Privacy

1. Introduction

In the following, we inform about the processing of personal data when using

our website getivy.com
of our services within the scope of the product Ivy
of our profiles in social media.

Personal data is any data that can be related to a specific natural person, e.g. their name or IP address.

1.1. Contact details

The responsible party pursuant to Art. 4 (7) EU General Data Protection Regulation (GDPR) is Ivy GmbH, Reichenbachstr. 16, 80469 Munich, Germany, e-mail: hello@getivy.de. We are legally represented by Ferdinand Dabitz, Simon Wimmer, Peter Lieck, Joshua Becker. Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin, Germany, www.heydata.eu, e-mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal basis

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

Art. 6 (1) p. 1 lit. a DSGVO serves as the legal basis for processing operations for which we obtain consent.

Art. 6 para. 1 p. 1 lit. b DSGVO is the legal basis insofar as the processing of personal data is necessary for the fulfillment of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him.

This legal basis also applies to processing that is necessary for pre-contractual measures, such as inquiries about our products or services.

Art. 6 (1) p. 1 lit. c DSGVO applies if we fulfill a legal obligation with the processing of personal data, as may be the case, for example, in tax law.

Art. 6 (1) p. 1 lit. f DSGVO serves as the legal basis when we can invoke legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed, where available (e.g. for the UK, Canada and Israel), by adequacy decisions of the EU Commission (Art. 45 Ab. 3 DSGVO).

If no adequacy decision exists (e.g., for the USA), the legal basis for the data transfer is usually, i.e., unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 (2) lit. b DSGVO, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies want to access data.

1.4. Storage period

Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for reasons of commercial or tax law.

1.5 Rights of the persons concerned

Data subjects have the following rights vis-à-vis us with regard to the personal data concerning them:

Right to information,

Right to rectification or deletion,

Right to restriction of processing,

Right to object to processing,

Right to data portability,

Right to revoke consent given at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details for the data protection supervisory authorities are available at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

In the context of a business relationship or other relationship, customers, interested parties or third parties only have to provide us with the personal data that is required for the establishment, implementation and termination of the business relationship or for the other relationship, or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7 No automatic decision-making in individual cases

For the establishment and implementation of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 DSGVO. Should we use these procedures in individual cases, we will inform about this separately if this is required by law.1.8. ContactingWhen contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 p. 1 lit. f DSGVO) to answer inquiries directed to us. We delete the data accruing in this context after storage is no longer necessary, or restrict processing if there are legal retention obligations.1.9. customer surveysFrom time to time, we conduct customer surveys in order to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 p. 1 lit f DSGVO. We delete the data when the results of the surveys have been evaluated.

2. Newsletter

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 (1) p. 1 lit. a DSGVO. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

3. Data processing on our website

3.1 Informational use of the website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

These data are:

IP address

Date and time of the request

Time zone difference from Greenwich Mean Time (GMT)

Content of the request (concrete page)

Access status/HTTP status code

Data volume transferred in each case

Website from which the request comes

Browser

Operating system and its interface

Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2 Web hosting and provision of the website

Our website hosts Webflow. The provider is Webflow, Inc., 398 11th St., Floor 2, San Francisco, CA 94103, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the USA. Further information can be found in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.

It is our legitimate interest to provide a website, so that the legal basis of the described data processing is Art. 6 para. 1 p. 1 lit. f DSGVO.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is ensured by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

3.3 Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message.

The legal basis for the processing is our legitimate interest to answer inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f DSGVO.

We delete the data accruing in this context after the storage is no longer required or restrict the processing if there are legal retention obligations.

3.4 Job advertisements

We post jobs that are available within our company on our website, on sites linked to the website, or on third-party websites.

The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 (1) DSGVO in conjunction with Section 26 (1) BDSG. We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.

Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 para. 1 p. 1 lit. a DSGVO).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their resumes and cover letters. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 (2) a DSGVO).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 p. 1 lit. a DSGVO.We pass on the applicants' data to the responsible employees in the HR department, to our order processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to also use their data for further application procedures, we will not delete their data until one year after receipt of the application.

3.5 Payment service provider

For the processing of payments we use either Tink AB, Vasagatan 11, SE-111 20 Stockholm, Sweden, Plaid Financial Ltd, New Penderel House, 4th Floor, 283-288 High, Holborn, London WC1V 7HP, UK, TrueLayer Ltd,1 Hardwick St, Islington, EC1R 4RB London, UK or for the processing of credit card payments Stripe Payments Europe, Ltd, Ireland, which are themselves data controllers in the sense of Art. 4 No. 7 DSGVO. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 p. 1 lit. b DSGVO).

3.6. Third party suppliers

3.6.1 Typeform

We use Typeform for questionnaires and forms. The provider is Typeform S.L., 163 Carrer de Bac de Roda, Barcelona, Spain. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in retrieving information from customers and others in a simple and appealing way.

The data is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://admin.typeform.com/to/dwk6gt.

3.6.2 Google Analytics

We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

3.6.3 Google Optimize

For the optimization of our website we use the tool Google Optimize of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, ("Google"). The tool is an integration to Google Analytics, processes the data from Google Analytics and helps to perform simple tests on the design and content of the website. More information about this can be found under the paragraph for Google Analytics in this Privacy Policy. The legal basis for data processing is Art. 6 para. 1 p. 1 lit. a DSGVO. The consent can be revoked at any time via the data provided on this contact page. The revocation does not affect the lawfulness of the processing until the revocation.

Further information on data processing can be found in the provider's privacy policy at http://www.google.com/policies/privacy.

3.6.4 Hotjar

We use Hotjar for analytics. The provider is Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's, STJ 3141, Malta. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

3.6.5 Weglot

We use Weglot for translations. The provider is Weglot, 138, rue Pierre Joigneaux in BOIS-COLOMBES (92270), France. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in automatically translating information on our website.

3.6.6 Google Tag Manager

We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.6.7 Webflow

We use Webflow to create websites. The provider is Webflow, Inc., 398 11th St., Floor 2, San Francisco, CA 94103, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world.

We delete the data when the purpose for collecting it no longer applies. Further information is available in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.

3.6.8 Sentry

We use Sentry to monitor applications and track errors in applications or on websites. The provider is Functional Software, Inc, 132 Hawthorne Street San Francisco, CA 94107, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 (1) p. 1 lit. a DSGVO. We have a legitimate interest to adequately monitor the functionality of our applications. The processing is based on consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

3.6.9 Mongo DB Atlas

We use the Mongo DB Atlas cloud database. The provider is MongoDB, Inc, 3 Shelbourne Building, Crampton Avenue Ballsbridge, Dublin 4, Ireland ("MongoDB"). The data processing is based on our legitimate interests in the technically error-free and optimized provision of our services. The legal basis is therefore Art. 6 para. 1 p. 1 lit. f DSGVO. In the MongoDB database, we process the personal data specified under item 4.

3.6.10. Sendgrid

We use Sendgrid to send e-mails. The provider is Twilio, Inc, 375 Beale Street, Suite 300, San Francisco, CA 94105, USA (privacy policy: https://www.twilio.com/legal/privacy). The provider processes content, usage, meta/communication data and contact data in the USA.

The legal basis for sending order confirmations is Art. 6 para. 1 b) DSGVO. If emails are sent on the basis of consent, the consent is the legal basis according to Art. 6 para. 1 lit. a) DSGVO. The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.twilio.com/legal/privacy.

3.6.11. Amazon Web Services (AWS Cloud)

We use AWS as cloud storage. The provider is Amazon Web Services EMEA Sàrl, Avenue John F. Kennedy 38, 1855 Luxembourg, Luxembourg. The provider processes IP addresses, profile pictures and documents uploaded by users in the EU. The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in maintaining a modern and cost-effective hosting environment. The data is deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://aws.amazon.com/de/privacy/.

4. Data processing during the use of our product Ivy

With respect to users of our Ivy digital wallet, we process the following data in the course of registration and use in order to perform the service of our product to the customer:

Name, Email address,

Phone number

Address

Content/price of an e-commerce shopping cart.

After entering the above data, the user is redirected to the Tink service of Tink AB, Vasagatan 11, SE-111 20 Stockholm, Sweden. At Tink, the user selects his institution from a list of banks and is redirected by Tink to the login of the respective bank. At the bank, the payment is approved and the user is then redirected back to Ivy. In the process, we only receive the information whether the authentication of the payment was successful.

To ensure the highest possible bank connectivity, we add other open banking infrastructure providers in addition to Tink. If there are any problems connecting Tink to the customer's bank, the user will be redirected to TrueLayer or Plaid. The providers are TrueLayer Ltd,1 Hardwick St, Islington, EC1R 4RB London, UK and Plaid Financial Ltd, New Penderel House, 4th Floor, 283-288 High, Holborn, London WC1V 7HP, UK. Via TrueLayer or Plaid, the user is redirected to the login of the respective bank. At the bank, the payment is released and the user gets back to Ivy. Thereby we only get the information if the authentication of the payment was successful. If the user's bank is not available at any of the above mentioned banks, he/she can pay by credit card. To process credit card payments, we use Stripe Payments Europe, Ltd., Ireland, which itself is a data controller within the meaning of Art. 4 No. 7 DSGVO. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 p. 1 lit. b DSGVO).

In the case of an express checkout, we forward personal data to the respective merchant from whom the user was referred (e-mail address, cell phone number, name, address, shipping method).

The legal basis for the data processing described is consent obtained from the user (Art. 6 para. 1 p. 1 lit. a DSGVO), insofar as forwarding to third parties is concerned. Users can revoke consent at any time, e.g. by contacting hello@getivy.de. The processing of the data until the time of revocation remains lawful.

The processing of the remaining data is necessary for the execution of the contract concluded with users (Art. 6 para. 1 p. 1 lit. b DSGVO).

We do not process personal data to calculate the number of trees to be planted for each transaction.

We delete the data when the account is deleted or when users request deletion and there are no retention rights or obligations to the contrary.

5. data processing on social media platforms

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

6. changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

7. questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.