We want you to feel comfortable on our website and not have to worry about the security of your data. That is why data protection is an important part of our corporate philosophy. In this Privacy Policy, you will find all the information about which Personal Data we collect and process and for what purpose. Equally, we will also inform you of your data protection rights and how you can assert them.
General Principles
What is Personal Data?
Personal Data is "any information relating to an identified or identifiable natural person. This includes, for example, name or address data, telephone number, mobile number, or online identifiers such as your device id and your IP address.
What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party for data processing is Writerstoolhub based in Cologne, Germany (“Writerstoolhub”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us by email using our contact form or write to us at the above address..
What law applies?
Our use of your Personal Data is subject to Germany's Federal Data Protection Act (Bundesdatenschutzgesetz) ("BDSG"), and the EU's General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.
What are the Legal Bases for processing Personal Data
In accordance with the BDSG and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
Who is the competent data protection authority?
You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data. The representative at federal level is the Federal Commissioner for Data Protection and Freedom of Information (BfDI) (www.bfdi.bund.de) and the supervisory authority in NRW is: The State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (LDI-NRW) (www.ldi.nrw.de). However, we would appreciate it if you could clarify your concerns before contacting the BfDI or the LDI-NRW first.
How long will you keep my data?
We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with the Germany`s Commercial Law and Fiscal Code. Depending on the document and legal regulation, the retention and documentation periods specified therein are five years (HGB), six years (A0) or ten years (HGB). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
What Personal Data do we process?
Technical Data
When you access our website, some access data is recorded automatically and stored in a log file on our website's server. This means if you browse and simply have a look at our website, we process a) the IP address of your computer, b) the date and time of your access, c) the name and URL of the accessed file, d) the browser used, e) the amount of bytes transferred, f) the status of the page request, g) the session ID and g) the referrer URL. The legal basis for processing is our legitimate interest.
Hosting of our website
We use the hosting services of Webflow Inc. (398 11th St, San Francisco, CA 94103, USA) for the purpose of hosting and displaying our website. Webflow does so on the basis of processing on our behalf, and that also means that all data collected on our website is processed on Webflow's servers. The basis for processing is our legitimate interest, and the initiation and/or fulfillment of a contract.
Content Management System
We also use the Content Management System (CMS) of Webflow to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to Webflow. This represents a legitimate interest.
Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in Germany`s Data Protection and Privacy in Telecommunications and Telemedia Act (“TTDSG”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Cookie consent
Our website uses the consent management tool “CookieScript” (Objectis Ltd. Laisves st. 60, LT-05120 Vilnius Lithuania) to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
Economic analyses and market research
For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics by Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, US, und Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland). The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.
Google reCAPTCHA
We also use Google's reCAPTCHA from Google to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as you enter our website. The legal basis for using reCAPTCHA is our legitimate interest.
Google Tag Manager
We use Google Tag Manager, which allows website tags to be managed via an interface. The Google Tag Manager only implements tags. No cookies are set, and no Personal Data is collected. Google Tag Manager triggers other tags that may collect data but does not itself access this data. The legal basis for using Google Tag Manager is our legitimate interest.
Contacting us
You can contact us in various ways and data is always collected in the process. You provide us with most of the data that we process when you contact us such as your name, and email address. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted again, provided that there is no legal obligation to retain it.
When using our services
We process the Personal Data involved in your use of our services in order to be able to provide our contractual services and you will be redirected to Gumroad (521 Del Medio Avenue #225, Mountain View, CA, 94040). Being redirected requires your i) IP address; and ii) other technical data related to your access to be disclosed, which is subject to Gumroad's Privacy Policy and we have no influence over Gumroad's privacy practice.Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.
Customer Support, Data management and Marketing Administration
For optimal customer support, we may store the data related to our customers in our customer relationship management system and if you are subscriber to our newsletter in our marketing system provided by beehiiv Inc (228 Park Avenue # 2329976, New York, New York 10003 USA). Our newsletter subscriptions are administered and managed using the services of Substack (111 Sutter Street, 7th Floor, San Francisco CA 94104, USA). For optimal data management, we store the data related to your contract with us in our Airtable (Formagrid, Inc. 799 Market St Fl 8 San Francisco, CA 94103 USA) based backend solution. This data processing is based on our legitimate interest in providing our customer service and marketing.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
When you are making a donation
If you decide to support us via Buy Me a Coffee (2035 Sunset Lake Road, Suite B-2 Newark, DE 19702, USA), the following data is processed: Amount of donation, Browser language, Extension name, Browser type and version, Operating system and version, and Identifying information about the devices that connect to the payment service provider. The legal bases of the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our legitimate interest.
Data Sharing
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
Internal
If necessary, we transfer your Personal Data within Writerstoolhub. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.
External bodies
Personal Data is transferred to our service providers in the following instances:
in the context of fulfilling our contract with you,
to use marketing services and to advertise our services online,
to communicate with you,
to provide our website, and
to state authorities and institutions as far as this is required or necessary.
International transfers
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
Security of your data
In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorized persons, we use appropriate technical and organizational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Marketing
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of email using the service provider MailerLite Ltd (548 Market St, PMB 98174, San Francisco, CA 94104-5401, United States) but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
Social Media
General
We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Information collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
Market research and advertising
In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.
When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
Advertising
We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.
We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website. The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.
Your Rights and Privileges
Privacy rights
Under the BDSG and GDPR, you can exercise the following rights:
- The right to access;
- The right to rectification;
- The right to erasure;
- The right to restrict processing;
- The right to object to processing;
- The right to data portability;
- The right to complaint to a supervisory authority
Updating your information
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can withdraw consents you have given at any time by contacting us.
Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
What we do not do
We do not request Personal Data from minors and children;
We do not use Automated decision-making including profiling; and
We do not sell your Personal Data.
Changes
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will revise the effective date. This Privacy Policy was last updated on Wednesday, 21st of February 2024.
Questions
If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.
Why do we have a Cookie Policy?
This Cookie Policy sits in line with Germany`s Data Protection and Privacy in Telecommunications and Telemedia Act (“TTDSG”) and common law requirements and the Privacy and Electronic Communications Directive (“PECD”). In accordance with them, we need to inform you about the cookies we use and obtain your consent when using certain types of cookies namely Functional, Performance, Analytical and Advertising Cookies.
What are cookies?
Cookies are small text files that are placed on your device by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites.
The cookies we use
We use three categories of cookies on our sites:
These cookies are necessary for the website to operate. our website cannot function without these cookies and they can only be disabled by changing your browser preferences.
These cookies allow us to measure and report on website activity by tracking page visits, visitor locations and how visitors move around the site. The information collected does not directly identify visitors. We drop these cookies to help us analyze the data.
Marketing cookies help us provide you with personalized and relevant services or advertising, and track the effectiveness of our digital marketing activities. Social media cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit.
We utilize cookies, and other online identification technologies such as web beacons, or pixels to provide users with an improved user experience.
Analytics
Google Analytics
We use Google Analytics, a web analytics service provided by Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, US, und Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland). Google Analytics also uses cookies to enable our website to analyze how users use our website across multiple devices. The information generated by the cookies about your use of our website is transmitted to and stored by Google, including transmission to the United States. The following data is processed through the use of Google Analytics:
Google states that it will not associate your IP address with any other data held by Google. The use of this service is based on your consent.
Opting Out
Google Analytics
You can disable tracking by Google Analytics with future effect by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser following this link http://tools.google.com/dlpage/gaoptout?hl=en.
General
If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only).
Cookie Consent
When you first visit our website, you will be asked to give your consent to cookies being stored on your device. You can accept all cookies or adjust your cookie settings to store only some of the above categories of cookies on your device. You can also refuse all cookies, except for necessary cookies, which are cookies that are required for the proper functioning of the website.
You should be aware that if you disable/reject certain cookies, we will not be able to provide you with the best possible user experience on our website, as there may be services and features that you will not be able to use if cookies are required for us to remember the choices you have made.
You can revoke your consent or change your cookie settings at any time.
How to delete cookies?
You can set your web browser to disable cookies. Please note that most browsers offer different ways to protect your privacy. If you do not activate or deactivate certain cookies via the browser settings, it is possible that certain functionalities will not be available to you as expected.
You can configure the use of cookies in your browser settings by following the relevant link Google Chrome, Mozilla Firefox, Microsoft Edge, Opera, Safari at any time or deactivate them completely.
Please note that if you disable cookies in this way, you will not be able to set new cookies. However, it will not prevent previously set cookies from continuing to work on your device until you clear all cookies in your browser settings.
Changes
We may update this Cookie Policy from time to time. If we make changes to this Cookie Policy, we will revise the effective date. This Cookie Policy was last updated on Wednesday, 21st of February 2024.
Questions
If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.
