aforementioned purposes and to maintain the security and functionality of the CDN.
The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimisation of our online offer in accordance with Art. 6 Para. 1 lit. f. DSGVO.
We transfer the data to Google on the basis of the EU standard contract clauses. You can find further information in the Google data protection declaration:
Google Tag Manager
The Google Tag Manager combines most tracking pixels and scripts so that users can load our websites faster.
We use Google Analytics to continuously improve our website.
Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the Internet. In doing so, pseudonymous user profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymisation, i.e. the IP addresses of the users are shortened.
We only use Google Analytics with activated IP anonymisation. This means that the user’s IP address is shortened by Google within member states of the European Union or in other states that are party to the Agreement on the European Economic Area.
Users can prevent the transmission of data to Google and the processing of this data by Google by means of a browser plugin.
The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The personal data of users will be deleted or anonymised after 14 months.
Google Universal Analytics
We use Google Analytics in the design as “universal analytics”. “Universal Analytics” refers to a Google Analytics method in which user analysis is based on a pseudonymous user ID, thus creating a pseudonymous profile of the user with information from the use of various devices (so-called “cross-device tracking”).
Google AdWords and conversion measurement
We use Google AdWords for marketing purposes.
We use Google AdWords on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. DSGVO) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
We use the online marketing process Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to better target ads for and within our online services in order to show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called “remarketing”. For these purposes, when you visit our website and other websites on which the Google advertising network is active, Google will execute code directly by Google and incorporate so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). This file records which websites the user has visited, what content he is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visiting times and other information on the use of the online offer.
We use conversion tracking to gain access to conversion statistics.
We also receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to compile conversion statistics for us. However, we only learn the total number of anonymous users who clicked on our ad and were redirected to a page with a conversion tracking tag. We do not receive any information that personally identifies users.
User information is processed pseudonymously within the Google advertising network. This means, for example, that Google does not store and process the name or e-mail address of the user, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. I.e. from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.
Jetpack (WordPress Stats)
Jetpack helps us to statistically evaluate visitor access and thus improve our online offer.
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO) the plugin Jetpack (here the sub-function “WordPress Stats”), which integrates a tool for the statistical evaluation of visitor accesses, and by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses so-called “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website.
The information generated by the cookie about your use of this website is stored on a server in the USA. The processed data can be used to create user profiles, which are only used for analysis and not for advertising purposes.
Facebook pixels, custom audiences and Facebook conversion
We use the services of Facebook for online advertising. This means that data on surfing behaviour is collected, but not evaluated in a personalised manner or linked to other data of the respective user.
Within our online offer, due to our legitimate interests in analysis, optimization and economic operation of our online offer and for these purposes, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are located in the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used.
On the one hand, the Facebook pixel enables Facebook to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads placed by us only to those Facebook users who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and do not appear to be annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion”).
The processing of data by Facebook takes place within the framework of Facebook’s Data Use Policy. Accordingly, general information on the display of Facebook Ads, in the Facebook Data Use Policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook pixel and its functionality can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.
You may object to the collection by the Facebook pixel.
You may object to the collection by the Facebook Pixel and use of your information to display Facebook Ads. To control what types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions for usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, which means they apply to all devices, such as desktop computers or mobile devices.
We use “Bing Ads” from Microsoft Corporation for marketing purposes.
Within our online offer, we set up our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. DSGVO) we use the conversion and tracking tool “Bing Ads” from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. In doing so, Microsoft stores cookies on the users’ devices in order to enable an analysis of the use of our online offer by the users, if users have accessed our online offer via a Microsoft Bing ad (so-called “conversion measurement”). In this way, Microsoft and we can recognize that someone has clicked on an ad, been redirected to our online offer and reached a previously determined target page (so-called “conversion page”). We only learn the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No IP addresses are stored. No personal information about the identity of the user is disclosed.
For more information about Microsoft Bing Ads’ privacy practices and cookies, users should review Microsoft’s privacy statement at https://privacy.microsoft.com/de-de/privacystatement.
Intercom CRM System
Service requests are handled by the provider Intercom.
In order to be able to process user enquiries more quickly and efficiently (legitimate interest according to Art. 6 Para. 1 lit. f. DSGVO), we use an external CRM system from Intercom Inc., 55 2nd St, 4th Fl., San Francisco, CA 94105, USA (“Intercom”) to process service enquiries via our websites. All data that we transmit via Intercom is sent with 256 bit encryption.
Intercom uses user data only for the technical processing of the requests and does not share it with third parties. In order to use Intercom at least the indication of a correct e-mail address is necessary. A pseudonymous use is possible. In the course of processing service requests it may be necessary to collect additional data (name, address). The use of Intercom is optional and serves to improve and accelerate our customer and user service.
If users do not agree to the collection of data via and storage of data in the external system of Intercom, we offer them alternative contact options for submitting service requests via e-mail, telephone or mail.
Please also refer to Intercom’s data protection notice: https://www.intercom.com/security.
Service requests via our hotline are handled by the provider Aircall.
Our site uses the external service provider Aircall, 42, rue du Faubourg Poissonnière, 75010, Paris, France, for the efficient and simplified processing of service requests via our hotline (legitimate interest according to Art. 6 para. 1 lit. f. DSGVO). Aircall fulfils the minimum requirements for processing data in accordance with the law and is subject to the European data protection directives.
To manage logins to our system, we use the tool Auth0.
Mongo DB Cloud
We manage our database with Mongo DB Cloud.
Mongo DB Cloud is a product of mongoDB, 229 W 43rd Street, New York, 10036, USA, which manages the databases of the online services of the Zenhomes. The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimization of our online services in accordance with Art. 6 para. 1 lit. f. DSGVO.
Please also note the data protection information of https://www.mongodb.com/legal/privacy-policy.
We track down technical faults through Sentry.
In order to be able to identify technical errors in our online products more quickly, we make use of the following services on the basis of our legitimate interests (i.e. interest in the optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) we use the services of Functional Software Inc. (Sentry), 132 Hawthorne Street, San Francisco, California 94107, USA (“Sentry”).
Please also note the data protection information at https://sentry.io/privacy/.
Segment helps us to make our systems run more efficiently and thus faster.
Segment will be evaluated by us on the basis of our legitimate interests (i.e. interest in the optimization and economic operation of our online offering within the meaning of Art. 6 (1) lit. f. DSGVO) to analyse the interaction of users with our online offer and to optimise the product on the basis of this data.
We transfer the data to Segment on the basis of the EU standard contract clauses. Segment does not use this data itself under any circumstances, but only forwards it on our behalf to services that are commissioned by us and named in this data protection declaration.
Please also note the data protection information at https://segment.com/docs/legal/privacy/.
With Adjust we analyse the use of our mobile apps to better adjust them to our customers.
For the analysis of the use of our mobile apps, we base our decisions on our legitimate interests (i.e. interest in the optimization and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. DSGVO) the app analysis service Adjust (adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin).
For the analysis Adjust uses IP and Mac addresses of the App users, which are used exclusively anonymously. The analyses are used exclusively for the purposes of our own market research as well as for the optimization and need-based design of the App.
Through Plista you will only see our ads if you are interested in products as we offer them.
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in terms of Art. 6 para. 1 lit. f. DSGVO) the services of plista GmbH, Torstraße 33-35, 10119 Berlin.
We use Outbrain so that you only see our ads when you are interested in them. You can easily object to the required tracking.
We use the technology of Outbrain Inc. 39 West 13th Street, 3rd floor, New York, NY 10011, USA, which enables us to point our users to additional content on third party websites that may be of interest to them. We use these on the basis of our legitimate interests in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO.
The further reading recommendations integrated by Outbrain, e.g. below an article, are determined on a purely pseudonymous basis on the basis of the previous content read by the user.
Further information on Outbrain’s data protection can be found at http://www.outbrain.com/de/legal/privacy.
Taboola gives you recommendations based on your interests and your surfing behavior. You can deactivate this tracking.
We make use of the tracking on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we use the service of Taboola, Inc., 1115 Broadway, 7th Floor, New York, New York 10010, USA, which enables us to provide user-specific recommendations for content and advertisements based on surfing behavior and customer interests. The user profiles are created using pseudonyms, they are not merged with the data about the bearer of the pseudonym and do not allow any conclusions about personal data.
Further information about Taboola can be found at https://www.taboola.com/privacy-policy. There you can deactivate tracking at any time in the “User Choices” section. After OptOut, no more personalized content/advertising will be played out to you.
Firstlead GmbH / ADCELL Partner Program
ADCELL is our partner in tracking affiliate programs so that we can trace the origin of an order.
This web site uses on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. DSGVO) tracking cookies of Firstlead GmbH, Rosenfelder Str. 15-16, 10315 Berlin, Germany, with the brand ADCELL.
The applicable data protection regulations of Adcell can be found at https://www.adcell.de/agb.
With Ask Nicely we collect customer and user feedback.
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) for the technical recording of customer and user feedback Ask Nicely, a product of Ask Nicely Limited, Lvl 1, 63 Ponsonby Rd, Ponsonby 1011, Auckland, New Zealand.
New Zealand has been confirmed by the European Commission as having an adequate level of data protection by the Adequacy Decision and is therefore a safe third country in the sense of Art. 45 DSGVO.
When using feedback functions, a connection to Ask Nicely’s IT systems is established and data entered is stored there. Ask Nicely is used to automatically send survey e-mails to receive customer ratings and other customer feedback. When customers respond to such a request, information such as the e-mail address is used to contact them to respond to a review or feedback, for example. The feedback and data provided will not be published. If users do not wish to provide customer feedback, there is an option to unsubscribe by clicking on the unsubscribe button located at the bottom of the email received. If users sign in for feedback features by providing an existing Facebook or Google account, a connection to the Facebook server or the Google or Google Mail server will be established and the data necessary for identification will be exchanged. If the user is logged in as a member of Facebook, Facebook assigns this information to the user’s personal Facebook user account, which can only be prevented by logging out before using the feedback function.
Further information on this can be found at https://www.asknicely.com/privacy.
We use Hotjar to make our website even more user-friendly.
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of Art. 6 Par. 1 lit. f. DSGVO) Hotjar, an analysis software of Hotjar Ltd. Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, Europe (“Hotjar”).
Hotjar makes it possible to measure and evaluate user behavior on our website. Hotjar allows us to record your mouse and scroll movements and clicks, among other things, to determine which areas of the site are viewed most often.
Furthermore, we can determine how long you stayed on a page and when you left it. We can also determine at what point you stopped entering information into a form.
The information generated by the “tracking code” and “cookie” about your visit to our website is transmitted to the Hotjar servers in Ireland and stored there.
Further information on this can be found at https://www.hotjar.com/legal/policies/privacy.
You can prevent Hotjar from collecting the information by clicking on the following link and following the instructions there: https://www.hotjar.com/opt-out.
Online presence in social media
Our online presences in social media are subject to the terms and conditions and data processing guidelines of the respective operators.
We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to be able to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Integration of third party services and content
For technical reasons, your IP address is transmitted for third-party content, such as videos and maps, but otherwise no data that you store with us.
Within our online offer, we set up a data protection policy based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. DSGVO), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of these contents are aware of the IP address of the users, as without the IP address they would not be able to send the contents to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information about the browser and operating system, referring websites, visiting time and other details about the use of our online offer, as well as being linked to such information from other sources.
Data protection information in the application process
We also collect, process and delete applicant data in accordance with data protection regulations.
We process the applicant data only for the purpose and within the scope of the application procedure in accordance with the legal requirements. The processing of applicant data is carried out to fulfil our (pre-)contractual obligations within the framework of the application procedure in accordance with Art. 6 Para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing becomes necessary for us, e.g. within the framework of legal procedures (in Germany, § 26 BDSG applies additionally).
The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data are marked as such, otherwise they result from the job descriptions and basically include personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and certificates. In addition, applicants can voluntarily provide us with additional information.
By submitting their application to us, applicants agree to the processing of their data for the purposes of the application procedure in accordance with the type and scope described in this data protection declaration.
Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 DSGVO are voluntarily communicated as part of the application procedure, their processing is also carried out in accordance with Art. 9 Para. 2 letter b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 DSGVO are requested from applicants as part of the application procedure, their processing is also carried out in accordance with Art. 9 Para. 2 letter a DSGVO (e.g. health data if this is necessary for the exercise of the profession).
If made available, applicants can submit their applications to us by means of an online form on our website. The data will be transmitted to us in encrypted form according to the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We can therefore not assume any responsibility for the transmission path of the application between the sender and the receipt on our server and therefore recommend rather to use an online form or the postal dispatch. This is because instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post.
The data provided by the applicants can be processed by us for the purposes of the employment relationship if the application is successful. Otherwise, if the application for a job offer is not successful, the applicants’ data is deleted. Applicants’ data is also deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to a justified revocation by the applicants, the data will be deleted after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
The retention of applicant data in our talent pool is voluntary based on consent.
As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent within the meaning of Art. 6 para. 1 lit. b. and Art. 7 DSGVO.
The application documents in the talent pool will be processed solely in the context of future job advertisements and the search for employees and will be destroyed at the latest after expiry of the deadline. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application procedure and that they can revoke this consent at any time in the future and declare their objection within the meaning of Art. 21 DSGVO.
Amendment of the data protection declaration
Status August 7, 2020
This data protection declaration is an English translation of the German original (available via www.zenhomes.com/de/datenschutz). Only the German original is legally binding.