1. Data protection at a glance
General notes
The following notices 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 detailed information on the subject of data protection, please refer to our privacy policy listed below this text.
Data collection on this website
Who is responsible for the data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the responsible office” 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 z. B. be 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 primarily technical data (e.g. internet browser, operating system or time of the 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.
You can contact us at any time with regard to this and other questions on the subject of data protection.
And you can adjust your cookie settings via this link:
2. Hosting and content delivery networks (CDN)
We host the content of our website with the following provider:
External hosting
This website is hosted externally. The personal data collected on this website is stored on the servers of the hoster(s). This can primarily be IP addresses, contact requests, meta and communication data, contract data, contact data, names, website access and other data generated via a website.
External hosting is carried out for the purpose of contract fulfillment vis-à-vis our potential and existing customers (Art. 6 para. 1 lit. b DSGVO) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f DSGVO). If a corresponding consent has been requested, the processing is based exclusively on 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 end device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
Our hoster(s) will process your data only to the extent necessary to fulfill its performance obligations and follow our instructions with respect to such data.
We use the following hoster(s):
webgo GmbH
Heidenkampsweg 81
20097 Hamburg
Job processing
We have concluded a contract on order processing (AVV) for the use of the above 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 GDPR.
Cloudflare
We use the service “Cloudflare”. The provider is Cloudflare Inc, 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”).
Cloudflare offers a globally distributed content delivery network with DNS. In doing so, the information transfer between your browser and our website is technically routed through Cloudflare’s network. This enables Cloudflare to analyze traffic between your browser and our website and serve as a filter between our servers and potentially malicious traffic from the Internet. In doing so, Cloudflare may also use cookies or other technologies to recognize Internet users, but these are used solely for the purpose described here.
The use of Cloudflare is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6 para. 1 lit. f DSGVO).
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.cloudflare.com/privacypolicy/.
You can find more information about security and privacy at Cloudflare here: https://www.cloudflare.com/privacypolicy/.
Job processing
We have concluded a contract on order processing (AVV) for the use of the above 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 GDPR.
3. General notes and mandatory information
Privacy
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 privacy policy.
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 this is done and for what purpose.
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 the data against access by third parties is not possible.
Note on the responsible entity
The responsible party for data processing on this website is:
Michael Kosko
Sepapaja 6
15551 Tallinn
Estonia
Phone: +905441334988
E-mail: michael.kosko@empulses.de
The responsible body is the natural or legal person who, alone or together with others, decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).
Storage duration
Unless a more specific storage period has been specified 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. tax or commercial law retention periods); in the latter case, the data will be deleted once these reasons have ceased to exist.
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 categories of data pursuant to Art. 9 para. 1 DSGVO are processed. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or to access information on your end device (e.g. via device fingerprinting), data processing is also carried out on the basis of Section 25 Para. 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 GDPR. Furthermore, we process your data insofar as this is necessary for the fulfillment of a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. The data processing may further be based on our legitimate interest according to Art. 6 para. 1 lit. f DSGVO shall take place. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this data protection declaration.
Note on data transfer to the USA and other third countries
Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. When these tools are active, your personal data may be transferred to and processed in these third countries. We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in these countries. For example, U.S. companies are obligated to release personal data to security authorities without you, the data subject, being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) will process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence on these processing activities.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to object to data collection in special cases and to direct marketing (Art. 21 DSGVO)
IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF 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 ON GROUNDS RELATING TO 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 DATA PROTECTION DECLARATION. 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 IS FOR THE ESTABLISHMENT, EXERCISE OR DEFENSE OF 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 ASSOCIATED 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 ART. 21 PARA. 2 DSGVO).
Right of appeal to the competent supervisory authority
In the event of breaches 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 breach. The right of appeal is without prejudice to other administrative or judicial remedies.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, 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 applicable, a right to correction or deletion of this data. You can contact us at any time with regard to this and other questions on the subject of personal data.
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 restrict 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 may request the restriction of data processing instead of erasure.
- If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.
- If you file an objection pursuant to Art. 21 para. 1 DSGVO, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to demand the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may – apart from being stored – 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 browser address bar changes from “http://” to “https://” and by the lock symbol in your browser bar.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Objection to advertising e-mails
The use of contact data published within the scope of the imprint obligation for the transmission of not expressly requested advertising and information materials is hereby contradicted. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.
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 terminal device. Session cookies are automatically deleted after the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or until they are automatically deleted by your web browser.
Cookies may 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 from third-party companies within websites (e.g. cookies for processing payment services).
Cookies have various functions. Numerous cookies are technically necessary because certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies may be used to evaluate user behavior or for advertising purposes.
Cookies that are required to carry out the electronic communication process, to provide certain functions you want (e.g. for the shopping cart function) or to optimize the website (e.g. cookies for measuring web audience) (necessary cookies). on the basis of Art. 6 para. 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 based exclusively on 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 cookies are disabled, the functionality of this website may be limited.
Which cookies and services are used on this website can be found in this privacy policy.
Consent with Borlabs Cookie
Our website uses Borlabs Cookie Consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in accordance with data protection law. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg (hereinafter Borlabs).
When you enter our website, a Borlabs cookie is stored in your browser, which stores the consents you have given or revoked. This data is not shared with the provider of Borlabs Cookie.
The collected data will be stored until you request us to delete it or delete the Borlabs cookie yourself, or until the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details about Borlabs Cookie data processing can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.
The use of Borlabs cookie consent technology is done in order to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.
Contact form
If you send us inquiries via the contact form, the information you provide in the inquiry form, including the contact data you enter there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not share this data without your consent.
The processing of this data is based on Art. 6 para. 1 lit. b DSGVO, provided that your request is related to the performance of a contract or is necessary for the performance of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling 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 ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.
Request by e-mail, phone or fax
If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your request. We do not share this data without your consent.
The processing of this data is based on Art. 6 para. 1 lit. b DSGVO, provided that your request is related to the performance of a contract or is necessary for the performance of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling 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 sent to us via contact requests will remain with us until you request deletion, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
Communication via WhatsApp
For communication with our customers and other third parties, we use, among other things, the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Communication takes place via end-to-end encryption (peer-to-peer), which prevents WhatsApp or other third parties from gaining access to the communication content. However, WhatsApp receives access to metadata that is created in the course of the communication process (e.g. sender, recipient and time). We would also like to point out that WhatsApp, according to its own statement, shares personal data of its users with its parent company Meta, which is based in the USA. For more details on data processing, please see WhatsApp’s privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.
WhatsApp is used on the basis of our legitimate interest in communicating as quickly and effectively as possible with customers, interested parties and other business and contractual partners (Art. 6 para. 1 lit. f DSGVO). If a corresponding consent has been requested, the data processing is carried out exclusively on the basis of the consent; this can be revoked at any time with effect for the future.
The communication content exchanged between and on WhatsApp remains with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.
We use WhatsApp in the “WhatsApp Business” variant.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.whatsapp.com/legal/business-data-transfer-addendum.
We have concluded an order processing agreement (AVV) with the above-mentioned provider.
SimplyMeet.me
On our website you have the possibility to make appointments with us. For booking appointments we use the tool “SimplyMeet.me”. The provider is SIMPLYBOOK.ME LTD30 Gladstonos Street, P. Makedonas Court, Mezzanine Floor, 3041, Limassol, Cyprus, (hereinafter “SimplyMeet.me”).
For the purpose of booking an appointment, enter the requested data and the desired date in the mask provided. The data entered will be used for the planning, execution and, if necessary, follow-up of the appointment. The appointment data is stored for us on the servers of SimplyMeet.me, whose privacy policy you can view here: https://simplymeet.me/en/policy.
The data you enter 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. Mandatory legal provisions – in particular retention periods – remain unaffected.
The legal basis for data processing is Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in making it as uncomplicated as possible to arrange appointments with interested parties and customers. If a corresponding consent has been requested, the processing is based exclusively on 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 end device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
Job processing
We have concluded a contract on order processing (AVV) for the use of the above 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 GDPR.
5. Newsletter/Pocket-Coach
Newsletter/Pocket-Coach data
If you would like to receive the newsletter/Pocket-Coach offered on the website, we need an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you are authorized to receive it of the newsletter/Pocket-Coach. Further data is not collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
Data analysis
With the help of our locally hosted newsletter tool, we are able to analyze our newsletter campaigns. So we can e.g. For example, you can see whether a newsletter message has been opened and which links, if any, have been clicked. In this way, we can determine, among other things, which links were clicked particularly often.
It is also possible for us to subdivide (“cluster”) the newsletter/Pocket Coach recipients into different categories. The newsletter recipients can e.g. B. subdivide by gender or language. In this way, the newsletters can be better adapted to the respective target groups.
If you do not want us to analyze you, you must unsubscribe from the newsletter/Pocket-Coach. For this purpose, we provide a corresponding link in every newsletter message.
Legal basis
The processing of the data entered in the newsletter registration form is based exclusively on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter/pocket coach at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
Storage duration
The data you have stored with us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter/pocket coach or after it no longer serves. We reserve the right to remove e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6 para. 1 lit. f DSGVO to delete or block.
Data that has been stored by us for other purposes remains unaffected by this.
After you have been removed from the newsletter distribution list, we may store your e-mail address in a blacklist if this is 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 the legal requirements when sending newsletters/Pocket-Coach (legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR). The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.
6. Plugins and tools
Google Fonts (local hosting)
This site uses so-called Google Fonts, which are provided by Google, for the uniform display of fonts. The Google Fonts are installed locally. A connection to Google servers does not take place.
For more information on Google Fonts, please visit https://developers.google.com/fonts/faq and see Google’s privacy policy: https://policies.google.com/privacy?hl=de.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to check whether data is entered on this website (e.g. in a contact form) by a human or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the website visitor spends on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyses run completely in the background. Website visitors are not made aware that an analysis is taking place.
The storage and analysis of the data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and from SPAM. If a corresponding consent has been requested, the processing is based exclusively on 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 end device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
For more information about Google reCAPTCHA, please see the Google Privacy Policy and the Google Terms of Service at the following links: https://policies.google.com/privacy?hl=de and https://policies.google.com/terms?hl=de.
7. eCommerce and payment providers
Processing of customer and contract data
We collect, process and use personal customer and contractual data for the purpose of establishing, defining the content of and amending our contractual relationships. We collect, process and use personal data about the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill the user. The legal basis for this is Art. 6 para. 1 lit. b GDPR.
The collected customer data will be deleted after completion of the order or termination of the business relationship and expiration of any existing legal retention periods. Statutory retention periods remain unaffected.
8. Audio and video conferencing
Data processing
Among other things, we use online conferencing tools to communicate with our customers. The tools we use in detail are listed below. When you communicate with us via video or audio conferencing over the Internet, your personal data is collected and processed by us and the provider of the respective conferencing tool.
In doing so, the conference tools collect any data that you provide/enter to use the tools (email address and/or your phone number). Furthermore, the conferencing tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).
Furthermore, the provider of the tool processes all technical data required for the handling of online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and connection type.
If content is exchanged, uploaded or otherwise made available within the tool, this is also stored on the servers of the tool providers. Such content specifically includes cloud recordings, chat/instant messages, voicemails uploaded photos and videos, files, whiteboards, and other information shared while using the Service.
Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the corporate policy of the respective provider. For further information on data processing by the conference tools, please refer to the privacy statements of the respective tools used, which we have listed below this text.
Purpose and legal basis
The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 lit. b DSGVO). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO). Insofar as consent has been requested, the tools in question are used on the basis of this consent; consent can be revoked at any time with effect for the future.
Storage duration
The data collected directly by us via the video and conference tools will be deleted from our systems as soon as you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies. Stored cookies remain on your terminal device until you delete them. Mandatory statutory retention periods remain unaffected.
We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.
Conference tools used
We use the following conferencing tools:
Google Meet
We use Google Meet. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For details on data processing, please refer to Google’s privacy policy: https://policies.google.com/privacy?hl=de.
Job processing
We have concluded a contract on order processing (AVV) for the use of the above 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 GDPR.