Private Policy

1) Introduction and Contact Details of the Controller

1.1 We are pleased about your visit to our website and your interest in our services. We inform you here about the processing of your personal data when using our website. Personal data are all data with which you can be personally identified.

1.2 The controller of data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is subtel GmbH, Mainzer Str. 3, 10247 Berlin, Germany, Email: info@subtel.be. The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

2) Data Collection When Visiting Our Website

2.1 When you use our website purely for informational purposes, i.e., if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to our server (the "Server Log Files"). Thus, when you visit our website, only the following data, which are technically necessary for us to display the website, are collected:

The website visited
The date and time of access
The amount of data sent (in bytes)
The source/reference from which you came to our site
The browser used
The operating system
The IP address used (if applicable: in anonymized form)
The processing is carried out in accordance with Article 6(1)(f) GDPR based on our legitimate interest in improving the stability and functionality of the website. The data will not be transmitted or used for any other purpose. However, we reserve the right to check the server log files retrospectively if there are concrete indications of illegal use.

2.2 This website uses SSL (Secure Socket Layer) or TLS (Transport Layer Security) encryption for security reasons and to protect the transmission of personal data and other confidential content (such as orders or inquiries). You can recognize an encrypted connection by the string "https://" and/or the lock symbol in the browser bar.

3) Hosting & Content Delivery Network

3.1 For hosting our website and displaying its content, we use a provider who provides its services either by itself or through selected subcontractors exclusively on servers located within the European Union.

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

We have concluded an order processing contract with this provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

3.2 Cloudinary

We use a content delivery network provided by the following provider: Cloudinary Ltd, 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, United States

This service enables us to transmit large multimedia files such as graphics, page content, or scripts more quickly via a network of regionally distributed servers. Processing is carried out to preserve our legitimate interest in improving the stability and functionality of our website in accordance with Article 6(1)(f) GDPR. We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

Regarding data transfer to the United States, the provider refers to the standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

4) Cookies

To make the visit to our website attractive and to enable the use of certain functions, we use cookies, i.e., small text files that are stored on your device. Some of these cookies are automatically deleted after the browser is closed ("session cookies"), while others remain longer on your device and allow page settings to be saved ("persistent cookies"). In the latter case, you can see the storage duration in the overview of the cookie settings of your web browser.

If personal data are also processed by certain cookies we use, the processing is carried out in accordance with Article 6(1)(b) GDPR for the execution of the contract, in case of consent given in accordance with Article 6(1)(a) GDPR, or to safeguard our legitimate interests in the best possible functionality of the website and a user-friendly and effective design of the site visit in accordance with Article 6(1)(f) GDPR.

You can configure your browser so that you are informed about the setting of cookies and decide individually about their acceptance or 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) Contacting Us

5.1 Trustpilot

We use the services of the following provider for the purpose of review reminders: Trustpilot A/S, Pilestraede 58, 1112 Copenhagen K, Denmark

Based solely on your explicit consent in accordance with Article 6(1)(a) GDPR, we transmit your email address and, if applicable, other customer data to the provider so that they can contact you by email for a review reminder.

You can revoke your consent at any time with effect for the future by contacting us or the provider.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

5.2 Personal data are collected when you contact us (e.g., via contact form or email). The data collected through the contact form can be seen from the respective contact form. These data are stored and used solely for the purpose of responding to your request and for the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Article 6(1)(f) GDPR.

If your contact aims at concluding a contract, then the additional legal basis for processing is Article 6(1)(b) GDPR.

Your data will be deleted after the final processing of your inquiry, i.e., when it can be inferred from the circumstances that the matter in question has been finally clarified and provided there are no statutory retention obligations to the contrary.

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

Personal data are collected and processed in accordance with Article 6(1)(b) GDPR if you provide them to us when opening a customer account. The data collected can be seen from the respective input form on our website. Deletion of your customer account is possible at any time and can be done by sending a message to the address of the controller mentioned above. After deletion of your customer account, your data will be deleted unless we are obliged to keep them for a longer period due to tax or commercial law retention periods and/or if you have consented to further storage.

7) Data Processing for Order Handling

7.1 In order to process your order, we work together with the following service providers who assist us wholly or partially in the execution of concluded contracts. Certain personal data are transmitted to these service providers in accordance with the following information.

We pass on your payment data to the commissioned credit institution within the framework of payment processing if this is necessary for payment processing. If we use payment service providers, we explicitly inform you about this below. The legal basis for the transfer of data is Article 6(1)(b) GDPR.

7.2 Transfer of Personal Data to Shipping Service Providers

- UPS

We use the following provider as a shipping service provider: United Parcel Service Deutschland Inc. & Co. OHG, Görlitzer Straße 1, 41460 Neuss, Germany

Pursuant to Article 6(1)(a) GDPR, we will forward your email address and/or telephone number to the provider prior to the delivery of the goods for the purpose of coordinating a delivery date or delivery notification, provided you have given your explicit consent during the ordering process. Otherwise, we will only forward the name of the recipient and the delivery address to the provider for the purpose of delivery in accordance with Article 6(1)(b) GDPR. The data will only be passed on insofar as it is necessary for the delivery of the goods. In this case, prior coordination of the delivery date with the provider or the delivery notification is not possible.

You can revoke your consent at any time with effect for the future by notifying the controller named above or the provider.

7.3 Use of Payment Service Providers

- Adyen

On this website, one or more online payment methods are available from the following provider: Adyen, Simon Carmiggeltstraat 6 - 50, 1011 DJ Amsterdam, Netherlands

If you select a payment method offered by the provider that involves an advance payment (e.g., credit card payment), your payment data communicated during the ordering process (including name, address, bank information, card data, currency, and transaction number), as well as information about the content of your order, will be transmitted to the provider in accordance with Article 6(1)(b) GDPR. In this case, your data will be transmitted solely for the purpose of processing the payment by the provider and only to the extent necessary for this purpose.

8) Web Analysis Services

8.1 Google Analytics 4

This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which allows the analysis of your use of our website.

By default, Google Analytics 4 places cookies on your device as small text files that collect certain information when you visit the website. The scope of this information also includes your IP address, which is, however, truncated by Google by the last digits to exclude a direct personal reference.

The information is transmitted to Google's servers and processed there. Data transfers to Google LLC, based in the USA, are also possible.

Google uses the information collected on our behalf to evaluate your use of the website, to compile reports on website activity, and to provide us with other services related to website and internet usage. The IP address transmitted and truncated by your browser in the context of Google Analytics is not merged with other Google data. The data collected as part of the use of Google Analytics 4 are stored for a period of two months and then deleted.

All the processing described above, in particular the placement of cookies on the device used, will only take place if you have given us your express consent in accordance with Article 6(1)(a) GDPR.

Without your consent, Google Analytics 4 will not be used during your visit to the site. You can revoke your consent at any time with effect for the future. To exercise your revocation, please disable this service via the "Cookie Consent Tool" provided on the website.

We have concluded an order processing contract with Google, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

You can find more information about Google Analytics 4 at
https://business.safety.google/intl/en/privacy/ and https://policies.google.com/privacy?hl=en and
https://policies.google.com/technologies/partner-sites?hl=en

Demographic Characteristics
Google Analytics 4 uses the special "demographic characteristics" function and can thus create statistics that provide information about the age, gender, and interests of site visitors. This is done by analyzing interest-based advertising and third-party information. This allows target groups to be identified for marketing activities. However, the collected data cannot be assigned to a specific person and are deleted after being stored for a period of two months.

Google Signals
As an extension of Google Analytics 4, Google Signals can be used on this website to generate cross-device reports. If you have activated personalized ads and linked your devices to your Google account, Google can, subject to your consent to the use of Google Analytics in accordance with Article 6(1)(a) GDPR, analyze your usage behavior across devices and create database models, including cross-device conversions. We do not receive any personal data from Google, only statistics. If you wish to stop cross-device analysis, you can disable the "Personalized Ads" function in your Google account settings. To do this, follow the instructions on this page: https://support.google.com/My-Ad-Center-Help/answer/12155764?hl=en&visit_id=638189012320422084-1464883330&rd=1&sjid=10160301342023274019-EU

You can find more information about Google Signals here: https://support.google.com/analytics/answer/7532985?hl=en&sjid=10160301342023274019-EU#zippy=%2Cthemen-in-diesem-artikel%2Ccet-article-aborde-les-points-suivants

UserIDs
As an extension of Google Analytics 4, the "UserIDs" function can be used on this website. If you have consented to the use of Google Analytics 4 in accordance with Article 6(1)(a) GDPR, created an account on this website, and log into this account from different devices, your activities, including conversions, can be analyzed across devices.

For data transfers to the USA, the provider has adhered to 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.

8.2 Google Tag Manager

This website uses the "Google Tag Manager," a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). The Google Tag Manager provides a technical basis for bundling various web applications, including tracking and analysis services, and for calibrating, controlling, and subjecting them to conditionally via a single user interface.

The Google Tag Manager itself does not store or read any information on users' devices. The service does not carry out its own data analyses.

However, when a page is called up, your IP address is transmitted to Google via the Google Tag Manager and possibly stored there. A transmission to the servers of Google LLC in the USA can occur.

This processing only takes place if you have given us your express consent in accordance with Article 6(1)(a) GDPR. Without this consent, the Google Tag Manager will not be used during your site visit.

You can revoke your consent at any time with effect for the future. If you wish to revoke your consent, please deactivate this service using the "Cookie Consent Tool" provided on the website. We have concluded an order processing contract with Google, whereby Google is obliged to protect the data of our site visitors and not to pass them on to third parties.

For data transfers to the USA, the provider has adhered to 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.

You can find more information about Google Tag Manager's privacy policy at https://business.safety.google/intl/en/privacy/ and https://support.google.com/tagmanager/answer/9323295?hl=en
You can find separate information regarding the services and applications grouped under the Google Tag Manager in the corresponding sections of this privacy policy.

9) Retargeting, Remarketing, and Referral Advertising

Google Ads Conversion Tracking

Our website uses the online advertising program "Google Ads" and, within its framework, Google Ads Conversion Tracking provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland ("Google+"). We use the offer of Google Ads, and in particular its advertising insertion techniques ("Google Ads") on third-party websites, to draw attention to our offers. The data collected allows us to determine the success of our various advertising campaigns. We are committed to showing you only ads that may interest you, to make our website more attractive to you, and to achieve a fair calculation of advertising costs.

The conversion tracking cookie is set when a user clicks on a Google Ads ad placed by Google. Cookies are small text files stored on your computer system. 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, we (and Google) can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie, so cookies cannot be tracked across the websites of different Ads customers. The information collected using the conversion cookie is used to create conversion statistics for Ads customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that personally identifies users. The use of Google Ads may also result in the transmission of personal data to the servers of Google LLC in the USA.

You can obtain more information about Google's privacy policy at: https://policies.google.com/privacy?gl=de&hl=en /.

All the processing described above, especially reading information on the device used, will only be carried out if you have given us your express consent in accordance with Article 6(1)(a) GDPR. Without this consent, the use of Google Ads Conversion Tracking during your site visit will not take place.

You can revoke your consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the "Cookie Consent Tool" provided on the website.

You can also permanently object to the setting of cookies by Google Ads Conversion Tracking by downloading and installing the Google browser plugin available at the following link: https://support.google.com/ads/answer/7395996?hl=en

Please note that certain functions of this website may not be available or may be limited if you have deactivated the use of cookies.

For more information on Google's privacy policy, please visit: https://business.safety.google/intl/en/privacy/ and https://policies.google.com/privacy?hl=en

10) Page Features

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 ESW5, Ireland

When you access a page of our website that contains such a plugin, your browser establishes a direct connection to the provider's servers to load the plugin. Certain information, including your IP address, is transmitted to the provider.

If the playback of embedded videos is triggered via the plugin, the provider uses cookies to collect information about user behavior, compile playback statistics, and prevent misuse.

If you are logged into a user account registered with the provider during your site visit, your data will be directly assigned to your account when you click on a video. If you do not want this assignment to your account, you must log out before activating the play button.

All the processing mentioned above, especially the placement of cookies for reading information on the device used, will only take place if you have expressly consented to it in accordance with Article 6(1)(a) GDPR. You can revoke the consent given at any time with effect for the future by deactivating this service using the "Cookie Consent Tool" provided on the website.

For data transfers to the USA, the provider has adhered to 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 Sign-In

We provide a single sign-on function on our website from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland

If you have an account registered with the provider, you can use these account details to create a user account or register on our website.

When you visit this website, this registration function establishes a direct connection between your browser and the provider's servers, even if you do not have an account with the provider or are not logged into such an account. The provider thus receives the information that you have visited our website. The information collected in this way (including, if applicable, your IP address) is transmitted directly from your browser to a server of the provider and stored there. However, this information is not used to personally identify you and is not transmitted to third parties.

These data processing operations are carried out in accordance with Article 6(1)(f) GDPR based on our legitimate interest in making our online presence more user-friendly and interactive.

If you click on the registration button to register on our website by entering your account data open on the provider's site, the provider will transmit to us, based solely on your express consent in accordance with Article 6(1)(a) GDPR, the general and publicly accessible information you have stored in your account (user ID, name, address, email address, age, and gender).

We store and use the data transmitted by the provider to create a user account containing the necessary data (title, first name, last name, address data, country, email address, date of birth), if you have validated them with the provider. Conversely, based on your consent, data (e.g., information about your browsing or purchasing behavior) can be transferred from our side to your account open with the provider.

The consent given can be revoked at any time towards us with effect for the future.

In addition to a data transmission to the aforementioned provider site, data may also be transmitted to: Google LLC, USA

For data transfers to the USA, the provider has adhered to 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.

More information on Google's data protection is available here: https://business.safety.google/intl/en/privacy/

10.3 Google Web Fonts

This site uses web fonts provided by the following provider for uniform font display: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland

When you access a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly and establishes a direct connection to the provider's servers. Certain browser information, including your IP address, is transmitted to the provider.

The processing of personal data during the connection to the font provider only takes place if you have expressly consented to it 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 using the "Cookie Consent Tool" provided on the website. If your browser does not support web fonts, a standard font will be used by your computer.

For data transfers to the USA, the provider has adhered to 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.

More information on Google's data protection is available here: https://business.safety.google/intl/en/privacy/

11) Rights of the Data Subject

11.1 The applicable data protection law grants you the following rights (rights to information and intervention) vis-à-vis the controller regarding the processing of your personal data, about which we inform you below:

- Right of access (Article 15 GDPR)

- Right to rectification (Article 16 GDPR): You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you and/or to have incomplete personal data completed.

- Right to erasure or "right to be forgotten" (Article 17 GDPR);
- Right to restriction of processing (Article 18 GDPR);
- Right to notification and communication (Article 19 GDPR);
- Right to data portability (Article 20 GDPR);
- Right to withdraw consent given (Article 7(3) GDPR);
- Right to lodge a complaint (Article 77 GDPR).

11.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST IN THE CONTEXT OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING 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 PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE, OR DEFEND 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 PURPOSES BY FOLLOWING THE ABOVE PROCEDURES.

IF YOU EXERCISE YOUR RIGHT TO OBJECT TO PROCESSING FOR DIRECT MARKETING PURPOSES, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA FOR THESE PURPOSES.

12) Duration of Storage of Personal Data

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing, and—if applicable—in addition by the respective statutory retention period (e.g., commercial and tax retention periods).

When processing personal data based on explicit consent in accordance with Article 6(1)(a) GDPR, these data are stored until the data subject revokes their consent.

If there are statutory retention periods for data that are processed within the scope of legal or quasi-legal obligations on the basis of Article 6(1)(b) GDPR, these data are routinely deleted after the expiry of the retention periods, provided they are no longer necessary for contract fulfillment or contract initiation and/or if we have no legitimate interest in further storage.

When processing personal data based on Article 6(1)(f) GDPR, these data are stored until the data subject exercises their right to object in accordance with Article 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 to assert, exercise, or defend legal claims.

When processing personal data for direct marketing purposes based on Article 6(1)(f) GDPR, these data are stored until the data subject exercises their right to object in accordance with Article 21(2) GDPR.

Unless otherwise stated in the other information of this declaration on specific processing situations, stored personal data will otherwise be deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.