Privacy policy of bygora
Who is responsible according to the General Data Protection Regulation (GDPR)?
What personal data does the website process?
What personal data does the bygora Marketplace process?
What rights do I have regarding my personal data?
Does bygora use cookies?
What about the bygora Newsletter?
How does the KYC check through Trulioo work?
What additional tools and cookies does bygora use?
bygora uses HTML5 Local Storage for the purpose of verifying the User’s authorization to access the User profile and the bygora Marketplace. Through Local Storage, specific data related to the User is stored in the User’s browser.
The website of bygora uses the cookie consent technology of Consent Manager Provider (“CookieYes“) in order to obtain your consent to the storage of certain cookies on your end device and to document this in a data protection compliant manner. The provider of this technology is CookieYes Limited, 3 Warren Yard Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom, website: https://cookieyes.com/ (hereinafter “Consent Manager Provider”). When you enter the bygora website, a connection is established to Consent Manager Provider’s servers in order to obtain your consent and other declarations regarding cookie use. Subsequently, Consent Manager Provider stores a cookie in your browser in order to be able to allocate the consents granted to you or their revocation. The data collected in this way is stored until you request bygora to delete it, delete the Consent Manager Provider cookie yourself or until the purpose for storing the data no longer applies. Mandatory legal storage obligations remain unaffected. Consent Manager Provider is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 p. 1 lit. c GDPR.
The website and the bygora Marketplace use Google Analytics, a web analytics service provided by Google Inc. (“Google”), established in the European Union as Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how Users use the site. The information generated by the cookie about the use of this website by the User is usually transmitted to a Google server in the USA and stored there. On behalf of bygora, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to bygora. The IP address transmitted by the User’s browser within the scope of Google Analytics is not merged with other Google data. The User may refuse the use of cookies by selecting the appropriate settings on the User’s browser, however, please note that if you do this you may not be able to use the full functionality of this website. Furthermore, the User can prevent the collection of the data generated by the cookie and related to the use of the website by the User (incl. IP address) to Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout. This website uses Google Analytics with the extension “_anonymizeIp()”. This means that IP addresses are processed in a shortened form, thus excluding the possibility of personal references. If the data collected about the User is personally identifiable, this is immediately excluded and the personal data is deleted immediately. bygora uses Google Analytics to analyze and regularly improve the use of our website. The statistics obtained enable bygora to improve its offer and make it more interesting for the User. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to so-called Binding Corporate Rules, which raise the standard of data protection regulations to an appropriate level of protection. The legal basis for the use of Google Analytics is Article 6 (1) sentence 1 lit. f DS-GVO.
The website of bygora uses Google AdSense. This is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, for the integration of advertisements. Google AdSense uses cookies. These are files which are stored on your PC and enable Google to analyze the data relating to your use of our website. In addition, Google AdSense also uses web beacons, which are invisible graphics that enable Google to analyze clicks on this website, traffic to this website and similar information. The information obtained via cookies and web beacons, your IP address and the delivery of advertising formats are transmitted to a Google server located in the USA and stored there. Google may share this collected information with third parties if required to do so by law or if Google instructs third parties to process the data. However, Google will merge your IP address with the other stored data. By making the appropriate settings on your Internet browser, you can prevent the aforementioned cookies from being stored on your PC. However, this may mean that the contents of this website can no longer be used to the same extent. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Within the scope of its legitimate interest in a technically flawless online offer and its economically efficient design and optimisation pursuant to Art. 6 Para. 1 lit. f GDPR, bygora uses the Smartlook analysis software from Smartsupp.com s.r.o., Milady Horakove 13, 602 00 Brno, Czech Republic. This tool records movements on the observed websites in so-called heatmaps. This allows bygora to recognize anonymously where visitors click and how far they scroll. This enables bygora to design its website in a better and more customer-friendly way. The protection of your personal data is very important to bygora when using this tool. All data is collected without bygora being able to assign it to specific Users. bygora can only track how the mouse was moved, where it was clicked and how far it was scrolled. Furthermore, the screen size of the device, the type of device, information on the browser, the country from which access was made and the preferred language are recorded. If personal data of you or third parties are displayed on a website, these are automatically hidden by Smartlook. Therefore, they are not traceable for bygora. By means of a “Do Not Track header” bygora can prevent the use of the tool Smartlook. Then no data will be collected about your visit to the website. You can also deactivate the Smartlook tool alone using the opt-out switch at https://www.smartlook.com/opt-out/. The privacy policy of Smartlook can be found here: https://help.smartlook.com/en/articles/3244452-privacy.
bygora uses the Amazon Web Services (“AWS“) service provided by Amazon Web Services, Inc, P.O. Box 81226, Seattle, WA 98108-1226, USA. The data is stored exclusively in data centers in the European Union (Frankfurt am Main, Germany and Dublin, Ireland), which are certified according to ISO 27001, 27017 and 2018 as well as PCI DSS Level 1. Of course, there are strictly limited access rights for AWS on the part of bygora and the data is automatically encrypted. As a company, AWS has subjected itself to so-called Binding Corporate Rules. More information about AWS and data protection can be found at https://aws.amazon.com/en/compliance/gdpr-center/ and https://aws.amazon.com/en/privacy/.
For the services we offer, bygora uses the technical platform and services of Facebook Ireland Ltd, 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland. The services include “Facebook” and “Instagram” (hereinafter together “social media site”, both operated by Facebook Ireland Ltd. bygora points out to the User that the User uses the social media site and its functions on his own responsibility. This applies in particular to the interactive functions (e.g. commenting, sharing, rating). Facebook processes personal data relating to the User’s account, the User’s IP address and the end devices used by the User; cookies are used for data collection. These are small files that are stored on the User’s end devices. Facebook describes in general terms what information it receives and how it is used in its data usage guidelines. There, the User will also find information on how to contact Facebook, on the options for objecting and on the settings for advertisements. The data use policy is available at the following link:
Facebook: http://facebook.com/about/privacy
Instagram: https://help.instagram.com/519522125107875
The information may be used by Facebook to provide bygora, as the operator of the Facebook pages, with statistical information such as gender and age distribution about the use of the social media page. In addition, Facebook may display further information or advertisements to Users according to their preferences. Facebook provides more detailed information on this at the following link: http://facebook.com/help/pages/insights. The data collected about the User in this context is processed by Facebook Ltd. and may be transferred to countries outside the European Union. If the User visits one of bygora’s social media presences (e.g. Instagram), the User triggers a processing of his personal data during such a visit. In this case, bygora is jointly responsible with the operator of the social media site for the data processing operations within the meaning of Art. 26 GDPR, insofar as bygora actually makes a joint decision with the operator of the social media site about the data processing and bygora also has an influence on the data processing. As far as possible, bygora has concluded joint responsibility agreements with the operator of the social media site in accordance with Art. 26 GDPR, in particular the Page Controller Addendums of Facebook Ireland Ltd. The User can in principle assert his rights both against bygora and against the operator of the social media site. bygora asks the User to note that despite the joint responsibility according to Art. 26 GDPR with the operators of social networks, bygora has no full influence on the data processing of the individual social networks. The corporate policy of the provider has a significant influence on bygora’s options. In the event of the assertion of data subject rights, bygora can only forward these requests to the operator of the social media site. In which way the operator of the social media site uses the data from the visit of the social media site for its own purposes, to which extent activities on the social media site are assigned to individual Users, how long the operator of the social media site stores this data and whether data from a visit of the social media site is passed on to third parties, is not conclusively and clearly stated by the operator of the social media site and is not known to bygora. When a social media site is accessed, the IP address assigned to the User’s terminal device is transmitted to the operator of the social media site. According to the operator of the social media site, this IP address is anonymized (for “German” IP addresses) and deleted after 90 days. The operator of the social media site also stores information about the end devices of its Users (for example, as part of the “registration notification” function); if necessary, the operator of the social media site is thus able to assign IP addresses to individual Users. If the User is currently logged in to the social media site as a User, a cookie with the identifier User is located on the User’s end device. This enables the operator of the social media site to track that the User has visited this site and how the User has used it. Buttons embedded in websites (e.g. Facebook Like button) enable the operator of the social media site to record the User’s visits to these websites and assign them to the User’s social media profile. Based on this data, content or advertising can be offered tailored to the User. If the User wishes to avoid this, the User should log out of the social media site or deactivate the “stay logged in” function, delete the cookies present on the User’s device and exit and restart the browser. In this way, information by which the User can be directly identified will be deleted. This allows the User to use bygora’s social media site without revealing his or her identifier. When the User accesses interactive functions of the site (like, comment, share, message, etc.), a login screen of the operator of the social media site appears. After any login, the User is again recognizable as a specific User for the operator of the social media site. Alternatively, the User can use a different browser than usual to visit the social media site of bygora. The legal basis for the use of the social media site is Art. 6 para. 1 p. 1 lit. f GDPR.
The bygora website uses the share function of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. When the User clicks on the LinkedIn “share button” (plug-in), the User – provided he is logged into his User account at LinkedIn – is redirected to his User account in a separate browser window and can share the electronic publication deposited on the bygora website by adding a comment. Via the plug-in, a direct connection is established between the User’s browser and the LinkedIn server. LinkedIn thereby receives the information that the User has visited the bygora website with his IP address. In addition, it is then possible for LinkedIn to assign the User’s visit to the bygora website to you and your User account. bygora points out that it has no knowledge of the content of the transmitted (personal) data or its use by LinkedIn. Further information on this can be found in LinkedIn’s privacy policy at: https://www.linkedin.com/legal/privacy-policy. The legal basis for the use of LinkedIn is Art. 6 para. 1 p. 1 lit. f GDPR.
The website of bygora uses the service “Twitter“. This service is offered on the technical platform and by means of the services of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. The data controller for individuals living outside the United States is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland. If you call up the page and are logged into your Twitter account at the same time, Twitter can directly assign the visit to our website to your Twitter account. If you do not want Twitter to assign your data to your account, you must log out of Twitter before visiting our website. We would like to point out that you use the Twitter short message service offered on your own responsibility and that we are not aware of all details of data processing at Twitter at the present time. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating). Insofar as data processing is carried out by bygora, this is the responsibility of bygora GmbH, Ettaler Str 21, 82061 Neuried, Germany. The data collected about you when using the service is processed by Twitter Inc. and may be transferred to countries outside the European Union. This data includes your IP address, the application you are using, information about the terminal device you are using (including device ID and application ID), information about websites you have visited, your location and your mobile provider. This data is assigned to the data of your Twitter account or your Twitter profile. We have no influence on the type and scope of the data processed by Twitter, the type of processing and use or the transfer of this data to third parties. Information on what data is processed by Twitter and for what purposes can be found in Twitter’s privacy policy (https://twitter.com/en/privacy). Information on how you can view your own data on Twitter can be found at https://support.twitter.com/articles/2072711#. Furthermore, you have the possibility to request information via the Twitter data protection form or the archive requirements: support.twitter.com/forms/privacy, see also here: https://support.twitter.com/articles/20170320#. Options to restrict the processing of your data are available in the general settings of your Twitter account and under the item “Privacy and security”. In addition, you can restrict Twitter’s access to contact and calendar data, photos, location data, etc. on mobile devices (smartphones, tablet computers) in the settings options there. However, this depends on the operating system used. Twitter buttons or widgets integrated into websites and the use of cookies enable Twitter to record your visits to these websites and assign them to your Twitter profile. Based on this data, content or advertising can be offered tailored to you. Information on this and the available setting options can be found on the following Twitter support pages: https://support.twitter.com/articles/20171570#; https://support.twitter.com/articles/20170520#. In addition, bygora collects and processes the following data from your use of the service: The data entered by you on Twitter, in particular your username and the content published under your account, are processed by us insofar as we retweet or reply to your tweets, if applicable, or also write tweets from us that refer to your account. The data freely published and disseminated by you on Twitter are thus included by bygora in the offer and made accessible to the followers of bygora. The aforementioned data is processed by bygora for the purpose of customer loyalty and promotional use; the legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f GDPR. The legitimate interest follows from the purposes for data collection listed above.
The website of bygora uses the service “Pinterest“. This service is offered on the technical platform and by means of the services of Pinterest Inc, 808 Brannan Street San Francisco, CA 94103-490, USA (hereinafter “Pinterest”). If you call up the page and are logged into your Pinterest account at the same time, Pinterest can directly assign the visit to our website to your Pinterest account. If you do not want Pinterest to assign your data to your account, you must log out of Pinterest before visiting our website. We would like to point out that you use the offered Pinterest service on your own responsibility and that we are not aware of all details of data processing at Pinterest at the present time. This applies in particular to the use of interactive functions (e.g. sharing, commenting). Insofar as data processing is carried out by bygora, this is the responsibility of bygora GmbH, Ettaler Str 21, 82061 Neuried, Germany. Please note that the exact data processing at Pinterest is beyond our knowledge. Information on the purpose and scope of the processing and use of your data by Pinterest, as well as your rights in this regard and options for protecting your privacy, can be found in the Pinterest data protection information: https://about.pinterest.com/en/privacy-policy. The data collected about you when using the service is processed by Pinterest and thereby transmitted to countries outside the European Union. We have no influence on the type and scope of the data processed by the provider, the type of processing and use or the transfer of this data to third parties, in particular to countries outside the European Union. When you visit the Service, cookies and similar technologies such as pixels, web beacons and local storage may be used to collect information about your use of the Service and to provide you with features. In addition, advertisers or other partners of the Provider may serve cookies or similar technologies on your device. Information about how to contact the Provider and how the Provider uses or shares information about your visit to the Service with third parties is also available in the Service’s Privacy Policy https://policy.pinterest.com/de/privacy-policy. Information on how you can manage or delete information about yourself can also be found at https://policy.pinterest.com/en/privacy-policy. The data entered by you on Pinterest, in particular your username and the content published under your account, are processed by bygora insofar as bygora includes them in its offer and makes them accessible to its followers. The aforementioned data is processed by bygora for the purpose of customer loyalty and promotional use; the legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f GDPR. The legitimate interest follows from the purposes for data collection listed above.
The website of bygora uses the service “Tradedoubler“. Tradedoubler is a German affiliate network that offers affiliate marketing. The operating company of Tradedoubler is Tradedoubler GmbH, Herzog- Wilhelm-Straße 26, 80331 Munich, Germany. Tradedoubler is an Internet-based form of marketing that enables website operators, known as merchants or advertisers, to display advertisements, which are usually remunerated via click or sale commissions, on third-party websites, i.e. on the websites of sales partners, also known as affiliates or publishers. The merchant provides an advertising medium via the affiliate network, i.e. an advertising banner or other suitable means of Internet advertising, which is subsequently integrated by an affiliate on its own Internet pages or advertised via other channels, such as keyword advertising or e-mail marketing. Tradedoubler sets a cookie on the information technology system of the data subject. Tradedoubler’s tracking cookie does not store any personal data. Only the identification number of the affiliate, i.e. the partner referring the potential customer, and the order number of the visitor to a website and the advertising material clicked on are stored. The purpose of storing this data is to process commission payments between a merchant and the affiliate, which are processed via the affiliate network, i.e. Tradedoubler. The data subject can prevent the setting of cookies by the website of bygora at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Tradedoubler from setting a cookie on the information technology system of the data subject. In addition, cookies already set by Tradedoubler can be deleted at any time via an Internet browser or other software programs. The storage of “Tradedoubler cookies” takes place on the basis of Art. 6 para. 1 lit. f) GDPR. bygora has a legitimate interest in this, as the affiliate remuneration can only be determined through the cookies. The Tradedoubler privacy policy can be found at http://www.tradedoubler.com/en/privacy-policy/.
bygora has integrated components of the service “TradeTracker” on the website. TradeTracker is an affiliate network that offers affiliate marketing. Affiliate marketing is an Internet-based form of distribution that enables commercial operators of Internet sites, the so-called. Merchants or advertisers are able to display advertisements, which are usually remunerated via click or sale commissions, on third-party websites, i.e. on the websites of sales partners, also known as affiliates or publishers. The merchant provides an advertising medium via the affiliate network, i.e. an advertising banner or other suitable means of Internet advertising, which is subsequently integrated by an affiliate on its own Internet pages or advertised via other channels, such as keyword advertising or e-mail marketing. The operating company of TradeTracker is TradeTracker Deutschland GmbH, Eiffestraße 426, 20537 Hamburg, Germany. TradeTracker sets a cookie on the information technology system of the data subject. The tracking cookie from TradeTracker does not store any personal data. Only the identification number of the affiliate, i.e. the partner referring the potential customer, as well as the order number of the visitor to a website and the advertising material clicked on are stored. The purpose of storing this data is to process commission payments between a merchant and the affiliate, which are processed via the affiliate network, i.e. TradeTracker. The data subject can prevent the setting of cookies at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent TradeTracker from setting a cookie on the information technology system of the data subject. In addition, cookies already set by TradeTracker can be deleted at any time via an internet browser or other software programs. The applicable data protection provisions of TradeTracker can be found at https://tradetracker.com/en/privacy-policy/.
The website of bygora uses the performance advertising network of AWIN AG, Eichhornstraße 3, 10785 Berlin. As part of its tracking services, “AWIN” stores cookies for the documentation of transactions (e.g. of leads and sales) on end devices of Users who visit or use websites or other online offers of its customers (e.g. register for a newsletter or place an order in an online shop). These cookies are used solely for the purpose of correctly assigning the success of an advertising medium and the corresponding billing within its network. AWIN does not collect, process or use personal data. Only the information about when a certain advertising medium was clicked on by an end device is placed in a cookie. In the AWIN tracking cookies, an individual sequence of numbers is stored, which cannot be assigned to the individual User, with which the partner program of an advertiser, the publisher and the time of the User’s action (click or view) are documented. AWIN also collects information about the end device from which a transaction is carried out, e.g. the operating system and the calling browser. The storage of “AWIN cookies” is based on Art. 6 Para. 1 lit. f) GDPR. bygora has a legitimate interest in this, as the amount of its affiliate remuneration can only be determined through the cookies. If you would like more information about AWIN’s data processing, you can find it here: https://www.awin.com/en/legal.
Michael Koid (CEO bygora)