Privacy Policy

Last updated: 26.01.2022

1. Introduction

In the following, we provide information about the collection of
personal data when using

● our website paywithdango.com

● our profiles in social media.

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


1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data
Protection Regulation (GDPR) is Leano GmbH, An der Haupttribüne 1,
52070 Aachen, Germany, email: hello@paywithdango.com. We are
legally represented by Omar Allaoui.


Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin,
www.heydata.eu, E-Mail: datenschutz@heydata.eu.


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

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

● Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for
processing operations for which we obtain consent.

● Art. 6 para. 1 s. 1 lit. 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 site visitor purchases a product from us or we
perform a service for him. This legal basis also applies to
processing that is necessary for pre-contractual measures, such
as in the case of inquiries about our products or services.

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

● Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can
rely on legitimate interests to process personal data, e.g. for
cookies that are necessary for the technical operation of our
website.


1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties
outside the EEA, the security of the data during the transfer is
guaranteed by adequacy decisions of the EU Commission, insofar as
they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3
GDPR).


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


1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will
be deleted as soon as they are no longer required for their intended
purpose and no legal obligations to retain data conflict with the
deletion. If the data are not deleted because they are required for other
and legally permissible purposes, their processing is restricted, i.e. the
data are blocked and not processed for other purposes. This applies,
for example, to data that must be retained for commercial or tax law
reasons.


1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their
personal data:

● Right of access,

● Right to correction or deletion,

● Right to object to the processing,

● Right to data transferability,

Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection
supervisory authority about the processing of their personal data.


1.6. Obligation to provide data

Within the scope of the business or other relationship, customers,
prospective customers or third parties need to provide us with personal
data that is necessary for the establishment, execution and termination
of a business or other relationship or that we are legally obliged to
collect. Without this data, we will generally have to refuse to conclude
the contract or to provide a service or will no longer be able to perform
an existing contract or other relationship.
Mandatory data are marked as such.


1.7. No automatic decision making in
individual cases

As a matter of principle, we do not use a fully automated decision-
making process in accordance with article 22 GDPR to establish and
implement the business or other relationship. Should we use these
procedures in individual cases, we will inform of this separately if this is
required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to
us (e.g. names and e-mail addresses) will be stored by us in order to
answer questions. The legal basis for the processing is our legitimate
interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us.
We delete the data accruing in this context after the storage is no
longer necessary or restrict the 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 our legitimate interest to get to know our
customers and their wishes better, so that the legal basis for the
associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the
data when the results of the surveys have been evaluated.


2. Data processing on our
website


2.1. Informative use of our website

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


These data are:

● 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 comes

● Browser

● Operating system and its interface

● Language and version of the browser software.

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


2.2. Web hosting and provision of the
website

Our website is hosted by Webflow, Inc. 208 Utah, Suite 210, San
Francisco, CA 94103, USA. The provider thereby processes the personal
data transmitted via the website, e.g. on content, usage,
meta/communication data or contact data. It is our legitimate interest
to provide a website, so that the legal basis for data processing is Art. 6
para. 1 s. 1 lit. f GDPR.

We use a content delivery networks to help provide our website. The
providers are Cloudflare Inc., 106 East 6th Street, Suites 350 and 400,
Austin, TX 78701, USA (privacy policy: https://www.cloudflare.com/en-
gb/privacypolicy/) and Amazon Web Services, Inc., 410 Terry Avenue
North, Seattle WA 98109, USA (privacy policy:
https://aws.amazon.com/de/privacy/?nc1=f_pr). The provider thereby
processes the personal data transmitted via the website, e.g. on
content, usage, meta/communication data or contact data. It is our
legitimate interest to provide a website, so that the legal basis for data
processing is Art. 6 para. 1 s. 1 lit. f GDPR.


2.3. Contact form

When contacting us via the contact form on our website, we store the
data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in answering
inquiries directed to us. The legal basis for the processing is therefore
Art. 6 para. 1 s. 1 lit. f GDPR.


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


2.4. Vacant positions

We publish positions that are vacant in our company on our website, on
pages linked to the website or on third-party websites.
The processing of the data provided as part of the application is carried
out for the purpose of implementing the application process. Insofar as
this is necessary for our decision to establish an employment
relationship, the legal basis is Art. 88 para. GDPR in conjunction with
Sec. 26 para. 1 of the German Data Protection Act
(Bundesdatenschutzgesetz). We have marked the data required to carry
out the application process accordingly or refer to them. If applicants
do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If
applicants provide further information, the basis is their consent (Art. 6
para. 1 s. 1 lit. a GDPR).


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


Finally, we process the applicants' data for further application
procedures if they have given us their consent to do so. In this case, the
legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.


We pass on the applicants' data to the responsible employees in the HR
department, to our data processors in the area of recruiting and to the
employees otherwise involved in the application process.

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


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


2.5. Payment processors

For the processing of payments, we use payment processors who are
themselves data controllers within the meaning of Art. 4 No. 7 GDPR.
Insofar as they receive data and payment data entered by us in the
ordering process, we thereby fulfill the contract concluded with our
customers (Art. 6 para. 1 s. 1 lit. b GDPR).


These payment processors are:

●    PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxemburg

●    Stripe Payments Europe, Ltd., Irland

●    Adyen N.V., Amsterdam


2.6. Registration form for restaurants

For testing our service in restaurants, we process the data provided in
the registration form. The legal basis is Art. 6 para. 1 p. 1 lit. b GDPR, as
we process the data to perform the contract with the restaurant.

The data is:

● name

● phone

● restaurant name

● cash register system

● postal code

●email


2.7. Third parties


2.7.1. Hotjar

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


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


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/.

2.7.2. Google Analytics

We use Google Analytics for analytics. The provider is Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5,
Ireland. The provider processes usage data (e.g. web pages visited,
interest in content, access times) and meta/communication data (e.g.
device information, IP addresses) in the USA.


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


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


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://policies.google.com/privacy?hl=en-US.

3. Data processing on social
media platforms

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


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


3.1. Facebook

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


We are joint controllers for processing the data of visitors to our profile
on the basis of an agreement within the meaning of Art. 26 GDPR with
Facebook. Facebook explains exactly what data is processed at
https://www.facebook.com/legal/terms/information_about_page_insigh
ts_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 requests to Facebook. Data
subjects will therefore receive a faster response if they contact
Facebook directly.


3.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland
Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The
privacy policy is available here:
https://help.instagram.com/519522125107875.


3.3. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland
Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy
is available here: https://https://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.


3.4. Xing

We maintain a profile on Xing. The operator is XING AG,
Dammtorstraße 29-32, 20354 Hamburg. The privacy policy is available
here: https://privacy.xing.com/de/datenschutzerklaerung.


4. Changes to this privacy policy

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


5. Questions and comments

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


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