DATA PROTECTION DECLARATION

This privacy policy provides information in accordance with data protection regulations about the collection of data from the data subject, in particular with regard to Art. 13 GDPR.

Data protection declaration

1. Responsible body within the meaning of the GDPR

Zwopr GmbH Atelierstraße 29 81671 Munich www.zwopr.com Local Court Munich, HRB 256547

Managing Director: Bernhard Koller E-Mail: datenschutz@zwopr.com

2. Data protection officer:

You can reach the data protection officer at the following contact options: datenschutz@zwopr.com

The data subject can contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

3. Rights of data subjects

As a data subject, you are generally entitled to the right to information about which personal data stored about you. This includes the right to information about your data stored by us and its processing (Art. 15 GDPR), the right to object to data, data processing (Art. 21 GDPR) and data portability (Art. 21 GDPR). Insofar as your request does not conflict with a legal obligation to retain data, you have the right to have incorrect data right to rectification of inaccurate data and to erasure or restriction of processing of personal data of the personal data in accordance with Art. 16 GDPR. If the processing is based on consent (pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR), this consent can be withdrawn at any time without affecting the revoked at any time without affecting the lawfulness of the processing carried out on the basis of the consent processing is affected.You also have a right to data portability.

Furthermore, you have the right to lodge a complaint with a data protection supervisory authority pursuant to Art. 77 GDPR if you believe that the processing of your personal data is not lawful. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy. If the processing of data is based on your basis of your consent, you are entitled in accordance with Art. 7 GDPR to withdraw your consent to the use of your personal data at any time.

Please note that the revocation only takes effect for the future. Processing that took place before the withdrawal is not affected. Please also note that we may have to retain certain data for a certain period of time in order to fulfill legal requirements for a certain period of time.

Insofar as your personal data is processed in accordance with Art. 6 para. 1 lit. f GDPR to safeguard legitimate interests, you have the right, pursuant to Art. 21 GDPR, to object at any time on grounds relating to your particular situation, to object to the processing of this data at any time.

We will then no longer process this personal data unless we can demonstrate compelling legitimate grounds for the processing. These must outweigh your interests, rights and freedoms, or the processing must be for the establishment, exercise or defense of legal claims.

To exercise these rights, please contact the controller or its data protection officer.

4 Collection and processing of personal data

Personal data is information that can be used to identify a person or describe their behavior, i.e. information that can be traced back to a person. This includes, among other things name, address, e-mail address or telephone number.

a) General information

When you access our website, i.e. if you do not register or otherwise provide information, general information is automatically

information, information of a general nature is automatically collected. This information (server log files) includes, for example, the type of web browser, the operating system operating system used, the domain name of your internet service provider, your IP address and similar information.

They are processed for the following purposes in particular:

1. ensuring a smooth connection setup of the website,

2. to ensure the smooth use of our website

3. evaluation of system security and stability and

4. for other administrative purposes.

We do not use your data to draw conclusions about your person. Information of this kind may be statistically evaluated by us in order to optimize our website and the optimize the technology behind it.

b) Cookies

Like many other websites, we also use so-called "cookies". Cookies are are small text files that are stored on your end device (laptop, tablet, smartphone, etc.) when you when you visit our website. This provides us with certain data such as your IP address, browser used and operating system. Cookies cannot be used to start programs or transmit viruses to a computer. We can use the information contained in cookies to make navigation easier for you and ensure the correct display of our web pages.

Under no circumstances will the data we collect be passed on to third parties or linked to personal data without your link to personal data without your consent.

Of course, you can also view our website without cookies. Internet browsers are regularly set to accept cookies. In general, you can deactivate the use of cookies at any time via your browser settings. Please use the help functions of your Internet browser to find out how to change these settings. Please note that individual functions of our website may not work if you have deactivated the use of cookies.

If you allow us to use cookies through your browser settings or consent, the following cookies the following cookies may be used on our websites: Insofar as these cookies may (also) affect personal data, we will inform you about this in the following sections.

You can delete individual cookies or the entire cookie inventory via your browser settings. You will also receive information and instructions on how to delete these cookies or how their storage can be blocked in advance. Depending on your browser provider, you will find the necessary information under the following links:

1. Mozilla Firefox: https://support.mozilla.org/de/kb/cookies-loeschen-daten-von-websites-

Remove cookies

2. Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-

delete-manage-cookies

3. Google Chrome: https://support.google.com/accounts/answer/61416?hl=de

4. Opera: http://www.opera.com/de/help

5. Safari: https://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=en_DE

c) Registration on our website

When registering to use our personalized services, some personal data is collected, such as name, address, contact and communication data (e.g. telephone number and e-mail address).

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 during registration at any time. Of course, we will also provide you with information about the personal data we have stored about you at any time.

d) Comment function

When users leave comments on our website, in addition to this information, the time of their creation and the user name previously chosen by the website visitor is stored. This is for our security, as we can be prosecuted for unlawful content on our website, even if they were created by users.

By providing the comment function, we would like to make it easy for you to interact with us. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

e) Newsletter

Your data will only be used to send you the newsletter you have subscribed to by e-mail. Your name will be used to address you personally in the newsletter and, if necessary, to identify you if you wish to exercise your rights as a data subject.

To receive the newsletter, it is sufficient to provide your e-mail address. The data you provide will be used exclusively for this purpose. Subscribers may also be informed by e-mail about circumstances relevant to the service or registration (e.g. changes to the newsletter service or technical circumstances).

We require a valid e-mail address for effective registration. In order to verify that registration is actually made by the owner of an e-mail address, we use the "double opt-in" procedure. For this purpose, we log the subscription to the newsletter, the sending of a confirmation email and the receipt of the requested reply. No further data is collected. The data is used exclusively for sending the newsletter and is not passed on to third parties.

Legal basis:

On the basis of your express consent (Art. 6 para. 1 lit. a GDPR), we will regularly send you our newsletter or comparable information by e-mail to your specified e-mail address. You can revoke your consent to the storage of your personal data and its use for the newsletter dispatch at any time with effect for the future. In every newsletter contains a corresponding link. You can also unsubscribe at any time directly on this website or inform us of your revocation via the contact option provided at the end of this privacy policy.

Recipients:

Recipients of the data may be processors.

Storage period:

The data will only be processed in this context for as long as the corresponding consent is available. After that, it will be deleted.

Provision prescribed or required: The provision of your personal data is voluntary, solely on the basis of your consent. We cannot send you our newsletter without your consent.

f) Contact form

The data you enter will be stored for the purpose of individual communication with you. This requires you to provide a valid e-mail address and your name. This is used to assign the request and subsequently answer it. The further data is optional.

Legal basis:

The processing of the data entered in the contact form takes place on the basis of a legitimate interest (Art. 6 para. 1 lit. f GDPR).

By providing the contact form, we would like to make it easy for you to contact us. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

If you contact us to request a quote, the data entered in the contact form will be processed for the purpose of data entered in the contact form for the implementation of pre-contractual measures (Art. 6 para. 1 lit. b GDPR).

Recipients:

Recipients of the data may be processors.

Storage period:

Data will be deleted no later than 6 months after processing the request. If there is a contractual relationship, we are subject to the statutory retention periods according to the German Commercial Code (HGB) and delete your data after these periods have expired.

Provision prescribed or required:

The provision of your personal data is voluntary. However, we can only process your request if you provide us with your name, e-mail address and the reason for the request.

g) Use of Facebook marketing measures

Type and purpose of processing:

We advertise our services on other websites and use tracking measures to evaluate the advertising methods. This enables us to determine which advertising measures you have used to become aware of us and contact us. This takes place via a script ("pixel") that we use on our website. This allows us to understand whether and which users were directed to our website when they clicked on an advertisement were directed to our offer. However, no personal data about you will be processed as long as you do not contact us. In this case we can merge the contact data with the online identification data from the pixel.

Legal basis:

Tracking measures are carried out for the purpose of optimizing and evaluating of our offer. The processing of the aforementioned data is necessary to safeguard our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, i.e. the performance of our business activities.

Recipient:

The recipient of the data is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. However, your data may also be transferred to Facebook in the USA. Facebook is certified under the Privacy Shield Agreement and thereby guarantees to comply with European data protection law.

Storage period:

The data is deleted as soon as it is no longer required for our recording purposes.

Third country transfer:

Google processes your data in the USA and has submitted to the EU_US Privacy Shield

https://www.privacyshield.gov/EU-US-Framework.

h) Profiling, opt-out

If you are logged in to the website of Facebook Ireland Ltd. Facebook Ireland Ltd. can recognize that you have visited our website.

The purpose and scope of the data collection and the further processing and use of the data by Facebook Ireland Ltd. as well as your rights in this regard and setting options to protect your privacy, please refer to the data protection information (www.facebook.com/about/privacy/) of Facebook Ireland Ltd.

You can make your own settings for the advertisements on Facebook (https://www.facebook.com/settings?tab=ads). Among other things, you can use the following links to pages you can prevent the collection of data (opt-out): NAI - http://optout.networkadvertising.org/ or EDAA http://www.youronlinechoices.com/uk/your-ad-choices/.

i) Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter: "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 information generated by the cookie about your use of this website is usually transmitted to a Google server