DATA PROTECTION
1. Introduction
With the following information, we would like to give you, as the “data subject”, an overview of the processing of your personal data by us and your rights under data protection laws. It is generally possible to use our website without entering personal data. However, if you would like to use special services from our company via our website, processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain your consent.
The processing of personal data, such as your name, address or e-mail address, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to “WallutaGmbH”. By means of this data protection declaration, we would like to inform you about the scope and purpose of the personal data we collect, use and process.
As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection possible for the personal data processed via this website. However, internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are free to send personal data to us via alternative means, for example by telephone or post.
2. Responsible party
The responsible party within the meaning of the GDPR is:
Walluta GmbHSierksdorferstraße 14a23730 Neustadt in HolsteinGermany
Representative of the responsible party: Werner Wildberger
3. Data protection officer
You can contact the data protection officer as follows:
e-mail: info@walluta.de
You can contact our data protection officer directly at any time with all questions and suggestions regarding data protection.
4. Definitions
The data protection declaration is based on the terms used by the European legislator for directives and regulations when issuing the General Data Protection Regulation (GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
In this data protection declaration, we use the following terms, among others:
Personal data
Personal data is all information relating to an identified or identifiable natural person. A natural person is considered identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Affected person
Affected person is any identified or identifiable natural person whose personal data is processed by the controller (our company).
Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or linking, restriction, erasure or destruction.
Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future.
Profiling
Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Processor
A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient
A recipient is a natural or legal person, public authority, agency or other body to which personal data is disclosed, whether or not it is a third party. However, authorities which may receive personal data in the context of a specific investigation in accordance with Union or Member State law shall not be regarded as recipients.
Third party
A third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who are authorized to process the personal data under the direct responsibility of the controller or processor.
Consent
Consent is any expression of will given voluntarily by the data subject for a specific case in an informed and unambiguous manner in the form of a declaration or other unambiguous confirmatory act by which the data subject indicates that they agree to the processing of personal data concerning them.
5. Legal basis for processing
Art. 6 Para. 1 lit. a GDPR (in conjunction with Section 15 Para. 3 TMG) serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary to fulfill a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6 (1) (b) GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Art. 6 (1) (c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) lit. d GDPR.
Ultimately, processing operations could be based on Art. 6 (1) lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal bases if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47, Sentence 2 GDPR).
6. Technology
6.1 SSL/TLS encryption
This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognize an encrypted connection by the fact that “https://” appears in the address line of the browser instead of “http://” and by the lock symbol in your browser line.
We use this technology to protect the data you transmit.
6.2 Data collection when visiting the website
If you only use our website for information purposes, i.e. if you do not register or otherwise send us information, we only collect data that your browser sends to our server (in so-called “server log files”). Our website records a range of general data and information each time you or an automated system accesses a page. This general data and information is stored in the server’s log files. The following can be recorded:
the browser types and versions used,
the operating system used by the accessing system,
the website from which an accessing system reaches our website (so-called referrers),
the sub-websites that are accessed via an accessing system on our website,
the date and time of access to the website,
an abbreviated Internet protocol address (anonymized IP address),
the Internet service provider of the accessing system.
When using this general data and information, we do not draw any conclusions about you personally.
This information is rather required in order to
correctly deliver the contents of our website,
optimize the contents of our website and the advertising for it,
ensure the long-term functionality of our IT systems and the technology of our website, and
to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack.
This data and information collected is therefore evaluated by us both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files are stored separately from all personal data provided by a data subject.
The legal basis for data processing is Art. 6 Paragraph 1 Clause 1 Letter f of GDPR. Our legitimate interest follows from the purposes for data collection listed above.
7. Cookies
7.1 General information on cookies
We use cookies on our website. These are small files that your browser automatically creates and that are stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our site.
The cookie stores information that is related to the specific device used. However, this does not mean that we receive immediate knowledge of your identity.
The use of cookies serves, on the one hand, to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your device for a specific period of time. If you visit our site again to use our services, it will automatically be recognized 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. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These cookies enable us to automatically recognize that you have already been with us when you visit our site again. These cookies are automatically deleted after a defined period of time.
7.2 Legal basis for the use of cookies
The data processed by cookies, which are required for the proper functioning of the website, are therefore necessary to protect our legitimate interests and those of third parties in accordance with Art. 6 Paragraph 1 Clause 1 Letter f of GDPR. For all other cookies, you have given your consent via our opt-in cookie banner in accordance with Art. 6 (1) (a) GDPR.
8. Contents of our website
8.1 Data processing when opening a customer account and for contract processing
In accordance with Art. 6 Paragraph 1 Letter b of GDPR, personal data is collected and processed when you provide it to us for the purpose of executing a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. Your customer account can be deleted at any time and can be done by sending a message to the above-mentioned address of the person responsible. We store and use the data you provide to process the contract. After the contract has been fully processed or your customer account has been deleted, your data will be blocked with regard to tax and commercial retention periods and deleted after these periods have expired, unless you have expressly consented to further use of your data or we have reserved the right to use the data in a legally permitted manner, about which we will inform you accordingly below.
8.2 Data processing when registering to use Walluta online media
In accordance with Art. 6 Paragraph 1 Letter b of GDPR, personal data is collected and processed when it is made available to us for registration to use Walluta online media using the web application. In detail, the following basic steps are required:
The customer registers on the domain www.walluta.de or a landing page of walluta.de and follows the instructions for opening the account. Verification of the email address is required.
This is followed by activation of the account at Walluta and the creation of a crypto wallet at Tangany. Acceptance of Tangany’s terms and conditions is required for this. It is then possible to receive cryptocurrency.
To send cryptocurrencies, two-factor authentication (2FA) via e.g. Google Authenticator and KYC verification by the partner NowID or by trained Walluta staff is required.
After successfully setting up 2FA and KYC, the customer data is shared with the provider Tangany and the wallet’s “Send” function is available.
The KYC information is passed on to Tangany to carry out the services.
8.3 Data processing when registering to use Walluta online media using mobile applications
In accordance with Art. 6 Para. 1 lit. b GDPR, personal data is collected and processed when it is made available to us by the customer for registration to use Walluta online media using the mobile application. With the exception of the following corresponding steps, the following are then required:
The customer visits the respective app store (Google Play or Apple App Store) and downloads the mobile application.
The customer registers in the mobile application and follows the instructions for opening the account. Verification of the email address is required.
By clicking on the link in the confirmation email sent to the customer, the customer confirms the identity of their email address. By confirming their registration, the customer accepts these general terms and conditions. The customer is obliged to use an email address for registration to whose mailbox they have exclusive personal access.
8.4 Data processing for order processing
The personal data we collect will be passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment details to the commissioned credit institution as part of the payment processing, insofar as this is necessary for the payment processing. If payment service providers are used, we will provide explicit information about this below. The legal basis for the transfer of data is Art. 6 Para. 1 lit. b GDPR.
8.5 Contact / contact form
When you contact us (e.g. via contact form or email), personal data is collected. The data collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in answering your request in accordance with Art. 6 Para. 1 lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 Para. 1 lit. b GDPR. Your data will be deleted after your request has been finally processed; this is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention periods to the contrary.
9. Web analysis
9.1 Google Analytics
On our websites we use Google Analytics, a web analysis service provided by Google Ireland Limited (https://www.google.de/intl/de/about/) (Gordon House, Barrow Street, Dublin 4, Ireland; hereinafter referred to as “Google”). In this context, pseudonymized usage profiles are created and cookies (see “Cookies”) are used. The information generated by the cookie about your use of this website, such as browser type/version, operating system used, referrer URL (the previously visited page), host name of the accessing computer (IP address), time of the server request, is transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage for the purposes of market research and needs-based design of these websites. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other data from Google. The IP addresses are anonymized so that an assignment is not possible (IP masking).
You can prevent the installation of cookies by setting your browser software accordingly; however, we would like to point out that in this case, not all functions of this website may be fully available.
This processing is only carried out if you give your express consent in accordance with Art. 6 Paragraph 1 Letter a of GDPR.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).
As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on the following link: Disable Google Analytics. An opt-out cookie is set that prevents future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.
You can find more information on data protection in connection with Google Analytics in the Google Analytics Help (https://support.google.com/analytics/answer/6004245?hl=de).
10. Plugins and other services
10.1 Google Tag Manager
This website uses Google Tag Manager, a cookie-free domain that does not collect any personal data.
This tool enables “website tags” (i.e. keywords that are embedded in HTML elements) to be implemented and managed via an interface. By using the Google Tag Manager, we can automatically track which button, link or personalized image you have actively clicked on and can then record which content on our website is particularly interesting to you.
The tool also triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If you have deactivated at domain or cookie level, this will remain in place for all tracking tags that are implemented with Google Tag Manager.
These processing operations only take place if you give your express consent in accordance with Art. 6 (1) (a) GDPR.
10.2 Google WebFonts
Our website uses so-called web fonts provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, for the uniform display of fonts. When you access a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.
For this purpose, the browser you use must connect to Google’s servers. This allows Google to know that our website was accessed via your IP address. Google Web Fonts are used in the interest of a uniform and attractive display of our website.
These processing operations only take place if you give your express consent in accordance with Art. 6 (1)(a) GDPR.
Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/
11. Your rights as a data subject
11.1 Right to confirmation
You have the right to request confirmation from us as to whether personal data concerning you is being processed.
11.2 Right to information Art. 15 GDPR
You have the right to receive information from us at any time free of charge about the personal data stored about you and a copy of this data in accordance with the statutory provisions.
11.3 Right to rectification Art. 16 GDPR
You have the right to request the rectification of inaccurate personal data concerning you. You also have the right to request the completion of incomplete personal data, taking into account the purposes of the processing.
11.4 Deletion Art. 17 GDPR
You have the right to request that we delete the personal data concerning you immediately if one of the statutory reasons applies and if processing or storage is not necessary.
11.5 Restriction of processing Art. 18 GDPR
You have the right to request that we restrict processing if one of the statutory requirements is met.
11.6 Data portability Art. 20 GDPR
You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. You also have the right to transmit this data to another controller without hindrance from us to whom the personal data was made available, provided that the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and the processing is carried out using automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
Furthermore, when exercising your right to data portability pursuant to Art. 20 (1) GDPR, you have the right to have the personal data transmitted directly from one controller to another, where technically feasible and where doing so does not adversely affect the rights and freedoms of others.
11.7 Objection Art. 21 GDPR
You have the right to object at any time to the processing of personal data concerning you based on Art. 6 Paragraph 1 Letter e (data processing in the public interest) or f (data processing based on a balance of interests) GDPR for reasons arising from your particular situation.
This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 GDPR.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
In individual cases, we process personal data in order to conduct direct advertising. You can object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling insofar as it is related to such direct advertising. If you object to us processing your data for direct marketing purposes, we will no longer process the personal data for these purposes.
In addition, you have the right to object to the processing of personal data concerning you for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR for reasons related to your particular situation, unless such processing is necessary to perform a task carried out in the public interest.
In connection with the use of information society services, you are free to exercise your right of objection by means of automated procedures that use technical specifications, regardless of Directive 2002/58/EC.
11.8 Revocation of consent under data protection law
You have the right to revoke your consent to the processing of personal data at any time with effect for the future.
11.9 Complaint to a supervisory authority
You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.
12. Routine storage, deletion and blocking of personal data
We only process and store your personal data for the period necessary to achieve the purpose of storage or if this has been provided for by the legal provisions to which our company is subject.
If the purpose of storage no longer applies or a prescribed storage period expires, the personal data is blocked or deleted routinely and in accordance with the legal regulations.
13. Duration of storage of personal data
The criterion for the duration of storage of personal data is the respective statutory retention period. After the period has expired, the corresponding data is routinely deleted if it is no longer required to fulfill or initiate a contract.
14. Up-to-dateness and changes to the data protection declaration
This data protection declaration is currently valid and is dated June 2022.
Due to the further development of our websites and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. You can access and print out the current privacy policy at any time on the website at “www.mondogate.com/datenschutzerklaerung”.
This privacy policy was created with the support of the data protection software: audatis MANAGER.