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Privacy Policy

Preamble

The protection and security of personal data is a high priority for us. We are committed to the transparency of data processing. Therefore, in the following we inform you about the type, measure and use of your personal data as well as the persons involved. With conviction, we also present your rights regarding the data we collect. As the responsible party, the

BlockAxs GmbH

Albert-Einstein-Str. 1,

49076 Osnabrück,

represented by its managing directors
Fabian Pohl and Marcel Horndasch

E-mail address: info@pacta.ai

(hereinafter "BlockAxs", "we" or "us")

is prepared to take all measures required by law to protect your personal data.

1. Persons concerned

This privacy policy applies to personal data of:

  • customers, business and contractual partners;
  • Interested parties and communication partners;
  • Users (e.g. website visitors, users of the PACTA platform);
  • all other natural persons who are in contact with us, e.g. agents, messengers and representatives or employees of legal entities.

2. Nature of personal data

The following personal data is processed by BlockAxs:

  • Inventory data (e.g. names, addresses)
  • Content data (e.g. text input, photographs, videos)
  • Contact details (e.g. e-mail, telephone numbers)
  • Meta/communication data (e.g. device information, IP addresses)
  • Usage data (e.g. websites visited, interest in content, access times)
  • Contract data (e.g. subject matter of the contract, term, customer category)
  • Payment data (e.g. bank details, invoices, payment history)

3. Legal basis for data processing

Processing of your personal data may be based on the following legal grounds:

a) Consent, Art. 6 para. 1 p. 1 lit. a DSGVO

You have given your consent to the processing of personal data concerning you for a specific purpose or purposes. This consent can be revoked at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of this consent until the withdrawal. The revocation can be made form-free and should preferably be addressed to:

BlockAxs GmbH

Paul-Lincke-Ufer 8b,

10999 Berlin

Email: info@pacta.ai

b) Contract performance and pre-contractual requests, Art. 6 para. 1 p. 1 lit. b. DSGVO

The processing is necessary for the performance of a contract to which you are a party or for the performance of pre-contractual measures taken at your request.

c) Obligation, Art. 6 para. 1 p. 1 lit. c. DSGVO

The processing is necessary for compliance with a legal obligation to which BlockAxs is subject.

d) Legitimate interests, Art. 6 para. 1 p. 1 lit. f. DSGVO

The processing is necessary to protect our legitimate interests or those of third parties, unless your interests or fundamental rights and freedoms requiring the protection of personal data override these.

4. Data logging of general information during the visit of our websites

4.1. During the visit of our website (https://pacta.ai) and our app (https://pacta-cloud.app), the respective web server automatically records log files that cannot be assigned to a specific person. This data includes, for example, the browser type and version, operating system used, referrer URL (the previously visited page), IP address of the requesting computer, access date and time of the server request and the client's file request (file name and URL) as well as, under certain circumstances, location data, including location data from your mobile device. Please note that most mobile devices allow you to control or disable the use of location services in the mobile device's settings menu.

4.2. The use of hosting services and logging of general data are used to provide the following services: Infrastructure and platform services, computing capacity, storage and database services, emailing, security and technical maintenance services that we use to operate our online services. In no case BlockAxs uses the collected data for the purpose of drawing conclusions about your person. Additional personal data is only collected if you provide additional voluntary information when using the website, as described below.

4.3. The legal basis for the data logging is Art. 6 (1) lit. f) DSGVO in conjunction with Art. 28 DSGVO. Our legitimate interest is the efficient and secure provision of our websites.

5. Contact form and e-mail correspondence

5.1. We offer you the possibility to contact us via a form on our websites (contact form). You must provide at least your e-mail address and your name.

5.2. If you contact us via a contact form or by e-mail, your details will be stored for the purpose of processing the enquiry and for possible follow-up questions. If you have provided us with personal data, we will use it exclusively for the purpose of fulfilling your wishes and requirements. This personal data will not be passed on to third parties.

5.3. Data processing for the purpose of contacting us via a contact form is carried out in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO on the basis of your voluntarily given consent.

5.4. The data processing for the purpose of answering your e-mails is carried out in accordance with Art. 6 Para. 1 S. 1 lit. b DSGVO.

5.5. After processing your request, the collected data will be deleted immediately, unless there are legal retention periods.

6. Newsletter

6.1. On our websites, you can register for our newsletter and thereby declare your voluntary consent to the sending of our newsletter to you by way of the double opt-in procedure. In doing so, reference is made to the declaration of consent and this data protection declaration. The advertised goods and/or services are named in the declaration of consent.

6.2. In this respect, we process your e-mail address and your first and last name. You have transmitted this data to us in the course of registering for the newsletter on one of our websites via the corresponding input mask.

6.3. When registering for the newsletter, we also store your IP address and the date and time of registration. The collection of this data serves the legal protection of BlockAxs.

6.4. After your registration, we will send you an email in which we ask you to reconfirm your consent to receive the newsletter. If you do not confirm your subscription within a certain period of time, your information will be blocked and automatically deleted after one month.

6.5. You can unsubscribe from the newsletter at any time. To do so, either use the corresponding link at the end of each newsletter or send us an e-mail to info@pacta.ai (preferably with the subject "Unsubscribe Newsletter").

6.6. For the dispatch of the newsletter we use external order data processors.

6.7. Newsletter tracking: The BlockAxs newsletters contain so-called tracking pixels, which enable a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, BlockAxs may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by the data subject. Such personal data collected via the tracking pixel contained in the newsletters are stored and evaluated by us in order to optimize the newsletter dispatch and to better adapt the content of future newsletters to the interests of the data subject. This personal data is not passed on to third parties.

6.8. Data processing for the purpose of sending the newsletter is carried out in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO on the basis of your express voluntary consent.

6.9. After unsubscribing from our newsletter or revoking your consent, the data you submitted for registration will be deleted.

7. Registration and conclusion of contract

7.1. Within the framework of the conclusion of a contractual relationship between you and BlockAxs as well as during your registration on our PACTA platform, we collect inventory data, content data, contact data, meta/communication data, usage data, contract data and payment data.

7.2. If you conclude a paid subscription, we may also work together with commissioned payment service providers. We pass on your payment data to the commissioned payment service provider as part of the payment processing - for the purpose of the payment - insofar as this is necessary for the payment processing.

7.3. This data is processed for the purpose of implementing and processing the contractual relationship.

7.4. The legal basis for data processing is Art. 6 para. 1 p. 1 lit. b. DSGVO.

7.5. Your personal data will be stored for as long as required by the purpose of the contract and any statutory and contractual retention obligations.

8. Use of cookies

8.1. On some of our pages, we use so-called "session cookies" to make it easier for you to use our websites. These are small text files that are only stored on your hard drive for the duration of your visit to our website and, depending on the settings of your browser program, are deleted again when you close the browser. These cookies do not retrieve any information stored about you on your hard drive and do not affect your PC or its files. If you visit our site again in order to use our services, it will automatically be recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.

8.2. In addition, we use cookies to statistically record and evaluate the use of our website and to optimise our offer for you. These cookies enable us to automatically recognise that you have already been to our website when you visit it again. These cookies are automatically deleted after a defined period of time.

8.3. Most browsers are set to accept cookies automatically. However, you can disable the storage of cookies or set your browser to notify you when cookies are sent. Please note that you may not be able to use certain functions of our website if you have deactivated the use of cookies.

8.4. The data processed by cookies is necessary for the aforementioned purposes to protect our legitimate interests and those of third parties in accordance with Art. 6 (1) p. 1 lit. f. DSGVO required.

8.5. If you leave our site via a link or by clicking on any banner advertising and thus reach external sites, it may be that cookies are also set by the addressees of the target site clicked on. We are not legally responsible for these cookies. Regarding the use of such cookies and the information stored on them by our advertising partners, please compare their data protection declarations. You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies.

9. Google Analytics

9.1. Our websites use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics 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 the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. The IP addresses are anonymized so that an assignment is not possible (so-called IP masking).

9.2. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services associated with the use of the website and the Internet for the purposes of market research and the design of these websites in line with requirements. Our legitimate interest in data processing also lies in these purposes. The legal basis for the use of Google Analytics is § 15 para 3 TMG in conjunction with Art. 6 para 1 p. 1 lit. f. DSGVO.

9.3. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing the following browser add-on

https://tools.google.com/dlpage/gaoptout?hl=de

9.4. The data sent by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs are automatically deleted after 14 months. The deletion of data whose retention period has been reached takes place automatically once a month.

9.5. Further information on data protection in connection with Google Analytics can be found, for example, in the Google Analytics Help at:

https://support.google.com/analytics/answer/6004245?hl=de

10. Google AdWords

10.1. We also use the online advertising program "Google Ads" within the framework of Google Ads the conversion tracking. Google Conversion Tracking is an analysis service provided by Google. When you click on an ad placed by Google, a cookie for conversion tracking is stored on your end device. These cookies lose their validity after 30 days, do not contain any personal data and are therefore not used for personal identification. If you visit certain pages of our website and the cookie has not yet expired, Google and we can recognize that you clicked on the ad and were redirected to that page. Each Google Ads customer receives a different cookie. Thus, there is no way that cookies can be tracked across Ads customers' websites.

10.2. The information collected by the conversion cookie is used to create conversion statistics for Ads customers who have opted in to conversion tracking. This tells clients the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. Our legitimate interest in data processing also lies in these purposes. The legal basis for the use of Google Ads is § 15 para. 3 TMG in conjunction with Art. 6 para. 1 p. 1 lit. f. DSGVO.

10.3. If you do not wish to participate in tracking, you can object to this use by preventing the installation of cookies from the domain "googleadservices.com" through a corresponding setting in your browser software (deactivation option). You will then not be included in the conversion tracking statistics. You can find further information and Google's privacy policy at:

http://www.google.com/policies/technologies/ads/

http://www.google.de/policies/privacy/

11. Hubspot

11.1. On this website we use the service HubSpot for various purposes. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500 Hubspot is an integrated software solution that we use to cover various aspects of our online marketing. These include: Email Marketing, Social Media Publishing & Reporting, Reporting, Contact Management (e.g. user segmentation & CRM), Landing Pages and Contact Forms.

11.2. Our sign-up service allows visitors to our website to learn more about our company, download content, and provide their contact information and other demographic information. This information, as well as our website content, is stored on servers operated by our software partner HubSpot. It may be used by us to contact visitors to our website and to determine which of our company's services are of interest to them. All information we collect is subject to this privacy policy. We use all collected information exclusively to optimize our marketing measures.

https://legal.hubspot.com/privacy-policy

11.3. More information from HubSpot regarding EU data protection regulations:

https://legal.hubspot.com/security?

You can find more information about the cookies used by HubSpot here:

https://knowledge.hubspot.com/reports/what-cookies-does-hubspot-set-in-a-visitor-s-browser?

https://knowledge.hubspot.com/account/hubspot-cookie-security-and-privacy

11.4. As part of the optimization of our marketing measures, the following data may be collected and processed via Hubspot:

  • Geographical position
  • Browser type
  • Navigation information
  • Reference URL
  • Performance data
  • Information about how often the application is used
  • Mobile Apps data
  • Login information for the HubSpot subscription service
  • Files displayed on site
  • Domain names
  • Pages viewed
  • Aggregated use
  • Version of the operating system
  • Internet Service Provider
  • IP address
  • Device identifier
  • Duration of the visit
  • Where the application was downloaded from
  • Operating system
  • Events that occur within the application
  • Access times
  • Clickstream data
  • Device model and version

11.5. In addition, there is a possibility that we may also use Hubspot to provide contact forms in the future.

11.6. The legal basis of the processing is your consent pursuant to Art. 6 (1) lit. a DSGVO. If you do not want the aforementioned data to be collected and processed via Hubspot, you can refuse your consent or revoke it at any time with effect for the future.

11.7. The personal data shall be kept for as long as necessary to fulfil the purpose of the processing. The data will be deleted as soon as they are no longer necessary to achieve the purpose.

11.8. Within the scope of processing via HubSpot, data may be transmitted to the USA. The security of the transfer is ensured via so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a level of security that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent pursuant to Art. 49 (1) lit. a DSGVO may serve as the legal basis for the transfer to third countries.

12. Online presence in social media

12.1. We maintain online presences in social networks and platforms in order to communicate with customers, interested parties and users and to inform them about our services.

12.2. Furthermore, social plugins ("plugins") are used on our websites. When you open our website with such a plugin, it establishes a direct connection with the servers of the social media platform via your browser. This transmits to them the information that you have accessed the page. If you are logged in with your respective account, the visit to our website can be directly assigned to your profile by clicking on the plugin. Even if you do not have a profile, it cannot be ruled out that your IP address is stored by the platform.

12.3. We would like to point out that to this extent your data may be processed outside the territory of the European Union. This may lead to risks for you, e.g. because the enforcement of user rights could become more difficult.

12.4. In addition, your data is usually processed for market research and advertising purposes. For example, user profiles are created from user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the platforms that allegedly correspond to the interests of the users. For this purpose, cookies are usually stored on the computers of the users, in which the user behavior and the interests of the users are stored. In addition, data can also be stored in the usage profiles independently of the devices used by the users, especially if the users are logged in as members of the respective platforms.

12.5. The processing of users' personal data is based on our legitimate interest in effectively informing users and communicating with users pursuant to Art. 6 para. 1 p. 1 lit. f. DSGVO. If users are asked for consent to data processing by the respective providers (i.e. you agree to this, e.g. by ticking a box or clicking a button), the legal basis of the processing is Art. 6 para. 1 p. 1 lit. a. DSGVO, Art. 7 DSGVO.

12.6. For a detailed description of the respective processing and the options for unsubscribing, please refer to the following linked information of the respective provider:

a) Facebook (Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94304, USA)

Privacy Policy:

https://www.facebook.com/about/privacy/

OptOut:

https://www.facebook.com/settings?tab=ads

b) Instagram (Instagram Inc., 1601 Willow Road, Menlow Park, California, 94025, USA)

Privacy/OptOut:

http://instagram.com/about/legal/privacy/

c) Twitter (Twitter Inc. 1355 Market Street, Suite 900, San Francisco, CA 94103, USA)

Privacy Policy:

https://twitter.com/de/privacy

OptOut:

https://twitter.com/personalization

d) LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland)

Privacy Policy:

https://www.linkedin.com/legal/privacy-policy

OptOut:

https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

e) XING (XING SE, Dammtorstraße 30, 20354 Hamburg, Deutschland)

Privacy/OptOut:

https://privacy.xing.com/de/datenschutzerklaerung

f) Youtube (belonging to Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)

Privacy/OptOut:

http://www.google.com/policies/technologies/ads/

http://www.google.de/policies/privacy/

12.7. Also with regard to requests for information and the assertion of rights of use, we point out that these can most effectively be asserted directly with the providers. Only the providers have access to the users' data and can take appropriate action and provide information directly. If you need assistance, we are always at your disposal.

13. Data subject rights

13.1. Since we take your rights seriously, we would like to present them to you. They result from the respective regulations of the EU-DSGVO.

13.2. You can request information about your personal data processed by us. You have the right to request that inaccurate personal data concerning you be corrected without delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

13.3. You have the right to request that personal data concerning you be deleted without delay, provided that one of the following reasons applies:

a) The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

b) You withdraw your consent and there is no other legal basis for the processing;

c) You object to the processing and there are no overriding legitimate grounds for processing;

d) Your personal data have been processed unlawfully;

e) The deletion of your personal data is necessary for compliance with a legal obligation under Union or Member State law to which BlockAxs is subject.

13.4. The right to erasure of your data may be excluded pursuant to Art. 17 (3) DSGVO if a legitimate reason makes the processing of your data necessary.

13.5. You have the right to request a restriction of the processing of your personal data if one of the following conditions is met:

a) The accuracy of your personal data is disputed by you for a period of time that allows us to verify the accuracy of the personal data;

b) The processing is unlawful and you request restriction of use instead of erasure;

c) We no longer need your data for the purposes of processing, but you need it to assert, exercise or defend against legal claims;

d) You have filed an objection as long as it has not yet been determined whether your legitimate interests prevail.

13.6. We will notify all recipients to whom personal data has been disclosed of any rectification or erasure of the personal data or restriction of processing, unless this proves impossible or involves a disproportionate effort. We will inform you of these recipients if you so request.

13.7. You also have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out in the public interest or on the basis of legitimate interests on our part. This also applies to profiling based on these interests. We will no longer process such personal data unless compelling legitimate grounds for the processing override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

The objection can be made without formalities and should preferably be addressed to:

BlockAxs GmbH

Paul-Lincke-Ufer 8b,

10999 Berlin

E-mail address: info@pacta.ai

13.8. Finally, you are entitled to lodge a complaint with the competent data protection supervisory authority.

13.9. You have the right to obtain the personal data concerning you that you have provided to BlockAxs in a structured, commonly used and machine-readable format.You have the right to transfer this data to another controller without hindrance from BlockAxs.

14. Data economy

14.1. We do not store your data for longer than is necessary for the respective processing purposes.

14.2. If the data is no longer required for the fulfilment of contractual or legal obligations, it is regularly deleted.

15. Amendment of this privacy policy

We will update this policy from time to time to protect your personal information. You should review this policy from time to time to stay informed about how we are protecting your information and continually improving the content of our website. If we make any material changes to the collection, use and/or disclosure of the personal information you provide to us, we will notify you by placing a prominent and prominent notice on the Site. By using the Website, you agree to the terms of this Personal Information Protection Policy. For each subsequent visit to our website, the current version of the privacy policy will apply.