Privacy Policy pursuant to Art. 13 GDPR

Name and Address of the Controller

The responsible party within the meaning of the General Data Protection Regulation (GDPR) and other data protection regulations is:

NewEase AG
Bahnhofstraße 1
47574 Goch
Germany

Phone: +49 211 545571-0
Email: [email protected]

Name and Address of the Data Protection Officer

The Data Protection Officer of the Controller is:

Freyberg Consulting
Owner: Felix Freyberg
Mandrellaplatz 3
12555 Berlin
Germany

Email: [email protected]

General Information on Data Processing

Legal Basis for the Processing of Personal Data

In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not explicitly mentioned in the privacy policy, the following applies:

• The legal basis for obtaining consent is Art. 6 (1) lit. a in conjunction with Art. 7 GDPR.

• The legal basis for processing to fulfill our services and carry out contractual measures as well as to answer inquiries is Art. 6 (1) lit. b GDPR.

• The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c GDPR.

• If the processing of your data is necessary to safeguard a legitimate interest of our company or a third party, and if the interests, fundamental rights, and freedoms of the data subject do not override the former interest, Art. 6 (1) lit. f GDPR serves as the legal basis for the processing.

• In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) lit. d GDPR serves as the legal basis.

Data Deletion and Storage Duration

We adhere to the principles of data minimization pursuant to Art. 5 (1) lit. c GDPR and storage limitation pursuant to Art. 5 (1) lit. e GDPR. We store your personal data only as long as necessary to achieve the purposes stated here or as provided for by the retention periods stipulated by law. After the respective purpose ceases to apply or after these retention periods expire, the corresponding data will be deleted as quickly as possible.

Note on Data Transfer to Third Countries

Tools from companies based in third countries are also integrated into our website. If these tools are active, your personal data may be transferred to the servers of the respective companies. The level of data protection in third countries generally does not correspond to EU data protection law. This entails the risk that your data may be passed on to authorities in these countries. We have no influence on these processing activities.

External Links

This website may contain links to third-party websites or to other websites under our responsibility. If you follow a link to a website outside our responsibility, please note that these websites have their own privacy policies. We assume no responsibility or liability for these external websites and their privacy policies. Therefore, please check whether you agree with their privacy policies before using these websites.

You can recognize external links either by the fact that they are colored slightly differently from the rest of the text or are underlined. Your cursor will indicate external links when you move it over such a link. Only when you click on an external link will your personal data be transferred to the destination of the link. In doing so, the operator of the other website receives, in particular, your IP address, the time you clicked the link, the page on which you clicked the link, as well as other information that you can find in the privacy policy of the respective provider.

Please also note that individual links may lead to a data transfer outside the European Economic Area. This could give foreign authorities access to your data. You may not have any legal remedies against such data access. If you do not want your personal data to be transferred to the link destination or even exposed to unwanted access by foreign authorities, please do not click on any links.

Rights of the Data Subject

As a data subject within the meaning of the GDPR, you have the opportunity to assert various rights. The data subject rights arising from the GDPR are the right of access (Article 15), the right to rectification (Article 16), the right to erasure (Article 17), the right to restriction of processing (Article 18), the right to object (Article 21), the right to lodge a complaint with a supervisory authority, and the right to data portability (Article 20).

Right of Withdrawal:
Some data processing operations can only be carried out with your explicit consent. You have the right to withdraw your consent at any time. The lawfulness of the data processing carried out until the withdrawal remains unaffected by this.

Right to Object:
If the processing is based on Art. 6 (1) lit. e or f GDPR, you as the data subject have the right to object to the processing of your personal data at any time for reasons arising from your particular situation. This right also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 GDPR. Unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or if the processing serves the establishment, exercise, or defense of legal claims, we will cease processing your data after an objection has been made.

If the processing of personal data serves the purpose of direct marketing, you also have the right to object at any time. The same applies to profiling connected with direct marketing. Here too, we will no longer process personal data as soon as you object.

Right to Lodge a Complaint with a Supervisory Authority:
If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, without prejudice to any other administrative or judicial remedy.

Right to Data Portability:
If your data is processed automatically based on consent or the fulfillment of a contract, you have the right to receive this data in a structured, commonly used, and machine-readable format. Furthermore, you have the right to request the transfer and provision of the data to another controller, provided this is technically feasible.

Right to Access, Rectification, and Erasure:
You have the right to obtain information about your processed personal data regarding the purpose of the data processing, the categories, the recipients, and the duration of storage. If you have any questions on this topic or other topics regarding personal data, you can of course contact us using the contact options provided in the legal notice.

Right to Restriction of Processing:
You can request the restriction of the processing of your personal data at any time. To do so, you must meet one of the following conditions:

• You contest the accuracy of the personal data. For the duration of the verification of accuracy, you have the right to request a restriction of processing.

• If processing is unlawful, you can request the restriction of the use of the data as an alternative to erasure.

• If we no longer need your personal data for the purposes of processing, but you need the data for the establishment, exercise, or defense of legal claims, you can request the restriction of processing as an alternative to erasure.

• If you object to the processing pursuant to Art. 21 (1) GDPR, a balancing of your interests and ours will be carried out. Until this balancing has taken place, you have the right to request the restriction of processing.

A restriction of processing means that the personal data, apart from storage, may only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.

Provision of the Website (Web Hoster)

Our website is hosted by:

HighLevel Inc.
400 North Saint Paul St., Suite 920
Dallas, Texas 75201
USA

The server location is the USA.

When you visit our website, we automatically collect and store information in so-called server log files. Your browser automatically transmits this information to our server or to the server of our hosting company. These are:

• IP address of the website visitor's end device

• Device used

• Hostname of the accessing computer

• Visitor's operating system

• Browser type and version

• Name of the accessed file

• Time of the server request

• Amount of data

• Information on whether the data retrieval was successful

This data is not merged with other data sources.

Instead of operating this website on our own server, we can also have it operated on the server of an external service provider (hosting company), which we have named above in this case. The personal data collected by this website is then stored on the servers of the hosting company. In addition to the data mentioned above, the web host also stores for us, for example, contact requests, contact details, names, website access data, meta and communication data, contract data, and other data generated via a website.

The legal basis for processing this data is Art. 6 (1) lit. f GDPR. Our legitimate interest is the technically error-free presentation and optimization of this website. If the website is accessed to enter into contract negotiations with us or to conclude a contract, Art. 6 (1) lit. b GDPR serves as an additional legal basis. In the event that we have commissioned a hosting company, a data processing agreement exists with this service provider.

Use of Local Storage Items, Session Storage Items, and Cookies

Our website uses local storage items, session storage items, and/or cookies. Local storage is a mechanism that enables the storage of data within the browser on your end device. This data mostly contains user preferences, such as the "day" or "night mode" of a website, and remains until you manually delete the data. Session storage is very similar to local storage, whereas the storage duration only lasts during the current session, i.e., until the current tab is closed. After that, the session storage items are deleted from your end device. Cookies are information that a web server (server that provides web content) stores on your end device in order to be able to identify this end device. They are either temporarily stored for the duration of a session (session cookies) and deleted after the end of your visit to a website, or permanently stored (permanent cookies) on your end device until you delete them yourself or they are automatically deleted by your web browser.

These objects can also be stored on your end device by third-party companies when you enter our site (third-party requests). This enables us as the operator and you as the visitor of this website to use certain services of third parties installed on this website. Examples include the processing of payment services or the display of videos.

These mechanisms have a variety of uses. They can improve the functionality of a website, control shopping cart functions, increase the security and comfort of website use, and carry out analyses regarding visitor flows and behavior. Depending on the individual functions, these must be classified under data protection law. If they are necessary for the operation of the website and intended to provide certain functions (shopping cart function) or serve to optimize the website (e.g., cookies for measuring visitor behavior), their use is based on Art. 6 (1) lit. f GDPR. As a website operator, we have a legitimate interest in storing local storage items, session storage items, and cookies for the technically error-free and optimized provision of our services. In all other cases, the storage of local storage items, session storage items, and cookies only takes place with your explicit consent (Art. 6 (1) lit. a GDPR).

Insofar as local storage items, session storage, or cookies are used by third-party companies or for analysis purposes, we will inform you about this separately within the framework of this privacy policy. Your required consent will be requested and can be revoked at any time.

Use of External Services

External services are used on our website. External services are services from third-party providers that are used on our website. This can be done for various reasons, for example, for embedding videos or for the security of the website. When using these services, personal data is also passed on to the respective providers of these external services.

Content Delivery Network (CDN)

We use a Content Delivery Network (CDN) to optimize the performance and availability of our website. For this purpose, your IP address and the information on when you visited our website are processed by this service provider, who provides this network. All further information on data processing by this service provider can be found in their privacy policy.

We base this processing on a legitimate interest (Art. 6 (1) lit. f GDPR). Our legitimate interest in using a Content Delivery Network is to be able to present our website as quickly, securely, and reliably as possible.

CloudFlare

We use the CloudFlare service on our website. The provider of the service is Cloudflare Germany GmbH, Rosental 7, 80331 Munich, Germany.

The use of the service may result in data transfer to a third country (USA). The provider is certified under the EU-U.S. Data Privacy Framework and therefore offers an adequate level of data protection.

Further information can be found in the provider's privacy information at the following URL: https://www.cloudflare.com/privacypolicy/

Interface Software

Business processes run cheaper, faster, and more error-free when they are automated using software via interfaces. In this way, they can be efficiently integrated into corporate processes via one's own website or social networks. We use interface software on our website to link different applications with each other and to securely transfer personal data from one application to another.

Processing only takes place if you consent to this data processing (via our consent banner on the website). The legal basis for this processing is consent (Art. 6 (1) lit. a GDPR). Without your consent, data processing in the manner described above will not take place. If you revoke your consent (e.g., via the consent banner or other options provided on this website), we will stop this data processing. The lawfulness of the processing carried out until the revocation remains unaffected.

Google APIs

We use the Google APIs service on our website. The provider of the service is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The use of the service may result in data transfer to a third country (USA). The provider is certified under the EU-U.S. Data Privacy Framework and therefore offers an adequate level of data protection.

Further information can be found in the provider's privacy information at the following URL: https://policies.google.com/privacy

Leadconnector

We use the Leadconnector service on our website. The provider of the service is HighLevel Inc., 400 North Saint Paul St., Suite 920, Dallas, Texas 75201, USA.

The use of the service may result in data transfer to a third country (USA). The provider is certified under the EU-U.S. Data Privacy Framework and therefore offers an adequate level of data protection.

Further information can be found in the provider's privacy information at the following URL: https://www.gohighlevel.com/privacy-policy

Social Media

We use social media plugins to connect our website with our social media channels. The integration of the plugins is intended to make it easier for visitors to our website to follow our channels on social networks, share content, like, or comment. Some social media plugins enable the analysis of the user behavior of website visitors regarding their behavior on social networks. The use of plugins is intended to increase the awareness and number of followers of our channels.

Personal data is also processed by the plugins and data is transferred to these social networks. This transfer occurs as soon as the website is accessed. Processed data includes, for example: name, address, email address, telephone number, access time, device information, IP address.

Processing only takes place if you consent to this data processing (via our consent banner on the website). The legal basis for this processing is consent (Art. 6 (1) lit. a GDPR). Without your consent, data processing in the manner described above will not take place. If you revoke your consent (e.g., via the consent banner or other options provided on this website), we will stop this data processing. The lawfulness of the processing carried out until the revocation remains unaffected.

Facebook Connect

We use the Facebook Connect service on our website. The provider of the service is Meta Platforms Ireland Limited (Marketplace), 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

The use of the service may result in data transfer to a third country (USA). The provider is certified under the EU-U.S. Data Privacy Framework and therefore offers an adequate level of data protection.

Further information can be found in the provider's privacy information at the following URL: https://de-de.facebook.com/policy.php

Web Fonts

This site uses so-called web fonts for the uniform display of fonts, which are provided by an external provider and loaded by the browser when the website is accessed. In doing so, the provider of the web font gains knowledge that our website was accessed from your IP address, as your browser establishes a direct connection to the provider of the web font.

The legal basis for this processing is our legitimate interest in a visually appealing website (Art. 6 (1) lit. f GDPR).

Font Awesome

We use the Font Awesome service on our website. The provider of the service is Fonticons Inc., 307 S Main St Bentonville, Arkansas 72712, USA.

The use of the service may result in data transfer to a third country (USA).

Further information can be found in the provider's privacy information at the following URL: https://fontawesome.com/privacy

Google Fonts

We use the Google Fonts service on our website. The provider of the service is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The use of the service may result in data transfer to a third country (USA). The provider is certified under the EU-U.S. Data Privacy Framework and therefore offers an adequate level of data protection.

Further information can be found in the provider's privacy information at the following URL: https://policies.google.com/privacy

GoHighLevel (CRM and Online Marketing Platform)

We use GoHighLevel on this website. The provider is HighLevel Inc., 400 North Saint Paul St., Suite 920, Dallas, Texas 75201, USA (hereinafter GHL).

GHL enables us, among other things, to manage existing and potential customers as well as customer contacts. With the help of GHL, we are able to record, sort, and analyze customer interactions via email, social media, or telephone across various channels. The personal data collected in this way can be evaluated and used for communication with the potential customer or for marketing measures (e.g., newsletter mailings). With GHL, we are also able to record and analyze the user behavior of our contacts on our website.

The use of GHL is based on Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in the most efficient customer management and customer communication possible. If corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 (1) lit. a GDPR. The consent can be revoked at any time.

Further information on data processing by HighLevel Inc can be found here:

• https://www.gohighlevel.com/privacy-policy

• https://www.gohighlevel.com/gdpr

• https://www.gohighlevel.com/privacy-and-security

• https://www.gohighlevel.com/data-processing-agreement

The use of the service may result in data transfer to a third country (USA). The provider is certified under the EU-U.S. Data Privacy Framework and therefore offers an adequate level of data protection.

Appointment Booking with GHL

On our website, you have the opportunity to book appointments with us. We also use GHL for appointment booking.

For the purpose of booking an appointment, you enter the requested data and the desired date into the mask provided for this purpose. The entered data is used for the planning, execution, and, if necessary, follow-up of the appointment. The appointment data is stored for us on the servers of GHL.

The data you enter will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies. Mandatory statutory provisions – in particular retention periods – remain unaffected.

The legal basis for data processing is Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in making appointment scheduling with interested parties and customers as uncomplicated as possible.

Contact Form

On our website, there is the possibility to notify us via a contact form. To contact us via this form, your contact details in particular are required.

The legal basis here refers to processing for the purpose of fulfilling a contract or pre-contractual measures pursuant to Art. 6 (1) lit. b GDPR. In addition, there may be a legitimate interest in maintaining business relationships or answering your inquiry for other reasons. The legal basis for processing your data in this case would be Art. 6 (1) lit. f GDPR.

The data will be deleted when we have conclusively answered your inquiry and no other retention obligations stand in the way.

Telephone Contact or Email Contact

In accordance with legal requirements, we have provided a telephone number and email address on our website. The data transmitted via these channels is automatically stored by us in order to process corresponding inquiries or to be able to contact the inquiring person. This data will not be passed on to third parties without consent.

If contact is made by telephone or via our email address for pre-contractual or contractual purposes, the processing of personal data is based on the legal basis of Art. 6 (1) lit. b GDPR. For all other contacts on your part, the processing of personal data by us is based on our legitimate interest pursuant to Art. 6 (1) lit. f GDPR.

Presence on Social Media

Social networks process the personal data of their users to a large extent. When you visit our profiles, your IP address and other information about the devices you use are processed, which enables the IP addresses to be assigned to individual users. We have no influence on this data processing. We point out that you use our profiles on social networks and their functions on your own responsibility. Details on data processing can be found in the operator's privacy policy.

The purpose of our profiles on social media platforms is to expand our internet presence and the associated greater awareness. Therefore, legitimate interest pursuant to Art. 6 (1) lit. f GDPR is to be used as the legal basis. Furthermore, regarding the processing activities by the social networks, reference is made to their own legal bases (e.g., consent pursuant to Art. 6 (1) lit. a GDPR), which you can find in the respective privacy policy.

In principle, we are jointly responsible with the social media platform for the data processing operations triggered when you visit our profile. Therefore, you can assert your data subject rights pursuant to Art. 15ff GDPR against the social media platform as well as against us. However, we point out that we cannot influence the data processing by the social media platform.

Presence on Facebook

We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Details can be found in Facebook's privacy policy: https://www.facebook.com/about/privacy/

Presence on Instagram

We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Detailed information on the handling of personal data can be found in Instagram's privacy policy: https://help.instagram.com/519522125107875

Presence on LinkedIn

We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

Detailed information on the handling of personal data can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy

Presence on X

We have a profile on X. The provider is X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Details can be found in X's privacy policy: https://twitter.com/de/privacy