Information on the Basic Data Protection Regulation
For information on compliance with the General Data Protection Regulation (GDPR), you will find here a general description of the technical and organizational measures taken, an explanation of the most important principles, and a list of the order processors with whom Balu AI GmbH works.
Last modified: April 20, 2020
I. Name and address of the person responsible
The responsible party within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:
balu.ai and other subdomains are the property of.
Zelos Ventures GmbH, registered office Wormser Str. 47, 50677 Cologne, Germany,
Cologne Local Court HRB 103075.
Wormser Str. 47
D – 50677 Cologne
Phone number: +49-221-51 11 75
E-mail address: email@example.com
Managing Director: Gil Osammor
II. Name and address of the data protection officer
The data protection officer of the responsible party is:
Am Volkspark 1, 50321 Brühl, Germany
Tel.: 02232 1515126
III General use of the website
1. scope of the processing of personal data
As a matter of principle, we process personal data of our users only to the extent necessary to provide a functional website and our content and services. The processing of personal data of our users is regularly carried out only with the consent of the user. An exception applies in those cases where obtaining prior consent is not possible for factual reasons and the processing of the data is permitted by legal regulations.
In general, we only collect personal information from users of our website in connection with inquiries about our services, e.g. via the „Contact“ page or the „Online Check“. As a „Balu“ customer, you will also receive access to your personal Balu dashboard and user account via a log-in on our website. In the user account, your personal information is stored and used by us only to the extent necessary to provide you with the contracted services and to organize and manage our contractual relationship. In addition to the data mentioned above, this information may include: Your home/business address; Your home/business landline or mobile phone number; Your password and username of your choice; Your payment information; Your date of birth; Any other information you provide to us, for example, for publication in search engines, online directory media and social networks; Details of the Balu services you have purchased. If you send us an email in connection with an inquiry about a job opportunity on our „Careers“ page, we may store your Personal Information associated with such inquiry, including, for example: Your educational information; Your work experience; Your career history; Your job-related preferences.
When you contact us (e.g., via contact form or email), we store your information to process the inquiry and in case follow-up questions arise. We only store and use further personal data if you consent to this or if this is legally permissible without special consent.
2. legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 (1) lit. a EU General Data Protection Regulation (DSGVO) serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
Insofar as processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 (1) lit. c DSGVO serves as the legal basis.
In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) lit. f DSGVO serves as the legal basis for the processing.
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3. data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may take place beyond this if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
IV. Provision of the website and creation of log files
1. description and scope of data processing
Each time our website is called up, our system automatically records data and information from the computer system of the calling computer.
When calling up our website https://balu.ai., information is automatically sent to the server of our website by the browser used on your end device. This information is temporarily stored in a so-called log file. The following information is collected without your intervention and stored until automated deletion:
IP address of the requesting computer,
Date and time of access,
Name and URL of the accessed file,
website from which the access was made (referrer URL),
browser used and, if applicable, the operating system of your computer and the name of your access provider.
2. legal basis for data processing
The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f DSGVO.
3. purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.
In these purposes also lies our legitimate interest in data processing according to Art. 6 para. 1 lit. f DSGVO.
4 Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
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5. possibility of objection and removal
The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
a) Description and scope of data processing
However, cookies allow you to use some of the features on our website, so we recommend that you leave the cookie function turned on.
b) Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 (1) lit. f DSGVO.
c) Purpose of data processing
In these purposes also lies our legitimate interest in the processing of personal data according to Art. 6 para. 1 lit. f DSGVO.
d) Duration of storage, possibility of objection and elimination
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e) Third-party cookies
You can block cookies by making the appropriate setting in your browser and prohibiting the setting of certain or all cookies. However, if you block all cookies (including Essential Cookies) via your browser settings, you may not be able to access our website or parts of it.
1. scope of processing of personal data
We use the open source software tool Matomo (formerly PIWIK) on our website to analyze the surfing behavior of our users. The software sets a cookie on the user’s computer (for cookies, see already above). If individual pages of our website are called up, the following data is stored:
(1) Two bytes of the IP address of the user’s calling system.
(2) The web page called up
(3) The website from which the user accessed the accessed website (referrer)
(4) The subpages that are accessed from the accessed website
(5) The length of time spent on the website
(6) The frequency with which the web page is accessed
The software runs exclusively on the servers of our website. A storage of the personal data of the users takes place only there. The data is not passed on to third parties.
2 Google Analytics and Heap Analytics
We use the Pardot Marketing Automation System („Pardot MAS“), a special software for recording and evaluating the use of a website by website visitors and for sending newsletters.
When you visit this website, Pardot MAS records your click path and uses it to create an individual usage profile using a pseudonym. For this purpose, cookies are used that allow your browser to be recognized.
You can deactivate the creation of pseudonymized usage profiles at any time by configuring your Internet browser so that cookies from the domain „pardot.com“ are not accepted. However, this may lead to certain restrictions in the functions and user-friendliness of our offer.
6 Google Ads
We use the offer of Google Ads Conversion to draw attention to our attractive offers with the help of advertising media (so-called Google Ads) on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. In this way, we pursue the interest of displaying advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.
These advertisements are delivered by Google via so-called „ad servers“. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as display of the ads or clicks by users, can be measured. If you access our website via a Google ad, Google Ads will store a cookie on your end device. These cookies usually lose their validity after 30 days and are not intended to identify you personally. For this cookie, the unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values.
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 that page. A different cookie is assigned to each Ads customer. Cookies can therefore not be tracked across Ads customers‘ websites. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can see which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising tools; in particular, we cannot identify users on the basis of this information.
Due to the marketing tools used, your browser automatically establishes a direct connection with 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: Through the integration of Ads Conversion, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. 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, there is a possibility that the provider learns your IP address and stores it.
We also use the remarketing function within the Google Ads service. With the remarketing function, we can present users of our website with advertisements based on their interests on other websites within the Google advertising network (in Google Search or on YouTube, so-called „Google Ads“ or on other websites). For this purpose, the interaction of the users on our website is analyzed, e.g. which offers the user was interested in, in order to be able to display targeted advertising to the users on other sites even after they have visited our website. For this purpose, Google stores a number in the browsers of users who visit certain Google services or websites in the Google display network. This number, known as a „cookie“, is used to record the visits of these users. This number is used to uniquely identify a web browser on a particular end device and not to identify a person; personal data is not stored.
You can prevent participation in this tracking procedure in various ways:
(a) by setting your browser software accordingly; in particular, the suppression of third-party cookies will result in you not receiving ads from third-party providers;
b) by installing the plug-in provided by Google at the following link: https://www.google.com/settings/ads/plugin;
c) by disabling the interest-based ads of the providers that are part of the self-regulatory campaign „About Ads“ at the link http://www.aboutads.info/choices, this setting being deleted when you delete your cookies;
d) by permanent deactivation in your browsers Firefox, Internetexplorer or Google Chrome at the link http://www.google.com/settings/ads/plugin,
e) by means of appropriate cookie setting. We point out that in this case you may not be able to use all features of this offer in full.
Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org.
Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
VII Legal basis for the processing of personal data
The legal basis for the processing of users‘ personal data is Art. 6 (1) lit. f DSGVO.
VIII Purpose of the data processing
The processing of the users‘ personal data enables us to analyze the surfing behavior of our users. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. In these purposes also lies our legitimate interest in processing the data in accordance with Art. 6 para. 1 lit. f DSGVO. By anonymizing the IP address, the interest of users in their personal data protection is sufficiently taken into account.
IX Duration of storage
The data is deleted as soon as it is no longer required for our recording purposes.
X. possibility of objection and removal
XI. social plug-ins from Facebook, Twitter, LinkedIn and Xing
We offer you on our website the possibility of using so-called „social plug-ins“ of the companies:
Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA;
„Tweet“ button by Twitter Inc, 795 Folsom St, Suite 600, San Francisco, CA 94107, USA;
„Recommended button“ by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA;
„Share button“ by XING AG, Gänsemarkt 43, 20354 Hamburg, Germany.
In this case, the plugins are only displayed on the website as a graphic that contains a link to the corresponding website of the plugin provider. By clicking on the graphic, you are thus redirected to the respective services of the providers. Only then will your data be sent to the respective services. Unless you click on the graphic, no exchange of any kind takes place between you and the aforementioned social networks.
Within our website, we also use the „tracking pixel“ of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA („Facebook“). This pixel can be used to track the behavior of users after they have been redirected to our website by clicking on a Facebook ad. This allows us to record the effectiveness of the Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, which means that we do not see the personal data of individual users. However, this data is stored and processed by Facebook, about which we inform you according to our level of knowledge.
Facebook may link this data to your Facebook account and also use it for its own advertising purposes, in accordance with Facebook’s Data Use Policy https://www.facebook.com/about/privacy/.
You have the option to prohibit Facebook and its partners from displaying advertisements. You can edit the settings for Facebook’s ads at the following link: https://www.facebook.com/ads/website_custom_audiences/..
XII Rights of the data subject
If personal data is processed by you, you are a data subject within the meaning of the GDPR and you are entitled to the following rights against the controller:
1. right to information
You may request confirmation from the controller as to whether personal data concerning you are being processed by us.
If such processing is taking place, you may request information from the controller about the following:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information on the origin of the data, if the personal data are not collected from the data subject;
(8) the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.
2. right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
3. right to restriction of processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
(3) the controller no longer needs the personal data for the purposes of processing, but you need it for the establishment, exercise or defense of legal claims; or
(4) if you have objected to the processing pursuant to Article 21(1) DSGVO and it has not yet been determined whether the controller’s legitimate grounds override your grounds.
Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4. right to erasure
a) Obligation to erasure
You may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay, if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) DSGVO and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
(4) The personal data concerning you have been processed unlawfully.
(5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you was collected in relation to information society services offered pursuant to Article 8(1) DSGVO.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
The right to erasure does not exist to the extent that the processing is necessary
(1) for the exercise of the right to freedom of expression and information; (2) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Article 89(1) DSGVO, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
(5) for the assertion, exercise or defense of legal claims.
5. right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right against the controller to be informed about these recipients.
6. right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that.
(1) the processing is based on consent pursuant to Art. 6(1)(a) DSGVO or Art. 9(2)(a) DSGVO or on a contract pursuant to Art. 6(1)(b) DSGVO and
(2) the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
8. right to revoke the declaration of consent under data protection law.
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9. automated decision in individual cases including profiling.
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is permitted by legal provisions of the Union or the Member States to which the controller is subject and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests; or
(3) is made with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests. With regard to the cases mentioned in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, which include, at a minimum, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
10. right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
Status: April 2020