Private policy
1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We appreciate your visit to our website and thank you for your interest. Below we provide information about how your personal data is handled when you use our website. Personal data means all data by which you can be personally identified.
1.2 The controller responsible for data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is subtel GmbH, Mainzer Str. 3, 10247 Berlin, Germany, Telephone: 08 - 5664 2802, email: info@subtel.se. The controller for the processing of personal data is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data.
1.3 The controller has appointed a Data Protection Officer for this website, who can be reached at the following details: "Jan Eichelmann, Mainzer Str. 3, 10247 Berlin"
2) Data Collection When Visiting Our Website
2.1 If you use our website purely for information purposes, meaning you do not register or otherwise provide information to us, we only collect the data that your browser transmits to our server (so-called “server log files”). When you access our website, we collect the following data, which is technically necessary for us to display the website:
- Our visited website
- Date and time of access
- Amount of data sent in bytes
- Source/referral from which you reached our page
- Browser used
- Operating system used
- IP address used (if applicable, in anonymized form)
Processing is carried out pursuant to Art. 6 (1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. This data is neither passed on nor used for any other purpose. However, we reserve the right to retrospectively check the server log files if there are concrete indications of illegal use.
2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser’s address bar.
3) Hosting & Content Delivery Network
We use a Content Delivery Network provided by the following provider: Cloudinary Ltd., 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, USA
By using this service, we can transmit large media files such as images, page content, or scripts more quickly via regionally distributed servers. The legal basis for this processing is our legitimate interest in improving the stability and functionality of the website according to Article 6 (1)(f) of the GDPR.
To protect our visitors’ personal data, we have concluded a Data Processing Agreement with the provider, which prohibits the disclosure of data to third parties.
Regarding the transfer of personal data to the USA, the provider relies on the standard contractual clauses issued by the European Commission to ensure the level of data protection in Europe is maintained.
4) Cookies
To make our website more attractive for you and to allow you to use all its functions, we use small text files, so-called cookies, which are stored on your computer, mobile device, or other device. Some of these cookies are automatically deleted when you close your browser (so-called session cookies), while others remain on your device for a longer period to store your settings for the website (so-called persistent cookies). You can view the storage duration of persistent cookies in the cookie settings overview of your browser.
Where the cookies we place also involve the processing of your personal data, the legal basis for this processing is either: performance of a concluded contract according to Article 6 (1)(b) of the GDPR; your consent according to Article 6 (1)(a) of the GDPR; or our legitimate interest in providing the best possible system functionality of the website and making your visit to our website as user-friendly and efficient as possible, pursuant to Article 6 (1)(f) of the GDPR.
Using your browser settings, you can decide whether you want to be informed about cookies being placed on your device and whether you want to give consent for individual cookies, certain categories of cookies, or all cookies in general.
Note: If you reject the use of cookies, you may not be able to use all the features our website would otherwise offer you.
5) Contact
5.1 Trustpilot
For review reminders, we use the services of the following provider: Trustpilot A/S, Pilestræde 58, 1112 Copenhagen K, Denmark
Only if you have given your explicit consent according to Article 6 (1)(a) of the GDPR will we transmit your email address and possibly other customer data to the provider so that they can send you an email reminder to submit a review.
You can revoke your consent at any time with effect for the future by notifying us or the provider.
To protect our visitors’ personal data, we have concluded a Data Processing Agreement with the provider, which prohibits the disclosure of data to third parties.
5.2 When contacting us (e.g. via a contact form or email), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is used and stored solely for the purpose of responding to your inquiry or for making contact and carrying out the associated technical administration.
The legal basis for processing the data is our legitimate interest in responding to your inquiry according to Art. 6 (1)(f) GDPR. If the purpose of the contact is to conclude a contract, then an additional legal basis for processing is Art. 6 (1)(b) GDPR. The data will be deleted once your inquiry has been processed. This applies if it can be inferred from the circumstances that the relevant matter has been conclusively resolved, provided no statutory retention obligations prevent such deletion.
6) Data Processing When Opening a Customer Account and for Contract Management
Pursuant to Art. 6 (1)(b) GDPR, personal data will also be collected and processed if you provide it to us for the purpose of fulfilling a contract or opening a customer account. The data collected can be seen from the respective input forms. You can delete your customer account at any time by notifying the address/person responsible mentioned above. We store and use the data you provide for the processing of orders. Once the contract has been fully fulfilled or your customer account has been deleted, your data will be blocked in compliance with tax and commercial retention periods and then deleted unless you have expressly consented to further use of your data or if we are legally permitted to further process your data, which we inform you about below.
7) Data Processing for Order Handling
7.1 The personal data we collect is disclosed to the transport company commissioned with the delivery within the scope of order processing, insofar as this is necessary to deliver the goods. We also disclose your payment data to the financial institution commissioned to process payments, insofar as it is necessary for payment handling. If a payment service provider is used, this will be clearly communicated below. The legal basis for the transfer of data is Art. 6 (1)(b) GDPR.
7.2 Use of Payment Providers (Payment Service Providers)
- Adyen
This website offers one or more online payment methods by the following provider: Adyen, Simon Carmiggeltstraat 6 - 50, 1011 DJ Amsterdam, Netherlands
If you select a payment method with this provider (such as credit card payment), the payment details you provide during the order (name, address, bank and credit card details, currency, transaction number, etc.), along with information about the content of the order, will be transmitted to the provider in accordance with Article 6 (1)(b) GDPR. In this case, your personal data will only be transmitted for the purpose of processing the payment and only to the extent necessary for this purpose.
- Paypal
This website offers one or more online payment methods by the following provider: PayPal (Europe) S.à r.l. et Cie, S.C.a., 22-24 Boulevard Royal, L-2449 Luxembourg
If you select a payment method with this provider (such as advance payment), the payment details you provide during the order (name, address, bank and credit card details, currency, transaction number, etc.), along with information about the content of the order, will be transmitted to the provider in accordance with Article 6 (1)(b) GDPR. In this case, your personal data will only be transmitted for the purpose of processing the payment and only to the extent necessary for this purpose.
If you select a payment method that involves a credit purchase, you will also be asked during the order process to provide certain personal information (first and last name, street address with house number, postal code, city, date of birth, email address, telephone number, and possibly data on alternative payment methods).
In accordance with our legitimate interest under Article 6 (1)(f) GDPR in determining our customers’ creditworthiness, we transmit this personal data to the provider for the purpose of a credit check. The provider checks whether the payment method you selected can be approved, basing its decision on the personal data you have provided as well as other data (such as the contents of the shopping cart, invoice amount, order history, payment history), with regard to the risk of non-payment or inability to collect the claim.
8) Web Analytics Services
Google Analytics 4
This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (hereinafter "Google"), which can be used to analyze how websites are utilized.
When using Google Analytics 4, so-called cookies are typically employed. Cookies are small text files that are stored on your computer, mobile device, or other terminal and help analyze your usage of a website. The data collected by the cookies regarding your usage of the website (including the IP address transmitted by your terminal—but with the last digits truncated, see below) is generally transmitted to one of Google’s servers, where it is stored and processed. In doing so, the data may also be transmitted to servers belonging to Google LLC, based in the USA, for further processing.
When using Google Analytics 4, the IP address your terminal transmits upon visiting the website is always automatically collected and processed in anonymized form, so that the recorded data cannot be directly linked to you as an individual. This automatic anonymization is achieved by Google truncating the last digits of the IP address transmitted by your terminal within the European Union (EU) or other Contracting States of the European Economic Area (EEA).
On our behalf, Google uses this and other data to evaluate your usage of the website, compile reports about your behavior on the website, and provide us with these and other services related to your usage of the website and the internet. In this regard, Google Analytics 4 will not combine the IP address transmitted by your terminal (once truncated) with other data from Google. Data collected in connection with the use of Google Analytics 4 is stored for 2 months and then deleted.
Google Analytics 4 also offers a so-called demographic feature that allows the creation of statistics on age, gender, and interests of the website’s users, based on evaluations of interest-based advertising and data from third-party providers. This makes it possible to determine and distinguish between different user groups for the purpose of optimizing marketing measures targeted at specific audiences. The data collected via the "demographic feature" cannot be associated with any particular individual and thus not with you personally. Data collected via the "demographic feature" is stored for two months and then deleted.
All the processing described above, particularly the placement of Google Analytics cookies for the storage and reading of information on the device you use to visit the website, is carried out only if you have given us your express consent under Article 6 (1)(a) of the GDPR. If you do not give your consent, Google Analytics 4 will not be used when you visit the site. You can withdraw your consent at any time with future effect. To do so, simply deactivate this service in our "Cookie Consent Tool" available on the website.
On this website, the service "Google Signals" may also be used as an extension of Google Analytics. With Google Signals, Google can create cross-device reports ("cross-device tracking"). If you have enabled "personalized ads" in your Google Account settings and linked your internet-enabled devices to your Google Account, Google can analyze user behavior across devices and create database models based on this, provided that you have given your consent to the use of Google Analytics under Article 6 (1)(a) of the GDPR (as described above). The logins and device types of all site visitors who are logged into a Google Account and complete a conversion are taken into account. The data shows, among other things, which device you first clicked on an ad from and on which device the corresponding conversion took place. Where Google Signals is used, we do not receive any personal data from Google, only statistics created on the basis of Google Signals. You can disable the "personalized ads" function in your Google Account settings to turn off cross-device analysis.
To do so, follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=sv
Further information can be found here: https://support.google.com/analytics/answer/7532985?hl=sv
As an extension of Google Analytics, the "UserIDs" function can also be used on this website. By assigning individual UserIDs, we allow Google to create cross-device reports ("cross-device tracking"). This means that your user behavior can be analyzed across devices if you have consented to the use of Google Analytics in accordance with Article 6 (1)(a) of the GDPR, if you have created a personal account on this website and are logged into your personal account on various devices using your relevant login credentials. The data collected in this way shows, among other things, on which device you first clicked on an ad and on which device the relevant conversion took place.
We have concluded a Data Processing Agreement with Google for our use of Google Analytics 4, which obliges Google to protect our customers’ personal data and not to pass them on to third parties.
For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
For more legal information on Google Analytics 4, see: https://business.safety.google/intl/sv/privacy/ and https://policies.google.com/privacy?hl=sv&gl=de
For more detailed information on the data processing triggered by Google Analytics 4 and on how Google handles data from websites, please refer to: https://policies.google.com/technologies/partner-sites
9) Retargeting/Remarketing/Recommendation Advertising
Google Ads Conversion Tracking
This website uses the online advertising program Google Ads and, within the scope of Google Ads, the Google conversion tracking function provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (hereinafter referred to as Google). We use the services of Google Ads to draw attention to our attractive offers on external websites by means of advertising tools (Google Adwords). By analyzing the data from advertising campaigns, we can determine how successful the individual advertising measures are. Our goal with this technology is to show you advertising that interests you, to make our website more interesting for you, and to achieve a fair calculation of our advertising costs.
The conversion tracking cookie is placed on the user’s device when the user clicks on an ad placed by Google Ads. Cookies are small text files that are stored on your computer, mobile device, or other device. These cookies generally become invalid after 30 days and are not used for personal identification. If the user visits certain pages of this website while the cookie is still valid, Google and we can detect that the user clicked on the Google ad and was redirected to that page. Each Google Ads customer receives a different conversion cookie. Thus, cookies cannot be tracked across the websites of Google Ads customers. The data collected using the conversion cookies is used to compile conversion statistics (completion of a transaction) for those Google Ads customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can identify users personally.
When using Google Ads, personal data may also be sent to servers belonging to Google LLC in the USA.
For more detailed information on the data processing triggered by Google Ads conversion tracking and on how Google handles data from websites, please refer to https://policies.google.com/technologies/partner-sites?hl=sv.
The personal data processing described above, especially the storage of cookies for reading information on the user’s computer, mobile device, or other device, is carried out only if you have given us your explicit consent pursuant to Article 6 (1)(a) of the GDPR. You may revoke your consent at any time with effect for the future by deactivating this service in the Cookie Consent Tool provided on the website.
To permanently object to the placement of conversion tracking cookies by Google Ads on your device, you can also download and install a browser plugin that Google provides at the following link:
https://support.google.com/ads/answer/7395996
In order to optimize our interest-based advertising toward users who have provided data as part of a business relationship or similar, we use a "customer matching" function within Google Ads. For this purpose, we electronically transfer one or more files containing aggregated customer data (primarily email addresses and phone numbers) to Google. Google does not gain access to the data in plain text; instead, the information in the customer files is automatically encrypted via a special algorithm during transmission. Google can then only use the encrypted information to match it with existing Google Accounts that were created for this purpose. This makes it possible to strategically place targeted advertising across all Google services connected to the respective Google Account.
Such transmission of customer data to Google takes place only if you have given us your consent under Article 6 (1)(a) of the GDPR. You can revoke your consent at any time with effect for the future.
For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
More information on Google’s privacy measures with respect to the customer matching function can be found here: https://support.google.com/google-ads/answer/6334160?hl=sv&ref_topic=10550182
Google’s privacy policy can be found here: https://business.safety.google/intl/sv/privacy/ and https://policies.google.com/privacy?hl=sv.
10) Site Functions
10.1 YouTube
This website uses plugins for displaying and playing videos from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Data may also be transferred to: Google LLC., USA
When you visit a page on our website that contains such a plugin, your browser establishes a direct connection to the provider’s servers to load the plugin. In this process, certain data, including your IP address, is transmitted to the provider.
If you start playing embedded videos via the plugin, the provider also uses cookies to collect information about user behavior, compile playback statistics, and prevent misuse.
If you are logged into a user account with the provider during your visit to the page, your data will be directly associated with your account when you click on a video. If you do not want this association with your account, you must log out before clicking the play button.
The personal data processing described above, in particular the use of cookies for reading information on your device, takes place only if you have given us your express consent pursuant to Article 6 (1)(a) of the GDPR. You may revoke your consent at any time with future effect by deactivating this service via the Cookie Consent Tool provided on the website.
For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
10.2 Google Web Fonts
In order to display fonts uniformly, this site uses so-called web fonts from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Data may also be transferred to: Google LLC, USA
When you open a page, your browser loads the required web fonts from its cache to display texts and fonts correctly, establishing a direct connection to the provider’s servers. In this process, certain browser information, including your IP address, is transmitted to the provider.
The processing of personal data in connection with connecting to the font provider is carried out only if you have given your explicit consent under Article 6 (1)(a) of the GDPR. You can revoke your consent at any time with future effect by disabling this service via the Cookie Consent Tool provided on the website. If your browser does not support web fonts, a default font on your computer is used instead.
For data transfers to the USA, the provider has signed the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
More information on Google’s data protection measures can be found here: https://business.safety.google/intl/sv/privacy/
11) Rights of the Data Subject
11.1 The applicable data protection law grants you comprehensive rights as a data subject with respect to the controller (rights to information and intervention), which we inform you about below:
- Right of access according to Art. 15 GDPR;
- Right to rectification according to Art. 16 GDPR;
- Right to erasure according to Art. 17 GDPR;
- Right to restriction of processing according to Art. 18 GDPR;
- Right to notification according to Art. 19 GDPR;
- Right to data portability according to Art. 20 GDPR;
- Right to revoke consent according to Art. 7 (3) GDPR;
- Right to lodge a complaint according to Art. 77 GDPR.
11.2 Right to object
When we process your personal data based on our overriding legitimate interest as part of a balancing of interests, you have the right at any time, for reasons arising from your particular situation, to object to this processing with effect for the future.
If you exercise your right to object, we will stop processing the data in question. However, we reserve the right to continue processing if we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, fundamental rights, and freedoms, or if the processing serves to assert, exercise, or defend legal claims.
If your personal data is processed by us for direct marketing purposes, you have the right at any time to object to the processing of your personal data for such marketing purposes. You can exercise this right to object as described above.
If you exercise your right to object, we will cease processing the relevant data for direct marketing purposes.
12) Duration of Storage of Personal Data
The duration of storage of personal data depends on the respective statutory retention period (e.g., commercial and tax retention periods). After the period expires, the corresponding data will be routinely deleted, provided it is no longer needed for the fulfillment or initiation of the contract and/or if there is no legitimate interest on our part for further storage.