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Private policy

1) Information on the Data Controller’s Collection of Personal Data and Contact Details

1.1 We are pleased that you have visited our website and thank you for your interest. The following text explains how we process your personal data when you use our website. Personal data are all details that can be used to identify you as an individual.

1.2 The Data Controller of this website in accordance with the General Data Protection Regulation (GDPR) is subtel GmbH, Mainzer Str. 3, 10247 Berlin, Germany, Phone: 78 79 3103, e-mail: info@subtel.dk. The Data Controller is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.

1.3 The person responsible for this website has appointed a Data Protection Officer, who can be contacted at: "Jan Eichelmann, Mainzer Str. 3, 10247 Berlin"

2) Data Collection When Visiting Our Website

2.1 When you visit our website for informational purposes only, meaning you do not register or otherwise transmit information, we only collect the data that your browser sends to our server (so-called “server log files”). If you visit our website, we collect the following information, which is technically necessary for us to display the website:

  • Our visited website
  • Date and time of the visit
  • Amount of data transmitted in bytes
  • Source/referral from which you reached the website
  • The browser used
  • The operating system used
  • The IP address used (if applicable, in anonymized form)

We process personal data in accordance with Article 6(1)(f) GDPR because we have a legitimate interest in improving the stability and functionality of our website. We neither disclose these data nor use them otherwise. However, we reserve the right to review the server log files at a later time if there are specific indications of unlawful use.

2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the Data Controller), this website uses TLS/SSL encryption. You can recognize an encrypted connection by the sequence “https://” and the lock symbol in your browser’s address bar.

3) Hosting & Content Delivery Network

3.1 In order to host our website and present the content of the page, we use a provider who provides its services itself or via selected subcontractors exclusively on servers located within the European Union.

All data collected on our website are processed on these servers.

We have entered into a data processing agreement with the provider, which ensures that the data of our website visitors are protected and that the data are not disclosed to third parties without authorization.

3.2 Cloudinary

We use a content delivery network from the following provider: Cloudinary Ltd., 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, USA

This service enables us to deliver large media files, such as graphics, websites, or scripts, more quickly via a network of regionally distributed servers. Processing is carried out in order to safeguard our legitimate interests in improving the stability and functionality of our website in accordance with Article 6(1)(f) GDPR.

We have entered into a data processing agreement with the provider, ensuring that our website visitors’ data are protected and that unauthorized disclosure to third parties is prohibited.

To transfer data to the USA, the provider uses the European Commission’s standard contractual clauses for transferring personal data, which are intended to ensure compliance with the European level of data protection.

4) Cookies

In order to make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files stored on your device. Some of these cookies are automatically deleted when you close your browser (“session cookies”), while others remain on your device for a longer period of time and enable the storage of site settings (“persistent cookies”). You can see how long persistent cookies are stored in the overview of cookie settings in your web browser.

If personal data are also processed by individual cookies that we use, this is done in accordance with Article 6(1)(b) GDPR for the performance of a contract, in accordance with Article 6(1)(a) GDPR if you have given your consent, or in accordance with Article 6(1)(f) GDPR to protect our legitimate interest in providing the best possible functionality of the website and a customer-friendly, effective website experience.

You can set your browser so that you are informed about the placement of cookies and can decide on a case-by-case basis whether to accept them or to exclude the acceptance of cookies in certain cases or in general.

Please note that if you do not accept cookies, the functionality of our website may be limited.

5) Contact

5.1 Trustpilot

For review reminders, we use services from the following provider: Trustpilot A/S, Pilestræde 58, 1112 Copenhagen K, Denmark

We only send your email address and possibly other customer data to this provider on the basis of your explicit consent in accordance with Article 6(1)(a) GDPR so that they can contact you by email with a review reminder.

You can withdraw your consent from us or from the provider at any time with effect for the future.

We have concluded a data processing agreement with the provider, which ensures that our website visitors’ data are protected and that unauthorized disclosure to third parties is prohibited.

5.2 If you contact us (e.g. via contact form or email), personal data are collected. You can see from the contact form which data are collected when using the form. These data are stored and used solely for the purpose of responding to your inquiry or for contacting you and the related technical administration.

The legal basis for processing these data is our legitimate interest in responding to your inquiry in accordance with Article 6(1)(f) GDPR. If you contact us for the purpose of concluding a contract, Article 6(1)(b) GDPR constitutes an additional legal basis for processing. Your data will be deleted once your inquiry has been fully processed if it can be inferred from the circumstances that the matter in question has been finally resolved and provided that there are no statutory retention obligations to the contrary.

6) Data Processing When Opening a Customer Account and for Contract Execution

In accordance with Article 6(1)(b) GDPR, personal data continue to be collected and processed if you provide them to us for the execution of a contract or when opening a customer account. You can see from the respective input forms which data are collected. You may delete your customer account at any time by sending a message to the Data Controller at the address indicated above. We store and use the data you provide for contract processing. Once the contract has been fully executed or your customer account has been deleted, your personal data will be blocked in accordance with applicable tax and commercial retention periods and deleted once these periods expire, unless you have expressly consented to the further use of your data or we are legally permitted to continue using your data, about which we will inform you accordingly.

7) Data Processing for Order Handling

For the execution of the contract, we transmit the personal data we collect to the transport company responsible for delivery, if this is necessary to deliver the goods. In the context of payment processing, we transmit your payment data to the credit institution commissioned with handling the payment if this is necessary for payment processing. If we use a payment service provider, we will explicitly inform you of this. The legal basis for the transfer of data is Article 6(1)(b) GDPR.

8) Web Analytics Services

Google Analytics 4

This website uses Google Analytics 4, a service of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), to analyze website usage.

When using Google Analytics 4, the so-called “cookies” are generally placed. Cookies are text files that are stored on your device and that enable an analysis of your use of the website. The information collected by the cookie about your use of the website (including the shortened IP address sent by your device, truncated by the last digits) is usually transmitted to a Google server in the USA and stored and processed there. In this context, data may also be transferred to servers of Google LLC in the USA, where it may be further processed.

When using Google Analytics 4, the IP address transmitted by your device when using the website is automatically anonymized by default, so that the data collected cannot be directly linked to you personally. This automatic anonymization takes place by truncating the IP address by the last digits within member states of the European Union (EU) or other contracting states to the Agreement on the European Economic Area before transmission by Google.

On our behalf, Google uses the data and other information obtained to analyze your use of the website, to compile reports on website activity, and to provide us with additional services related to the use of the website and the internet. The shortened IP address transmitted by your device in connection with Google Analytics 4 is not merged with other Google data. The data collected through the use of Google Analytics 4 are stored for 2 months and then deleted.

Via a special function, the so-called “demographic characteristics,” Google Analytics 4 is also able to generate statistics that provide information about the age, gender, and interests of website users based on an evaluation of interest-based advertising and by using data from third parties. This makes it possible to define and differentiate user groups on the website for the purpose of targeting marketing measures. Data collected via the “demographic characteristics” cannot be attributed to any particular individual and thus cannot be traced back to you personally. Data collected via the “demographic characteristics” are stored for 2 months and then deleted.

All of the processing described above, in particular the use of Google Analytics cookies for storing and reading information on the device you use to visit the website, will only take place if you have given us your explicit consent in accordance with Article 6(1)(a) GDPR. Without your consent, Google Analytics 4 will not be used during your visit to the website. You can revoke your consent at any time for the future. To exercise your revocation, please disable this service in the “Cookie Consent Tool” on the website.

The service “Google Signals” may also be used on this website as an extension to Google Analytics. With Google Signals, Google can create cross-device (so-called “cross-device tracking”) reports. If you have activated “personalized ads” in your Google account settings and linked your internet-enabled devices to your Google account, Google can analyze user behavior across devices and create database models based on that, provided that you have consented to the use of Google Analytics in accordance with Article 6(1)(a) GDPR (see above). This takes into account logins and device types for all website visitors who were logged into a Google account and performed a conversion. The data show, among other things, on which device you clicked an ad for the first time and on which device the corresponding conversion took place. Insofar as Google Signals is used, we do not receive any personal data from Google, only statistics created based on Google Signals. You have the option to deactivate “personalized ads” in your Google account settings and thus deactivate cross-device analysis.

You can do this by following the instructions on this page: https://support.google.com/ads/answer/2662922?hl=da
More information is available here: https://support.google.com/analytics/answer/7532985?hl=da

The “UserIDs” function may also be used on this website as an extension of Google Analytics. By assigning individual UserIDs, we can instruct Google to create cross-device (so-called “cross-device tracking”) reports. This enables us to analyze your user behavior across devices if you have given your corresponding consent to the use of Google Analytics in accordance with Article 6(1)(a) GDPR, if you have created a personal account by registering on this website, and are logged in to your personal account on different end devices with your login credentials. The data collected in this way show, among other things, on which device you clicked an ad for the first time and on which device the associated conversion took place.

For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision by the European Commission.

Further legal information on Google Analytics 4 can be found at the following links: https://business.safety.google/intl/da/privacy/ and https://policies.google.com/privacy?hl=da&gl=da
More information about the data processing in Google Analytics 4 and how Google handles data from websites can be found here: Additional information about Google Signals is available at the following link: https://policies.google.com/technologies/partner-sites?hl=da

9) Retargeting/Remarketing/Advertising Recommendations

Google Ads conversion tracking with Customer Match

This website uses the online advertising program “Google Ads,” and, in the context of Google Ads, the conversion tracking service of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). We use Google Ads to draw attention to our interesting offers by means of advertisements (so-called Google AdWords) on external websites. From the data of the advertising campaigns, we can determine how successful the individual advertising measures are. Our aim is to show you advertisements that are of interest to you, to make our website more interesting for you, and to achieve a fair calculation of advertising costs.

A cookie for conversion tracking is set when a user clicks on an ad placed by Google Ads. Cookies are small text files stored on your device. These cookies usually expire after 30 days and are not used for personal identification. If the user visits certain pages on this website and the cookie has not yet expired, we and Google can recognize that the user clicked on the ad and was redirected to that page. Each Google Ads customer receives a different cookie. Thus, cookies cannot be tracked across Google Ads customers’ websites. The information obtained by means of the conversion cookie is used to generate conversion statistics for Google Ads customers who have opted for conversion tracking. Customers learn the total number of users who have clicked on their ad and were redirected to a page containing a conversion tracking tag. However, they do not receive any information that can personally identify users.

In the context of using Google Ads, personal data may also be transferred to servers of Google LLC in the USA.

Further information on the data processing associated with Google Ads Conversion Tracking and Google’s handling of data from websites can be found here: https://policies.google.com/technologies/partner-sites

All processing described above, in particular the setting of cookies for the analysis of information on your device, will only take place if you have given us your express consent in accordance with Article 6(1)(a) GDPR. You can revoke your consent at any time with future effect by deactivating this service through the cookie tool provided on the website.

You can permanently deactivate Google Ads conversion tracking cookies by downloading and installing the browser plug-in available at:
https://www.google.com/settings/ads/plugin?hl=da

For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision by the European Commission.

In order to present our customers, whose data we have obtained through a purchase or similar transaction, with even more relevant advertising, we use the customer match feature in Google Ads. For this purpose, we electronically transmit one or more files containing aggregated customer data (particularly email addresses and phone numbers) to Google. Google does not gain access to the plain text data; the information is automatically encrypted during the transfer using a special algorithm. Google can only use the encrypted information to match it to existing Google accounts that the individuals in question have set up. This allows targeted advertising to be displayed through all Google services associated with the relevant Google account.

Customer data is only transmitted to Google with your explicit consent in accordance with Article 6(1)(a) GDPR. This consent can be revoked at any time with effect for the future. Further information on Google’s privacy policy in connection with the customer match feature can be found here: https://support.google.com/google-ads/answer/6334160?hl=da&ref_topic=10550182

Google’s privacy policy can be found here: https://business.safety.google/intl/da/privacy/ and https://policies.google.com/privacy?hl=da

10) Website Functions

10.1 YouTube

This website uses plugins for displaying and playing videos from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data may also be transmitted to: Google LLC, USA

When you visit a page on our website that contains such a plugin, your browser establishes a direct connection to the provider’s servers in order to load this plugin. In this process, certain information, including your IP address, is transmitted to the provider.

If integrated videos are played via this plugin, the provider also uses cookies to collect information about user behavior, create playback statistics, and prevent improper actions.

If you are logged in to one of the provider’s user accounts while visiting the website, your data will be linked to your account when you click on the video. If you do not want this association with your account, you must log out before playing the video.

All of the above-mentioned processes, in particular the use of cookies to analyze information on the device you are using, only take place if you have given your explicit consent in accordance with Article 6(1)(a) GDPR. You can revoke any consent you have given at any time with effect for the future by deactivating this service via the “cookie consent tool” on the website.

For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision by the European Commission.

10.2 Google Web Fonts

In order to ensure a uniform display of fonts, this site uses so-called web fonts from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data may also be transmitted to: Google LLC, USA

When you open a page, your browser loads the required web fonts into its cache in order to display texts and fonts correctly, and it establishes a direct connection to the provider’s servers. Certain information, including your IP address, is transmitted to the provider in the process.

The processing of personal data in connection with the establishment of a connection to the font provider is carried out only if you have given your explicit consent in accordance with Article 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future by disabling this service via the “cookie consent tool” on the website. If your browser does not support web fonts, a standard font from your computer will be used.

For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision by the European Commission.

Further information about Google’s data protection can be found here: https://business.safety.google/intl/da/privacy/

10.3 Google reCAPTCHA

On this website, we use the CAPTCHA service from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

The service checks whether an entry is made by a natural person or whether there is misuse in the form of automated or mechanical processing, and it protects against spam, DDoS attacks, and similar automated malicious activities. To ensure that the action is performed by a human and not an automated bot, the provider collects the IP address of the device used, identification data for the browser used, and the type of operating system, as well as the date and duration of the visit, and transmits these to the provider’s servers for evaluation. This may involve the use of cookies, i.e. small text files stored in the browser on your end device.

If the above-described processing is carried out on the basis of cookies, they are only set if you have given us your explicit consent in accordance with Article 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the “cookie consent tool” on the website.

If the above-described processing is carried out without the use of cookies, the legal basis is our legitimate interest in determining individual responsibility on the internet and avoiding misuse and spam in accordance with Article 6(1)(f) GDPR.

We have concluded a data processing agreement with the provider, which ensures that our website visitors’ data are protected and prevents unauthorized disclosure to third parties.

For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision by the European Commission.

Further information about Google’s data protection can be found here: https://business.safety.google/intl/da/privacy/

11) Your Rights

11.1 Applicable data protection law grants you comprehensive rights (rights of access and intervention) vis-à-vis the Data Controller with respect to the processing of your personal data. These are explained below:

  • Right of access according to Article 15 GDPR.
  • Right to rectification according to Article 16 GDPR.
  • Right to erasure according to Article 17 GDPR.
  • Right to restriction of processing according to Article 18 GDPR.
  • Right to notification according to Article 19 GDPR.
  • Right to data portability according to Article 20 GDPR.
  • Right to withdraw consent according to Article 7(3) GDPR.
  • Right to lodge a complaint according to Article 77 GDPR.

11.2 Right to object

 

If we process your personal data on the basis of a balancing of interests due to our overriding legitimate interest, you have the right to object to this processing at any time with effect for the future for reasons arising from your particular situation.

 

If you exercise your right to object, we will stop processing the data concerned. However, we reserve the right to continue processing if we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or if the processing is for the purpose of asserting, exercising, or defending legal claims.

 

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing. You can exercise your right to object as described above.

 

If you exercise your right to object, we will stop processing the data affected for direct marketing purposes.

 

12) Retention Period of Personal Data

The retention period of personal data is determined by the respective statutory retention period (e.g. commercial and tax retention periods). After the expiry of these periods, the corresponding data are routinely deleted if they are no longer required for the fulfillment or initiation of a contract and/or if we no longer have a legitimate interest in further storage.