Privacy policy
Effective Date: Jan 01, 2023
Debtist GmbH ("us", "we", or "our") operates the website [https://www.debtist.com](https://www.debtist.com) (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from [https://www.debtist.com](https://www.debtist.com).
Collection and Use of Information
We collect several different types of information for various purposes to provide and improve our Service to you.
Data Protection Officer
Susan Jung
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Cookies and Usage Data
Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Use of Data
Debtist GmbH uses the collected data for various purposes:
To provide and maintain the Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer care and support
To provide analysis or valuable information so that we can improve the Service
To monitor the usage of the Service
To detect, prevent and address technical issues
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Debtist GmbH will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Legal Requirements
Debtist GmbH may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Debtist GmbH
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: Privacy Policy - Privacy & Terms - Google
Cloudflare
We use the analytics service Cloudflare ("Cloudflare") to ensure the security of our services. The provider is Cloudflare Germany GmbH., Rosental 7 c/o Mindspace, 80331 Munich, Germany.
Cloudflare allows us to collect server log data to detect technical problems at an early stage and to defend against Distributed Denial-of-Service and other attacks. The log data contains IP addresses. The legal basis for this type of data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. The legitimate interests we pursue are, in particular: ensuring the operational security of the system and protecting our offering against possible external attacks.
The use of Cloudflare may require the transfer of your personal data to the USA. The European Court of Justice assesses the USA as a country with an insufficient level of data protection according to EU standards. We have therefore implemented safeguards for the protection of your data by concluding so-called Standard Data Clauses within the meaning of Art. 46 para. 2 lit. c GDPR. For further information on data processing by Cloudflare (including the storage duration of the collected data), please refer to the provider's privacy policy at www.cloudflare.com/de-de/privacypolicy/.
Microsoft Advertising (Bing Ads)
This website uses the "Bing Ads" remarketing function of Microsoft Corporation One Microsoft Way, Redmond, WA 98052-6399, USA. ("Microsoft Advertising"). A cookie is stored on your computer by Microsoft Bing Ads if you have reached our website via a Microsoft Bing ad. This enables Microsoft Bing and us to recognize that someone has clicked on an ad, been redirected to our website, and reached a previously defined target page (conversion page). We only learn the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No personal information about the user's identity is shared.
If you do not want information about your behavior to be used by Microsoft as described above, you can refuse the necessary setting of a cookie - for example, by means of a browser setting that generally deactivates the automatic setting of cookies. You can also prevent the collection of the data generated by the cookie and related to your use of the website and the processing of this data by Microsoft by declaring your objection under the following link: choice.microsoft.com/de-DE/opt-out. Further information on data protection and the cookies used by Microsoft and Bing Ads can be found on the Microsoft website at privacy.microsoft.com/de-de/privacystatement.
Apollo
This website uses Apollo, a business intelligence platform that allows companies using it to receive information that helps them improve their marketing to potential customers. Apollo is a product of ZenLeads, Inc, a US company headquartered at 535 Mission Street, Suite #1100, San Francisco, California, 94105, USA.
Apollo is an integrated software solution that we use to cover various aspects of our online marketing, including lead generation, database expansion, and email marketing.
All data collected by us is subject to this Privacy Policy and is collected based on our legitimate interests (solely for the purpose of optimizing our marketing measures and improving the quality of our website) in accordance with Art. 6 para. 1 lit. f of the GDPR.
For this purpose, we have concluded a Data Processing Agreement with ZenLeads, Inc., in which ZenLeads, Inc. undertakes to process the user data in strict compliance with our instructions and the data protection standards of the European Union.
Further information on Apollo's privacy policy can be found at https://www.apollo.io/privacy/.
Payments
The controller has integrated components from Novalnet AG on this website. Novalnet AG is a full payment service provider that, among other things, handles payment processing. If the data subject selects a payment method during the ordering process in the online shop, the data subject's data is automatically transmitted to Novalnet AG. By selecting a payment option, the data subject consents to this transfer of personal data for the purpose of payment processing.
The personal data transmitted to Novalnet generally includes the first name, last name, address, gender, email address, IP address, and, if applicable, date of birth, telephone number, mobile phone number, as well as other data necessary for payment processing. Personal data related to the respective order is also necessary for the execution of the purchase contract. In particular, payment information such as bank details, card number, expiry date and CVC code, and data on goods and services, and prices may be exchanged reciprocally.
The purpose of the data transfer is, in particular, identity verification, payment administration, and fraud prevention. The controller will only transmit personal data to Novalnet AG if there is a legitimate interest in the transfer. The personal data exchanged between Novalnet AG and the controller may be transmitted by Novalnet AG to credit agencies. This transmission serves the purpose of identity and credit checks.
Novalnet AG also passes on personal data to service providers or subcontractors if this is necessary to fulfil contractual obligations or if the data is to be processed.
The data subject has the option to revoke their consent to the handling of personal data by Novalnet AG at any time. A revocation does not affect personal data that must be processed, used, or transmitted for mandatory (contractual) payment processing.
In the context of this contractual relationship, Debtist transmits personal data collected for the application, execution, and termination of this business relationship to CRIF GmbH, Victor-Gollancz-Straße 5, 76137 Karlsruhe. The legal bases for these transfers are Article 6 (1) (b) and Article 6 (1) (f) of the General Data Protection Regulation (GDPR). Transfers based on Article 6 (1) (f) GDPR may only take place insofar as this is necessary to protect the legitimate interests of Debtist or third parties and does not outweigh the interests or fundamental rights and freedoms of the data subject that require the protection of personal data. The data exchange with CRIF GmbH also serves to fulfil legal obligations for carrying out creditworthiness checks of customers (§§ 505a and 506 of the German Civil Code). CRIF GmbH processes the data received and also uses it to provide its contractual partners in the European Economic Area and Switzerland, and possibly other third countries (if an adequacy decision of the European Commission exists for them), with information, inter alia, for assessing the creditworthiness of natural persons.
Further information on the activities of CRIF GmbH can be found in the CRIF information sheet or viewed online at https://www.crif.de/datenschutz.
Address Determination
For address determination/address verification - in particular for the purpose of debt collection, customer service, and identity verification - we engage EURO-PRO Gesellschaft für Data Processing mbH. Further information on data processing can be found at https://www.europro.de/datenschutz/.
In the context of debt collection, we transmit personal data collected to CRIF GmbH, Leopoldstraße 244, 80807 Munich. The legal bases for this transfer are Article 6 (1) sentence 1 lit. b and lit. f of the General Data Protection Regulation (GDPR). The data exchange with CRIF GmbH also serves to fulfil legal obligations for carrying out creditworthiness checks (§§ 505a and 506 of the German Civil Code). CRIF GmbH processes the data received and also uses it for the purpose of profiling (scoring) to provide its contractual partners in the European Economic Area and Switzerland, and possibly other third countries, with information, inter alia, for assessing the creditworthiness of natural persons. The transfer of personal data to third countries takes place in accordance with Art. 44 ff. GDPR. Further information on the activities of CRIF GmbH can be found in their information sheet or viewed online at https://www.crif.de/datenschutz.
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children's Privacy
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "Effective Date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us via our contact form.
Refund Policy
We stand behind our products and your satisfaction with them is important to us. However, since our products are service-based, we do not offer refunds.
Last Updated: September 09, 2024