Name/Co.: Tiny Giant Heroes UG (haftungsbeschränkt)
City, country: Berlin, Germany
Commercial Register/No.: Amtsgericht Berlin-Charlottenburg, HRB 219084 B, 14.07.2020
Managing Director: Maura Widjaja
E-mail address: maura.widjaja(at)gmail.com
Types of data processed:
Inventory data (name, user name)Contact details (e-mail address)Content data (text input, uploads (images, videos, sounds, pdfs, etc.))Contract data (for example contract object, duration, customer category)Payment data (for example bank details, payment history)Metacommunication data (IP address)Usage data (times of creation and update of account and associated data)information relating to the competitions and invitations for tenders organized for the Online Offer and other projects
Processing of special categories of data (Art. 9 para. 1 GDPR):
No special categories of data will be processed.
Categories of data subjects involved in the processing:
Visitors and users of the Online OfferCustomers and their employeesemployeesIn the following, we will refer to the persons concerned collectively as "users".
Purpose of the processing:
Provision of the Online Offer, its contents and functions.Provision of contractual services, service and customer care.Answer contact requests and communicate with users.Marketing and advertisingSecurity measures (verification of authenticity of participants)Carrying out competitions and invitations to tender via the Online Offer
Applicable legal bases
We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as well as the varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk; these measures include in particular ensuring the confidentiality, integrity and availability of data by controlling the physical access to the data as well as the access to, inputting, passing on, ensuring the availability and separation of the data concerning them. In addition, we have established procedures to ensure that data subjects' rights are exercised, that data is deleted and that we react to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 GDPR).The security measures include in particular the encrypted transmission of data between your browser and our server.
Cooperation with processors and third parties
Insofar as we disclose data to other persons and companies (processors or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 Para. 1 lit. b GDPR is necessary for the performance of the contract), if you have consented to this, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Art. 44 et seqq. GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA through the "Privacy Shield") or the observance of officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects
You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with Art. 15 GDPR.According to Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.Pursuant to Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data pursuant to Art. 18 GDPR.You have the right to demand that the data concerning you which you have provided to us be received in accordance with Art. 20 DSGVO and that it be transferred to other responsible parties.Pursuant to Art. 77 GDPR, you also have the right to file a complaint with the competent supervisory authority.
Right to withdraw
You have the right to withdraw consents granted pursuant to Art. 7 para. 3 GDPR with effect for the future.
Right to object
You may object at any time to the future processing of the data concerning you in accordance with Art. 21 GDPR. The objection may in particular be lodged against processing for the purposes of direct marketing.
Cookies and right to object to direct advertising
Deletion of data
Provision of contractual services
We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 Para. 1 lit b. GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.Users can create a user account, in particular by viewing their submissions to competitions. Within the framework of registration, the required mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines, but can be set by the user. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its retention for commercial or tax reasons pursuant to Art. 6 para. 1 lit. c GDPR. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.Within the scope of registration and renewed registrations as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so pursuant to Art. 6 Para. 1 lit. c GDPR.We process usage data (e.g., participation in competitions) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile in order to inform the user, for example, of participation in new competitions based on their previous participation.The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of data retention is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiration (end of commercial (6 years) and tax (10 years) retention obligation); information in the customer account remain until its deletion.Contacting usWhen contacting us (via contact form or e-mail), the user's details will be processed in order to settle the contact request and its processing in accordance with Art. 6 Para. 1 lit. b GDPR.The user data can be stored in our Customer Relationship Management System ("CRM System") or comparable inquiry organization.We use the CRM system "Freshdesk" and the chat tool "Freshchat" from Freshworks, Inc. (1250 Bayhill Drive, Suite 315, San Bruno, CA 94066, USA) on the basis of our legitimate interests (efficient and fast processing of user enquiries). For this purpose we have concluded a contract with Freshworks with so-called standard contract clauses in which Freshworks undertakes to process the user data only in accordance with our instructions and to comply with the EU data protection level. Freshworks is also certified under the Privacy Shield Agreement, providing an additional guarantee of compliance with European data protection legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000GnbQAAS&status=Active).We will delete the requests if they are no longer necessary. We check the necessity every two years; inquiries from customers who have a customer account are stored permanently and refer to the customer account details for deletion. In the case of statutory archiving obligations, deletion takes place after their expiration (end of commercial (6 years) and tax (10 years) retention obligation).
Comments and Contributions
If users leave comments or other contributions, their IP addresses will be stored for 7 days on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f GDPR.This is done for our safety, if someone leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and contributions. In this case, we ourselves can be prosecuted for the comment or contribution and are therefore interested in the author's identity.
Collection of access data and log files
On the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f GDPR, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.Log file information is stored for a maximum of seven days for security reasons (e.g. to clarify abuse or fraud) and then deleted. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
Disclosure of contact data of third parties
Contact data of third-party companies should only be forwarded to Tiny Giant Heroes if they do not identify a natural person or if you have the consent of the person concerned to be forwarded to Tiny Giant Heroes.
On the basis of our legitimate interests (i.e. interest in the optimization and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f GDPR), we use the Cloud Computing Platform of the company DigitalOcean LLC ("DigitalOcean"). This means that DigitalOcean provides us with services such as infrastructure services, computing capacity, storage space, security and technical maintenance. An order processing contract exists.DigitalOcean is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000TQNgAAO&status=Active).Data processing and storage takes place on servers in computer centers in Germany.
Amazon Web Services
On the basis of our legitimate interests (i.e. interest in the optimization and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f GDPR) we use the services S3 and CloudFront of the company Amazon Web Services, Inc. ("Amazon Web Services"). This means that Amazon Web Services provides file storage and caching of these for us. An order processing contract exists.Amazon Web Services is certified under the Privacy Shield Agreement and thus provides a guarantee of compliance with European data protection legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active).
On the basis of our legitimate interests (i.e. interest in the economic operation of our online service as defined in Art. 6 Para. 1 lit. f GDPR) we use Sparkpost, the Email Delivery Service of Message Systems, Inc. ("Sparkpost"). This means that Sparkpost is used for email communication with our users. An order processing contract exists.Sparkpost is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt0000000KzTTAA0&status=Active).
On the basis of our legitimate interests (i.e. interest in the economic operation of our online service as defined in Art. 6 Para. 1 lit. f GDPR) we use the Error Reporting Tool from Rollbar, Inc. ("Rollbar"). That means Rollbar notifies us about errors on the website. An order processing contract exists.Rollbar is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt0000000TNcNAAW&status=Active).In the event of an error, personal data such as IP address, name of the website accessed, date and time of access, browser type and version, the user's operating system are transmitted to Rollbar for efficient error detection and correction. The data will be stored for a maximum period of 14 days or until the completion of the error correction and then deleted.
Online presences in social media
Cookies & range measurement
Google Tag Manager
Google Re/Marketing Services
Facebook Pixels, Custom Audiences and Facebook Marketing Services
Integration of third-party services and content