Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared by brainbot gmbh. Personal Information means any information relating to an identified or identifiable natural person, who may be identified, directly or indirectly by reference to an identifier such as a name, an identification number, location data, online information (e.g. an IP address) or to one or more factors relating to that person.

This notice applies to personal information provided to us by visitors to https://blog.shutter.network/ and https://shutter.network (the "website"), end users, beta testers, suppliers, contractors, job applicants, or other direct or indirect affected persons of the activities we carry out and functions we perform in running the website. In this notice "you" refers to any individual whose personal information we hold or process.

1. Basis on which we process personal data

Personal Information we hold about you will be processed either because:

• the processing is necessary in pursuit of a "legitimate interest" (Art. 6 Para. 1 lit. f GDPR); a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security;
• you have consented to the processing for the specific purposes described in this notice (Art. 6 Para. 1 lit. a GDPR);
• the processing serves to fulfill a contract to which the data subject is a party or to carry out pre-contractual measures (Art. 6 Para. 1 lit. b GDPR);
• the processing serves to fulfill a contract to which the data subject is a party or to carry out pre-contractual measuthe processing is necessary in order for us to comply with our obligations under a contract between you and us.res (Art. 6 Para. 1 lit. b GDPR);

2. Personal information we collect

When you visit the website, we may automatically collect certain information about you and your device. We refer to this automatically-collected information as "Device Information." We collect it through the following technologies:

• Server log files — collected automatically on every visit. Includes your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• Matomo Analytics (cookieless mode) — active by default on every visit. Collects your anonymised IP address (truncated by 2 bytes), browser type, operating system, pages visited, referrer URL, and time zone. No cookie is set and no persistent identifier is stored on your device.
• Matomo Analytics (cookie mode) — only active if you accept cookies via the notice shown on your first visit. Sets a cookie that allows us to recognise your browser on future visits for session continuity. You can withdraw this consent at any time by clearing your browser's local storage for this site.

Additionally, if you sign up for a newsletter through the website, we collect your email address. We refer to this information as "Subscription Information." In the course of our interactions, we may also collect a record and details of any correspondence or communications between you and us relating to any information request or job application submitted to us. We refer to this information as "Communication Information". When we talk about "Personal Information" in this Privacy Policy, we are talking both about Device Information, Subscription Information and Communication Information.

3. How do we use your personal information?

Your Subscription Information will only be used to send you the subscribed newsletter by email. To receive the newsletter, it is sufficient to enter your email address. When you register to receive our newsletter, the data you provide will only be used for this purpose. Subscribers can also be informed via email about circumstances that are relevant to the service or registration (e.g. changes to the newsletter offer or technical conditions). For an effective registration, we need a valid email address. In order to check that a registration is actually made by the owner of an email address, we use the "double opt-in" procedure. For this purpose, we log the order of the newsletter, the sending of a confirmation email and the receipt of the response requested. Further data is not collected. The data will only be used for sending the newsletter and will not be passed on to third parties.

We use or may use the Subscription Information regarding our other personalized services and Communication Information that we collect generally to communicate with you and to provide any other information you have requested or respond to any other correspondence. If you are registered with us, you can access content and services that we only offer to registered users. Registered users also have the option of changing or deleting the data provided when registering at any time. If users leave comments or forum posts on our website, the time of their creation and the user name previously selected by the user are saved in addition to this information. This serves our security as we can be prosecuted for illegal content on our website, even if it was created by users.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our website (ensuring a problem-free connection to the website, evaluating system security and stability and for other administrative purposes). (This process is for our legitimate interests in managing the information we provide via our website and to assess how people use the website.) We do not use your Personal Information to draw conclusions about you personally. Personal Information may be statistically evaluated by us in order to optimize our website and the technology behind it.

4. Sharing your personal information

We share your personal information with third parties such as processors to help us use your personal information, as described above. We may disclose your personal information to other third-parties that enable us to provide the website and any connected services including technical support providers who may have access to personal data. These may include software and website developers, IT support and mail management service providers. In all cases, our agreement with the relevant third party will contain appropriate provisions regarding the use and security of your personal information. Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

5. Do not track

Please note that we do not alter our website's data collection and use practices when we see a Do Not Track signal from your browser.

6. Transferring your information outside Europe

We will not transfer any data in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:

• if you live outside of the EEA, we may communicate with you during the course of our interactions and such communications may include personal information (such as Subscription Information);
• we may have certain third-party service suppliers who are based outside the EEA or who store data outside of the EEA;
• if you communicate with us while you are outside of the EEA there may be some data transfer to you or your device;
• from time to time your information may be stored in devices which are used by affiliates engaged by brainbot gmbh when outside of the EEA.

If we transfer your information outside of the EEA in a systematic way, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and your privacy rights will continue to be enforceable against us as outlined in this notice.

7. Your rights

In accordance with the GDPR and data protection laws applicable to you, the following rights may be available to you: The right (1) to be informed about our data processing activities (Art. 15 GDPR) (2) of access to the Personal Information we hold about you (Art. 15 GDPR) (3) to correction of your Personal Information if it is incomplete or inaccurate (Art. 16 GDPR) (4) to deletion of your Personal Information (Art. 17 GDPR) or (5) to restriction or limitation of the processing of your Personal Information (Art. 18 GDPR) and (6) to object to the processing of your Personal Information (Art. 21 GDPR) and (7) to receive copies of your Personal Information in a commonly used form and to transfer it directly to a third party (Art. 20 GDPR). If we are relying on your consent as the basis on which we are processing your Personal Information, you have the right at any time to withdraw your consent with future effect. Regarding your newsletter subscription, there is a corresponding link in every newsletter. You can also unsubscribe directly from this website at any time or inform us of your revocation. Any request made under (2) above (a subject access request) or any other notification in respect of your rights must be sent to us by post to: brainbot gmbh, Taunusstraße 61, 55120 Mainz, Germany.

If you are of the opinion that the brainbot gmbh data processing activities infringe upon applicable data protection regulations or your personal data protection rights, you have the right to report this to the competent supervisory authority in Germany.

8. Data retention

If you sign up for a newsletter through the website or we acquire your personal information due to another interaction with brainbot gmbh, we will generally maintain your personal information for our records for twelve months unless you ask us to delete this information before such time has passed. We may retain your personal information for more than twelve months if we consider it is necessary to enable us to satisfactorily provide the information on the website or administer the website or to enable us to comply with any statutory, legal or contractual obligation we may have. We review the personal information (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still accurate and is still relevant to brainbot gmbh and its website. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required. Generally, personal information will be deleted as soon as it is no longer required for the purpose of the collection. Regarding Device Information, this is generally the case when the respective session has ended. The server log files will be deleted after 7 days.

9. Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard your personal information and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

• compliance with our internal IT security procedures;
• protecting our servers by both hardware and software firewalls;
• locating our data processing storage facilities in secure locations;
• using appropriate support tools and mailing list management providers;
• when necessary, disposing of or deleting your data in a secure manner;
• regularly backing up and encrypting all data we hold.

We will ensure that all contractors, staff or individuals engaged by us are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf or providing services to us are aware of their privacy and data security obligations. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted by you to us by email. Once we have received your information, we will use the procedures and security features referred to in this Privacy Policy to try to prevent unauthorised access.

10. Web analysis tool Matomo

This website uses Matomo, an open-source analytics tool, for statistical analysis of website traffic. Matomo is operated as a cloud service by InnoCraft Ltd. (New Zealand) and processes data on behalf of brainbot gmbh.

By default, Matomo is operated in cookieless mode. No cookies are set and IP addresses are anonymised before storage (truncated by 2 bytes). The legal basis for this processing is our legitimate interests in understanding how the website is used (Art. 6(1)(f) GDPR). If you accept via the cookie notice shown on your first visit, analytics cookies will be set to recognise your browser on future visits. This cookie-based processing is based on your consent (Art. 6(1)(a) GDPR), which you may withdraw at any time by clearing your browser's local storage for this site. For more information, see: matomo.org/privacy-policy

11. Cookies

We use analytics cookies only when you have explicitly consented via the cookie notice shown on your first visit. Cookies set by Matomo are small files your browser stores on your end device (laptop, tablet, smartphone, etc.) that allow us to recognise your browser on future visits. If you do not consent, no Matomo cookies are placed. You can withdraw consent at any time by clearing your browser's local storage or configuring your browser to block cookies.

12. Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

13. Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at contact@brainbot.com.