Política de Privacidade

APOMEDS DATA PROTECTION POLICY

1. Introduction

Below, we provide information about the processing of personal data when using

- our social media profiles (further information under section 4).

Personal data is any information relating to an identified or identifiable natural person, such as their name or IP address.

GDPR refers to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation - GDPR).

1.1. Contact details

The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is

APO GLOBAL LIMITED (hereinafter “APO GLOBAL”), Ibex House, 61 Baker Street, Weybridge, KT13 8AH, Greater London, United Kingdom.

Our data protection officer can be contacted via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu

Tech Revenues Limited, Florinis 7, Greg Tower, 2nd floor, 1065 Nicosia, Cyprus, is the representative of APO GLOBAL for data privacy matters in the European Union (Article 27 GDPR).

1.2. Scope of data processing, processing purposes, and legal bases

The scope of data processing, processing purposes, and legal bases are explained in detail below. The following are generally considered to be the legal basis for data processing:

- Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent.

- Art. 6 (1) (b) GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a website visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, such as enquiries about our products or services or for clarifying technical problems during the ordering process.

- Art. 6 para. 1 sentence 1 lit. c GDPR applies if we fulfil a legal obligation by processing personal data, as may be the case in tax law, for example.

- Art. 6 (1) (f) GDPR serves as the legal basis if we can invoke legitimate interests for the processing of 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, we guarantee the security of the data during transfer, insofar as (e.g. for the United Kingdom, Canada and Israel) adequacy decisions of the EU Commission (Art. 45 (3) GDPR) are available.

This may lead to risks for users, e.g. because it is more difficult to enforce their rights or because government agencies have access to the data.

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

1.4. Storage period

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention obligations preventing its deletion. If the data is not deleted because it is required for other, 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 are required to retain for commercial or tax reasons.

1.5. Rights of data subjects

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

- Right to information

This right means that you have the right to contact companies, authorities or other organisations to find out whether they process your personal data and, if so, to obtain access to the data and information about its use. You have the right to know whether your personal data is being processed or not. If your personal data is being processed, you have the right to obtain a copy of the data.

- Right to rectification

You have the right to contact companies, authorities and organisations that process your personal data and request that any inaccurate information about you be corrected. You also have the right to supplement any relevant personal data that is missing from the controller. Those who process your data themselves are responsible for regularly ensuring that the data is accurate and up to date.

- Right to erasure

The right to have your data erased is also known as the right to be forgotten. This means that you have the right to contact a company, authority or anyone who processes your personal data and request that your data be erased.

- Right to restriction of processing

This means that in certain specific situations, you have the right to request that the processing of your personal data be restricted. An example of such a situation is if you believe that information about you is incorrect and you have requested that your data be corrected. While the matter is being investigated, you may also request that the processing of the personal data in question be restricted.

In the event of a restriction, the data will be marked so that it may only be processed for specific purposes. If a restriction ends, you must be informed of this.

- Right to object to processing

The right to object applies if personal data is processed for the performance of a task carried out in the public interest, in the exercise of official authority or on the basis of a balancing of interests.

The controller is obliged to inform you of your right to object. This must be stated at the latest when you first make contact, and the information must be provided clearly, distinctly and separately from other information.

- Right to data portability

If you have consented to provide your personal data, or if you have provided the data on the basis of an agreement, you can request to receive the data.

You can not only request to receive the data, but also to have the personal data transferred to another controller, e.g. another company, if you wish to use its services. The controller is only obliged to transfer the data to another company if this is technically feasible.

- Right to withdraw consent at any time.

If a processing activity is carried out with consent as the legal basis (Art. 6(1)(a) GDPR), you have the right to withdraw this consent at any time with effect for the future. If you wish to withdraw your consent, you can contact us, for example, using the contact details provided in section 1.1 of this policy.

- Right to lodge a complaint

Data subjects also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of their personal data. The contact details of 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

Customers, interested parties or third parties must only provide us with personal data within the scope of a business relationship or other relationship that is necessary for the establishment, implementation and termination of the business relationship or other relationship, or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service, or we will no longer be able to perform an existing contract or other relationship.

Mandatory information, i.e. information that the user must fill in to complete a form, is marked as such.

1.7. No automated decision-making in individual cases

As a matter of principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement a business relationship or other relationship. Should we use these procedures in individual cases, we will provide separate information about this, provided that this is required by law.

1.8. Contacting us

When you contact us, e.g. by e-mail or telephone, we store the data you provide (e.g. names and e-mail addresses) in order to answer your questions. The legal basis for processing is our legitimate interest (Art. 6(1)(f) GDPR) in responding to enquiries addressed to us.

We delete the data collected in this context once the purpose for which contact was made has been fulfilled, or restrict processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is in 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 (1) (f) GDPR. We delete the data once the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used our services or purchased goods from us from time to time by email, SMS or other electronic means about our offers, unless they have objected to this. The legal basis for this data processing is Art. 6 (1) (f) GDPR. Our legitimate interest lies in direct marketing (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time without additional costs, for example via the link at the end of each email or by emailing our email address above.

Interested parties have the option of subscribing to a free newsletter. We process names and email addresses exclusively for the purpose of sending the newsletter. Registration takes place by selecting the appropriate field on our website, by ticking the appropriate box 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 para. 1 sentence 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking on the corresponding link in the newsletter or by sending a message to our email address given above. The processing of data until revocation remains lawful even in the event of revocation.

On the basis of the consent of the recipients (Art. 6 (1) (a) GDPR), we also measure the opening and click rates of our newsletters in order to understand which content is relevant to our recipients.

We send newsletters using the ActiveCampaign tool from ActiveCampaign, LLC, 1 N Dearborn St., 5th Floor, Chicago, Illinois 60602, USA (privacy policy: https://www.activecampaign.com/legal/privacy-policy. The provider processes content, usage, meta/communication data and contact data in the USA. This can lead to risks for users, e.g. because it is more difficult to enforce the rights of data subjects or because government agencies can access the data. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46(2)(c) GDPR) agreed by the EU Commission as part of the review procedure under Art. 93(2) GDPR, which we have agreed with the provider.

3. Data processing on our website

3.1. Note for website visitors from Germany

Our website stores information on the end device of website visitors (e.g. cookies) or accesses information that is already stored on the end device (e.g. IP addresses). The following sections provide details on what information this is.

This storage and access is based on the following provisions:

- Insofar as this storage or access is absolutely necessary in order for us to provide the service expressly requested by website visitors (e.g. to operate a chatbot used by website visitors or to ensure the IT security of our website), it is based on Section 25 (2) No. 2 TDDDG.

- Otherwise, this storage or access is based on the consent of the website visitors (Section 25 (1) TDDDG).

Subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2. Informational use of the website

When using the website for informational purposes, i.e. when visitors to the site do not send us any information separately, 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 in our legitimate interest, so the legal basis is Art. 6(1)(f) GDPR.

This data includes:

- IP address

- Date and time of the request

- Time zone difference to Greenwich Mean Time (GMT)

- Content of the request (specific page)

- Access status/HTTP status code

- Amount of data transferred in each case

- Website from which the request originates

- Browser

- Operating system and its interface

- Language and version of the browser software.

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

3.3. Web hosting and provision of the website

Our website is hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sarl, 38 avenue John F. Kennedy, L-1855, Luxembourg. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/de/privacy/?nc1=f_pr.

It is in our legitimate interest to provide a website, so the legal basis for the data processing described is Art. 6 (1) (f) GDPR.

We use the content delivery networks

- Cloudflare for our website. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication or contact data, in the USA. Further information can be found in the provider's privacy policy at https://www.cloudflare.com/de-de/privacypolicy/.

- Cloudfront (Amazon AWS) for our website. The provider is Amazon Web Services, Inc., P.O. Box 81226 Seattle, WA 98108-1226 USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication or contact data, in the USA. Further information can be found in the provider's privacy policy at https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation.pdf.

We have a legitimate interest in using sufficient storage and delivery capacities to ensure optimal data throughput even during peak loads. The legal basis for the data processing described is therefore Art. 6 (1) (f) GDPR.

The legal basis for the transfer to the USA is 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 (https://ec.europa.eu/info/ law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en ) adopted in accordance with the examination procedure pursuant to Art. 93(2) GDPR (Art. 46(2)(c) GDPR), which we have agreed with the provider.

3.4. Customer account

Visitors to the website can open a customer account on our website. We process the data requested in this context on the basis of our legitimate interest (Art. 6(1)(f) GDPR) in enabling website visitors to request medical services or order prescription medicines and process the account data in this context. This also applies to the use of the telephone number stored in the customer account to contact the customer in the event of a technical problem during the services or ordering process.

3.5. Google single sign-on procedure

Visitors to the site can log in to our website using a single sign-on procedure. To do so, they use the login details they have already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using the single sign-on procedure, we receive information from the provider that the site visitor is logged in with the provider, and the provider receives information that the site visitor is using the single sign-on procedure on our website. Depending on the settings of the site visitor in their account on the provider's site, the provider may provide us with additional information. The legal basis for this agreement is the consent of the website visitor who logs in with their account with us (Art. 6(1)(a) GDPR). The provider of the procedure is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (privacy policy: https://policies.google.com/privacy.

3.6. Ordering medication

Visitors to our website can order medication. When processing orders, we collect the following data:

- First name

- Surname

- Email address

- Billing address

- Delivery address

- Telephone number

- Date of birth

- Prescription

The data is processed for the purpose of fulfilling the contract concluded with the respective website visitor (Art. 6(1)(b) GDPR). Insofar as we process health data in this context, the legal basis is Art. 9(1)(h) GDPR. The processing of personal data, in particular the telephone number, is also carried out in accordance with Art. 6 (1) (b) GDPR for the purpose of implementing pre-contractual measures and executing the purchase contract. Your telephone number will be used to contact you to clarify technical problems during the ordering process, e.g. in the event of technical difficulties or cancellation of the order process.

We also pass on the aforementioned data to the following service providers, insofar as this is necessary in the context of the order:

- Delivery service (e.g. DHL or UPS)

- ActiveCampaign, LLC, 1 N Dearborn St., 5th Floor, Chicago, Illinois 60602, USA

- Apomedical Israel, Sderot Abba Eban 12, Herzliya, 4672530

- Sendcloud GmbH, Fürstenrieder Str. 70, 80686 Munich

The legal basis for processing is Art. 6 (1) (b) GDPR, as it is necessary for the performance of the contract, or the data processing agreement concluded with the provider, if applicable. Insofar as we process health data in this context, the legal basis is Art. 9 (2) (h) GDPR.

3.7. Advice from doctors

Visitors can also ask doctors for advice via a link on our website. By clicking on the button on our website that redirects visitors to Health & Go for telemedical services provided by doctors, visitors are redirected to the Health & Go website. Health & Go is responsible for processing the personal data of visitors to the website. Doctors can also prescribe medication to visitors to the website. The data is processed for the purpose of fulfilling the contract concluded with the respective visitor (Art. 6(1)(b) GDPR). Insofar as health data is processed in this context, the legal basis is Art. 9(1)(h) GDPR.

3.8. Use of the online pharmacy and/or doctor service

When using the online pharmacy, personal data is processed in order to identify individuals for the use of the online pharmacy.

The following data is processed:

- Names

- Address

- Date of birth,

- (facial) photo, when using the photo identification procedure

- Identification document, when using the photo identification procedure

We pass on the aforementioned data to FRESCODATA LLC/ID Merit, 5838 Edison Pl Suite 210, Carlsbad CA 92008, USA, insofar as this is necessary for the purpose of personal identification. Further information can be found in the provider's privacy policy at https://www.idmerit.com/gdpr-compliance/.

The legal basis for processing is Art. 6(1)(f) GDPR, as we have a legitimate interest (Article 6(1)(f) GDPR) in ensuring that the online pharmacy or doctor service can only be used by those whose identity has been verified. The use of the photo ID procedure is merely an alternative form of identification. Therefore, the legal basis is Art. 6 (1) (a) GDPR. Insofar as we process health data in this context, the legal basis is Art. 9 (2) (h) GDPR.

3.9. Payment service providers

We use payment processors to process payments, which are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data entered by us during the ordering process and payment data, we thereby fulfil the contract concluded with our customers (Art. 6 (1) (b) GDPR).

These payment service providers are:

- Apple Inc., USA (for Apple Pay), https://www.apple.com/de/legal/privacy/data/

- Google Ireland Limited, Ireland (for Google Pay), https://support.google.com/googlepay/answer/9039712?hl=de

- Klarna Bank AB (publ), Sweden (‘Klarna on account’), https://www.klarna.com/international/privacy-policy/

- Klarna Bank AB (publ), Sweden (‘Klarna Sofort’), https://www.klarna.com/international/privacy-policy/

- PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg, https://www.paypal.com/webapps/mpp/ua/privacy-full

- Mangopay S.A. – dpo.mangopay@mangopay.com

Please note the information in section 1.3 of this policy regarding the transfer of data to countries outside the EEA.

3.10. Cooperation between Apo Global and its Partners [MR1]

Apo Global, Apomeds NL B.V. and Apomedical Israel Ltd., Israel, cooperate with each other. Due to the close cooperation between the companies, corporate agreements have been concluded, in particular agreements pursuant to Article 26 GDPR, which provides a legal framework for transferring data and processing it in integrated teams (Article 6(1)(f) GDPR).

The cooperation also affects your use of Health & Go. If you click on the button on our website to be redirected to Health & Go. for telemedical services provided by doctors, you will be taken to the Health & Go. website. Health & Go. is responsible for processing your personal data on its own website. We only process your order or prescription data if you click on the “Order” button on the Health & Go. website. If a prescription is issued on the basis of an online diagnosis and you order a medicine from the partner pharmacy, they will check the prescription and use your data for the purposes listed above in section 3. (The processing of your personal data and its legal basis). Insofar as we process health data in this context, the legal basis is Art. 9 (2) (h) GDPR.

The cooperation also concerns the processing of data collected through cross-domain tracking using Google Analytics Cross-Site Tracking. Further information on this can also be found above under 3.11. The processing of your personal data and its legal basis – marketing/tracking cookies.

3.11. Technically necessary cookies

Our website uses cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the website more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter ‘technically necessary cookies’), the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.

Specifically, we use technically necessary cookies for the following purpose or purposes:

- Cookies that store the shopping basket,

- Cookies that store log-in data, and

- Cookies that payment providers set for payment processing and do not analyse user behaviour.

3.12. Third-party providers

3.12.1. Hotjar

We use Hotjar for analysis. 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.

The legal basis for processing is Art. 6 (1) (a) GDPR. Processing is based on consent. Data subjects can revoke their consent at any time by contacting us, e.g. using the contact details provided in our privacy policy. Revocation does not affect the lawfulness of processing prior to revocation.

The data will be 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://www.hotjar.com/legal/policies/privacy/ .

3.13.2. TrustedShops

We use TrustedShops as a seal of approval. The provider is Trusted Shops GmbH, Colonius Carré, Subbelrather Straße 15c, 50823 Cologne. The provider processes usage data (e.g. websites visited, interest in content, access times) in the EU.

3.13.3. Freshchat

We use Freshchat for live chat. The provider is Freshworks GmbH, Neue Grünstraße 17, 10179 Berlin. The provider processes content data (e.g. entries in online forms), contact data (e.g. email addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) as a processor in the EU.

3.13.4. Google Tag Manager

We use Google Tag Manager for analysis and advertising purposes. 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.

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

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.

3.13.5. Facebook Pixel

We use Facebook Pixel for analysis. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

3.13.6. Taboola

We use Taboola for conversion tracking. The provider is Taboola, Inc., 16 Madison Square West, 7th fl., New York, NY, 10010, 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.

Data collected directly for the purpose of placing advertisements will be deleted no later than thirteen months after the last interaction of the site visitor with the services. Further information is available in the provider's privacy policy at https://www.taboola.com/de/policies/datenschutzerklaerung.

3.13.7. TikTok Pixel

We use TikTok Pixel for analysis and advertising purposes. The provider is TikTok, Inc., 10100 Venice Blvd Suite 401 Culver City, CA 90232, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for processing is Art. 6(1)(a) GDPR. Processing is based on consent. Data subjects can revoke their consent at any time by contacting us, e.g. using the contact details provided in our privacy policy. Revocation does not affect the lawfulness of processing prior to revocation.

The legal basis for the transfer to a country outside the EEA is 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 (Art. 46(2)(c) GDPR) agreed by the EU Commission as part of the review procedure under Art. 93(2) GDPR, which we have agreed with the provider.

3.13.8. Outbrain

We use Outbrain for advertising. The provider is Outbrain Inc., 222 Broadway 19th Floor, New York, NY 10038, 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 for processing is Art. 6(1)(a) GDPR. Processing is based on consent. Data subjects can revoke their consent at any time by contacting us, e.g. using the contact details provided in our privacy policy. Revocation does not affect the lawfulness of processing prior to revocation.

3.13.9. Bing Ads Conversion Tracking

We use Bing Ads Conversion Tracking for conversion tracking and analysis. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, 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 for the transfer to a country outside the EEA is [Please add].

3.13.10. Cloudflare

We use Cloudflare for the security of our applications. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. 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 for processing is Art. 6(1)(f) GDPR. We have a legitimate interest in increasing the security of our app by preventing harmful traffic from reaching our server.

3.13.11. 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.

3.13.12. VWO

We use VWO for analysis. The provider is Wingify Software Private Limited, 1104, 11th Floor, KLJ Tower North B-5, Netaji Subhash Place, Pitampura, Delhi - 110034, India. 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 for processing is Art. 6(1)(f) GDPR. We have a legitimate interest in monitoring the performance of our applications appropriately.

3.13.13. Reddit Conversion Pixel

We use Reddit Conversion Pixel for analysis purposes. The provider is Reddit, Inc., 548 Market St. #16093, San Francisco, California 94104, 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.

3.13.14. Humanz

We use Humanz for conversion tracking. The provider is Humanz Ltd., 5th Floor 89 New Bond Street London W1S 1DA, UK. The provider processes usage data (e.g. websites visited, interest in content, access times) in the United Kingdom.

4. Data processing on social media platforms

We are represented on social media networks in order to present our organisation and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles based on their online behaviour, which are used, for example, to display advertising on the network pages and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information about usage behaviour in cookies on the users' computers. It cannot be ruled out that the operators may combine this information with other data. Further information and instructions on how users can object to processing by the site operators can be found in the privacy policies of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, meaning that they process data there. This may pose risks for users, e.g. because it makes it more difficult to enforce their rights or because government agencies may access the data.

When users of the networks contact us via our profiles, we process the data provided to us (e.g. name and email address) in order to respond to their enquiries. This is in our legitimate interest, so the legal basis is Art. 6(1)(f) GDPR.

4.1. Facebook

We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. One way to object to data processing is via the settings for advertisements: https://www.facebook.com/settings?tab=ads.

On the basis of an agreement, we are jointly responsible with Facebook for the processing of data from visitors to our profile in accordance with Art. 26 GDPR. Facebook explains exactly which data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward enquiries to Facebook. Data subjects will therefore receive a quicker response if they contact Facebook directly.

4.2. X

We maintain a profile on X (formerly known as Twitter). The operator is X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. The privacy policy is available here: https://x.com/de/privacy.

When users of the networks contact us via our profiles, we process the data provided to us (such as name and email address) in order to respond to the enquiries. This is our legitimate interest, so the legal basis is Art. 6(1)(f) GDPR.

The legal basis for the transfer to a country outside the EEA is 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 (Art. 46(2)(c) GDPR) agreed by the EU Commission as part of the review procedure under Art. 93(2) GDPR, which we have agreed with the provider.

4.3. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. When users of the networks contact us via our profiles, we process the data provided to us (such as name and email address) in order to respond to the enquiries. This is our legitimate interest, so the legal basis is Article 6(1)(f) GDPR.

The privacy policy is available here: www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

The legal basis for the transfer to a country outside the EEA is 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 (Art. 46(2)(c) GDPR), which were agreed with the provider by the EU Commission as part of the review procedure under Art. 93(2) GDPR.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with future effect. The latest version is available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please do not hesitate to contact us using the contact details provided above.

APOMEDS DATA PROTECTION POLICY

1. Introduction

2. Newsletter

3. Data processing on our website

4. Data processing on social media platforms

5. Changes to this privacy policy

6. Questions and comments

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