Privacy Policy

This privacy policy informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offering and the associated websites, functions and contents as well as external online presences, such as our social media profiles (hereinafter jointly referred to as “online offering”). With regard to the terms used, such as “processing” or “controller”, we refer you to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Data controller

Julia Lee / Palais 22 GmbH
Kennedyallee 70a,
60596 Frankfurt am Main, Germany
Email address: info@palais22.com
Owner-manager: Clemens Hummel
Link to Legal Notice

Types of processed data

– Inventory data (e.g., personal master data, names or addresses)

– Contact data (e.g., email, telephone numbers)

– Content data (e.g., text entries, photographs, videos)

– Usage data (e.g., websites visited, interest in content, access times)

– Meta/communication data (e.g., device information, IP addresses) 

Categories of data subjects

Visitors and users of the online offer (hereinafter referred to collectively as “users”).

Purpose of processing

– Provision of the online offer, its functions and contents

– Responses to contact requests and general communication with users

– Security measures

– Range measurement/marketing

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”). A natural person is regarded as identifiable if such person 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 (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations carried out with or without the aid of automated processes and involving personal data. The term is broad and covers practically every handling of data.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is filed separately and is subject to technical and organizational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.

The “controller” is the natural or legal person, public authority, institution or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

The “processor” is a natural or legal person, public authority, institution or other body which processes personal data on behalf of the controller.

Applicable legal bases

In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. For users from the area of application of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies, if the legal basis is not mentioned in the privacy policy:

The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR.
The legal basis for the processing for the fulfilment of our services and the implementation of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b GDPR.
The legal basis for the processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR.

The legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data is Art. 6 para. 1 lit. d GDPR.

The legal basis for the processing necessary for the performance of a task which is in the public interest or is carried out in the exercise of official authority entrusted to the data controller is Art. 6 para. 1 lit. e GDPR.

The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.

The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 (4) GDPR.

The processing of special categories of data (in accordance with Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.

Security precautions

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, extent, circumstances and purposes of the processing, as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

In particular, these measures include safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data as well as access to, entry, transfer, securing availability and separation of such data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and the response to security threats concerning data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and privacy-friendly default settings.

Cooperation with contract processors, joint controllers and third parties 

Insofar as we disclose data to other persons and companies (contract processors, joint controllers or third parties) within the scope of our processing, transfer data to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a data transfer to third parties, such as payment service providers, is necessary for the fulfilment of the contract), user consent, a legal obligation that provides for this or our legitimate interests (e.g. when using agents, web hosting services, etc.).

Insofar as we disclose, transfer or otherwise grant access to data to other companies of our group of companies, these activities are handled in particular for administrative purposes on the basis of a legitimate interest and beyond that on a basis corresponding to the legal requirements.

Transfer to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this will only occur to fulfil our (pre-)contractual obligations, on the basis of the user’s consent, a legal obligation or our legitimate interests. Subject to legal or contractual permissions, we process data or have data processed in a third country only if the legal requirements are met. I.e. the processing takes place e.g. on the basis of special guarantees, like the officially recognized statement of a data protection level corresponding to the EU (e.g., Privacy Shield in the USA) or the observance of officially recognized special contractual obligations.

Rights of data subjects

You have the right to obtain confirmation as to whether the data in question will be processed and to be informed of such data and to obtain further information and a copy of the data in accordance with the sttatutory provisions.

You have the right, in accordance with the statutory provisions, to request the completion of your personal data or the correction of incorrect data concerning you.

In accordance with the statutory provisions, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.

You have the right to request the personal data that you have provided to us in accordance with the statutory provisions and to request that such data be transferred to other controllers.

You also have the right to file a complaint with the competent supervisory authority in accordance with the statutory provisions.

Right of withdrawal

You have the right to revoke consent given with effect for the future.

Right of objection

You may object at any time to the future processing of your personal data in accordance with the statutory provisions. In particular, you may object to the processing of your data for the purposes of direct marketing.

Cookies and right to object to direct advertising

“Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user’s visit to an online service. Temporary cookies, or “session (transient) cookies”, are cookies that are deleted after users leave an online presence and close their browser. Such cookies can store, for example, the content of a shopping basket in an online shop or a login status. Cookies are referred to as “permanent” or “persistent” if they remain stored even after the browser has been closed. For example, the login status can be saved if users visit a website after several days. Such cookies can also store the interests of the users, which are used for range measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller for operating the online service (otherwise, if they are only the latter’s cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and notify you thereof in our privacy policy.

If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the browser settings. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be raised for a large number of services, particularly in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. In addition, cookies can be switched off in the browser settings. Please note that in this case it may not be possible to use all functions of this online offering.

Deletion of data

The data processed by us will be deleted in accordance with the statutory provisions or their processing will be restricted. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them.

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or fiscal reasons.

Changes and updates to the privacy policy 

We ask you to inform yourself regularly about the contents of our privacy policy. We will adapt the privacy policy whenever changes to the data processing carried out by us may make adaptations necessary. We will inform you if changes require your cooperation (e.g. consent) or any other individual notification.

Business-related processing

In addition, we process

– Contract data (e.g., subject matter of the contract, duration, customer category)

– Payment data (e.g., bank details, payment history)

of our customers, interested parties and business partners for the purpose of providing contractual services and customer services, marketing, advertising and market research.

Google Tag Manager

Google Tag Manager is a solution that allows us to manage website tags via an interface (and thus integrate, for example, Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users’ personal data, reference is made to the following information on Google services. 

Terms of use: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google AdSense with personalized ads

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 9404, Mountain View, CA 9404 ((“Google”) on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering in accordance with Art. 6 Para. 1 lit. f. GDPR). 

Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). 

We use the AdSense service to display ads on our website and receive a remuneration for the display or other use of these ads. For these purposes, usage data such as a click on an advertisement and the IP address of the relevant user are processed. In doing so, the IP address is shortened by the last two digits. For this reason, only anonymized user data is processed.

We use AdSense with personalized ads. Google uses information based on websites or apps users visit and the user profiles they create to draw conclusions about users’ interests. Advertisers use this information to tailor their campaigns to those interests, which is beneficial to both users and advertisers. For Google, ads are personalized when data collected or known determines or influences the selection of ads. This includes, but is not limited to, past searches, activities, site visits, use of apps, demographics and location information. Specifically, this includes demographic targeting, targeting to interest categories, remarketing and targeting to match lists and target audience lists uploaded to DoubleClick Bid Manager or Campaign Manager.

For more information about Google’s use of data, settings and opt-out preferences, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for Google’s ad displays (https://adssettings.google.com/authenticated).

Google AdWords and conversion measurement

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 9404, Mountain View, CA 9404 ((“Google”) on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering in accordance with Art. 6 Para. 1 lit. f. GDPR). 

Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). 

We use the Google AdWords online marketing process to place ads on the Google Advertising Network (e.g., in search results, videos, websites, etc.) so that they are displayed to users who may have an interest in the ads. This allows us to display ads for and within our online offerings in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which they have shown an interested in other online offerings, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are called up, a Google code is executed directly by Google and (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, what content the user is interested in and what offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visit times and other information on the use of the online service.

We also receive an individual “conversion cookie”. The information collected through the cookie is used by Google to generate conversion statistics for us. However, we are only informed about the anonymous total number of users who clicked on our ad and were directed to a page tagged with a conversion tracking tag. However, we do not receive information that personally identifies individual users.

User data is processed anonymously within the Google Advertising Network. This means, for example, that Google does not store and process the user’s name or e-mail address, but processes the relevant data cookie-related in anonymized user profiles. Consequently, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without anonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.

For more information about Google’s use of data, settings and opt-out preferences, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for Google’s ad displays (https://adssettings.google.com/authenticated).

Jetpack (WordPress Stats)

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering in accordance with Art. 6 para. 1 lit. f. GDPR), we use the Jetpack plug-in (in particular the sub-function “WordPress Stats”), which includes a tool for the statistical evaluation of visitor access by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack 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 online service is stored on a server in the USA. User profiles of the users can be created from the processed data. These are only used for analysis and not for advertising purposes. Further information can be found in Automattic’s privacy policy: https://automattic.com/privacy/ and information on Jetpack cookies: https://jetpack.com/support/cookies/.