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Privacy policy

Privacy Policy

34–41 minutes

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

1.1 We are pleased that you are visiting our website and thank you for your interest. Below, we inform you about how we handle your personal data when you use our website. Personal data means any data by which you can be personally identified.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is:

STRATAGEMA FZCO
UAE, DSO-IFZA -14794
Dubai Digital Park – Office A2,
Dubai Silicon Oasis
STRATAGEMA FZCO

Sergei Korotkov

Registration Number: DSO-FZCO-13510

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of processing personal data.

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

2) Data Collection When Visiting Our Website

When you use our website for informational purposes only—i.e., if you do not register or otherwise provide information—we collect only the data that your browser transmits to our server (“server log files”). When you access our website, we collect the following data, which is technically necessary to display the website to you:

The website you visited
Date and time of access
Amount of data transmitted in bytes
Source/referrer from which you reached the page
Browser used
Operating system used
IP address (where applicable, in anonymized form)

Processing is carried out pursuant to Art. 6(1)(f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data is not disclosed or used for other purposes. However, we reserve the right to review the server log files retrospectively if there are specific indications of unlawful use.

3) Cookies

To make visiting our website more attractive and to enable the use of certain functions, we use cookies on various pages. Cookies are small text files stored on your device. Some cookies we use are deleted after the end of the browser session, i.e., after you close your browser (“session cookies”). Other cookies remain on your device and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (“persistent cookies”). Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.

If personal data is processed by individual cookies implemented by us, processing is carried out pursuant to Art. 6(1)(b) GDPR either for the performance of a contract, or pursuant to Art. 6(1)(f) GDPR to safeguard our legitimate interests in ensuring the best possible functionality of the website and a customer-friendly and effective design of the website visit.

We may work with advertising partners who help us make our online offering more interesting for you. For this purpose, when you visit our website, cookies from partner companies may also be stored on your hard drive (third-party cookies). If we cooperate with such advertising partners, you will be informed individually and separately in the sections below about the use of such cookies and the scope of the information collected.

Please note that you can configure your browser to inform you about the setting of cookies and to decide individually whether to accept them, or to exclude acceptance of cookies for certain cases or generally. Each browser differs in how it manages cookie settings. This is described in each browser’s help menu, which explains how to change your cookie settings. You can find the relevant information for the respective browsers at the following links:

Please note that if cookies are not accepted, the functionality of our website may be limited.

4) Contact

When you contact us (e.g., via contact form or email), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your inquiry and for contacting you, as well as for the associated technical administration.

The legal basis for processing this data is our legitimate interest in responding to your inquiry pursuant to Art. 6(1)(f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis is Art. 6(1)(b) GDPR. Your data will be deleted after final processing of your inquiry. This is the case when it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that no statutory retention obligations prevent deletion.

5) Online Marketing

5.1 Facebook Pixel for Creating Custom Audiences with Advanced Matching (Without a Cookie Consent Tool)

Within our online offering, the “Facebook Pixel” of the social network Facebook is used in advanced matching mode, operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”).

Based on the user’s explicit consent, when a user clicks a Facebook advertisement placed by us, Facebook Pixel adds a parameter to the URL of our linked page. This URL parameter is then stored in the user’s browser via a cookie set by our linked page. In addition, this cookie collects specific customer data such as the email address, which we collect on our website linked to the Facebook advertisement in processes such as purchases, account logins, or registrations (advanced matching). The cookie is then read by Facebook Pixel and enables the forwarding of the data, including the specific customer data, to Facebook.

With the help of the Facebook Pixel with advanced matching, Facebook is able to determine visitors to our online offering as a target group for displaying ads (“Facebook Ads”). Accordingly, we use the Facebook Pixel with advanced matching to display our Facebook Ads only to Facebook users who have shown an interest in our online offering or who have certain characteristics (e.g., interests in specific topics or products determined based on visited websites) that we transmit to Facebook (“Custom Audiences”). We also use Facebook Pixel with advanced matching to ensure that our Facebook Ads correspond to users’ potential interests and are not perceived as intrusive. We can further evaluate the effectiveness of Facebook advertising for statistical and market research purposes by tracking whether users were redirected to our website after clicking a Facebook ad (“conversion”). Compared to the standard Facebook Pixel version, the advanced matching function helps us measure the effectiveness of our advertising campaigns more accurately by capturing more attributable conversions.

All data transmitted is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with Facebook’s data policy (https://www.facebook.com/about/privacy/). The data may enable Facebook and its partners to display advertisements on and outside of Facebook.

These processing operations occur exclusively upon the granting of explicit consent pursuant to Art. 6(1)(a) GDPR.

Consent for the use of the Facebook Pixel may only be given by users who are older than 13 years. If you are younger, we ask you to obtain permission from your legal guardians.

The information generated by Facebook is generally transmitted to a Facebook server and stored there; this may also involve transmission to Facebook Inc. servers in the USA. You can withdraw your consent at any time by deactivating Facebook Pixel tracking. For this purpose, you can set an opt-out cookie by clicking the link below, which deactivates Facebook Pixel tracking:

Deactivate Facebook Pixel

This opt-out cookie only works in this browser and only for this domain. If you delete your cookies in this browser, you must click the above link again.

5.2 Use of Google Ads Conversion Tracking

This website uses the “Google Ads” online advertising program and, as part of Google Ads, conversion tracking by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). We use Google Ads to draw attention to our attractive offers on external websites using advertising materials (so-called Google AdWords). We can determine how successful individual advertising measures are in relation to the data of advertising campaigns. We pursue the aim of showing you advertising that is of interest to you, making our website more interesting for you, and achieving fair billing of the incurred advertising costs.

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

If you do not wish to participate in tracking, you can block this use by disabling the Google conversion tracking cookie via your internet browser under “User Settings.” You will then not be included in the conversion tracking statistics. We use Google Ads on the basis of our legitimate interest in targeted advertising pursuant to Art. 6(1)(f) GDPR. As part of the use of Google Ads, personal data may also be transmitted to Google LLC servers in the USA.

Further information on Google’s data protection provisions can be found at: https://www.google.de/policies/privacy/

You can permanently object to the setting of cookies by Google Ads conversion tracking by downloading and installing the browser plug-in available under the following link:
https://www.google.com/settings/ads/plugin?hl=de

Please note that certain functions of this website may not be available or may only be available to a limited extent if you have disabled the use of cookies.

Where legally required, we have obtained your consent for the processing described above pursuant to Art. 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future. To exercise your withdrawal, deactivate this service in the “Cookie Consent Tool” provided on the website, or alternatively follow the objection option described above.

6) Web Analytics Services

Google (Universal) Analytics

This website uses Google (Universal) Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). Google (Universal) Analytics uses cookies, which are text files stored on your device that enable analysis of your use of the website. The information generated by the cookie about your use of this website (including the shortened IP address) is generally transmitted to a Google server and stored there; this may also involve transmission to Google LLC servers in the USA.

This website uses Google (Universal) Analytics exclusively with the “_anonymizeIp()” extension, which ensures that the IP address is anonymized by shortening it and excludes direct personal identification. Through this extension, your IP address is shortened by Google within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google LLC server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide us with other services related to website and internet use. The IP address transmitted by your browser as part of Google (Universal) Analytics is not merged with other Google data.

Google Analytics also enables the creation of statistics relating to “demographic characteristics,” such as age, gender, and interests of visitors, based on interest-based advertising evaluation and the inclusion of third-party information. This allows the definition and differentiation of website user groups for the purpose of optimizing marketing measures for target groups. However, data sets collected via “demographic characteristics” cannot be assigned to a specific person.

All processing described above, in particular the setting of Google Analytics cookies for reading information on the device used, will only take place if you have given us your explicit consent pursuant to Art. 6(1)(a) GDPR. Without such consent, Google Analytics will not be used during your visit.

You may withdraw your consent at any time with effect for the future. To exercise your withdrawal, please deactivate this service in the “Cookie Consent Tool” provided on the website. We have concluded a data processing agreement with Google for the use of Google Analytics, obligating Google to protect the data of our website visitors and not to pass it on to third parties.

For the transfer of data from the EU to the USA, Google relies on standard contractual clauses of the European Commission, which are intended to ensure compliance with European data protection standards in the USA.

Further information on Google (Universal) Analytics is available here: https://policies.google.com/privacy?hl=de&gl=de

7) Retargeting / Remarketing / Referral Advertising

Criteo (Criteo SA)

On this website, information about the browsing behavior of website visitors is collected, stored, and analyzed in pseudonymized form using cookie text files via technology provided by Criteo SA, 32 Rue Blanche, 75009 Paris, France (“Criteo”), based on our legitimate interest in displaying personalized advertising pursuant to Art. 6(1)(f) GDPR. Using an algorithm, Criteo analyzes browsing behavior and can then display targeted product recommendations as personalized advertising banners on other websites (so-called publishers). Under no circumstances can the collected data be used to personally identify visitors to this website. No other use or transfer to third parties takes place.

To object to the data collection and creation of pseudonymized user profiles for the future, you can download the following opt-out cookie:
Criteo Opt-Out (https://www.criteo.com/de/privacy/)

Further information on Criteo’s technology can be found in Criteo’s privacy policy:
https://www.criteo.com/de/privacy

Where legally required, we have obtained your consent pursuant to Art. 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future. To exercise your withdrawal, please follow the objection option described above.

Google Ads Remarketing

Our website uses Google Ads remarketing functions. We advertise this website in Google search results and on third-party websites. The provider is Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). For this purpose, Google sets a cookie in the browser of your device, which automatically enables interest-based advertising based on the pages you have visited and using a pseudonymous cookie ID. Processing is based on our legitimate interest in optimal marketing of our website pursuant to Art. 6(1)(f) GDPR.

Further data processing only takes place if you have agreed with Google that your internet and app browser history will be linked to your Google account and that information from your Google account will be used to personalize ads you view on the web. If you are logged into Google during your visit to our website in this case, Google uses your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, your personal data is temporarily linked by Google with Google Analytics data to form target groups. As part of the use of Google Ads remarketing, personal data may also be transmitted to Google LLC servers in the USA.

You can permanently deactivate the setting of cookies for ad preferences by downloading and installing the browser plug-in available under the following link:
https://www.google.com/settings/ads/onweb/

Alternatively, you can obtain information about cookie settings and make settings at the Digital Advertising Alliance at www.aboutads.info. Finally, you can configure your browser to inform you about the setting of cookies and decide individually whether to accept them, or exclude acceptance of cookies for certain cases or generally. If cookies are not accepted, the functionality of our website may be limited.

Further information and Google’s privacy policy relating to advertising can be found here:
https://www.google.com/policies/technologies/ads

Outbrain Pixel

Within our online offering, we use the “Outbrain Pixel” of Outbrain, Inc., 39 W 13th St, New York 10011, USA (“Outbrain”). Outbrain Pixel sets a cookie on your computer if you have reached our website via an advertisement or another campaign. Cookies are small text files stored on your device. If the user visits certain pages of this website, we can recognize that the user clicked on the advertisement and was redirected to this page (conversion page). If personal data is processed in this context, this is done pursuant to Art. 6(1)(f) GDPR based on our legitimate interest in effective marketing.

The information collected using the conversion cookie is used to create conversion statistics, i.e., to record how many users reach a conversion page after clicking on an advertisement. We learn the total number of users who clicked our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive information that personally identifies users. If you do not wish to participate in tracking, you can object by disabling the Outbrain Pixel cookie in your internet browser under user settings, and by checking whether Outbrain advertising cookies have been set in your browser and disabling them.

Further information on Outbrain’s privacy policy is available at:
https://www.outbrain.com/de/legal/privacy

Taboola

This website uses retargeting technology by Taboola Inc., 16 Madison Square West, 7th Floor, New York, NY 10010, USA (“Taboola”). This allows visitors to our websites to be targeted with further own or third-party content in the form of banners based on their usage behavior, which is expected to match the user’s interests. Such content is displayed based on a cookie-based analysis of previous usage behavior, but no personal data is stored. For interest-based content determination, a cookie is stored on your computer or mobile device to collect pseudonymized data about your browsing behavior and to tailor content individually based on the stored information.

If the collected and analyzed information is personally identifiable, processing is carried out pursuant to Art. 6(1)(f) GDPR based on our legitimate interest in displaying personalized website content and in market research.

To generally deactivate the use of cookies on your device, you can configure your internet browser so that no cookies are stored on your device in the future or delete cookies already stored. Disabling all cookies may result in certain functions on our websites no longer being available.

You can also permanently object to the setting of cookies for ad preferences by Taboola by using the opt-out cookie option provided on the following page:
https://www.taboola.com/privacy-policy#optout

Further information on Taboola’s privacy policy can be found here:
https://www.taboola.com/privacy-policy

8) Rights of the Data Subject

8.1 Applicable data protection law grants you comprehensive rights as a data subject vis-à-vis the controller with regard to the processing of your personal data (rights of access and intervention), which we inform you about below:

Right of access (Art. 15 GDPR): You have the right to obtain information in particular about your personal data processed by us, processing purposes, categories of personal data, recipients or categories of recipients, planned storage period or criteria for determining it, the existence of rights to rectification, erasure, restriction of processing, objection, complaint to a supervisory authority, the origin of your data where not collected from you, the existence of automated decision-making including profiling, and (where applicable) meaningful information about the logic involved, scope, and intended effects, as well as your right to be informed of appropriate safeguards pursuant to Art. 46 GDPR in the event of transfers to third countries.
Right to rectification (Art. 16 GDPR): You have the right to have inaccurate data concerning you corrected without undue delay and/or incomplete data completed.
Right to erasure (Art. 17 GDPR): You have the right to request the erasure of your personal data where the requirements of Art. 17(1) GDPR are met. This right does not apply in particular where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims.
Right to restriction of processing (Art. 18 GDPR): You have the right to request restriction of processing of your personal data while the accuracy of your data is being verified, if you oppose erasure due to unlawful processing and request restriction instead, if you require the data for legal claims after we no longer need it for the original purpose, or if you have objected due to your particular situation and it is not yet clear whether our legitimate grounds override yours.
Right to notification (Art. 19 GDPR): If you have exercised the right to rectification, erasure, or restriction, the controller must notify all recipients to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.
Right to data portability (Art. 20 GDPR): You have the right to receive your personal data provided to us in a structured, commonly used, machine-readable format or to request transfer to another controller, where technically feasible.
Right to withdraw consent (Art. 7(3) GDPR): You have the right to withdraw consent at any time with effect for the future. In the event of withdrawal, we will delete the affected data without undue delay unless further processing can be based on another legal basis. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
Right to lodge a complaint (Art. 77 GDPR): If you believe that 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.

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

If you exercise your right to object, we will stop processing the data concerned. Further processing may remain reserved if we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or if processing serves the establishment, exercise, or defense of legal claims.

Where your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing. You may exercise the objection as described above.

If you object, we will stop processing your personal data for direct marketing purposes.

9) Duration of Storage of Personal Data

The duration for which personal data is stored is determined by the respective legal basis, the purpose of processing, and—where applicable—statutory retention periods (e.g., commercial and tax retention periods).

Where personal data is processed on the basis of explicit consent pursuant to Art. 6(1)(a) GDPR, the data will be stored until the data subject withdraws consent.

Where statutory retention periods apply to data processed as part of contractual or quasi-contractual obligations on the basis of Art. 6(1)(b) GDPR, such data will be routinely deleted after the retention periods expire, provided that it is no longer required for contract performance or initiation and/or we no longer have a legitimate interest in continued storage.

Where personal data is processed on the basis of Art. 6(1)(f) GDPR, such data will be stored until the data subject exercises their right to object pursuant to Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for processing that override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims.

Where personal data is processed for direct marketing purposes on the basis of Art. 6(1)(f) GDPR, such data will be stored until the data subject exercises their right to object pursuant to Art. 21(2) GDPR.

Unless otherwise stated in this policy regarding specific processing situations, stored personal data will be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.

Cookie Consent Tool

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the “Real Cookie Banner” consent tool. Details on how “Real Cookie Banner” works can be found at: https://devowl.io/de/rcb/datenverarbeitung/.

The legal bases for processing personal data in this context are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and related consents.

Providing personal data is neither contractually required nor necessary for entering into a contract. You are not obliged to provide personal data. If you do not provide personal data, we cannot manage your consents.