Privacy Policy
Protecting your personal data is important to us. This Privacy Policy explains what personal data is processed when you use our website, the purposes for which it is processed, the legal basis for such processing and the rights available to you.
1. Controller
The controller responsible for the processing of personal data on this website is the operator of Charicomm identified in our Legal Notice / Imprint.
The controller’s contact details can be found in our Legal Notice / Imprint.
2. General Information on Data Processing
Personal data means any information relating to an identified or identifiable natural person. This may include, for example, your name, email address, telephone number, IP address and usage or device information where such information can be associated with an individual.
We process personal data only where there is a lawful basis for doing so. Depending on the particular processing activity, this may include the performance of a contract or pre-contractual measures, compliance with a legal obligation, our legitimate interests or your express consent.
We do not sell personal data. Personal data is disclosed to external service providers or other recipients only where this is necessary to operate our website or provide our services, where you have given your consent, or where another lawful basis applies.
3. Server Log Files
When you access our website, our web server processes information that is technically necessary to provide the website.
This information may include your IP address, the date and time of access, the page or file requested, the referrer URL, browser type and browser version, operating system, amount of data transferred and information about whether the request was successful.
We process this information to provide our website securely and reliably, to identify and prevent attacks and to diagnose technical errors.
The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is the secure and reliable operation of our website.
The data is deleted when it is no longer required for these purposes, unless statutory retention obligations require us to retain it for a longer period.
4. Contacting Us
If you contact us by email, contact form, telephone or another method, we process the information you provide in order to respond to your enquiry.
This may include your name, contact details and the content of your message.
Where your enquiry relates to a contract or pre-contractual measures, the legal basis is Art. 6(1)(b) GDPR. For other enquiries, processing is based on our legitimate interest in responding to your request pursuant to Art. 6(1)(f) GDPR.
5. Cookies and Consent Management
Our website uses cookies and comparable technologies. Cookies are small pieces of information that may be stored on or accessed from your device.
Strictly necessary cookies and technologies are used where they are required to provide the website or a functionality expressly requested by you.
Analytics, marketing and tracking technologies are generally used only after you have given your consent through our consent management system.
The legal basis for storing information on your device or accessing information already stored on your device for analytics and marketing purposes is Section 25(1) TDDDG. Subsequent processing of personal data is based on your consent pursuant to Art. 6(1)(a) GDPR.
Borlabs Cookie
We use Borlabs Cookie to manage your consent preferences.
Borlabs Cookie stores your selections regarding permitted cookie and service categories in a technically necessary cookie. This enables our website to determine which services you have accepted or rejected.
Storing this consent choice is necessary in order to respect your privacy preferences during subsequent visits and page views.
You may change or withdraw your consent at any time with effect for the future through the cookie settings on our website.
6. Website Analytics
We use analytics services to understand how our website is used and to improve our website from both a technical and content perspective.
Where consent is required, the analytics services described below are used only after you have given the relevant consent through our cookie settings.
6.1 Matomo Analytics and Matomo Tag Manager
We use Matomo Analytics and Matomo Tag Manager. Our Matomo Cloud service is provided by InnoCraft Limited, 7 Waterloo Quay, PO Box 625, 6140 Wellington, New Zealand.
Matomo Analytics enables us to statistically analyse the use of our website. Data processed in this context may include pages visited, date and time of access, referrer URL, browser and device information, operating system, approximate location information and technical usage information.
We have configured Matomo so that IP addresses are anonymised or shortened.
Matomo Tag Manager is used to technically manage and deploy tags and scripts on our website. Depending on the service triggered through the Tag Manager, further data processing may take place. The relevant processing activities are described in this Privacy Policy.
Analytics processing is carried out on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG.
Our Matomo Cloud instance is hosted in Europe. Primary data is stored in Frankfurt, Germany, with backups stored in Dublin, Ireland. InnoCraft Limited itself is established in New Zealand.
The retention period depends on the settings configured in our Matomo instance and the relevant processing purpose. Data is deleted or anonymised once it is no longer required for our analytics purposes.
You may withdraw your consent at any time through the cookie settings on our website.
Further information is available in the Matomo Privacy Policy.
6.2 Google Analytics 4
We use Google Analytics 4, a web analytics service provided by Google. For users in the European Economic Area, the relevant Google services are generally provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics helps us understand how visitors use our website. Information processed may include page views, sessions, interactions with our website, approximate location, browser, device and operating system information.
Google Analytics may use a client ID stored in a first-party cookie to distinguish pseudonymous users where you have consented to the relevant storage.
IP addresses are used by Google Analytics during data collection, including for determining approximate location information. According to Google, Google Analytics 4 does not log or store IP addresses.
We use Google Analytics for analytics purposes on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG.
Depending on our Google Analytics configuration, user-level data may be retained for up to 14 months. Aggregated statistical reports may remain available for longer periods.
Processing or transfer of data within the Google group and, where applicable, outside the European Economic Area cannot be completely excluded. According to Google, applicable data protection transfer mechanisms are used for such transfers.
You may withdraw your consent at any time through the cookie settings on our website.
Further information is available in Google’s Privacy Policy.
7. Advertising and Conversion Tracking
We run online advertising campaigns and, after obtaining your consent, use technologies to measure the effectiveness of those campaigns.
These technologies allow us, for example, to determine whether a person visits our website after clicking one of our advertisements and subsequently performs an action defined by us, such as submitting an enquiry, completing a form or triggering another conversion event.
The marketing and conversion tracking services described below are generally activated only after you have consented to the relevant marketing category through our consent management system.
The legal basis is your consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG.
7.1 Google Ads and Conversion Tracking
We use Google Ads to display advertisements and measure their effectiveness.
For users in the European Economic Area, the relevant provider is generally Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
If you reach our website through a Google advertisement and have consented to marketing processing, Google and we may determine whether a defined conversion subsequently occurs.
Data processed may include information about advertisement clicks and advertising interactions, a Google Click ID or comparable identifiers, cookies, browser and device information, IP-based information, pages visited and conversion events.
We use this information to measure the effectiveness of our advertisements, attribute conversions, generate statistical campaign reports and optimise our advertising campaigns.
Where we use remarketing or personalised advertising functionality, the information may also be used to create audiences for future advertisements.
Google may process data within the Google group and, where applicable, outside the European Economic Area. According to Google, applicable data protection transfer mechanisms are used for such transfers.
You may withdraw your consent at any time through the cookie settings on our website.
Further information is available in Google’s Privacy Policy.
7.2 Meta Pixel / Facebook Pixel
We use the Meta Pixel, formerly also known as the Facebook Pixel, for conversion measurement and advertising optimisation.
For users in the European Region, the provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
After you have provided your consent, the Meta Pixel may collect information about your use of our website and certain events. This may include page views, URLs visited, referrer information, browser and device information, IP address, online identifiers and information about actions performed on our website.
This enables us, in particular, to determine whether users visit our website and perform a defined conversion after viewing or clicking one of our advertisements on Facebook or Instagram. The information may also be used to optimise our advertising campaigns and, where configured by us, to create audiences and conduct remarketing.
For the collection and transmission of certain event data through the Meta Business Tools, we and Meta Platforms Ireland Limited may act as joint controllers within the meaning of Art. 26 GDPR. Further processing of the data by Meta is generally carried out under Meta’s own responsibility.
The Meta Pixel is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG.
Meta may also transfer data to affiliated companies and recipients outside the European Economic Area, particularly in the United States. According to Meta, appropriate data protection transfer mechanisms are used for such transfers.
You may withdraw your consent at any time through the cookie settings on our website.
Further information is available in Meta’s Privacy Policy and the terms governing the Meta Business Tools.
7.3 OpenAI Ads and Conversion Tracking
We use OpenAI advertising services to display advertisements, particularly within ChatGPT and other advertising services provided by OpenAI, and to measure the effectiveness of these advertisements.
For customers established in the European Economic Area, the OpenAI contracting entity for the advertising services is OpenAI Ireland Ltd., 1st Floor, The Liffey Trust Centre, 117–126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland.
For conversion measurement, we use the OpenAI Pixel.
When you reach our website through an advertisement placed by us through OpenAI, OpenAI may append an OpenAI click reference known as “oppref” to the landing-page URL. After you have given your consent, the OpenAI Pixel may capture this click reference and store it in a first-party cookie. This makes it possible to associate a subsequent conversion on our website with an earlier advertisement click.
Data processed as part of conversion measurement may include cookies and online identifiers, browser and device information, the OpenAI click reference, event data and information about conversion actions defined by us.
Such actions may include page views, submitting a contact enquiry, completing a registration or other events that we define as conversions.
We process this information to measure and evaluate our OpenAI advertising campaigns, attribute conversions and optimise our advertising.
For ordinary processing through the OpenAI Ad Tools, OpenAI and we generally each act as independent controllers.
According to OpenAI, data relating to individuals in the European Economic Area is processed by OpenAI Ireland Limited in connection with the OpenAI Ad Tools. Where data is subsequently transferred to a jurisdiction that does not provide an adequate level of data protection, OpenAI states that it uses a valid data protection transfer mechanism.
The OpenAI Pixel is used only after you have given your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG.
You may withdraw your consent at any time with effect for the future through the cookie settings on our website.
Further information is available in OpenAI’s Privacy Policy and OpenAI’s Ad Tools Terms.
8. Withdrawal of Consent
You may withdraw consent that you have previously given at any time with effect for the future.
In particular, you can use the cookie settings on our website to deactivate individual categories or services.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
9. International Data Transfers
Some of the service providers we use belong to international groups of companies. Personal data may therefore be processed in countries outside the European Union or European Economic Area.
Where the European Commission has adopted an adequacy decision for the relevant country, transfers may be based on that decision. For transfers to the United States, this may include the EU-U.S. Data Privacy Framework where the relevant recipient is certified under that framework.
In other cases, Standard Contractual Clauses approved by the European Commission or other safeguards permitted under the GDPR may be used.
Additional information is available from the respective service provider.
10. Data Retention
We generally retain personal data only for as long as necessary for the respective processing purpose.
Where statutory commercial or tax retention requirements apply, certain data may be retained for a longer period.
For analytics and marketing services, the respective provider’s retention periods and the settings configured by us may also apply.
Once the relevant processing purpose no longer applies, the data is deleted or anonymised unless there is a lawful basis for continued retention.
11. Your Rights
Subject to the applicable legal requirements, you have the right to request access to the personal data we process about you, rectification of inaccurate data, erasure of your personal data, restriction of processing, data portability and the right to object to certain processing activities.
Where processing is based on your consent, you may withdraw that consent at any time with effect for the future.
You also have the right to lodge a complaint with a competent data protection supervisory authority.
12. Data Security
We implement appropriate technical and organisational security measures to protect your personal data against loss, manipulation, unauthorised access and other misuse.
Our website uses an encrypted HTTPS connection for the transmission of data between your device and our server.
Our security measures are reviewed and adapted in line with technological developments.
13. External Links
Our website may contain links to websites operated by third parties. The respective operators are generally responsible for the processing of personal data on those external websites.
Please review the privacy policies of the respective providers.
14. Changes to this Privacy Policy
We may update this Privacy Policy if our website, the services we use or applicable legal and regulatory requirements change.
The version currently published on our website applies.
