Data Privacy Policy


Find our privacy policy in German here.

We, Wando Internet Solutions GmbH (“we” or “Wando”) are glad that you are interested in our company.

We take the protection and the confidential treatment of your personal data very seriously. We endeavor to ensure that your personal data are processed in compliance with the data privacy laws of your jurisdiction, which may include the European Union General Data Protection Regulation (the “GDPR”) or the California Consumer Protection Act (the “CCPA”).

With this Data Privacy Policy (the “Privacy Policy”), we wish to inform you about the processing of your personal data on our website, https://infotoss.com (the “Website”) and to inform you of your rights regarding your personal data:

I. Name and contact information of the company and the company data protection officer:


This Privacy Policy shall apply to data processing by the following controller:

Wando Internet Solutions GmbH
Potsdamer Str. 188
10783 Berlin
Germany
Managing director: Emanuel Hoch
Email: [email protected]
Telephone: +49 30 208 987 630
Toll-Free US Number: +1 844 691 3161

a. Who should I contact if I have questions about my personal data?

If you would like to submit a request regarding your personal data, including a request to access your data or have your data erased, please contact our data protection officer using any of the contact methods designated below.

The company data protection officer can be reached at:
Email: [email protected]
Telephone: +49 203 29506 70
Website: https://infotoss.com/page/privacy-policy

II. What is “personal data”?


The subject matter of this Privacy Policy is “personal data.” These data encompass all information that pertain to an identified or identifiable natural person (the so-called data subject). Under California law, personal data also includes data that may identify a household. These data include details such as a person’s name, home address, email address, and telephone number.

III. What information do we collect, and why do we collect it?


When you visit the Website, information on your end device concerning the browser being used is automatically sent to our Website’s server. This information is temporarily stored in a so-called log file. The categories of personal information we collect and have collected through the Website in the preceding twelve months are listed below. This information is recorded without your assistance and is stored for up to ninety (90) days:

  • the Internet Protocol (IP) address of your device;
  • the date and time the IP address accessed the Website;
  • the name and URL of the webpages and data files the IP address requested from the Website;
  • the website from which your IP address was directed to our Website (referrer URL);
  • website over which our Website is retrieved; and
  • the browser used and, as applicable, the operating system of the IP address and the name of the internet service provider.

We process the information listed above for the following purposes:

  • to guarantee that the connection to the Website is smoothly established,
  • to guarantee convenient use of our Website,
  • to evaluate system security and stability, and
  • for additional administrative purposes.

IV. Cookies


We use cookies on our Website. A cookie is a small file that can be placed on your device that allows us to recognize and remember you. It is sent to your browser and stored on your end device (laptop, tablet, smartphone, and so forth). When you visit our Website, we may collect information from you automatically through cookies or similar technology.

The use of cookies serves the purpose of making our Website more convenient for you to use. Hence, we use so-called session-cookies in order to detect that you have already visited individual pages of our Website. These cookies are automatically deleted after you have left our Website.

Moreover, for the purpose of optimizing user friendliness, we also use temporary cookies, which are stored on your end device for a certain, fixed period of time. If you revisit our Website in order to make use of our services, then the fact that you have already visited us is automatically recognized, as are the entries and settings you have made, so that you do not have to re-enter everything.

We also use cookies to record use of our Website in statistical terms, for the purpose of optimizing the Website for you, to personalize content, to customize and tailor advertisements, and to increase security for our users. These cookies make it possible for us to automatically detect, when our Website is revisited, that you have already visited us. Each of the cookies is deleted after a maximum of two (2) years.

The data collected by using cookies are necessary for the purposes of the legitimate interests perused by us or by a third party, pursuant to Article 6(1)(f) GDPR.

Most browsers accept cookies automatically. However, you can configure your browser such that no cookies are stored on your computer or that a notice always appears before a new cookie is placed. The complete deactivation of cookies may, however, cause you to be unable to see some of the functions of our Website, such as personalized advertisements.

a. How to manage cookies

Below you can find more information about the third-party cookies we use to compile statistics and display advertisements on the Website, along with instructions on how to opt-out:

Google Analytics Performance cookie Opt out Privacy policy
Google Ads Advertising cookie Opt out Privacy policy
New Relic Performance cookie Opt out Privacy policy
Taboola Advertising cookie Opt out Privacy policy
Bing Ads Advertising cookie Opt out Privacy policy
Facebook Custom Audiences Advertising cookie Opt out Privacy policy

Browser manufacturers also provide help pages that allow you to manage your cookie preferences directly in your browser:

V. Do any third parties have access to my data?


We do not sell your personal data. We may, however, share your personal data with service providers we have carefully selected. The categories of personal data we may share are listed below:

  • the Internet Protocol (IP) address of your device;
  • the date and time the IP address accessed the Website;
  • the name and URL of the webpages and data files the IP address requested from the Website;
  • the website from which your IP address was directed to our Website (referrer URL);
  • the page over which our Website is retrieved; and
  • the browser used and, as applicable, the operating system of the IP address and the name of the internet service provider.

We only share your personal data with third parties when at least one of the following legal grounds applies:

  • you have consented to the sharing (Article 6(1)(a) GDPR);
  • the processing is necessary for the performance of a contract with you, or in order to take steps at your request prior to entering into a contract (Article 6(1)(b) GDPR);
  • the processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(c) GDPR); or
  • the processing is necessary for the purposes of the legitimate interests perused by us or by a third party, except where such interests are overridden by your interests or by fundamental rights and freedoms which require protection of your personal data (Article 6(1)(f) GDPR).

Below is a list of service providers (also referred to as “processors”) with whom we may share your personal data, for the purposes explained below under each processor. These processors have been carefully selected by us and are bound to follow our instructions within the scope of Article 28, GDPR.

a. Google Analytics

For the purpose of needs-based configuration and ongoing optimization of the Website, we use Google Analytics, a web analysis service of Google Inc. (https://google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) (“Google”). In this connection, pseudonymized user profiles are created and cookies (see Section 5) are used. The information generated by the cookie about your use of this Website, such as:

  • browser type/version,
  • operating system used,
  • referrer URL (the website previously visited),
  • the host name of the accessing computer (IP address), and the
  • time of the server inquiry
are transferred to and stored at a Google server in the United States in the course of the agreement governing contract data processing that we have entered into with Google. The information is used in order to evaluate the use of the Website, to compile reports about Website activities, and to render additional services associated with Website and internet use, for the purpose of market research and needs-based configuration of these websites. This information, too, may also be transferred to third parties, insofar as such is prescribed by law or to the extent that third parties process this data on our behalf. In no event is your IP address combined with other Google data. The IP addresses are anonymized, so that no attribution is possible (IP masking). Sessions and campaigns are ended after a certain timespan has elapsed. As a matter of default, sessions are ended after thirty (30) minutes of inactivity, and campaigns are ended after six (6) months. The time limit for campaigns can extend to a maximum of two (2) years.

For cases in which personal data is transferred to the United States, Google has subjected itself to the EU-US Privacy Shield and through this offers a guarantee of compliance with European data protection law. See: https://www.privacyshield.gov/EU-US-Framework.

You can prevent the installation of cookies by means of the appropriate setting of your browser software; however, we point out that in this case, it is possible that not all the functions of this Website will be able to be used to their fullest extent.

Moreover, you can prevent the recording of data generated by the cookie and gathered upon your use of the Website (including your IP address), as well as the processing of these data by Google, by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, particularly for browsers on mobile end devices, by clicking on this link you can also prevent any recording by Google Analytics. An opt-out cookie will be installed, preventing any future recording of your data during visits to this Website. The opt-out cookie will be valid only in this browser and only for our Website and is stored on your device. If you delete the cookies in this browser, then you will have to reinstall the opt-out cookie.

Additional information concerning data protection in connection with Google Analytics can be found at the Google Analytics help site (https://support.google.com/analytics/answer/6004245?hl=en).

b. Google Adwords Conversion Tracking

In order to record the use of our Website in statistical terms and for the purpose of optimizing our Website for you, we also use Google Conversion Tracking. In so doing, a cookie (see Section 4) is placed by Google Adwords on your computer, insofar as you have reached our Website through a Google ad.

These cookies become invalid after thirty (30) days and do not serve to identify you personally. If the user visits certain pages of the website of the Adwords customer and the cookie has not yet expired, then Google and the customer can tell that the user has clicked on the banner and has been forwarded to this website.

Each Adwords customer receives a different cookie. Therefore, cookies cannot be tracked over the websites of Adwords customers. The information obtained with the assistance of the conversion cookie serves the purpose of generating conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers obtain knowledge of the total number of users who have clicked on their banner and have been forwarded to a website furnished with a conversion tracking tag. However, they do not obtain any information with which users can be personally identified.

If you do not wish to participate in the tracking procedure, then you can also refuse the placement of cookies required for this purpose – e.g., by means of a browser setting that generally deactivates the automatic placement of cookies. You can also deactivate the cookies for conversion tracking by setting your browser so that cookies from the domain www.googleadservices.com are blocked. Google’s data protection notice regarding conversion tracking can be found here: https://services.google.com/sitestats/en.html.

c. Google Adsense

This Website uses Google Adsense, a service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Adsense makes it possible to integrate advertising into websites. To this end, Google places cookies (small text data files), or web beacons (invisible pixels) are displayed. These enable an analysis of visits to the Website. Thanks to the cookies for banner prompts, Google and its partners can provide users with advertising banners on the basis of retrievals of this Website or of other websites. The information thusly recorded – including the IP address – is usually transferred to a Google server in the United States and stored there. It is possible that Google will share this information with third parties. Placement of Adsense cookies can be prevented by means of browser settings. In addition, you can deactivate personalized advertising at the following website: https://adssettings.google.com/anonymous.

Further information concerning data protection by Google can be found at: https://www.google.com/intl/de/analytics/privacyoverview.html.

d. Google Dynamic Remarketing

Our Website uses the remarketing function of Google Inc. This function serves the purpose of presenting visitors to our Website advertising banners of interest as part of the Google advertising network. To this end, your browser stores cookies that make it possible to recognize visitors whenever they retrieve websites that belong to the Google advertising network. Then, on these websites, advertising banners can be displayed to you that relate to content that you have previously retrieved on websites that use the Google remarketing function. According to Google’s own specifications, in the course of this procedure it does not collect any personal data.

You can prevent the storage of cookies by setting your browser accordingly, as described in Section 4 of this Privacy Policy.

e. New Relic

On our Website, we use the web analysis service of New Relic Inc. (“New Relic”). New Relic uses cookies. The information generated by the cookie about the use of our Website by you is, as a rule, transferred to a New Relic server in the United States and stored there.

For cases in which personal data are transferred into the United States, New Relic has subjected itself to the EU-US Privacy Shield and hereby offers a guarantee of compliance with European data protection law, https://www.privacyshield.gov/EU-US-Framework.

New Relic will use this information on our behalf in order to evaluate the use of our online offers by the user, in order to compile reports as part of this online offer, and in order to render other services associated with the use of this online offer and of the use of the internet. In so doing, pseudonymous user profiles of the user can be created from the processed data.

We use New Relic only with an activated IP anonymization, meaning that users’ IP addresses are abbreviated by New Relic within the Member States of the EU or in other contracting states of the Treaty on the Functioning of the European Union. Only in exceptional circumstances is the complete IP address transferred to a New Relic server in the United States and abbreviated there.

The IP address transferred from the user’s browser is not combined with New Relic’s other data. You can prevent the storage of cookies by setting your browser software accordingly, as described in Section 4 of this Privacy Policy.

New Relic is a service of New Relic Inc., 101 Second Street, 15th Floor, San Francisco, CA 94105, USA. Its data privacy policy can be retrieved at: https://newrelic.com/termsandconditions/privacy.

f. Taboola

Our Website uses recommendation technology from Taboola, Inc., 1115 Broadway, 7th Floor, New York, NY 10010, USA (“Taboola”). Taboola places cookies that determine which content you are using on our Websites. The cookie makes it possible for us to create a pseudonymous profile of use by collecting personal data as well as protocol data, and to recommend content to you that matches your personal interests. In this way, we can individually configure our offer for you. This use profile does not allow any inference to be made about your person.

The content of the pseudonymous user profile consists of the following data: the user’s operating system, websites/content retrieved on our Websites, the referrer link, through which you came to our Website, the date and number of website retrievals, retrieves from error sites, location information (city and federal state), and the IP address in abbreviated form.

Additional information concerning data processing by Taboola can be found at: https://www.taboola.com/privacy-policy. You can prevent the storage of cookies by setting your browser accordingly, as described in Section 4 of this Privacy Policy.

g. Bing Ads Conversion Tracking

In addition, our Website uses conversion tracking from Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). Here, a cookie is placed on your computer by Microsoft Bing Ads, insofar as you have reached our Website via a Microsoft Bing banner. In this manner, we and Microsoft Bing can tell that someone has clicked on a banner, was forwarded to our Website, and has reached a previously determined target site (conversion site). In this process, we learn only the total number of users who have clicked on a Bing banner and were then forwarded to a conversion site. No personal information concerning the user’s identity is reported. If you do not wish to participate in the tracking procedure, you can also refuse the placement of cookies that is required for this purpose – e.g., by means of a browser setting that generally deactivates the automatic placement of cookies. Additional information concerning data protection and the cookies used at Microsoft Bing can be found on the Microsoft website: https://privacy.microsoft.com/de-de/privacystatement. Microsoft is certified by Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.

h. Social media (Shariff solution)

On our Website, we use the Shariff buttons of the Facebook and Twitter social media networks. These buttons involve simple HTML links. With these, we proceed within the scope of the Shariff solution. In the Shariff solution, a script retrieves how often, e.g., a site’s share button is actuated: to do so, the script establishes contact to the social network over the program interfaces and retrieves the figures. Your personal data are not transferred. Instead of your IP address, only our service address is transferred to Facebook and Twitter. You are directly connected to Facebook or Twitter only if you become active. Prior to that, the social networks cannot collect any data about you. As long as you do not click on a link to share content, you remain invisible to the networks. If you click on the link, then the informational duty concerning the collection and processing of data is no longer ours, but rather belongs to the operator of the social network.

i. Facebook Custom Audiences

Within the Website, we use the “website custom audiences” pixel of the social media network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA. In this way, so-called counting pixels are integrated on our Website. Whenever you visit our Website, a direct connection between your browser and the Facebook server is established over the counting pixel. By this means, from your browser Facebook receives, among other things, the information that our site was retrieved by your end device. If you are a Facebook user, then Facebook can use this to match the visit to our sites to your user account. We would like to point out that we, as the provider of the sites, receive no knowledge of the content of the data transferred or of its use by Facebook. All we can do is to select which segments of Facebook users (such as by age or interests) to whom our advertising ought to be displayed. In so doing, we use one of two modes of operation of Custom Audiences, for which no data sets, and particularly no email addresses, of our users – encrypted or not – are transferred to Facebook. Further information concerning this can be found in Facebook’s data privacy policy: https://www.facebook.com/about/privacy/.

If you wish to object the use of Facebook Website Custom Audiences, you can do so at: https://www.facebook.com/ads/website_custom_audiences/.

VI. Your data privacy rights


You have the right:

  • under the CCPA, to request erasure of your personal data;
  • under the CCPA, to request access to your personal data;
  • under the CCPA, to request information about the categories of personal data collected about you, the categories of sources from which that data was collected, the business or commercial purpose of collecting this data, and the categories of third parties with whom we share personal information;
  • under the CCPA, to be free from discrimination based on your exercise of your data privacy rights;
  • in accordance with Article 15 GDPR, to obtain access to your personal data that are processed by us. In particular, you can obtain access concerning the processing purposes, the category of personal data, the categories of recipients to whom your data are or have been disclosed, the storage term planned, the existence of a right to rectification, erasure, restriction of processing or the right to object, the existence of a right to lodge a complaint, the source of the data, insofar as such data were not collected by us, as well as concerning the existence of automated decision-making, including profiling, and, as applicable, significant information regarding the details of such:
  • in accordance with Article 16 GDPR, to demand the rectification or completion of your personal data stored with us;
  • in accordance with Article 17 GDPR, to demand the erasure of your personal data stored with us, to the extent that the processing is not necessary for the purpose of exercising the right of freedom of expression and information, for the purpose of compliance with a legal obligation, for reasons of public interest, or for the purpose of asserting, exercising, or defending legal claims;
  • in accordance with Article 18 GDPR, to demand the restriction of the processing of your personal data, to the extent that the accuracy of the data is contested by you, that the processing is unlawful, but you reject the erasure and we no longer require the data, but that you require the data for the purpose of asserting, exercising, or defending legal claims, or you have lodged an objection to the processing in accordance with Article 21 GDPR;
  • in accordance with Article 20 GDPR, to receive your personal data, which you have provided us, in a structured, commonly used, and machine-readable format or to demand that it be transferred to another controller;
  • in accordance with Article 7(3) GDPR, to withdraw your consent previously given to us at any time. As a consequence, we may no longer prospectively continue with the data processing that is based upon this consent, and
  • in accordance with Article 77 GDPR, to lodge a complaint with a supervisory authority. As a rule, you can do so with a supervisory authority at your usual place of residence or place of work or at our company seat.

VII. Right to object


Insofar as your personal data are processed on the basis of legitimate interests, you have the right, in accordance with Article 21 GDPR, to lodge an objection against the processing of your personal data, to the extent that reasons are present that result from your particular situation or that the objection pertains to direct advertising. In the latter case, you have a general right to object, which is implemented by us without providing details of a particular situation.

If you wish to avail yourself of your right to withdraw or to object, it is sufficient to send us an email at: [email protected]

VIII. Additional notices


In accordance with Article 13(2)(e) GDPR, we advise of the following:

It is neither contractually nor statutorily prescribed that you provide us with your personal data, nor is such required for entering into a contractual agreement. You are not obligated to provide us with personal data. You will not suffer any negative consequences as a result of not providing such.

In accordance with Article 13(2)(f) GDPR, we advise you of the following:

We do not process your personal data for the purposes of any automated decision-making.

In accordance with Article 13(1)(f) GDPR, we advise you that we have the intention of transferring individual parts of personal data to a third country or to an international organization. Should we do so, then we shall always adhere to applicable data protection law. In particular, we shall ensure that any data transfer is covered by a pertinent legal basis pursuant to Article 44 et seqq. GDPR. If you have any questions concerning the guarantees made by us, please feel free to contact us any time using the contact information above.

a. “Do Not Track” Requests

California law requires us to inform you how we respond to web browser “Do Not Track” (DNT) signals. Because there is not currently an industry or legal standard for honoring DNT signals, we do not honor them at this time. If you do not wish to be tracked, you can adjust your cookie settings as discussed in section 5 of this Privacy Policy.

IX. Data security


For visits to the Website, we utilize the commonly used SSL (secure socket layer) procedure, in conjunction with the highest level of encryption as may be supported by your browser. As a rule, this involves a 256-bit encryption. If your browser does not support a 256-bit encryption, then we resort to 128-bit v3 technology instead. You can tell whether or not an individual website of our online presence is transmitted with encryption by examining the bottom status bar of your browser for the depiction of the key or lock symbol set in the locked position.

Additionally, we employ suitable technical and organizational security measures in order to protect your data against accidental or intentional manipulation, partial or complete loss or destruction, or against unauthorized access. Our security measures are continuously improved in keeping with technological development.

X. Current version and amendment of this Data Privacy Policy


This Privacy Policy is currently valid as of November 22, 2019. Updates to this policy will be posted on the Website and will be accessible via the “PRIVACY POLICY” link at the bottom of our home page: https://infotoss.com.

Due to further development of our Website and offers made through it, or due to amended legal or official specifications, it may be necessary to amend this Data Privacy Policy.