data privacy

PRIVACY

1. data protection at a glance General information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For more detailed information on data protection, please refer to our privacy policy listed below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find his contact details in the section "Note on the responsible party" in this data protection declaration.

How do we collect your data?

On the one hand, your data is collected by you providing it to us. This can be, for example, data that you enter in a contact form.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. Internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

For this purpose, as well as for further questions on the subject of data protection, you can contact us at any time.

Analysis tools and third-party tools

When visiting this website, your surfing behavior may be statistically analyzed. This is done primarily with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

2. hosting and content delivery networks (CDN) Google Cloud CDN.

We use the content delivery network Google Cloud CDN. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google offers a globally distributed content delivery network. This technically routes the transfer of information between your browser and our website via Google's network. This allows us to increase the worldwide accessibility and performance of our website.

The use of Google Cloud CDN is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6 para. 1 lit. f DSGVO).

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:

https://cloud.google.com/terms/eu-model-contract-clause.

More information about Google Cloud CDN can be found here: https://cloud.google.com/cdn/docs/overview?hl=de.

The company has certification in accordance with the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. For more information, please contact the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000001L5AAI&status=Active

Order processing

We have concluded a contract on order processing (AVV) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that this processes the personal data of our website visitors only according to our instructions and in compliance with the DSGVO.

3. General notes and obligatory information Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this data protection declaration.

When you use this website, various personal data are collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

Note on the responsible party

The responsible party for data processing on this website is:

Cream Capital AG (Private Limited)

The Caldervale Road

West Yorkshire, United Kingdom, WF1 5PF Wakefieldt 09726045 Register Court: Company House Represented by:

Director Stuart Glinton

Telephone: +447500042468 E-mail: stuartglindon@gmail.com

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage period

Unless a more specific storage period has been stated within this data protection declaration, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO, insofar as special data categories

are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1) a DSGVO. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of Section 25 (1) TTDSG. The consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b DSGVO. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6 para. 1 lit. c DSGVO. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6 para. 1 lit. f DSGVO. Information about the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of personal data

In the course of our business activities, we cooperate with various external bodies. In some cases, this also requires the transfer of personal data to these external bodies. We only pass on personal data to external bodies if this is necessary within the framework of the performance of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in passing on the data in accordance with Art. 6 (1) lit. f DSGVO or if another legal basis permits the passing on of the data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on commissioned processing. In case of joint processing, a contract on joint processing will be concluded.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your explicit consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to the collection of data in specific cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6 ABS. 1 LIT. E OR F DSGVO, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION UNDER ARTICLE 21 (1) DSGVO).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ARTICLE 21 (2) DSGVO).

Right of appeal to the competent supervisory authority

In the event of violations of the GDPR, data subjects shall have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right of appeal is without prejudice to any other administrative or judicial remedy.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request direct transfer of the data to another responsible party, this will only be done insofar as it is technically feasible.

Information, correction and deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if necessary, a right to correction or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.

If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.

If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request restriction of the processing of your personal data instead of erasure.

If you have lodged an objection pursuant to Art. 21 (1) DSGVO, a balancing of your and our interests must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data - apart from its storage - may only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. data collection on this website cookies

Our internet pages use so-called "cookies". Cookies are small data packets and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser.

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies can be used to evaluate user behavior or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. When deactivating cookies, the functionality of this website may be limited.

You can find out which cookies and services are used on this website in this privacy policy.

Contact form

If you send us inquiries via the contact form, your data from the inquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b DSGVO, if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 (1) (f) DSGVO) or on your consent (Art. 6 (1) (a) DSGVO) if this has been requested; the consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions - in particular retention periods - remain unaffected.

Google Forms

We have integrated Google Forms on this website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter Google).

Google Forms allows us to create online forms to collect messages, requests and other input from our website visitors in a structured way. All entries made by you are processed on Google's servers. Google Forms stores a cookie in your browser that contains a unique ID (NID cookie). This cookie stores various information such as your language settings.

The use of Google Forms is based on our legitimate interest in determining your request in the most user-friendly way possible (Art. 6 para. 1 lit. f DSGVO). If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

The data you enter in the form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g., after we have completed processing your request). Mandatory legal provisions - in particular retention periods - remain unaffected.

For further information, please refer to Google's privacy policy at https://policies.google.com/.

The company is certified in accordance with the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. For more information, please contact the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000001L5AAI&status=Active

Order processing

We have concluded an order processing agreement (AVV) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that this processes the personal data of our website visitors only according to our instructions and in compliance with the DSGVO.

5. analysis tools and advertising Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, dwell time, operating systems used and the origin of the user. This data is summarized in a user ID and assigned to the respective end device of the website visitor.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Furthermore, Google Analytics uses various modeling approaches to supplement the collected data sets and uses machine learning technologies in the data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this service is based on your consent according to Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG. The consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:

https://privacy.google.com/businesses/controllerterms/mccs/.

The company is certified in accordance with the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. For more information, please contact the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000001L5AAI&status=Active

Browser Plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

For more information on how Google Analytics handles user data, please see Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Order processing

We have concluded an order processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising program of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to play advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Furthermore, targeted advertisements can be played on the basis of user data available at Google (e.g. location data and interests) (target group targeting). As the website operator, we can evaluate this data quantitatively by analyzing, for example, which search terms have led to the playout of our advertisements and how many ads have led to corresponding clicks.

The use of this service is based on your consent in accordance with Art. 6 Para. 1 lit. a DSGVO and § 25 Para. 1 TTDSG. The consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:

https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

Google Ads Remarketing

This website uses the functions of Google Ads Remarketing. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads Remarketing allows us to assign people who interact with our online offer to specific target groups in order to subsequently display interest-based advertising in the Google advertising network (remarketing or retargeting).

Furthermore, the advertising target groups created with Google Ads Remarketing can be linked to Google's cross-device functions. In this way, interest-based, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one end device (e.g. cell phone) can also be displayed on another of your end devices (e.g. tablet or PC).

If you have a Google account, you can object to personalized advertising at the following link:

https://www.google.com/settings/ads/onweb/.

The use of this service is based on your consent in accordance with Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG. The consent can be revoked at any time.

Further information and the data protection provisions can be found in Google's privacy policy at:

https://policies.google.com/technologies/ads?hl=de.

Target group formation with customer matching

For target group formation, we use, among other things, the customer matching of Google Ads Remarketing. In this process, we transfer certain customer data (e.g. e-mail addresses) from our customer lists to Google. If the customers in question are Google users and logged into their Google account, they are shown suitable advertising messages within the Google network (e.g. on YouTube, Gmail or in the search engine).

6. newsletter Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the specified e-mail address and agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the processing of the newsletter, we use newsletter service providers, which are described below.

Mailchimp with deactivated performance measurement

This website uses the services of Mailchimp for sending newsletters. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

Mailchimp is a service with which, among other things, the sending of newsletters can be organized. When you enter data for the purpose of receiving newsletters (e.g. e-mail address), this data is stored on Mailchimp's servers in the USA. We have deactivated the performance measurement at Mailchimp, so that Mailchimp will not evaluate your behavior when opening our newsletter.

If you do not want your data to be transferred to Mailchimp, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.

The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you have provided to us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data that has been stored by us for other purposes remains unaffected by this.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:

https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/#Annex_C_-_Standard_Contractual_Clauses.

After you have unsubscribed from the newsletter distribution list, your e-mail address will be stored by us or the newsletter service provider in a blacklist, if necessary, to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1) f DSGVO). The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

For more details, please refer to Mailchimp's privacy policy at: https://mailchimp.com/legal/terms/.

The company is certified in accordance with the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. For more information, please contact the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000TXVKAA4&status=Active

Order processing

7. plugins and tools

YouTube with enhanced data protection

This website embeds videos from the website YouTube. The operator of the pages is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the transfer of data to YouTube partners is not necessarily excluded by the extended data protection mode. Thus, YouTube - regardless of whether you watch a video - establishes a connection to the Google DoubleClick network.

As soon as you start a YouTube video on this website, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, YouTube can save various cookies on your end device after starting a video or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve the user experience, and prevent fraud attempts.

If applicable, further data processing operations may be triggered after the start of a YouTube video, over which we have no control.

YouTube is used in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO. Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Further information about data protection at YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=de.

8. own services Google Drive

We have integrated Google Drive on this website. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Drive allows us to include an upload area on our website where you can upload content. When you upload content, it is stored on Google Drive's servers. When you enter our website, a connection to Google Drive is also established so that Google Drive can determine that you have visited our website.

The use of Google Drive is based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in a reliable upload area on its website. If a corresponding consent has been requested, the processing is based exclusively on Art. 6 (1) a DSGVO; the consent can be revoked at any time.

Order processing

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