Privacy Policy | BrokerFlat

We are delighted about your interest in our services and take your privacy very seriously. This data protection policy sets out and explains the nature, scope and purpose of the processing of personal data ("data") through the services and presence of BrokerFlat LLC (hereinafter "BF" or "we" or "us" or "company") and the related websites (e.g., www.brokerflat.com or social/business network websites), features, content, business processes and external offline and online services (all of which are referred to herein as "service(s)").

BF does not target clients in EU/EWR. Irrespective of this, for website visitors/clients/users for whom European Union law is applicable, this Privacy Policy, the GDPR itself and the following legal references to the provisions of the GDPR apply. Regarding the legal terms used, reference should be made, in particular, to the definitions in Art. 4 of the GDPR (General Data Protection Regulation).

For all other users, this Privacy Policy applies without the applicability of the GDPR and without the respective reference to the GDPR in the following statement in a corresponding manner and as far as it is legally required and applicable for these users.

Categories of Affected Persons (Data Subjects)

Users, visitors, interested parties, clients and business partners of BF's services (in this policy all categories are referred to as "users").

Categories of Processed Data

Inventory data (e.g., name, postal address), contact details (e.g., email address, telephone number), identity details, content data (e.g., submitted or transmitted texts, photographs, videos or other content), usage data (e.g., visited websites, content-related interests, time and duration of access), metadata and communication data (e.g., information about accessing devices, type of browser, IP addresses).

As well as business-related processing: contract data (e.g., commencement of contract, duration, subject matter of the contract, preferred means of communication), payment details (bank details, currency, payment history).

Purposes of Data Processing

Provision, maintenance and optimization of the services including their functions and content
Answering contact and support requests and communicating with users
Security and integrity
Marketing and determination of reach
Additional business-related contract fulfilment, provision of services, customer care as well as marketing, advertising and market research

Legal Bases and Terms

In accordance with the requirements of Art. 13 GDPR, we are informing you of the legal bases of our data processing. If the legal basis is not mentioned in this data protection policy, the following applies:

As far as permissible, BF uses the data processing of cookies and so-called tracking (analysis of visitor behavior, measurement of reach, among other things) regarding the users, in return for the services we provide free of charge, including support.

The legal basis for obtaining consent is Art. 6 (1)(a) and Art. 7 GDPR, the legal basis for the processing of data for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1)(b) GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, such as in cases of inquiries about our services or the utilization of the test phases. The legal basis for processing to comply with our legal obligations is Art. 6 (1)(c) GDPR, the legal basis for processing in order to protect our legitimate interests is Art. 6 (1)(f) GDPR. Art. 6 (1)(d) GDPR serves as the legal basis in the case of essential interests of the affected person or of another natural person as a necessity for the processing of personal data.

Key Definitions

Responsible: the natural or juridical person, authority, agency or other body that, alone or together with others, decides on the purposes and means of processing personal data.
Third-party: a natural or juridical person, authority, agency or body other than the affected person, the responsible person, the order processor and the persons authorized under the direct responsibility of the responsible person or the order processor, to process the personal data.
Personal data: all information that is about an identified or identifiable natural person.
Processing: any process or series of operations related to personal data carried out with or without the assistance of automated processes.
Profiling: all kinds of automated processing of personal data which consists of using that personal data to evaluate certain personal aspects about a natural person.
Pseudonymization: the processing of personal data in such a manner that personal data can no longer be ascribed to a specific data subject without the need for additional information.
Order processor: a natural or juridical person, authority, agency or other body that processes personal data on behalf of the responsible person.
Consent: a voluntary statement from the affected person, in an informed and unequivocal manner, expressing that this person agrees to the processing of the personal data concerning him/her.

Affected Persons (Data Subjects) Have the Right...

...to revoke their consent according to Art. 7 (3) GDPR with effect in the future (right of revocation).
...to contradict to future processing of the data concerning them according to Art. 21 GDPR at any time (right of contradiction).
...to request a confirmation as to whether relevant data is being processed and to information about this data, as well as to further information and a copy of the data in accordance with Art. 15 GDPR.
...to demand the completion of the data concerning them or the correction of the incorrect data, in accordance with Art. 16 GDPR.
...to demand that relevant data be deleted immediately according to Art. 17 GDPR or, alternatively, to demand limitation of the data being processed.
...to demand that the data about you, which you provided to us, be obtained in accordance with Art. 20 GDPR and to request the transmission thereof to other responsible persons.
...to make a complaint with the responsible supervisory authority pursuant to Art. 77 GDPR.

Duration of Storage, Deletion of Data

The data processed by us is deleted or limited in accordance with Art. 17 and Art. 18 GDPR. Unless expressly stated in this data protection policy, the data stored by us is deleted as soon as it is no longer necessary for its purpose and the deletion does not conflict with any statutory storage requirements.

Externals and Transfer/Transmission to Third Countries

If we disclose data to external persons or companies (order processors or third parties), transmit data to third parties or otherwise grant others access to the data, then only on the basis of juridical consent, if the affected person has given his/her consent, if there is a legal obligation to do so or if it is based on our legitimate interests.

If we process data outside of the European Union (EU) or the European Economic Area (EEA), or if we utilize third-party services, this will only be done if it is necessary to fulfil our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or if it is justified based on our legitimate interests.

Contractual Relationships

BF enters a manifold of contractual relationships and pre-contractual relationships. We process the data of our contractual partners in accordance with Art. 6 (1)(b) GDPR to fulfil our contractual or pre-contractual services.

The processed data includes the master data of the contractual partner (i.e. name, address), contact details (i.e. address, email address, telephone number), as well as contract data (i.e. services utilized, content of the contract, contractual communication, name of a contact person) and payment data (bank details, payment history, etc.).

Hosting, Log Files, Email Dispatch

The hosting services we utilize are necessary to provide the following services: infrastructure and application services, computing and storage capacity, database services, email dispatch, as well as security and technical maintenance services. Our website is hosted by Amazon Web Service (AWS).

We or our hosting provider, collect(s) data based on legitimate interests about every access to the server (so-called server log files). Access data includes the name of the visited website, file, date and time of visit, amount of data transferred, browser type and version, user's operating system, referrer URL, IP address and the requested provider. Log file information is stored for a maximum of 7 days and deleted thereafter.

Registration Function, Verification

Users may have the possibility to create an account. Upon registration, the required mandatory information is communicated to users and processed based on Art. 6 (1)(b) GDPR. The processed data includes, in particular, the login information (email address, password, country).

The users can be informed by email about information that is related to their account or the booked service. As soon as users have cancelled their account, or the term has expired, their data concerning the account will be deleted, subject to legal storage obligations.

Establishing Contact

When contacting us (e.g., by contact form, email, telephone or on social networks), the user's information is processed for the purpose of processing the request. User information can be stored in a Customer Relationship Management (CRM) system. We delete the contact inquiries when it is no longer necessary to keep them and check the necessity every two years.

By subscribing to our newsletter, you consent to the receipt and the procedures described below.

Content of the Newsletter

We only send newsletters, emails and other electronic notifications with advertising information with the consent of the recipient or legal permission.

Double Opt-In and Logging

Registration for our newsletter is made using the double-opt-in method, if legally necessary. After registration, an email is sent asking for confirmation of the registration.

Performance Measurement

The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients in accordance with Art. 6 (1)(a) and Art. 7 GDPR.

Termination or Revocation

You can cancel the receipt of our newsletter at any time, in other words, revoke your consent. An unsubscribe link to cancel the newsletter can be found at the end of every newsletter.

Cookies and Right to Contradict Direct Advertising

A cookie is a small file that is stored on a user's computer. We can use temporary and permanent cookies. If users do not want cookies to be stored on their computers, they can use the appropriate option in the system settings of the browser to disable this process.

A general objection to the use of cookies used for online marketing can be declared via the US-American website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/.

Use of Third-Party Services and Contents

Within our service, based on our legitimate interests in the analysis, optimization and economic operation of our services, we incorporate third-party content or service offers. This always presupposes that the third-party providers of this content detect the IP addresses of the users.

Social Networks and Business Platforms

We are present on social networks and platforms to communicate with (potential) clients, interested parties, business partners and users, and to inform them about our services there.

The processing of users' personal data takes place in accordance with our legitimate interests in effectively informing users and communicating with users in accordance with Art. 6 (1)(f) GDPR.

Protection and Security Measures

In accordance with Art. 32 GDPR, BF considers the currency of technology, the costs of implementation, and the type, scope, circumstances and purposes of processing, and appropriate technical and organizational measures to ensure a level of protection appropriate to the risk incurred.

Responsible

BrokerFlat LLC