Privacy Policy

1. Privacy policy overview

General notes

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data are all data by which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.

Data collection on this website

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. Their contact details can be found in the section “Note on the Responsible Body” in this privacy policy.

How do we collect your data?

Your data is collected firstly by you providing it to us. This could be data that you enter into a contact form, for example.

Other data is automatically collected by our IT systems when you visit the website, either automatically or with your consent. This is primarily technical data (e.g., internet browser, operating system, or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the website is provided without errors. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient, and purpose of your stored personal data. You also have the right to demand the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. In addition, you have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time for further questions on the topic of data protection.

Analytics tools and third-party tools

When visiting this website, your surfing behavior can be statistically evaluated. This is mainly done with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

2. Hosting

We host the contents of our website with the following provider:

Hetzner

The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (hereinafter referred to as Hetzner).

Details can be found in Hetzner’s privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz.

The use of Hetzner is based on Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in the most reliable possible presentation of our website. If a corresponding consent was requested, the processing is exclusively based on Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) in the sense of the TTDSG. The consent can be revoked at any time.

Order processing

We have concluded a contract for order processing (AVV) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the DSGVO.

3. General notes and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations as well as this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We point out that data transmission over the Internet (e.g., when communicating by email) can have security gaps. A complete protection of data from access by third parties is not possible.

Note on the responsible body

The responsible body for data processing on this website is:

Ecoco
Otto-Röhm-Straße 75
64293 Darmstadt

Phone: +49 (0) 151 701 393 02
E-Mail: info@turtails.com

The responsible body is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).

Storage duration

Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, deletion will take place once these reasons no longer apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data based on Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR, if special categories of data according to Art. 9 (1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49 (1) lit. a GDPR. If you have consented to the storage of cookies or to access information in your device (e.g., via device fingerprinting), data processing also takes place based on § 25 (1) TTDSG. Consent can be revoked at any time. If your data is necessary for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data based on Art. 6 (1) lit. b GDPR. Furthermore, we process your data, if this is necessary to fulfill a legal obligation, based on Art. 6 (1) lit. c GDPR. Data processing may also be based on our legitimate interest according to Art. 6 (1) lit. f GDPR. The relevant legal bases applicable in individual cases are informed in the following sections of this privacy policy.

Note on data transfer to the USA and other third countries

We use tools from companies based in the USA or other data protection non-secure third countries. When these tools are active, your personal data may be transferred to these third countries and processed there. We point out that in these countries, a level of data protection comparable to that of the EU cannot be guaranteed. For example, US companies are obliged to hand over personal data to security authorities, without you as the person concerned being able to take legal action against this. Therefore, it cannot be excluded that US authorities (e.g., intelligence services) process, evaluate, and permanently store your data located on US servers for surveillance purposes. We have no influence on these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your explicit consent. You can revoke previously given consent at any time. The legality of data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 (1) LIT. E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED IS TAKEN FROM THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION ACCORDING TO ART. 21 (1) GDPR).

IF YOUR PERSONAL DATA ARE PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING, IN SO FAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL THEN NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION ACCORDING TO ART. 21 (2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In case of infringements of the GDPR, the persons concerned have a right to lodge a complaint with a supervisory authority, especially in the Member State of their habitual residence, place of work or place of the alleged infringement. This right to lodge a complaint is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data, which we process automatically on the basis of your consent or in fulfillment of a contract, handed over to you or a third party in a common, machine-readable format. If you request the direct transfer of data to another responsible party, this will only be done as far as it is technically feasible.

Information, correction, and deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, their origin and recipient, and the purpose of data processing and possibly a right to correct or delete this data. For this, as well as for further questions on the subject of personal data, you can contact us at any time.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restrict processing exists in the following cases:

• If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you need them for the exercise, defense or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection according to Art. 21 (1) GDPR, a balance must be struck between your and our interests. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption

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.

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

4. Data collection on this website

Cookies

Our websites use so-called “cookies”. Cookies are small data packages and do not cause any damage to your device. They are either temporarily stored for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your device until you delete them yourself or an automatic deletion is performed by your web browser.
Cookies can be from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).

Cookies have various functions. Numerous cookies are technically necessary because certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies can be used to evaluate user behavior or for advertising purposes.

Cookies that are required for the electronic communication process, to provide certain functions desired by you (e.g., for the shopping cart function) or to optimize the website (e.g., cookies for measuring the web audience) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless another legal basis is given. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of his services. If consent to the storage of cookies and similar recognition technologies has been requested, processing will only be carried out based on this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG); the consent is revocable at any time.

You can set your browser to inform you about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. When disabling cookies, the functionality of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Browser type and browser version
• Used operating system
• Referrer URL
• Hostname of the accessing computer
• Time of the server request
• IP address

A merger of this data with other data sources is not carried out.

The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – for this, the server log files must be recorded.

Contact form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this was requested; the consent is revocable at any time.

The data you entered in the contact form remain with us until you ask us to delete them, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory statutory provisions – especially retention periods – remain unaffected.

Inquiry by email or phone

When you contact us by email or phone, your inquiry, including all resulting personal data (name, inquiry), is stored and processed by us for the purpose of handling your request. We do not disclose this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of requests directed at us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this was requested; the consent can be revoked at any time.

The data sent to us via contact requests will remain with us until you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Social media

Facebook

This website integrates elements of the social network Facebook. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook, however, the collected data is also transferred to the USA and other third countries.
An overview of the Facebook social media elements can be found here: https://developers.facebook.com/docs/plugins/?locale=en_US.

When the social media element is active, a direct connection is established between your device and the Facebook server. Facebook thereby receives information that you have visited this website with your IP address. If you click the Facebook “Like” button while you are logged into your Facebook account, you can link the content of this website to your Facebook profile. This allows Facebook to associate your visit to this website with your user account. We would like to point out that we, as the provider of these pages, have no knowledge of the content of the transmitted data or their use by Facebook. Further information on this can be found in Facebook’s privacy policy at: https://en-gb.facebook.com/privacy/explanation.

If consent (Consent) was obtained, the use of the aforementioned service is based on Art. 6 para. 1 lit. a GDPR and § 25 TTDSG. The consent can be revoked at any time. If no consent was obtained, the use of the service is based on our legitimate interest in achieving the widest possible visibility on social media.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its transmission to Facebook. The processing carried out by Facebook after forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in an agreement on joint processing. The text of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-safe implementation of the tool on our website. Facebook is responsible for the data security of the Facebook products. Data subject rights (e.g., requests for information) with regard to data processed by Facebook can be asserted directly with Facebook. If you assert the data subject rights with us, we are obliged to forward these to Facebook.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here to next interaction. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 und https://www.facebook.com/policy.php.

Twitter

This website integrates features of the service Twitter. These functions are offered by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

When the social media element is active, a direct connection is established between your device and the Twitter server. Twitter thus receives information about your visit to this website. By using Twitter and the “Re-Tweet” function, the websites you have visited are linked to your Twitter account and made known to other users. We would like to point out that we, as the provider of the pages, do not have any knowledge of the content of the transmitted data or their use by Twitter. For more information, please see Twitter’s privacy policy at: https://twitter.com/de/privacy.

Insofar as consent (Consent) was obtained, the use of the above service is based on Art. 6 Para. 1 lit. a DSGVO and § 25 TTDSG. The consent can be revoked at any time. If no consent was obtained, the service is used on the basis of our legitimate interest in as comprehensive visibility as possible in social media.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html.

You can change your privacy settings on Twitter in the account settings at https://twitter.com/account/settings.

Pinterest

On this website we use elements of the social network Pinterest, which is operated by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

When you access a page that contains such an element, your browser establishes a direct connection to the servers of Pinterest. This social media element transmits log data to the Pinterest server in the USA. This log data may contain your IP address, the address of the websites visited that also contain Pinterest functions, the type and settings of the browser, the date and time of the request, your use of Pinterest, and cookies.

Insofar as consent (Consent) was obtained, the use of the above service is based on Art. 6 Para. 1 lit. a DSGVO and § 25 TTDSG. The consent can be revoked at any time. If no consent was obtained, the service is used on the basis of our legitimate interest in as comprehensive visibility as possible in social media.

Further information on the purpose, scope and further processing and use of the data by Pinterest, as well as your related rights and options for protecting your privacy, can be found in Pinterest’s privacy notices: https://policy.pinterest.com/de/privacy-policy.

6. Analytics tools and advertising

Matomo

This website uses the open-source web analysis service Matomo.

With the help of Matomo, we are able to collect and analyze data on the use of our website by visitors. This allows us to determine when which page views were made and from which region they originate. We also collect various log files (e.g., IP address, referrer, browsers, and operating systems used) and can measure whether our website visitors perform certain actions (e.g., clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

Opt-out complete; your visits to this website will not be recorded by the Web Analytics tool. Note that if you clear your cookies, delete the opt-out cookie, or if you change computers or Web browsers, you will need to perform the opt-out procedure again.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

You are not opted out. Uncheck this box to opt-out. You are currently opted out. Check this box to opt-in.

The tracking opt-out feature requires cookies to be enabled.

IP anonymization

In the analysis with Matomo, we use IP anonymization. In this case, your IP address is shortened before the analysis so that it can no longer be clearly assigned to you.

Cookieless analytics

We have configured Matomo so that Matomo does not store any cookies in your browser.

Hosting

We host Matomo exclusively on our own servers, so all analysis data remains with us and is not passed on.

7. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we need an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. Further data will not be collected or only on a voluntary basis. We use these data exclusively for the dispatch of the requested information and do not pass them on to third parties.
The processing of the data entered into the newsletter subscription form is based solely on your consent (Art. 6 para. 1 lit. a GDPR). The consent to the storage of the data, the email address and their use for sending the newsletter can be revoked at any time, for example via the “unsubscribe” link in the newsletter. The legality of the already completed data processing operations remains unaffected by the revocation.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers or those of the newsletter service provider after you unsubscribe from the newsletter or after the purpose ceases to exist. We reserve the right to delete or block email addresses from our newsletter distribution list at our discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.

Data stored for other purposes with us remain unaffected by this.

After you have unsubscribed from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used solely for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You can object to the storage if your interests outweigh our legitimate interest.

8. Plugins and tools

YouTube with extended privacy

This website integrates videos from the YouTube website. The operator of the pages is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in extended privacy mode. According to YouTube, this mode ensures that YouTube does not store information about visitors to this site before they watch the video. The transfer of data to YouTube partners is not necessarily excluded by the extended privacy mode. Thus, regardless of whether you watch a video, YouTube establishes a connection to the Google DoubleClick network.

As soon as you start a YouTube video on this website, a connection is established to YouTube’s servers. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you allow YouTube to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, YouTube may store various cookies on your device after you start a video, or use comparable recognition technologies (e.g., device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve user-friendliness, and prevent attempts at fraud.

Possibly, further data processing operations can be triggered after the start of a YouTube video, over which we have no influence.

The use of YouTube is in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

For more information about privacy on YouTube, please see their privacy policy at: https://policies.google.com/privacy?hl=en.

Ninja Firewall

We have integrated Ninja Firewall on this website. The provider is NinTechNet Limited, Unit 1603, 16th Floor, The L. Plaza 367 – 375 Queen’s Road Central Sheung Wan, Hong Kong (hereinafter Ninja Firewall).

Ninja Firewall serves to protect our website from unwanted access or malicious cyber attacks. For this purpose, Ninja Firewall records IP address, request, referrer, and time of page access. Ninja Firewall is integrated on our own servers and does not transmit any personal data to the provider of the tool or other third parties.

We have activated IP anonymization at Ninja Firewall, so the tool only collects the IP address in a shortened form.

The use of Ninja Firewall is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the most effective possible protection of his website against cyber attacks.

Source: https://www.e-recht24.de