VON POLL REAL ESTATE

Politica sulla privacy

Von Poll Immobilien GmbH takes the protection of your privacy when using its website very seriously. We process your personal data in accordance with the applicable data protection regulations. The legal basis for this can be found in particular in the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG). The following provisions inform you in accordance with Articles 12, 13, and 21 of the GDPR about the processing of your personal data on our websites, applications, and social media profiles.

Table of contents

§ 1 Definitions

(1) Below, we provide information about the collection of personal data when using our website. This privacy policy uses the terms of the General Data Protection Regulation (GDPR). We would like to explain the most important terms here:

  • “Personal data” is any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); a natural person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution, or otherwise making available, alignment, or combination, restriction, erasure, or destruction.
  • “Controller” is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
  • “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  • “Recipient” means a natural or legal person, public authority, agency, or other body to which personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those authorities shall be carried out in compliance with the applicable data protection rules according to the purposes of the processing.
  • “Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
  • “Consent” is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

§ 2 Responsible party

(1) The responsible party for the processing of your personal data is von Poll Immobilien GmbH (hereinafter referred to as the “Provider”) with its registered office at Feldbergstraße 35, 60323 Frankfurt am Main, telephone: +49 (0) 69 26 91 57 0, fax: +49 (0) 69 26 91 57 11, email: [email protected].

(2) Our external data protection officer can be contacted as follows: ePrivacy GmbH, Burchardstraße 14, 20095 Hamburg, [email protected].  

§ 3 Purpose and legal basis of data processing

(1) Von Poll Immobilien GmbH (employees and brokers), its partners (independent commercial agencies, their brokers and employees) and service providers commissioned by us (processors) process your personal data on the following legal bases:

  • Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

(2) Your personal data will be processed for the following purposes:

  • for contract processing, in particular for processing orders and invoicing,
  • for providing our services,
  • for contacting you as requested,
  • for maintaining and strengthening our customer relationships,
  • for advertising purposes (including the email newsletter),
  • for quality assurance, and
  • for our statistics.

(3) Our website offers you services from our independent commercial agencies and our commercial and licensing partners. These include, for example, online real estate listings, an exclusive marketplace where properties across Europe are offered for sale, and customized real estate financing options. In addition, we also provide service-related offers related to real estate. This gives you the opportunity to contact the respective providers directly. You can find an overview of our current partners here: https://www.von-poll.com/en/company/locations.

(4) When you contact us by email or via a contact form, we store the data you provide (your email address, your name and telephone number, if applicable) in order to answer your questions. We delete the data collected in this context once storage is no longer necessary, or restrict processing if there are legal retention requirements.

§ 4 Recipients or categories of recipients of personal data

(1) Your data will be processed by von Poll Immobilien GmbH in accordance with Art. 5 ff GDPR. Your data may also be processed by the following groups of people:

  1. Employees who are authorized to administer the website and provide the associated services (e.g., customer service, IT department, etc.);
  2. Employees in the areas of marketing, finance, administration, and accounting, and other relevant departments;
  3. Third-party companies (e.g., IT service providers, hosting providers, etc.). Individual processes or support services are provided by carefully selected service providers commissioned by us. Data protection agreements in accordance with the GDPR have been concluded with these service providers in order to agree on an appropriate level of data protection.
  4. Master franchisees, license partners, and sales representatives who offer properties as part of the property search and to whom the user sends a contact request.
  5. Depending on the services you request, your data may be transferred to our license partner VON POLL FINANCE.
  6. Depending on the services you request, your data may be transferred to our license partner VON POLL COMMERCIAL.
  7. Depending on the services you request, your data may be transferred to our license partner VON POLL REAL ESTATE.
  8. Depending on the services you request, your data may be transferred to our license partner VON POLL HAUSVERWALTUNG.

§ 5 Storage period for your personal data

The data processed by von Poll Immobilien GmbH will be deleted in accordance with legal requirements as soon as the consent for processing is revoked or other permissions no longer apply (e.g., if the purpose of processing this data no longer applies or it is no longer necessary for the purpose). If the data is not deleted because it is required for other, legally permissible purposes, its processing will be restricted to these purposes, i.e., the data will be blocked and not processed for other purposes. 

§ 6 International data transfers

(1) Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies, or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent, or in the case of contractual or legally required transfers (Art. 49 (1) GDPR). In addition, we will inform you of the basis for third-country transfers for individual providers from third countries, whereby adequacy decisions take precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission.

(2) EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain US companies as adequate within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov (in English). We will inform you in our privacy policy which service providers we use are certified under the Data Privacy Framework.

§ 7 Your rights

(1) Right to information

The user has the right to request confirmation as to whether data concerning him or her is being processed and to obtain information about this data in accordance with the statutory provisions. 

(2) Right to rectification 

In accordance with the statutory provisions, the user has the right to request the completion or rectification of data concerning him or her. 

(3) Right to erasure and restriction of processing

The user has the right, in accordance with legal requirements, to request that data concerning him/her be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data. 

(4) Right to data portability 

The user has the right to receive data concerning him/her that he/she has provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements. 

(5) Right to object

If we process data on the basis of Art. 6 (1) (f) GDPR, users have the right to object to this processing at any time for reasons arising from their particular situation.

(6) Right of revocation

If the user has given separate consent for the processing of their personal data, they may revoke this consent at any time. The legality of the processing of the user's data up to the point of revocation remains unaffected by the revocation.

(7) Complaints to the supervisory authority

The user has the right to contact the competent supervisory authority with any questions or complaints. The competent supervisory authority for data protection issues is the state data protection officer of the federal state in which von Poll Immobilien GmbH has its registered office. This is the Hessian Data Protection Officer, Gustav-Stresemann-Ring 1, 65189 Wiesbaden. 

§ 8 SSL or TLS encryption

(1) For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

(2) If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

§ 9 Processing operations

Registration and use of our services

(1) In order to establish or implement the contractual relationship with our customers, it is regularly necessary to process the personal master data, contract data, and payment data provided to us. The legal basis for this processing is Art. 6 (1) (b) GDPR. We also process customer and prospect data for evaluation and marketing purposes. This processing is carried out on the legal basis of Art. 6 (1) (f) GDPR and serves our interest in further developing our offering. Further data processing may take place if you have given your consent (Art. 6 (1) (a) GDPR) or if this serves to fulfill a legal obligation (Art. 6 (1) (c) GDPR).

(2) In order to use parts of our service, you must register on our websites by providing your first and last name, telephone number, and email address. After registration, further personal data will be collected. The required information is shown in the registration form and includes, among other things, your name, postal address, email address, and, if applicable, telephone number. The provision of information marked as mandatory is essential in order for you to be able to use our services. The data is processed for the purpose of fulfilling the contractual service and payment processing. Unless expressly stated at the time of collection, the provision of data is not necessary or mandatory. An obligation may arise from legal requirements or contractual provisions. Additional information may also be provided, including the following data: Details about the property or interest in the property. The data provided will be processed for the purpose of providing services and processing contracts. Processing is based on the legal basis of Art. 6 (1) (b) GDPR. All data mentioned in this paragraph is entered by you yourself. You are responsible for its accuracy and can make corrections yourself. We will also store your data to the extent required by law for the purpose of fulfilling our archiving obligations.

(3) In addition to the data described above, we store further data during registration and use of our services that you did not actively enter into our input masks. This includes, for example, the date and time of registration and last log-in, language code, and referrer via which a form was submitted. This data is processed on the basis of our legitimate interest pursuant to Art. 6 (1) (f) GDPR in offering you optimized services. You can object to the use of your data at any time by contacting us at the above-mentioned contact details. Other data that you do not actively enter into our input mask includes the date on which you last accepted our terms and conditions and privacy policy, as well as information about the status of your contract with us and your payments to us. This data is processed for the purpose of fulfilling the contract in accordance with Art. 6 (1) (b) GDPR.

Newsletter dispatch

(1) With your consent, you can subscribe to our newsletter, which we use to inform you about our current interesting real estate offers. The advertised properties and services are named in the declaration of consent.

(2) We use the double opt-in procedure for registration for our newsletter. This means that after you register, we will send an email to the email address you provided, asking you to confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be blocked and automatically deleted. In addition, we store the times of registration and confirmation. The purpose of this procedure is to verify your registration and, if necessary, to investigate any possible misuse of your personal data.

(3) The only mandatory information required for sending the newsletter is your email address. The provision of further, separately marked data is voluntary and is used to address you personally. After your confirmation, we will store your email address for the purpose of sending you the newsletter. The legal basis is Art. 6 (1) (a) GDPR.

(4) You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can revoke your consent by clicking on the link provided in every newsletter email, by sending an email to [email protected], or by sending a message to the contact details provided in the legal notice.

Cookies

(1) When using the website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (the legal basis is Art. 6 (1) (f) GDPR):

  1. Date and time of the request
  2. Time zone difference to Greenwich Mean Time (GMT)
  3. Content of the request (specific page)
  4. Access status/HTTP status code
  5. Amount of data transferred in each case
  6. Website from which the request originates
  7. Browser
  8. Operating system and its interface
  9. Language and version of the browser software.

(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive and assigned to the browser you are using, and through which certain information flows to the entity that sets the cookie (in this case, us). Cookies cannot execute programs or transfer viruses to your computer. They serve to make the Internet offering more user-friendly and effective overall. We may work with advertising partners who help us to make our Internet offering more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). If we work with the aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case in the following paragraphs.

(3) Use of cookies:

a) This website uses the following types of cookies, the scope and functionality of which are explained below:

- Transient cookies (see b)

- Persistent cookies (see c).

b) Transient cookies are automatically deleted when you close your browser. These include, in particular, session cookies. These store a so-called session ID, which can be used to assign various requests from your browser to the shared session. This allows your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close your browser.

c) Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in your browser's security settings.

d) You can configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies. Please note that you may not be able to use all the features of this website.

e) We use cookies to identify you for subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit.

f) The Flash cookies used are not recorded by your browser, but by your Flash plug-in. We also use HTML5 storage objects, which are stored on your device. These objects store the necessary data independently of the browser you use and do not have an automatic expiration date. If you do not want Flash cookies to be processed, you must install an appropriate add-on, e.g., “Clear Flash Cookies” for Mozilla Firefox (https://addons.mozilla.org/en-US/firefox/addon/clear-browsing-data) or the Adobe Flash Killer Cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. We also recommend that you regularly delete your cookies and browser history manually.

(4) Log files

Each time you access our website, usage data is transmitted by your internet browser and stored in log files, known as server log files. The data records stored contain the following information: domain from which the user accesses the website, date and time of access, IP address of the accessing computer, website(s) visited by the user within the scope of the offer, amount of data transferred, browser type and version, operating system used, notification of whether the access was successful. These log file data records are evaluated in anonymized form in order to improve the website and make it more user-friendly, to find and correct errors, and to control server utilization.

Web Analytics

1. Use of Google Analytics

(1) This website uses Google Analytics, a web analytics service provided by Google Ireland Limited (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. We have activated IP anonymization on this website so that your IP address is truncated 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 will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website activity and internet usage to the website operator.

(2) If you have agreed to have your web and app browsing history linked to your Google account and to have information from your Google account used to personalize ads, Google will use this data for cross-device remarketing. This website also uses Google Analytics for cross-device analysis of visitor flows, which is carried out via a user ID. You can deactivate cross-device analysis of your usage in your customer account under “My data,” “Personal data.” Otherwise, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

(3) You can prevent the storage of cookies by adjusting your browser software settings accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

(4) Data processing, in particular the setting of cookies, is carried out with your consent on the basis of Art. 6 (1) lit. a GDPR. You can revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of your consent until revocation. We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offering and make it more interesting for you as a user.

(5) Third-party information: The responsible body for users in the EU/EEA is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Terms of use: https://www.google.com/analytics/terms/de.html, overview of data protection: https://www.google.com/intl/de/analytics/learn/privacy.html, and the privacy policy: https://www.google.de/intl/de/policies/privacy.

(6) “We have activated IP anonymization on this website so that your IP address is truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area.”

Social media

Use of social media plug-ins

(1) We currently use the following social media plug-ins: Facebook, Twitter, Xing, LinkedIn, YouTube, Instagram. You can recognize the provider of the plug-in by the marking on the box above its initial letter or logo. We offer you the option of communicating directly with the plug-in provider via the button. Only when you click on the marked field and thereby activate it will the plug-in provider receive the information that you have accessed the corresponding website of our online offering.

By activating the plug-in, your personal data is transmitted to the respective plug-in provider and stored there (in the case of US providers, in the USA). Since the plug-in provider collects data via cookies in particular, we recommend that you delete all cookies via your browser's security settings before clicking on the grayed-out box.

(2) We have no influence on the data collected and data processing operations, nor are we aware of the full extent of data collection, the purposes of processing, or the storage periods. We also have no information about the deletion of the data collected by the plug-in provider.

(3) The plug-in provider stores the data collected about you as usage profiles and uses them for advertising, market research, and/or the needs-based design of its website. Such evaluation is carried out in particular (even for users who are not logged in) to display needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. The plug-ins offer you the opportunity to interact with social networks and other users, enabling us to improve our offering and make it more interesting for you as a user. Data processing is carried out with your consent on the basis of Art. 6 (1) lit. a GDPR. You can revoke your consent at any time with effect for the future, without affecting the lawfulness of the processing carried out on the basis of your consent until revocation. You can also prevent social media plugins from loading by using add-ons for your browser. In addition, you can revoke your consent by adjusting your browser settings or by logging out of the respective social network. You can also deactivate user-based advertising via the Network Advertising Initiative's deactivation page (https://optout.networkadvertising.org), via https://www.youronlinechoices.com/de/praferenzmanagement, or via the US website (https://www.aboutads.info/choices).

(4) Data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, the data we collect will be directly associated with your existing account with the plug-in provider. If you click on the activated button and, for example, link the page, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button, as this will prevent your profile from being assigned to the plug-in provider.

(5) Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policies of these providers, which are provided below. There you will also find further information on your rights in this regard and setting options for protecting your privacy.

(6) Further information on the respective plug-in providers, in particular their privacy policies:

  1. Facebook: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland (Mutterunternehmen: Meta Platforms, Inc, 1601 Willow Road Menlo Park, CA 94025 Vereinigte Staaten); https://www.facebook.com/policy.php; weitere Informationen zur Datenerhebung: https://www.facebook.com/help/186325668085084, https://www.facebook.com/about/privacy/your-info-on-other#applicationssowie https://www.facebook.com/about/privacy/your-info#everyoneinfo. Widerruf über Facebook unter https://www.facebook.com/settings/?tab=ads#_. Es kann nicht ausgeschlossen werden, dass Meta Daten zum Zwecke der Speicherung und Weiterverarbeitung in die USA überträgt. Sofern eine solche Datenübertragung in die USA erfolgt, wird diese auf die Standardvertragsklauseln der EU-Kommission gestützt: https://www.facebook.com/legal/EU_data_transfer_addendum und https://de-de.facebook.com/help/566994660333381.
  2. „Google“: Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Irland, (Mutterunternehmen: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).; https://www.google.com/policies/privacy/partners/?hl=de.
  3. Xing: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Information on the purpose and scope of data collection and the further processing and use of data by Xing, as well as your rights and settings options in this regard, can be found here: https://privacy.xing.com/de/datenschutzerklaerung.
  4. LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; detailed information on the use of cookies can be found at https://www.linkedin.com/legal/cookie-policy and here https://www.linkedin.com/legal/privacy-policy. You can object to the analysis of usage behavior and targeted advertising by LinkedIn at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. In addition, you can revoke your consent by adjusting your browser settings or via LinkedIn: https://www.linkedin.com/psettings/. It cannot be ruled out that LinkedIn may transfer data to the USA for storage and further processing. If such data transfer to the USA takes place, it is based on the standard contractual clauses of the EU Commission: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs
  5. Instagram: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland (Mutterunternehmen: Meta Platforms, Inc, 1601 Willow Road Menlo Park, CA 94025 Vereinigte Staaten); Weitere Informationen hierzu finden Sie in der Datenschutzerklärung von Instagram: https://instagram.com/about/legal/privacy. Darüber hinaus können Sie Ihre Einwilligung durch eine entsprechende Einstellung Ihres Browsers oder über Instagram widerrufen: https://www.instagram.com/accounts/data_controls_support. Es kann nicht ausgeschlossen werden, dass Meta Daten zum Zwecke der Speicherung und Weiterverarbeitung in die USA überträgt. Sofern eine solche Datenübertragung in die USA erfolgt, wird diese auf die Standardvertragsklauseln der EU-Kommission gestützt: https://www.facebook.com/legal/EU_data_transfer_addendum und https://de-de.facebook.com/help/566994660333381.

2. Integration of YouTube videos

(1) We use the YouTube embedding function to display and play videos from YouTube, a service provided by Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, (parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA), hereinafter referred to as “Google.” We have integrated YouTube videos into our online offering that are stored on https://www.YouTube.com and can be played directly from our website.

(2) This uses the extended data protection mode, which, according to the provider, only starts storing user information when the video(s) is/are played; in any case, however, a connection is established with YouTube and the Google advertising network “DoubleClick.” When the playback of embedded YouTube videos is started, the provider YouTube uses cookies or comparable recognition technologies to collect information about user behavior. If you are logged in to Google, your data will be directly assigned to your account. If you do not want this assignment to your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses it for advertising, market research, and/or the needs-based design of its website. Such evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

(3) Data processing is based on your consent pursuant to Art. 6 (1) (a) GDPR. You may revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of your consent prior to revocation.

(4) It cannot be ruled out that personal data may be transferred to the USA when using YouTube. In such cases, the transfer is based on the EU standard contractual clauses pursuant to Art. 46 GDPR:

https://policies.google.com/privacy/frameworks?hl=de

(5) Further information on the purpose and scope of data collection and its processing by YouTube can be found in Google's privacy policy:

https://policies.google.com/privacy?hl=de.

3. Integration of mobile applications (iOS/Android)

(1) After purchasing and installing our mobile application (app) on a mobile device (iOS/Android), individual details about the personal or factual circumstances of an identified or identifiable person (personal data) are collected, processed, and used. Personal data is collected manually or automatically. The collected data is encrypted on the mobile device and also transmitted in encrypted form to our server infrastructure.

(2) Manual collection involves data that is required to log into our app, is directly related to the use of the app, and is entered manually by the user (e.g., inventory data, including email, IP address, username, and password).

(3) Automatic collection refers to self-stored information, including, in particular, contact information that can be read, personal, pseudonymous, or anonymous usage data that is created for the purpose of designing the app to meet user needs, analyzing and storing user behavior, and geographic data that is determined using app-based location-based services via GPS or Wi-Fi hotspots.

4) The following permissions are required to use the app in order to ensure its full functionality. Without these permissions, the app will not work or will be severely limited in its functionality:

  1. Creation, search, and use of user accounts
  2. Access to photos/media/files/user location
  3. Synchronization with the user account
  4. Retrieval of Internet data
  5. Sending/receiving push notifications
  6. Querying network connections

(5) Data processing is based on your consent in accordance with Art. 6 (1) (a) GDPR. The user can revoke their consent electronically at any time. This can be done during the installation of the app by not consenting to the respective query window on the mobile device. After installation and during use, the permissions can be customized in the privacy settings of the mobile device. The user's right of objection under Section 15 (3) TMG remains unaffected by this.

6) By clicking on the “Delete account” function, all personal data will be deleted. When the app is deleted from the mobile device, user data collected up to that point will remain assignable. No further data will be collected or processed.

Online advertising

1. Use of Google Ads

(1) We use Google Ads, a service provided by Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, (parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA), hereinafter referred to as “Google,” to draw attention to our attractive offers on external websites with the help of advertising media (so-called Google Adwords). We can determine how successful the individual advertising measures are in relation to the data from the advertising campaigns. Our interest in doing so is to show you advertising that is of interest to you, to make our website more interesting for you, and to achieve a fair calculation of advertising costs.

(2) These advertising materials are delivered by Google via so-called “ad servers.” To do this, we use ad server cookies, which allow certain parameters to be measured for performance measurement, such as the display of ads or clicks by users. If you access our website via a Google ad, Google Ads will store a cookie on your PC. These cookies usually expire after 30 days and are not intended to identify you personally. The unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), and opt-out information (indicating that the user no longer wishes to be targeted) are usually stored as analysis values for this cookie.

(3) These cookies enable Google to recognize your Internet browser. If a user visits certain pages of an Ads customer's website and the cookie stored on their computer has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page. Google uses cookies to analyze website usage, which forms the basis for creating interest-based advertisements. Cookies are used to record visits to the website and anonymized data about the use of the website. No personal data of website visitors is stored. If you then visit another website in the Google Display Network, you will be shown advertisements that are highly likely to take into account previously viewed product and information areas. We only receive statistical evaluations from Google. These evaluations enable us to identify which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users based on this information.

(4) Due to the marketing tools used, your browser automatically establishes a direct connection to Google's server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: By integrating AdWords Conversion, Google receives the information that you have accessed the corresponding part of our website or clicked on one of our ads. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may find out and store your IP address and email address.

(5) You can prevent participation in this tracking process in various ways:

  1. ) by adjusting your browser software settings accordingly; in particular, suppressing third-party cookies means that you will not receive any third-party ads;
  2. ) by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.de/settings/ads, although this setting will be deleted when you delete your cookies;
  3. ) by deactivating interest-based ads from providers who are part of the “About Ads” self-regulation campaign via the link https://www.aboutads.info/choices, whereby this setting will be deleted if you delete your cookies;
  4. ) by permanently deactivating them in your Firefox, Internet Explorer, or Google Chrome browsers via the link https://www.google.com/settings/ads/plugin. Please note that in this case, you may not be able to use all the functions of this website to their full extent.

(6) Data processing, in particular the setting of cookies, is carried out with your consent on the basis of Art. 6 (1) lit. a GDPR. You can revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of your consent until revocation. 

(7) It cannot be ruled out that Google may transfer data to the USA. This transfer is based on the standard contractual clauses (SCCs) approved by the EU Commission. Further information can be found here:

https://policies.google.com/privacy/frameworks?hl=de

(8) Further information on data protection at Google can be found here: https://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can visit the Network Advertising Initiative (NAI) website at https://www.networkadvertising.org.

2. Enhanced Conversion Measurement

(1) To improve the accuracy of our advertising performance measurement, we use the Enhanced Conversion Measurement feature. In this process, the data you actively enter into form fields (e.g., email address, phone number) is immediately pseudonymized (encrypted) in your browser using the SHA-256 hashing algorithm and then transmitted to Google in this form. This enables Google to attribute a conversion (e.g., a contact request) more precisely to your click on one of our advertisements and thereby assess the effectiveness of our advertising activities.

(2) The processing is carried out on the basis of your consent in accordance with Art. 6 (1) (a) GDPR, which you may withdraw at any time via our cookie settings.

(3) It cannot be ruled out that Google may transfer data to the United States. Such transfers are carried out on the basis of the Standard Contractual Clauses (SCCs) approved by the European Commission. Further information can be found here: https://policies.google.com/privacy/frameworks?hl=en

(4) Further information on data protection at Google can be found here: https://www.google.com/intl/en/policies/privacy and https://services.google.com/sitestats/en.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at https://www.networkadvertising.org.

3. Meta Pixel (Custom Audiences)

(1) Our websites use the tracking technology Meta Pixel (formerly Facebook Pixel) (Custom Audiences) from Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (parent company: Meta Platforms, Inc, 1601 Willow Road Menlo Park, CA 94025 United States). This technology enables us to individually target website visitors who have already shown interest in our website or who have been redirected to our website with advertising on the Facebook website. It serves to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes and can help to optimize future advertising measures.

(2) The display of personalized, interest-based advertising on the Facebook website is based on cookie technology and is completely pseudonymous. A persistent cookie is used for this purpose, which you can delete at any time in your browser's security settings (see above in this privacy policy).

(3) We do not store any personal data in the course of Facebook Conversation Tracking. The data collected remains anonymous to us and does not allow von Poll Immobilien GmbH to draw any conclusions about your identity or the identity of the users of this website. However, Facebook stores and processes the data for its own advertising purposes in accordance with its own data usage policy. This enables Facebook to place advertisements on Facebook pages and outside of Facebook. As the website operator, we have no influence over this use of data. Further information is available at the following link: https://www.facebook.com/policy.php.

(4) Data processing is carried out with your consent by confirming the cookie banner on our website on the basis of Art. 6 (1) lit. a GDPR. You can revoke your consent at any time with effect for the future without affecting the lawfulness of the processing carried out on the basis of your consent until revocation. The revocation can be made by deactivating the corresponding selection on our consent management platform (cookie banner), which you can access via the “Change declaration” link in the “Cookie declaration” section at the end of the privacy policy. In addition, you can revoke your consent by adjusting your browser settings or, as a logged-in user of the Facebook social network, at https://www.facebook.com/settings?tab=ads. You can also deactivate user-based advertising via the Network Advertising Initiative's deactivation page (https://optout.networkadvertising.org), via https://www.youronlinechoices.com/de/praferenzmanagement, or via the US website (https://www.aboutads.info/choices).

(5) It cannot be ruled out that Facebook may transfer data to the US for storage and further processing. If such data transfer to the USA takes place, it will be based on the standard contractual clauses of the EU Commission: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.

(6) For more information about how Facebook processes personal data, including how to exercise your rights as a data subject vis-à-vis Facebook, please refer to Facebook's data policy at https://www.facebook.com/about/privacy.

Integration of other third-party providers

1. Google Maps

(1) On this website, we use Google Maps (API) from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). This allows us to display interactive maps directly on the website and enables you to conveniently use the map function.

(2) When you visit the website, Google receives information that you have accessed the corresponding subpage of our website. This occurs regardless of whether Google provides a user account that you are logged in to or whether no user account exists. If you are logged in to Google, your data will be directly associated with your account. If you do not want this association with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses it for the purposes of advertising, market research, and/or the needs-based design of its website. Such evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right.

(3) Data processing, in particular the setting of cookies, is carried out with your consent on the basis of Art. 6 (1) lit. a GDPR. You may revoke your consent at any time with effect for the future, without affecting the lawfulness of the processing carried out on the basis of your consent until revocation.

(4) It cannot be ruled out that Google may transfer personal data to the USA. If such a transfer takes place, Google relies on the EU standard contractual clauses pursuant to Art. 46 GDPR. 

(5) Further information on the purpose and scope of data collection and its processing by Google can be found in the privacy policy. There you will also find further information on your rights in this regard and setting options for protecting your privacy: https://www.google.de/intl/de/policies/privacy.

2. HubSpot

(1) We use the HubSpot service provided by HubSpot Inc., 25 First Street, Cambridge, MA 02141, USA, for marketing, sales, and administrative purposes, e.g., to organize our customer relationships, to contact users of our website (e.g., to send newsletters), to analyze which of our company's services are of interest to you, and to efficiently process user inquiries.

(2) This involves the use of tracking technologies such as cookies and web beacons, which are stored on your device and enable us to analyze your use of the website. HubSpot evaluates the information collected (e.g., IP address, geographic location, browser type, duration of visit, and pages viewed) on our behalf to generate reports on website usage. If, for example, newsletters are subscribed to and studies and other documents are obtained, we can also use Hubspot to link a user's visits to their personal details (especially name/email address) on the basis of consent given, thus collecting personal data and informing users individually and in a targeted manner about their preferred topics.

(3) Data processing is carried out exclusively on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke your consent at any time with effect for the future without affecting the lawfulness of the processing carried out up to that point. 

(4) Since HubSpot is based in the US, data is transferred to a third country. HubSpot undertakes to comply with the EU standard contractual clauses in order to ensure an adequate level of data protection.

(5) Further information on the purpose and scope of data processing and your rights can be found in HubSpot's privacy policy at: https://legal.hubspot.com/privacy-policy.

3. PriceHubble

(1) We use services provided by PriceHubble AG, Brandschenkestrasse 30, 8001 Zurich, Switzerland, on our website. PriceHubble offers data-driven solutions for the real estate market and supports us with property valuation, market analysis, and search automation.

(2) PriceHubble collects, organizes, and analyzes various data related to the residential real estate market – including transaction data, listings, urban infrastructure, sociodemographic data, building permits, and more. Through the integration of this service, we provide you with tools such as property valuation, rent estimates, market analyses, and search assistance.

When using certain features – such as requesting a valuation or market analysis – personal data that you actively provide may also be processed. This may include your name, address, email address, telephone number, and property-related information.

(3) The processing of your data is carried out either for the performance of pre-contractual measures or the fulfillment of a contract pursuant to Art. 6(1)(b) GDPR, or based on our legitimate interest under Art. 6(1)(f) GDPR in providing our services in an efficient and user-oriented manner. You have the right to object to the processing of your data at any time with future effect.

(4) Switzerland is recognized by the European Commission as a third country with an adequate level of data protection.

(5) For more information about data processing by PriceHubble, please refer to their privacy policy:
https://www.pricehubble.com/en/privacy/privacy-policy

4. Font Awesome

(1) To ensure the uniform display of symbols and fonts on our website, we use “Font Awesome,” a service provided by Fonticons, Inc., 307 S. Main St., Suite 202, Bentonville, AR 72712, USA.

(2) The fonts are integrated locally on our server. When you visit our website, the files are therefore not loaded from Fonticons, Inc. servers, but directly from our own server. No personal data is transferred to Fonticons, Inc.

5. Real Estate Chatbot

(1) On our website, we use a “chatbot” provided by Bots4You GmbH, Kölner Straße 46, 57555 Mudersbach (hereinafter referred to as “Bots4You”). The chatbot is software programmed to automatically and systematically respond to user inquiries. It assists users in searching for real estate, responds to a variety of questions, including those relating to property rental and purchase, and can arrange consultation and viewing appointments on behalf of users.

(2) For this purpose, the chatbot necessarily processes connection data (including your anonymized IP address) and generates a so-called Universally Unique Identifier, or “UUID” (“contact number”). This pseudonym enables us to refer back to your previous inquiry in the event of renewed contact within a period of one month. Depending on the nature of your inquiry and your use of the chatbot, content and usage data may also be processed, such as your text inputs, information relating to viewing and consultation appointments, the use of specific content and access times, as well as, where applicable, master and contact data (name, address, telephone number, e-mail address), contract data, and location data.

(3) The use of the chatbot and the associated data processing serve to design our website in a manner that is tailored to user interests and customer needs. The processing of data is necessary in order to handle your inquiry and to optimize our services. These purposes also constitute our legitimate interests within the meaning of Article 6(1)(f) GDPR. Insofar as your inquiry relates to an existing contractual relationship or to our offers, the processing of your data is necessary for the performance of a contract or for the implementation of pre-contractual measures carried out at your request pursuant to Article 6(1)(b) GDPR. If you voluntarily provide us with additional personal data when using the chatbot, such processing is based on your consent in accordance with Article 6(1)(a) GDPR.

(4) In order to ensure the data protection–compliant processing of your personal data, we have concluded a data processing agreement with Bots4You GmbH. The personal data are processed exclusively within the European Union (EU) or the European Economic Area (EEA). No data are transferred to third countries.

(5) The personal data are deleted as soon as the purpose of the processing no longer applies or a prescribed retention period expires, unless further storage of the personal data is required for the conclusion or performance of a contract. You are not obliged to provide your personal data.

(6) Cookies are set when using the chatbot and are stored for a duration of one month. These cookies are technically necessary to provide the service, as they enable the system to recognize your session and reconnect your inquiries with previously provided information.

6. Profihost

(1) For the hosting and technical provision of our website, we use the services of Profihost GmbH, Expo Plaza 1, 30539 Hannover, Germany (hereinafter referred to as "Profihost"). Profihost provides the server infrastructure on which our website is operated.

(2) In the context of website usage, Profihost processes the following data on our behalf: access data (e.g., IP address, date and time of the request, requested file, data volume transferred, notification of successful retrieval, browser type and version, operating system), technical data required for providing the website content, and, if applicable, email communication if conducted via the hosting platform.

(3) Data processing is based on Art. 6(1)(f) GDPR (our legitimate interest in the secure, stable, and efficient operation of our website) and Art. 6(1)(b) GDPR (fulfillment of pre-contractual or contractual obligations, e.g., when using contact forms or other interactive features).

(4) We have entered into a data processing agreement with Profihost in accordance with Art. 28 GDPR. Data is processed exclusively on servers within the EU or EEA.

(5) For more information on data protection at Profihost, please visit:
https://www.profihost.com/datenschutz

7. Use of Mapbox (Map Display via Amazon Web Services)

(1) We use the mapping service Mapbox, provided by Mapbox Inc., 740 15th Street NW, 5th Floor, Washington, D.C. 20005, USA, on our website to display interactive maps and provide geographic information.

(2) When you access a page that includes an embedded Mapbox map, a direct connection to Mapbox servers (hosted via Amazon Web Services – AWS) is established. In this process, personal data such as your IP address, device information (e.g., operating system, browser type), communication data, and – when actively using mapping features (e.g., route planning) – also address data, may be processed. Additionally, a cookie may be stored on your device.

(3) Data processing, in particular the placement of cookies, is based on your consent in accordance with Art. 6(1)(a) GDPR. You can withdraw your consent at any time with effect for the future, without affecting the lawfulness of processing carried out prior to withdrawal.

(4) Mapbox may transfer processed data to the United States. To safeguard such third-country transfers, Mapbox states that it relies on the EU Standard Contractual Clauses adopted by the European Commission.

(5) For more information, please refer to Mapbox's privacy policy:
https://www.mapbox.com/legal/privacy

8. Google Maps

(1) We use the Google Maps mapping service on our website to make it easier for you to find our location.
The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

(2) When accessing a page with embedded Google Maps content, information about your use of the service is transmitted to Google servers and stored there. If you are logged into your Google account, this data may also be linked to your profile. Google may place cookies or use similar tracking technologies during this process.

(3) The use of Google Maps is based on your consent in accordance with Art. 6(1)(a) GDPR, provided you have given such consent when visiting the site.

(4) Data processing may also take place on servers in the United States. Google is certified under the EU-U.S. Data Privacy Framework, which ensures an adequate level of data protection.

(5) For more information on how Google processes personal data, please refer to Google's privacy policy:
https://policies.google.com/privacy?hl=en

9. AWS (Amazon Web Services)

(1) We use the hosting services of Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg (hereinafter referred to as "Amazon") for hosting our website.

(2) We have concluded a data processing agreement with Amazon in accordance with the applicable data protection regulations.

(3) Further information is available at:
https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation1.pdf
and
https://aws.amazon.com/de/compliance/data-privacy-faq

10. Cloudflare Turnstile

We use Cloudflare Turnstile, a service provided by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA (hereinafter referred to as "Cloudflare"), on our website. This service helps us protect our website from malicious bot attacks and ensures its availability without requiring visitors to complete CAPTCHA tasks to verify that they are human.

Cloudflare collects and analyzes data such as IP address, headers, user-agent, browser information, and session data (e.g., session duration and website interactions) through Turnstile in order to determine whether the visitor is a human or a bot.

This data processing is based on Art. 6(1)(f) GDPR. We have a legitimate interest in protecting our website from malicious attacks and ensuring its proper functionality.

You can find Cloudflare’s privacy policy at:
https://www.cloudflare.com/de-de/privacypolicy

11. Microsoft Advertising (Bing)

(1) We use Microsoft Advertising, an online advertising program by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland (hereinafter "Microsoft"), which enables us to display advertisements in search engines such as Bing, Yahoo!, or MSN when users enter certain search terms (keyword targeting).

(2) Additionally, targeted advertisements may be shown based on user data held by Microsoft (e.g., location data and interests) (audience targeting). As part of remarketing, we can address you with advertisements outside of our website after you have visited it. We can quantitatively evaluate this data by analyzing, for example, which search terms triggered our ads and how many ads resulted in clicks (conversion tracking). Besides using cookies, data such as IP address, browser and device information, pages visited, and session duration are processed.

(3) Data processing, especially the placement of cookies, is based on your consent under Art. 6(1)(a) GDPR. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal.

(4) Microsoft's privacy statement can be found here:
https://privacy.microsoft.com/en-us/privacystatement

12. Google Analytics for Firebase

(1) We use Google Analytics for Firebase, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, in our app. Google Analytics for Firebase allows us to analyze how users interact with our app and helps us to optimize and improve user experience.

(2) Google Analytics for Firebase collects app interactions (e.g., clicks, app executions, app starts, session duration, views and clicks on in-app ads, updates) and user properties (e.g., age group, country, city, language settings, device characteristics, app version) together with a randomly generated app instance ID to identify each app installation and the advertising ID of the device (Android & iOS).

(3) Data processing is based on your consent under Art. 6(1)(a) GDPR. You can withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

(4) Google's privacy policy can be found here: https://policies.google.com/privacy?hl=en

13. ChatGPT

(1) We use an AI-supported solution on our website. For this purpose, we integrate the ChatGPT service, an AI-based text generation tool provided by OpenAI, 3180 18th St, San Francisco, CA 94110, USA. By using this service, personal data may be processed in the form of user-generated text input.

(2) Data processing is based on Art. 6(1)(b) GDPR, insofar as it is necessary for the performance of a contract or pre-contractual measures under our terms of use. In other cases, data processing may be based on our legitimate interests pursuant to Art. 6(1)(f) GDPR. Data is only transmitted to OpenAI if you actively submit input.

(3) OpenAI may process data in the United States. To ensure an adequate level of data protection, we have concluded EU Standard Contractual Clauses with OpenAI.

(4) For more information on how OpenAI processes personal data, please refer to their privacy policy: https://openai.com/privacy

14. HeyGen

(1) We use the service HeyGen, offered by HeyGen Inc., 123 Innovation Drive, San Francisco, CA 94107, USA, to generate AI-created videos. This involves the processing of video and text data to create personalized video responses.

(2) Data processing is based on Art. 6(1)(b) GDPR (performance of a contract), or on our legitimate interests pursuant to Art. 6(1)(f) GDPR, for example to optimize our communication and marketing activities. If you voluntarily provide personal data to be used in a video, processing may also be based on your consent pursuant to Art. 6(1)(a) GDPR.

(3) Data may be stored and processed on servers in the United States. To ensure an adequate level of data protection, we have concluded EU Standard Contractual Clauses with HeyGen in accordance with Art. 46(2)(c) GDPR.

(4) For more information on data processing by HeyGen, please see their privacy policy:
https://www.heygen.com/privacy

15. Vimeo

(1) As part of our AI-based solution, we embed videos from the Vimeo platform, operated by Vimeo Inc., 555 West 18th Street, New York, NY 10011, USA. When you play a Vimeo video on our website, connection data (e.g., IP address, browser information) is transmitted to Vimeo.

(2) Data processing is based on your consent pursuant to Art. 6(1)(a) GDPR. You may withdraw your consent at any time with future effect, without affecting the lawfulness of processing carried out prior to withdrawal.

(3) Vimeo may transfer personal data to the United States. Vimeo is certified under the EU-U.S. Data Privacy Framework, so data transfers are based on the adequacy decision of the European Commission pursuant to Art. 45 GDPR.

(4) For more information on data processing by Vimeo, please refer to their privacy policy: https://vimeo.com/privacy

16. Use of Microsoft Clarity

(1) We use Microsoft Clarity, a web analytics tool provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Clarity allows us to analyze user interactions such as mouse movements, clicks, and scrolling behavior in order to improve the usability of our website. The data processed may include personal information such as IP address, browser details, device type, and user behavior.

(2) Data processing is based on your consent pursuant to Art. 6(1)(a) GDPR. You may withdraw your consent at any time with future effect, without affecting the lawfulness of the processing carried out prior to withdrawal.

(3) To safeguard data transfers to third countries, particularly the United States, Microsoft uses the EU Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. Additionally, Microsoft is certified under the EU-U.S. Data Privacy Framework, ensuring an adequate level of data protection in accordance with Art. 45 GDPR.

(4) For more information on how Microsoft Clarity processes personal data, please visit:
https://privacy.microsoft.com/en-us/privacystatement

 

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