Privacy Policy

Controller within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is:

Hans Albu Sanmiguel GmbH 
Kyreinstraße 8 
81371 Munich 

Telefon: Tel.: +49 (0) 89 890 819 11 
E-Mail: info@sanmiguel.io

Your Data Subject Rights

You may exercise the following rights at any time by contacting our data protection officer using the contact details provided above:

You may exercise the following rights at any time using the contact details of our data protection officer provided above: This includes the right to obtain information about the personal data we store about you and how we process it (Art. 15 GDPR), the right to request the correction of inaccurate personal data (Art. 16 GDPR), and the right to request the deletion of your data stored by us (Art. 17 GDPR). You also have the right to request the restriction of data processing, provided we are not yet permitted to delete your data due to legal obligations (Art. 18 GDPR), the right to object to the processing of your data (Art. 21 GDPR), and the right to data portability if you have consented to the processing or entered into a contract with us (Art. 20 GDPR).

If you have given us your consent, you may withdraw it at any time with effect for the future.

You may also lodge a complaint with a supervisory authority at any time, for example with the authority responsible for your place of residence, or with the data protection authority responsible for us as the controller.

A list of supervisory authorities (for the non-public sector), including their contact details, is available at: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

Collection of General Information When Visiting Our Website

Type and Purpose of Processing

When you access our website, that is, when you do not register or otherwise transmit information, general information is automatically collected. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your internet service provider, your IP address, and similar data.

This information is processed in particular for the following purposes:

Ensuring a smooth connection to the website,

Ensuring the smooth use of our website,

Evaluation of system security and stability, as well as

Optimizing our website.

We do not use your data to draw conclusions about your identity. Information of this kind may be evaluated anonymously for statistical purposes in order to optimize our online presence and the underlying technology.

Legal Basis and Legitimate Interest

The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR based on our legitimate interest in improving the stability and functionality of our website.

Recipients

Recipients of the data may include technical service providers who act as processors to operate and maintain our website.

Storage Period

The data will be deleted as soon as it is no longer necessary for the purpose of collection. For data required to provide the website, this is generally the case when the respective session ends.

Provision Prescribed or Required

The provision of the aforementioned personal data is neither legally nor contractually required. However, without the IP address, the service and functionality of our website cannot be guaranteed. In addition, certain services and features may not be available or may be restricted. For this reason, objection is excluded.

Cookies

Like many other websites, we also use so-called “cookies.” Cookies are small text files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website.

You can delete individual cookies or the entire set of cookies. You can also find information and instructions on how to delete these cookies or block their storage in advance. Depending on your browser provider, you can find the necessary information at the following links:

Mozilla Firefoxhttps://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox

Internet Explorerhttps://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Google Chromehttps://support.google.com/accounts/answer/61416?hl=de

Operahttps://www.opera.com/es-419/help

Safarihttps://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=de_DE

Non-technically necessary cookies

We also use cookies to better tailor the content on our website to the interests of our visitors or to improve it overall based on statistical analysis.

For information on which providers set cookies, please refer to the details below regarding the technologies used for display, tracking, remarketing, and web analytics.

Legal Basis

The legal basis for these processing activities is your consent in accordance with Art. 6(1)(a) GDPR.

Recipients

Recipients of the data may include technical service providers who act as processors on our behalf to ensure the operation and maintenance of our website.

For further recipients, please refer to the information below regarding the technologies used for display, tracking, remarketing, and web analytics.

Transfer to Third Countries

For further information, please refer to the listings of the individual display, tracking, remarketing, and web analytics providers.

Provision Required or Mandatory

Of course, you can generally use our website without cookies. Most web browsers are set to accept cookies by default. In general, you can disable the use of cookies at any time through your browser settings (see Withdrawal of Consent).

Please note that certain functions of our website may not work properly if you have disabled the use of cookies.

Provision Required or Mandatory

You can withdraw your consent at any time using our cookie consent tool.

Profiling

Details on the extent to which we analyze the behavior of website visitors using pseudonymized user profiles can be found in the information below regarding the technologies used for display, tracking, remarketing, and web analytics.

Newsletter

Type and Purpose of Processing

We send newsletters, emails, and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or based on legal permission. If the contents of the newsletter are specifically described during the subscription process, these descriptions are decisive for the user’s consent. Otherwise, our newsletters include information about our services and our company.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide your name for personalized communication or other information if required for the purposes of the newsletter.

Double-Opt-In Procedure: Newsletter registration takes place in a so-called double-opt-in process. This means you will receive an email after signing up, asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else’s email address.
Newsletter subscriptions are logged in order to document the registration process as required by law. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored by the email service provider are also logged.

Deletion and Restriction of Processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests to be able to prove that consent was previously given. The processing of this data is limited to the purpose of defending against possible legal claims. You can request the deletion of your data at any time, provided that you confirm that you had previously given consent. In case of obligations to permanently respect opt-outs, we reserve the right to store your email address solely for this purpose in a so-called “blocklist.”

The logging of the subscription process is based on our legitimate interests to prove that the process was conducted in accordance with legal requirements. If we commission a service provider to send emails, this is done based on our legitimate interest in a secure and efficient mailing system.

Legal Basis: The sending of newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interest in direct marketing, where legally permitted (e.g., for existing customers). If we commission a service provider to send emails, this is based on our legitimate interests. The registration process is documented based on our legitimate interests to demonstrate compliance with the law.

Contents: Information about us, our services, promotions, and offers.

Categories of Data Processed: Master data (e.g., names, addresses), Contact data (e.g., email addresses, phone numbers), Meta/communication data (e.g., device information, IP addresses), Usage data (e.g., pages visited, interest in content, access times)

Data Subjects: Communication partners.

Purpose of Processing: Direct marketing (e.g., via email or postal mail).

Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Right to Object (Opt-Out): You can unsubscribe from our newsletter at any time, meaning you can withdraw your consent or object to further receipt. You will find a link to unsubscribe at the end of every newsletter, or you may contact us using any of the contact details provided above, preferably via email.

Services and Service Providers Used

Mailchimp

Email delivery and email marketing platform;
Service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com
Privacy Policy: https://mailchimp.com/legal/privacy/
Standard Contractual Clauses (Ensuring data protection when processing in third countries): https://mailchimp.com/legal/data-processing-addendum/
Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/

Based on your explicit consent (Art. 6 para. 1 lit. a GDPR), we will regularly send you our newsletter or similar information via email to the email address you provided.

You may revoke your consent to the storage of your personal data and its use for newsletter delivery at any time with future effect. You will find a corresponding link in every newsletter.
You may also unsubscribe directly on this website at any time or notify us of your revocation using the contact details provided at the end of this privacy notice.

Recipients

The recipients of the data may include commissioned processors.

Storage Period

The data will only be processed in this context as long as the corresponding consent is in place. After that, the data will be deleted.

Provision Required or Necessary

The provision of your personal data is voluntary and based solely on your consent. Without this consent, we are unfortunately unable to send you our newsletter.

Withdrawal of Consent

You may withdraw your consent to the storage of your personal data and its use for newsletter delivery at any time with future effect. You can unsubscribe using the link included in every email or by contacting the data protection officer or the person responsible for data protection listed below.

Hubspot

Storage Period

The data will only be processed in this context as long as the corresponding consent is in place. After that, the data will be deleted.

Provision Required or Necessary

The provision of your personal data is voluntary and based solely on your consent. Without this consent, we are unfortunately unable to send you our newsletter.

Withdrawal of Consent

You may withdraw your consent to the storage of your personal data and its use for newsletter delivery at any time with future effect. You can unsubscribe using the link included in every email or by contacting the data protection officer or the person responsible for data protection listed below.

Use of Google Analytics

If you have given your consent, this website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter: “Google”). Google Analytics uses so-called “cookies,” which are text files stored on your computer that enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymization on this website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before transmission. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Further information on terms of use and data protection can be found at https://www.google.com/analytics/terms/ and https://policies.google.com/?hl=en.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services related to website and internet usage to the website operator.

The data we send and link to cookies, user identifiers (e.g., User-ID), or advertising IDs are automatically deleted after 14 months. The deletion of data whose retention period has been reached takes place automatically once a month.

Withdrawal of Consent

You can prevent Google Analytics from tracking your activity on our website by clicking on this link. An opt-out cookie will be set on your device. This prevents Google Analytics from collecting data on this website and in this browser in the future, as long as the cookie remains installed in your browser.

You can also prevent the storage of cookies by adjusting your browser settings. However, please note that you may not be able to fully use all the functions of this website if you disable cookies.

Additionally, you can prevent the collection of data generated by the cookie related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: Browser Add-on to disable Google Analytics.

Google Tag Manager

Google Tag Manager is a solution that allows us to manage website tags via an interface and thereby integrate other services into our online offering (please refer to the additional information in this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only receives the user’s IP address, which is necessary to run Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Website: https://marketingplatform.google.com
Privacy Policy: https://policies.google.com/privacy
Data Processing Agreement: https://business.safety.google/adsprocessorterms
Types of processing and data processed: https://privacy.google.com/businesses/adsservices
Data Processing Terms for Google Advertising Products and Standard Contractual Clauses for data transfers to third countries: https://business.safety.google/adsprocessorterms

LinkedIn Conversion Tracking and Insight Tag

The LinkedIn Insight Tag is a lightweight JavaScript code that we have added to our websites to enable detailed campaign reporting and to help us gain valuable insights into our website visitors. We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and gather additional insights about members who interact with our LinkedIn ads.

The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamps, and events like page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor’s browser until the visitor deletes the cookie or the cookie expires (the expiration period is a rolling six months from the last time the visitor’s browser loaded the Insight Tag).

You can disable LinkedIn cookies on your LinkedIn settings page, and we recommend reading their cookie policy for more information.

Website: https://www.linkedin.com
Privacy Policy: https://www.linkedin.com/legal/privacy-policy
Cookie Policy: https://www.linkedin.com/legal/cookie_policy
Opt-Out Option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Service Provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA

Embedded YouTube Videos

We embed YouTube videos on our website. The operator of the corresponding plugins is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (hereinafter “YouTube”). YouTube, LLC is a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”).
When you visit a page containing a YouTube plugin, a connection to YouTube servers is established. YouTube is thereby informed which pages you have visited. If you are logged into your YouTube account, YouTube can associate your browsing behavior with you personally. You can prevent this by logging out of your YouTube account before visiting the website.

When a YouTube video is started, the provider uses cookies that collect information about user behavior.

Further information about the purpose and scope of data collection and its processing by YouTube can be found in the provider’s privacy policy. There you will also find additional information about your rights and privacy settings options to protect your personal data: https://policies.google.com/privacy.

Withdrawal of Consent

The provider currently does not offer a simple opt-out or a way to block data transmission. If you wish to prevent tracking of your activities on our website, please withdraw your consent for the corresponding cookie category or all non-essential cookies and data transmissions via our cookie consent tool. Please note that if you do so, you may not be able to use our website, or you may only be able to use it with limited functionality.

SSL Encryption

To protect the security of your data during transmission, we use state-of-the-art encryption methods (such as SSL) via HTTPS.

Information About Your Right to Object According to Article 21 GDPR

Right to Object on a Case-by-Case Basis

You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data which is based on Article 6(1)(f) GDPR (data processing based on a balancing of interests); this also applies to profiling based on this provision within the meaning of Article 4(4) GDPR.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims.

Recipient of an Objection

Hans Albu Sanmiguel GmbH 
Kyreinstraße 8 
81371 München 

Phone: +49 (0) 89 890 819 11 
E-Mail: info@sanmiguel.io

Changes to Our Privacy Policy

We reserve the right to modify this privacy policy to ensure it always complies with current legal requirements or to reflect changes to our services in the privacy policy, for example, when introducing new services. The updated privacy policy will apply to your next visit.

Questions for the Data Protection Officer

If you have any questions regarding data protection, please contact us by email or directly reach out to the person responsible for data protection in our organization:

E-Mail: info@sanmiguel.io

The privacy policy was created with the support of activeMind AG, the experts for external data protection officers (Version #2020-09-30).

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