Updated July 2025

Preamble

Data protection is very important to us and your trust is our top priority. We therefore always treat your personal data confidentially and, of course, comply with all relevant legal data protection regulations. We therefore only process your personal data to the extent permitted by law or if you have given us your consent to do so.In this privacy policy, you will learn:
·       How we handle personal data on the internet.
·       What information about visitors to our website and users of our app is collected and evaluated.
·       Whether and how this information is used, passed on or otherwise processed. 
This policy applies to all information collected during the use of our website and our MyHunt app (hereinafter referred to as "app") or provided by the user.

1. Responsible party

Hunter & Companion GmbH          
Zielstattstr. 19    
81379 Munich

(hereinafter referred to as "HC") 

For further information, please refer to the imprint.

2. Data protection officer

Attorney Dr. Jochen Notholt
comp/lex – Data protection officer
Lindwurmstr. 10
80337 Munich
E-Mail: jn@comp-lex.de
Tel.: +49 89 41614295-2

3. Website

3.1 SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator. You can recognise 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.

3.2 When you visit our website

When you visit our website, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you. The legal basis for this processing is Art. 6 (1) (f) GDPR:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software

Microsoft AzureWe use the hosting service provider Microsoft Azure, One Microsoft Way, Redmond, WA 98052-6399,USA. Servers or systems at the server location in Frankfurt, Germany, are used for the processing of personal data.
For information on possible transfers to third countries (USA), please refer to section 7.1.

3.3 Cookies

This website uses cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, effective and secure. Cookies are small data files that are stored on your computer and saved by your browser.Most of the cookies we use are so-called "session cookies". They are automatically deleted at the end of your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognise your browser the next time you visit.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. If you deactivate cookies, the functionality of this website may be restricted.The website operator has a legitimate interest in storing cookies for the technically error-free and optimised provision of its services in accordance with Art. 6(1) 1 lit f GDPR.

3.4 Google Analytics

Our website optionally uses Google Analytics so that we can further improve future website visits. The provider is Google Inc., Google Ireland Limited (Gordon House,Barrow Street, Dublin 4, Ireland, hereinafter referred to as "Google").
For information on possible transfer to third countries (USA), see section 7.3.
You can consent to the use of Google Analytics when you visit the website. You can revoke your consent to the use of Google Analytics at any time.
You can manage your advertising preferences at any time in Google's ad settings and deactivate the use of cookies for personalised advertising there:
https://adssettings.google.com/authenticated
You can also delete cookies in your browser or object to them by using the opt-out cookie provided by the EU initiative "Your Online Choices":
https://www.youronlinechoices.com/de/praferenzmanagement/
If you give us your consent, we will evaluate your use of the website. To do this, we process the following personal data about you: ·      IP address (only processed in abbreviated or anonymised form
·      Date and time of the request
·      Timezone difference from Greenwich Mean Time (GMT)
·      Content of the request (specific page)
·      Access status/HTTP status code
·      Amount of data transferred in each case
·      Website from which the request originates
·      Browser
·      Type information about the end device
·      Operating system and its interface
·      Language and version of the browser software
·      Screen and window resolution
·      Your approximate location
·      Information about how long you stayed on the site
·      Information about your actions on the website
We therefore transmit the above data to Google for analysis purposes. We use IP anonymisation so that your IP address is truncated before being sent. On our behalf, Google evaluates the data on how you use the website, as this data is necessary for us to ensure the stability and security of the website and to develop it in line with your interests. The data collected in this way is not merged with your other profile information, but is included in anonymous statistics that help us to get to know our users better and to better tailor the website to their needs. The legal basis for the collection is your consent in accordance with Art. 6 (1) 1 lit a GDPR.
The recipient of the data is Google. We have concluded a contract with Google for order processing in accordance with Art. 28 GDPR and have implemented the EU standard contractual clauses.

3.5 Google Ads

We use "GoogleAds" on our website. This is an online advertising service provided by Google.Google Ads enables us to place interest-based and target group-oriented advertisements in the Google advertising network. To do this, Google uses cookies and similar technologies to collect usage information (e.g. websites visited, click and conversion data).
For information on possible transfers to third countries (USA), see section 7.3.
You can consent to the use of Google Analytics when you visit the website. You can revoke your consent to the use of Google Analytics at any time.
The purposes of processing are to compile usage and conversion statistics, place advertisements relevant to the target group and measure the effectiveness of advertising (conversion tracking). As with Google Analytics, processing is based on your consent. Please note the information provided there regarding revocation and the recipient of the data.

3.6 Google Analytics Remarking

Our websites use the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google AdWords and Google DoubleClick. The provider here is also Google, with the aforementioned address data.
For information on possible transfer to third countries (USA), see section 7.3.
This function enables the advertising target groups created with Google Analytics Remarketing to be linked to the cross-device functions of Google AdWords and GoogleDoubleClick. In this way, interest-based, personalised advertising messages that have been tailored to you based on your previous usage and surfing behaviour on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).
If you have given your consent, Google will link your web and app browsing history to your Google account for this purpose. This allows the same personalised advertising messages to be displayed on every device you log into with your Google account.
To support this feature, Google Analytics collects Google-authenticated user IDs, which are temporarily linked to our Google Analytics data to define and create target groups for cross-device advertising.
The summary of the data collected in your Google account is based solely on your consent, which you can give or withdraw from Google (Art. 6(1)(a) GDPR).
For data collection processes that are not merged into your Google account (e.g. because you do not have a Google account or have objected to the merger), the data is collected only on the basis of your express consent in accordance with Art. 6(1) lit. a GDPR.
Further information and the data protection provisions can be found in Google's privacy policy at: https://www.google.com/policies/technologies/ads/.
Processing is carried out on the basis of your consent, as is the processing of data byGoogle Analytics and Google Ads. Please note the information provided there regarding revocation and the recipient of the data.

3.7 IP-anonymization

We have activated the "IP anonymization" function. This means that your IP address will be truncated by Google within member states of theEuropean Union or in other signatory states to the Agreement on the EuropeanEconomic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website and this app, Google will process the information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

3.8 Plugins und Tools

3.8.1 Meta Pixel
We use the MetaPixel (formerly Facebook Pixel) from Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (hereinafter "Meta") on our website. Meta Pixel is an analytics service that tracks the behaviour of website visitors after they click on a Facebook advertisement. Cookies and similar technologies are used for this purpose. The data collected includes page views, click and conversion data.
For information on possible transfers to third countries (USA), see section 7.4.

The tool allows the effectiveness of Facebook advertisements to be evaluated for statistical and market research purposes and future advertising measures to be optimised.
The data collected is anonymous to us as the operator of this website; we cannot draw any conclusions about the identity of users. However, the data is stored and processed by Meta or Facebook, so that a connection to the respective user profile is possible and Meta can use the data for its own advertising purposes in accordance with the Meta Data Use Policy. This enables Meta to place advertisements on Meta services (in addition to Facebook, Instagram is also aMeta service) and outside of Meta services.
As the website operator, we have no influence over this use of the data. The data is transferred on the basis of your consent in accordance with Art. 6 (1) 1 aGDPR. Without your consent, no pixel cookie will be set and no data will be transferred to Meta.
More information about the processing of your data by Facebook:https://de-de.facebook.com/help/566994660333381/?helpref=uf_share
You can also deactivate the "Custom Audiences" remarketing function in the ad settings section athttps://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.
If you do not have a Facebook account, you can deactivate usage-based advertising from Facebook on the website of the European Interactive DigitalAdvertising Alliance:
http://www.youronlinechoices.com/de/praferenzmanagement/

3.8.2 Hotjar
This website uses the web analytics service Hotjar from Hotjar Ltd. Hotjar Ltd. is a European company based in Malta (Hotjar Ltd, Level 2, St Julians Business Centre, 3,Elia Zammit Street, St Julians STJ 1000, Malta, Europe Tel.: +1 (855)464-6788). This tool allows movements on websites where Hotjar is used to be tracked (so-called heat maps). For example, it is possible to see how far users scroll and which buttons they click on and how often. The tool also makes it possible to obtain feedback directly from website users. This provides us with valuable information that helps us to make our websites even faster and more customer-friendly. When using this tool, we pay particular attention to the protection of your personal data. This means that we can only track which buttons you click on and how far you scroll. Areas of the websites where personal data from you or third parties is displayed are automatically hidden by Hotjar and are therefore not traceable at any time. The use of Hotjar is based on our legitimate interest in accordance with Art. 6 (1) 1 lit f GDPR.
Hotjar offers every user the option of using a "Do Not Track header" to prevent the use of the Hotjar tool, so that no data about the visit to the respective website is recorded. This is a setting that all current versions of common browsers support. To do this, your browser sends a request to Hotjar, indicating that tracking of the respective user should be deactivated. If you use our website with different browsers/computers, you must set up the "DoNot Track header" separately for each of these browsers/computers.
Detailed instructions with information about your browser can be found at:https://www.hotjar.com/opt-out Further information about Hotjar Ltd. and the Hotjar tool can be found at: https://www.hotjar.com The privacy policy of Hotjar Ltd. can be found at: https://www.hotjar.com/privacy

4. MyHunt App

When you use our MyHunt app (hereinafter referred to as "app"), we process additional personal data. A detailed description of the respective data and an explanation of how we process it can be found below. The definition of the app also includes the functions corresponding to the app, provided that these are additionally made available via an internet address and can be accessed using an internet browser. Personal data is collected on the basis of the existing service contract in accordance with Art.6 (1) (b) GDPR. It is not possible to use the app without providing the above-mentioned registration data.Further personal data is collected and processed on the basis of our legitimate interest pursuant toArt. 6 (1) (1) (f) GDPR or on the basis of your express consent pursuant toArt. 6 (1) (1) (a) GDPR. You can object to the collection of this data at anytime without incurring any disadvantages.If you decide to use the application, you must create an account. These instructions apply regardless of whether you choose a PRO or free account.

4.1.1 Opening the app

As soon as the app is opened, the following personal information is collected and stored:
- IP address
- Time of opening the app,
- Operating system used as well as its version,
- Country, region,
- Mobile device used.

We collect the aforementioned data on the basis of Art. 6 (1) (f) GDPR and thus in our legitimate interest. This lies in improving our service and the app. The logged data is intended to help simplify the use of the app for the user and to make the app even better. The data collected here is stored in a personalised manner and can be assigned to the respective user.

4.1.2 Registration via the website or within the app

You can register directly in the app or via our website. For both types of registration, we store the following data:
·      Surname, first name,
·      Email address.
The personal data required here is mandatory information without which we cannot make the app available to you. The legal basis for this is Art. 6 (1) (b) GDPR in connection with the free usage agreement between you and HC.
You can optionally add a profile picture to your profile. This is not necessary for using the app. As the collection of data is voluntary, reference is made to Art. 6 (1) (a) GDPR.You can remove your picture from your profile at any time.
The data collected here is stored on the servers of Amazon Web Services (hereinafter "AWS") andMicrosoft Azure within the EU/EEA. It is not passed on to third parties.

Microsoft Azure
We use MicrosoftAzure, One Microsoft Way, Redmond, WA 98052-6399, USA, as our hosting service provider. Servers or systems at the server location in Frankfurt, Germany, are used for the processing of personal data.
For information on possible transfers to third countries (USA), please refer to section 7.1.

4.1.3 Social Sign-In

At the beginning of the registration process in the mobile app, you also have the option of registering with a single sign-on solution if you have an account with Facebook(Meta), Apple or Google.
The data protection and terms of use of the respective provider apply to registration and use. Your account details are entered directly on the provider's server and are not transmitted to us. The respective provider will inform you whether and which data from your social media account is made available to us.
Personal data(first name, surname, email address) will only be transmitted to us during registration via the provider (Facebook, Apple or Google) if you have given your express consent in accordance with Art. 6 (1) 1 lit a GDPR.
The data transmitted to us by the provider is used to set up your account in our app and to enable us to perform a plausibility check.
Your data will be deleted when you delete your user account with us. The legal basis for processing is the execution of the user relationship between you and us, Art. 6para. lit a GDPR, or between your employer and us, Art. 6 para. lit f GDPR(interest in securely authenticating your access through established services).
For information on data collection and further processing, as well as your rights in this regard and settings options for protecting your privacy, please refer to the privacy policies of Google, Facebook and Apple. The respective provider is responsible for data protection for the respective single sign-on solution.

4.1.4 Google Firebase

Data is collected via the Google Firebase application integrated into the app. We use Google Firebase Analytics, Firebase Dynamic Links and Firebase App Distribution. Firebase is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, on the basis of a data processing agreement. The data collected here is stored in the Google Cloud (BigQuery). The data is stored on a server located inFrankfurt. It cannot be ruled out that data may also be transferred to the USA.

For information on possible transfers to third countries (USA), see section 7.3.

Firebase Analytics
We use Google Analytics Firebase to collect general data about the use of the app, to analyze the use of the appp and to optimize the user experience. We collect and store the following data: Frequency of page views, search terms, use of website features, duration of visit. A detailed description of the information collected and processed can be found here: https://firebase.google.com/support/privacy#data_processing_information.

The legal basis for the use of the Google Analytics for Firebase service is your consent pursuant to Art. 6 (1) lit a DSGVO. Consent can be revoked at any time by deactivating the respective switch for this in the analysis settings.

Firebase Dynamic Links
With this service, Google processes device specifications and IP addresses on our behalf for iOS in order to open newly installed apps for a specific page or context. Google stores device specifications and IP addresses only temporarily to provide the service.

The legal basis for the use of Dynamic Firebase Links is Art. 6 (1) (f) GDPR. In doing so, we pursue our legitimate interest in improving and optimizing our apps, for which this service is technically necessary.

You can also object to the data collection at any time for the future. You can make the corresponding settings under the "Other" tab in your profile settings.

The data collected here will be stored for a period of 24 months and then deleted.

4.1.5 Facebook (Meta)

Further personal data in the form of the following information is collected by the integrated application of the provider Meta (Facebook) together with a randomly generated user ID and transmitted to them:
- Registration of a new account,    
- Launch of the app.
The data collected here is transmitted to Meta (Facebook) and stored outside the EU/EEA, regardless of whether you have an account with Facebook. For information on possible transfer to third countries (USA), see section 7.4.We have no influence on further data processing by Meta. You can find out more about Meta's (Facebook) privacy policy here: https://www.facebook.com/help/238318146535333We process the data collected here on the basis of our legitimate interest. The legal basis for data processing is Art. 6 (1) (f) GDPR. Our legitimate interest lies in monitoring various advertising campaigns that are placed in connection withFacebook. The data collected here is used solely for evaluation purposes and is anonymised/deleted after a period of 24 months. This data is not transferred to third parties. You can object to the collection of data at any time.

4.1.6 Creating a profile

When using the app, you can provide various information in your profile. In order to ensure that our users have a suitable onboarding experience with the app, we ask during registration whether the user is part of a hunting community and which animal species they hunt most frequently. The legal basis for this is Art. 6 (1) 1 litb GDPR.
This data is not visible to other users and does not appear in your profile. Your profile is only visible to users who are members of your hunting ground.
All other information that you provide in your profile as a user is voluntary. You can enter coordinates of hunting ground boundaries, hunting facilities, registered sightings and kills, as well as photos in your profile. This information is visible to other users if you have invited them to a hunting ground group.
The data collected is stored on the servers of our service providers AWS and Microsoft Azure.

4.1.7 Location tracking

With the help of the app, you can determine your location as part of active location tracking and display it on the map material available in order to share it with a post. Todo this, the app requires the appropriate access authorisation. As soon as you determine your location via the app, this data is stored.
Data collection takes place exclusively with your consent to data processing in accordance with Art.6 (1) (a) GDPR. You can determine and terminate data collection yourself at anytime. The legality of the data storage that has taken place up to that point remains unaffected. To delete the location information, you can delete the posts linked to your location or send us a message to this effect at info@hunterco.de .
The data collected is stored on the servers of our service providers AWS and Microsoft Azure.
You can deactivate location sharing at any time in the app settings.
Instructions for iOS (based on the version current at the time of this statement)
1.             Open the "Settings" app on your phone.            
2.              Scroll down to the "Apps" section and find the Jagdgefährte app
3.             Go to "Location" and choose whether and when you want to allow access to your location.

Instructions for Android(the process may vary slightly depending on the manufacturer):
1.    Open the "Settings" app on your phone
2.    Select"Location". Here you can disable location services completely or individually for the apps you use.

Microsoft Azure
The location notification is stored on our server. We use Microsoft Azure as our hosting provider. One Microsoft Way, Redmond, WA 98052-6399, USA. Servers or systems at the server location in Frankfurt, Germany, are used for the processing of personal data.
For information on possible transfers to third countries (USA), see section 7.1.
The processing of this data is necessary for the use of the app. If you do not wish to share this data with us, we cannot offer you the app.

4.1.8 Uploading photos

You can upload your own photos. The app requires permission to access your existing images so that you can integrate them into your hunting diary and/or share them with others.
Personal data is collected exclusively with your consent when you upload individual images to the app. The personal data collected here is derived from the information depicted in the images and the metadata of the images. The legal basis for data collection is therefore Art. 6 (1) S. 1 lit. a GDPR. You can delete the data collected here yourself at any time. This does not affect the lawfulness of the data processing that has taken place up to that point. Please note that although other users with whom you share your images cannot make copies of these images and we do not technically allow the images to be shared, it cannot be ruled out that other forms of reproduction may occur (screens-hots).

AWS Web Services
The photos uploaded here are stored on the servers of our hosting service provider Amazon Web Services / AWS (Amazon Web Services EMEA S.à.r.l., 38 Avenue John F. Kennedy L-1855 Luxembourg). In this respect, all uploads processed by us in connection with your use of the app are processed on AWS systems. Servers or systems at the server location in Frankfurt, Germany, are used for the processing of personal data.
For information on possible transfers to third countries (USA), please refer to section 7.2.
The processing of this data is necessary for the use of the app. If you do not wish to share this data with us, we cannot offer you the app.
The data collected is generally stored for as long as you use the app or until you request deletion of the relevant data or delete the images yourself.

4.1.9 Camera

The app requires access to the camera. Images are only taken when you activate the camera function of the app. The associated data processing is carried out with your consent and thus on the basis of Art. 6 (1) (a) GDPR.

4.1.10 Push-Notifications

We send push notifications to our users. On the one hand, these are systemic (if you are part of a hunting group, you automatically receive updates on new sightings, kills, etc.). We also use push notifications to communicate news (news articles) or to draw attention to special offers (e.g. discounted Pro version subscriptions).
Your Firebase installation ID and your device's push token are stored for the purpose of sending push notifications.Push notifications will only be sent to you after you have given your consent; the legal basis for this is Art. 6 (1) lit. a GDPR. The legal basis for the collection of data such as timestamps, push tokens and device IDs is Art. 6 (1) lit. b GDPR.Firebase Cloud MessagingWe use Firebase Cloud Messaging for the secure delivery of push notifications. Firebase Cloud Messaging is part of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.For information on possible transfers to third countries (USA), see section 7.3.Information about the device data collected can be found at: https://firebase.google.com/support/privacy#crash-stored-info  
You can revoke your consent to push notifications at any time as follows:
iOS (based on the version current at the time of validity of this declaration):
1. Open the "Settings" app on your phone.
2. Select "Notifications"
3. Scroll down to the Hunting Companion app
4. Turn off "Allow Notifications".
Android (the process may vary slightly depending on the manufacturer):
1. Open the "Settings" app on your phone.
2. Tap Apps & Notifications -> Notification Management
3. Under "Recently sent", look for apps that have recently sent you notifications. To find more apps, tap "See all".
4. Tap Advanced.
5. You can disable all notifications for a listed app. To select specific categories of notifications, tap the name of the app.

4.1.11 AI training of the MyHunt app

To enable our customers to make optimal use of the Jagdgefährten app, we use techniques known as artificial intelligence, i.e. techniques in accordance with Article 3(1) of theArtificial Intelligence Regulation (AI Regulation). We therefore process the following data to train our AI model:
1.    Uploaded photos in accordance withSection 4.1.8.
2.    Uploaded camera recordings (photos and videos) in accordance with Section 4.1.9,
3.    Location data,
4.    Time stamps (time and date) of the data in accordance with sections 1 to 3.
Training purposes include the identification of different animal species.
The legal basis for this processing is Art. 6(1)(f) GDPR ("legitimate interest"). Our legitimate interest lies in improving the performance, quality and functionality of our AI-based app features in order to offer users a technically optimised user experience tailored to hunting practices. We have ensured, as part of a balancing of interests, that your interests or fundamental rights and freedoms do not outweigh ours. In particular, processing is carried out in a manner that protects the privacy of users. Wherever possible, the data is used in anonymised or pseudonymised form.
You have the right to object to the processing of your personal data for AI training purposes at anytime for reasons arising from your particular situation.

4.1.12 Receiving data from the Internet

In order to be able to use the app to its full extent, various content is downloaded from the Internet when an Internet connection is available. No data is transferred to third parties as a result.

4.2 Data transmission to advertising providers

User-specific advertising is not used within the app. However, we use the tracking mechanisms provided to evaluate usage behaviour in relation to advertising content that is marked as such. This evaluation is, of course, only carried out within the scope of the consent given.

4.3 Data transfer to other app users

As a matter of principle, we do not pass on any personal data to other app users. The app can be used independently without other users being informed. You are free to exchange experiences with other users in groups and share content here. You decide for yourself what information you want to share with the other group members. Data processing is therefore based on Art. 6 (1) (a) GDPR. If you leave a group, your contributions will not be deleted.
You can delete them yourself within your profile or send us a deletion request by email to info@hunterco.de .

4.4 Payment processing for the use of the app by Stripe

The execution and thus the collection, processing and storage of electronic payment transaction data is carried out by our payment service provider, Stripe Payments Europe Ltd, Block 4, Har-court Centre, Harcourt Road, Dublin 2, Ireland ("Stripe"). Stripe makes it possible to offer various payment methods, such as credit card payments or direct debit.
For each payment transaction, Stripe receives data for processing the electronic payment transaction, such as the information you provided during the ordering process, along with information about your order (name, address, account number, bank code, credit card number if applicable, invoice amount, currency and transaction number). The processing of your data by Stripe is necessary for payment processing and thus for contract processing. The legal basis for this is Art. 6 (1) (b) GDPR . This data will be deleted after the expiry of the statutory retention obligations. Stripe processes your personal data on our behalf and within the scope of our instructions as a so-called processor in accordance with Art. 28 GDPR.
The service provider Stripe, which we use in this context and which processes personal data for us on our behalf and in accordance with our instructions as a so-called processor pursuant to Art. 28 GDPR, transfers data to group companies in the USA. The European Commission has asses-sed the level of data protection in the USA as inadequate. Data transfers to the USA are therefore carried out on the basis of the standard contractual clauses pursuant to Art. 46 (2) (c) GDPR. The standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D0087&from=DE. Alternatively, you can also request these documents from us using the contact details provided in section 2.

5. Newsletter

We will inform you by email about the benefits and possible uses of a PRO membership, as well as anyoffers and services from our advertising partners.

5.1 Own similar goods or services

If we inform you about the benefits and possible uses of a Pro membership and also about our own similar goods or services (purpose of processing), we base this processing on Section 7 (3) UWG (German Unfair Competition Act). In this respect, we use the email address you provided when registering for our website or app. You can object to this use at any time without incurring any costs other than the transmission costs according to the basic tariffs.

5.2 Third-party goods or services

We would also like to inform you about products and services from partner companies by email. We base the processing for this purpose on the consent you have given in accordance with Art. 6 (1) lit. a GDPR, which you can give, for example, when registering. You can revoke your consent at any time without giving reasons for the future. Simply use the unsubscribe link at the bottom of each newsletter or send us an email.

5.3 Double opt-in

Registration for email communication in accordance with Sections 5.1 and/or 5.2 is carried out using the double opt-in procedure; we log the date, time and IP address of your registration.

5.4 Customer.io

We use Customer.io software to send, plan and evaluate our newsletters. The service provider is the American company Peaberry Software Inc., 921 SW Washington Street, Suite 820, Portland, OR 97205, USA.For information on possible transfers to third countries (USA), see section 7.5.

6. Use of processors

In order to fulfil our contractual obligations, we rely on the services of carefully selected third par-ties who process the data on our behalf. These are processors with whom we have concluded an agreement in accordance with Art. 28 GDPR. In addition, we naturally ensure in advance that our processors comply with all data protection regulations so that your data is always secure.

7. Transfer to third countries

We only process your personal data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) if it is necessary for the fulfilment of our (pre)contractual obligations (in accordance with Art. 6 (1) (b) GDPR), on the basis of your consent (in accordance with Art. 6 (1) (a) GDPR), on the basis of a legal obligation (in accordance with Art. 6 (1) (c) GDPR) or on the basis of our legitimate interests (in accordance with Art. 6 (1) (f) GDPR). The same applies to processing by third parties on our behalf, the disclosure of your personal data to third parties and its transfer to third parties.
Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection equivalent to that of the EU or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

7.1 Microsoft Azure

We use Microsoft Azure, One Microsoft Way, Redmond, WA 98052-6399, USA, as our hosting service provider. Servers or systems at the server location in Frankfurt, Germany, are used for the processing of personal data, so that the data is stored within the EU/EEA. However, when using the services, it cannot be ruled out that data may also be transferred to the USA.
Data transfer to the USA is therefore based on the adequacy decision of the European Commissi-on on the EU-US Data Privacy Framework (DPF) in accordance with Art. 45 (1) GDPR. By joining the DPF, the participating US companies undertake to comply with EU data protection standards. In addition, standard contractual clauses pursuant to Article 46(2)(c) GDPR apply. The standard contractual clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Alterna-tively, you can also request these documents from us using the contact details provided in section 2. Further information on data processing and compliance by Microsoft Azure can be found at https://docs.microsoft.com/de-de/compliance/regulatory/offering-EU-Model-Clauses.

7.2 AWS

We use the services of the hosting provider Amazon Web Services / AWS (Amazon Web Services EMEA S.à.r.l., 38 Avenue John F. Kennedy L-1855 Luxembourg). In this respect, all uploads processed by us in connection with your use of the app are processed on AWS systems. Servers or systems at the server location in Frankfurt, Germany, are used for the processing of personal data, so that the data is stored within the EU/EEA. However, when using AWS services, it cannot be ruled out that data may also be transferred to Amazon Web Services Inc. in the USA.
Data transfer to the USA is therefore based on the European Commission's adequacy decision on the EU-US Data Privacy Framework (DPF) in accordance with Art. 45 (1) GDPR. By joining the DPF, the participating US companies undertake to comply with EU data protection standards. In addition, standard contractual clauses pursuant to Article 46(2)(c) GDPR apply. The standard contractual clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Alternatively, you can also request these documents from us using the contact details provided in section 2.

7.3 Google Services

We use the various Google services mentioned above, including Google Firebase services, on our website and in our app. Data processing is carried out on the basis of a data processing agree-ment with Google.
When using the services of Google LLC, data may also be transferred from Google to group companies and/or subcontractors in the USA, where it is stored. The possible processing locations can be found at the following link: https://www.google.com/about/datacenters/locations/.
Data transfers to the USA are therefore based on the European Commission's adequacy decision on the EU-US Data Privacy Framework (DPF) in accordance with Art. 45 (1) GDPR. By joining the DPF, the participating US companies undertake to comply with EU data protection standards. In addition, standard contractual clauses pursuant to Article 46(2)(c) GDPR apply, which are part of the data processing agreement with Google LLC, unless your express consent has been obtained in accordance with Article 6(1)(a) GDPR. The standard contractual clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en . Alternatively, you can also request these documents from us using the contact details provided in section 2.

7.4 Facebook (Meta)

The website uses Facebook pixels and Facebook integrations. The provider is Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook").
Data is therefore transferred to the USA on the basis of the European Commission's adequacy decision on the EU-US Data Privacy Framework (DPF) in accordance with Art. 45 (1) GDPR. By joining the DPF, the participating US companies undertake to comply with EU data protection standards. In addition, standard contractual clauses pursuant to Article 46(2)(c) GDPR apply, unless your express consent has been obtained in accordance with Article 6(1)(a) GDPR. The standard contractual clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Alternatively, you can also request these documents from us using the contact details provided in section 2.

7.5 Customer.io (Peaberry Software Inc.)

We use Customer.io software for sending, planning and evaluating our newsletters. The service provider is the American company Peaberry Software Inc., 921 SW Washington Street, Suite 820, Portland, OR 97205, USA.
Data is therefore transferred to the USA on the basis of the European Commission's adequacy decision on the EU-US Data Privacy Framework (DPF) in accordance with Art. 45 (1) GDPR. By joining the DPF, the participating US companies undertake to comply with EU data protection standards. In addition, standard contractual clauses pursuant to Article 46(2)(c) GDPR apply, unless your express consent has been obtained in accordance with Article 6(1)(a) GDPR. The standard contractual clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Alterna-tively, you can also request these documents from us using the contact details provided in section 2.

8. Deletion of personal data

In addition to the system-based deletion of your data described above, deletion can also take place if you actively delete your account.
Furthermore, your account may be deactivated and subsequently deleted if you have not used it for a long period of time and, based on our experience, we can no longer expect you to use it again.

9. Help center

If you have any questions, suggestions or complaints, please do not hesitate to contact our help centre. You can either contact us using our contact form at the following web addressht-tps://hunterco.de/feedbackmit, or send us an email to the following address: info@hunterco.de . In order to respond to your enquiry, we require your email address. We will collect this as soon as you send us an enquiry. The data is collected on the basis of our legitimate interest pursuant to Art. 6 (1) (f) GDPR. Our interest is to ensure the satisfaction of our users and to be able to respond to their suggestions and ideas. You have the right to object to the processing of your data.
We can determine or designate all other personal data transmitted to us in the text of the email, as we have no influence over this. We would like to point out that the transmission of data is voluntary and that unnecessary information should not be transmitted. The option of communicating by post is of course available. The legal basis for data collection is Art. 6 (1) (a) GDPR due to its voluntary nature. Consent to the processing of the data collected here can be revoked at any time without affecting the lawfulness of the data processing carried out to date.
The messages received here are processed exclusively by HC employees. No data is transferred to third parties or to a third country.
After responding to enquiries, they are stored for a period of 90 days and then deleted, as experience has shown that no further enquiries are made after this period.

10. Automated decision-making including profiling

The data we collect here is used to generate a personalised and tailored offer for you. However, this does not constitute automated decision-making in accordance with Art. 22 GDPR, as it has no legal effect on you. Nevertheless, we would like to provide as much transparency as possible in this regard.

11. Data subject rights for website and app

You have the right:
● request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of your data, if it was not collected by us, and the existence of automated decision-making, including profiling and, where applicable, meaningful information about its details;
● to request the immediate correction of inaccurate or incomplete personal data stored by us in accordance with Art. 16 GDPR;
● to request the erasure of your personal data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims;
● to request the restriction of the processing of your personal data in accordance with Art. 18 GDPR, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you refuse to have it deleted and we no longer need the data, but you need it to assert, exercise or defend legal claims, or you have lodged an objection to the processing in accordance with Art. 21 GDPR;
● to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request its transfer to another controller in accordance with Art. 20 GDPR;
● to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters for this purpose.

12. Revocation of consent given for website and app

If we process your personal data on the basis of your consent in accordance with Art. 9(2)(a) or Art. 6(1)(a) GDPR, you have the right to withdraw any consent you have given us in accordance with Art. 7(3) GDPR with effect for the future. If you wish to exercise your right of revocation, you can notify us by email at info@hunterco.de . Alternatively, you can also use the contact details provided in section 2 above.

13. Objection to processing based on legitimate interest for website and app

If we process your personal data on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right to object, which we will implement without you having to specify a particular situation.
If you wish to exercise your right to object, you can notify us by email at info@hunterco.de . Alternatively, you can also use the contact details provided in section 2 above.

14. Security measures for website and app

We take organisational, contractual and technical security measures in line with the state of the art to ensure that the provisions of data protection laws are complied with and to protect the data we process against accidental or intentional manipulation, loss, destruction or access by unauthorised persons. The security measures include, in particular, the encrypted transmission of data between your browser and our server.

15. Changes to this privacy policy

We reserve the right to change our privacy policy if this becomes necessary due to new technologies or changes to our data processing procedures, or to adapt it to changes in the legal situation relevant to us. However, this only applies to this privacy policy. If we process your personal data on the basis of your consent or if parts of the privacy policy contain provisions of the contractual relationship with you, any changes will only be made with your consent.
Website
You can view the current version of our privacy policy at https://de.hunterco.de/data-privacy.
App
You can view the current version of our privacy policy in your profile under "Privacy Policy".