Privacy policy

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your
personal data when you visit this website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject matter of data protection, please consult
our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available
under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this
Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information
you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during
your website visit. This data comprises primarily technical information (e.g., web browser, operating system,
or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data
may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived
personal data at any time without having to pay a fee for such disclosures. You also have the right to demand
that your data are rectified or eradicated. If you have consented to data processing, you have the option to
revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to
demand that the processing of your data be restricted under certain circumstances. Furthermore, you have
the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection
related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website.
Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration
below.

2. Hosting

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website are
stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests,
metadata and communications, contract information, contact information, names, web page access, and
other data generated through a web site.

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art.
6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a
professional provider (Art. 6(1)(f) GDPR).

Our host will only process your data to the extent necessary to fulfil its performance obligations and to
follow our instructions with respect to such data.

We are using the following host:

Strato AG
Pascalstraße 10
10587 Berlin

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence,
we handle your personal data as confidential information and in compliance with the statutory data
protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises
data that can be used to personally identify you. This Data Protection Declaration explains which data we
collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)
may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

poolinq GmbH
Motorstraße 32B,
80809 Munich

Phone: 0160 954 87 350
E-mail: info@poolinq.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes
decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail
addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain
with us until the purpose for which it was collected no longer applies. If you assert a justified request for
deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally
permissible reasons for storing your personal data (e.g., tax or

commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to apply.

Information on data transfer to the USA and other non-EU countries

Among other things, we use tools of companies domiciled in the United States or other from a data
protection perspective non-secure non-EU countries. If these tools are active, your personal data may
potentially be transferred to these non-EU countries and may be processed there. We must point out that in
these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For
instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as
the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out
that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal
data for surveillance purposes. We have no control over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also
revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness
of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct
advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE
THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON
GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED
ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS
BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE
WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO
PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA,
THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE
PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION
PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,
YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR
THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE
EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL
DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES
(OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory
agency, in particular in the member state where they usually maintain their domicile, place of work or at the
place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other
administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your
consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine
readable format. If you should demand the direct transfer of the data to another controller, this will be done
only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or
inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the address line of the browser
switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand
information about your archived personal data, their source and recipients as well as the purpose of the
processing of your data. You may also have a right to have your data rectified or eradicated. If you have
questions about this subject matter or any other questions about personal data, please do not hesitate to
contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is
concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in
the following cases:

– In the event that you should dispute the correctness of your data archived by us, we will usually need
some time to verify this claim. During the time that this investigation is ongoing, you have the right to
demand that we restrict the processing of your personal data.

– If the processing of your personal data was/is conducted in an unlawful manner, you have the option to
demand the restriction of the processing of your data in lieu of demanding the eradication of this data.

– If we do not need your personal data any longer and you need it to exercise, defend or claim legal
entitlements, you have the right to demand the restriction of the processing of your personal data instead
of its eradication.

– If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be
weighed against each other. As long as it has not been determined whose interests prevail, you have the
right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving
– may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to
protect the rights of other natural persons or legal entities or for important public interest reasons cited by
the European Union or a member state of the EU.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not
cause any damage to your device. They are either stored temporarily for the duration of a session (session
cookies) or they are permanently archived on your device (permanent cookies). Session cookies are
automatically deleted once you terminate your visit. Permanent cookies remain archived on your device
until you actively delete them, or they are automatically eradicated by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-
party cookies). These cookies enable you or us to take advantage of certain services offered by the third
party (e.g., cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions
would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The
purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required
cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping
cart function) or those that are necessary for the optimization of the website (e.g., cookies that provide
measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a
different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to
ensure the technically error free and optimized provision of the operator’s services. If your consent to the
storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the
consent obtained (Art. 6(1)(a) GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are
placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of
cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies
when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will
separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any
contact information provided therein will be stored by us in order to handle your inquiry and in the event
that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a
contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based
on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or
on your agreement (Art. 6(1)(a) GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the
data, revoke your consent to the archiving of data or if the purpose for which the information is being
archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without
prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name,
request) will be stored and processed by us for the purpose of processing your request. We do not pass these
data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a
contract or is required for the performance of pre-contractual measures. In all other cases, the data are
processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.
6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your
consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Plug-ins and Tools

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”),
Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is
transferred to one of Google’s servers in the United States, where it is archived. The operator of this website
has no control over the data transfer. In case Google Maps has been activated, Google has the option to use
Google web fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your
browser will load the required web fonts into your browser cache, to correctly display text and fonts.

We use Google Maps to present our online content in an appealing manner and to make the locations
disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If
a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of
Art. 6(1)(a) GDPR. This declaration of consent may be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://privacy.google.com/businesses/gdprcontrollerterms/ and
https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under:
https://policies.google.com/privacy?hl=en.

6. eCommerce and payment service providers

Processing of data (customer and contract data)

We collect, process, and use personal data only to the extent necessary for the establishment, content
organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art.
6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual
actions. We collect, process, and use personal data concerning the use of this website (usage data) only to
the extent that this is necessary to make it possible for users to utilize the services and to bill for them.

The collected customer data shall be eradicated upon completion of the order or the termination of the
business relationship. This shall be without prejudice to any statutory retention mandates.

7. Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we
use are listed in detail below. If you communicate with us by video or audio conference using the Internet,
your personal data will be collected and processed by the provider of the respective conference tool and by
us. The conferencing tools collect all information that you provide/access to use the tools (email address
and/or your phone number). Furthermore, the conference tools process the duration of the conference, start
and end (time) of participation in the conference, number of participants and other “context information”
related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the
online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type,
operating system type and version, client version, camera type, microphone or loudspeaker and the type of
connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the
servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant
messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while
using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our
possibilities are largely determined by the corporate policy of the respective provider. Further information
on data processing by the conference tools can be found in the data protection declarations of the tools
used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer
certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally
simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art.
6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this
consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems
immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the
data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal
retention periods remain unaffected.
We have no influence on the duration of storage of your data that is stored by the operators of the
conference tools for their own purposes. For details, please directly contact the operators of the conference
tools.

Conference tools used

We employ the following conference tools:
Google Meet
We use Google Meet. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4,
Ireland. For details on data processing, please see the Google privacy policy:
https://policies.google.com/privacy?hl=en.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.