This page was automatically translated from German. Only the German version is legally binding.
Company: Userlutions GmbH
Street number: Boxhagener Straße 71 E
Postcode, City: 10245 Berlin
Reg. No.: HRB 137205 B, Amtsgericht Berlin-Charlottenburg
Executive Director: Benjamin Uebel
Phone number: 030-54487024
Name: Benjamin Uebel c/o Userlutions GmbH
Street number: Boxhagener Straße 71 E
Postcode, City: 10245 Berlin
Phone number: 030-54487024
Email address: email@example.com
- Basic information on data processing and legal basis
1.1. This data protection declaration informs you about the type, scope and purpose of the processing of personal data within our online offer and the websites, functions and content connected to it (hereinafter jointly referred to as “online offer” or “website”). The data protection declaration applies irrespective of the domains, systems, platforms and devices (e.g. desktop or mobile) used on which the online offer is executed.
1.2. The terms used, such as “personal data” or their “processing” we refer to the definitions in Art. 4 of the General Data Protection Regulation (DSGVO).
1.3. The personal data of users processed within the framework of this online offer includes inventory data (e.g., names and addresses of customers and testers), contract data (e.g., services used, payment information), usage data (e.g., the web pages visited on our online offer, interest in our products) and content data (e.g., entries in forms).
1.4. The term “user” covers all categories of data subjects. They include our business partners, customers, interested parties, testers, applicants and other visitors to our online offering. The terms used, such as “user”, are to be understood as gender-neutral.
1.5. We process users’ personal data only in compliance with the relevant data protection regulations. This means that the user’s data will only be processed if legal permission has been granted. I.e., in particular if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) as well as online services, or is required by law, or if the user has given his consent, as well as on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation and security of our online offer in the sense of Art. 6 Para. 1 lit. f. DSGVO, in particular in the case of reach measurement, creation of profiles for advertising and marketing purposes as well as collection of access data and use of third-party services.
1.6. We point out that the legal basis of the consents is Art. 6 para. 1 lit. a. and Art. 7 DSGVO, the legal basis for the processing for the fulfilment of our services and the implementation of contractual measures Art. 6 para. 1 lit. b. DSGVO, the legal basis for processing for the fulfilment of our legal obligations Art. 6 para. 1 lit. c. DSGVO, and the legal basis for processing to protect our legitimate interests Art. 6 para. 1 lit. f. DSGVO is.
- Security measures
2.1. We take organisational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of the data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorised persons.
2.2. Security measures include encrypted transmission of data between your browser and our server, regular security backups, encrypted storage of sensitive customer and tester data, high-security servers in Germany, firewalls, intrusion detection systems, access control, training and commitment of our employees to data protection & confidentiality, pseudonymization and anonymization of testers, and selection of contractors under due diligence.
- Disclosure of data to third parties and third-party providers
3.1. Data is only passed on to third parties within the framework of legal requirements. We only pass on user data to third parties if this is necessary, e.g. on the basis of Art. 6 para. 1 lit. b) DSGVO is necessary for contractual purposes or on the basis of legitimate interests pursuant to Art. Article 6(2) 1 lit. f. DSGVO in the economic and effective operation of our business.
3.2. Where we use subcontractors to provide our services, we take appropriate legal precautions and technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal requirements.
3.3. If content, tools or other means from other providers (hereinafter collectively referred to as “third party providers”) are used within the scope of this data protection declaration and their named registered office is located in a third country, it is to be assumed that a data transfer to the third party providers’ countries of domicile takes place. Third countries are countries in which the GDPR is not directly applicable law, i.e. basically countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if there is an adequate level of data protection, user consent or otherwise legal permission.
- performance of contractual services
4.1. 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 in accordance with the German Data Protection Act. Article 6(2) 1 lit b. DSGVO.
4.2. Users can optionally create a user account by which they can view their tests. Within the scope of the registration, the required mandatory data are communicated to the users. The user accounts are not publicly accessible and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention for reasons of commercial or tax law. Article 6(2) 1 lit. c DSGVO necessary. It is the responsibility of the users to back up their data before the end of the contract if the contract is terminated. We are entitled to irretrievably delete all user data stored during the term of the contract.
4.3. A passing on of data to third parties does not take place in principle, except it is necessary for the pursuit of our claims or it exists for this a legal obligation in accordance with. Article 6(2) 1 lit. c GDPR.
4.4. When contacting us (via contact form or e-mail), the user’s details are used to process the contact request and its handling in accordance with the German Data Protection Act. Article 6(2) 1 lit. b) DSGVO processed.
4.5. User information may be stored in our Customer Relationship Management System (“CRM System”) or similar inquiry organization.
4.6. We use the CRM system “Pipedrive”, from the provider Pipedrive Inc. on the basis of our legitimate interests (efficient and fast processing of user requests). For this purpose, we have concluded a contract with Pipedrive with so-called standard contractual clauses, in which Pipedrive undertakes to process user data only in accordance with our instructions and to comply with the EU level of data protection. All data is stored on servers in Germany.
- Comments and contributions
5.1. When users leave comments or other contributions on our blog, their IP addresses are stored on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO stored for 7 days.
5.2. This is done for our security, in case someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
- Collection of access data and log files
6.1. We collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO 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.
6.2. Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of seven days and then deleted. Data whose further retention is necessary for evidentiary purposes shall be exempt from deletion until the final clarification of the respective incident.
- Cookies & Reach Measurement
7.1. Cookies are pieces of information that are transmitted from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Cookies may be small files or other types of information storage.
7.2. We use “session cookies”, which are only stored for the duration of the current visit to our online presence (e.g. to store the status of your login or your current test booking and thus enable the use of our online offer at all). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close the browser, for example.
7.4. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
) and additionally the USAmerican website (
) or the European website (
- Processing of usability test data
8.1. For participation in online usability tests, test videos are collected from the testers by means of a screen recorder on the one hand and written test data on the other.
8.2. The screen recorder for recording usability tests, which starts automatically when you participate in a usability test as a tester, transmits data in the form of videos to our web server. These are, among others, mouse movements, screenshots and microphone input. To ensure the technical stability and performance of the screen recorder on all possible computers of the testers, the operating system, browser version, RAM, CPU, hard disk space, anonymous IP address and the number of monitors are also automatically processed. The finished video is first saved on the tester’s computer. When the test is complete, this file is accessed to upload it to an FTP server.
8.3. In order to make a demographic assignment of the testers to the tests that are suitable for them, demographic data and personal characteristics are processed from the testers.
8.4. The tester’s data is made available to the client exclusively in pseudonymous form. Testers are responsible for not disclosing any personal information within the test videos that would compromise their anonymity to the client.
8.5. Privacy clause
Userlutions GmbH guarantees to comply with the legal provisions on data protection, in particular the DS-GVO, when providing its services, to commit its employees in this regard and to ensure compliance by its employees. Insofar as the audio-visual recordings, due to the voice or content (e.g. desktop recording), allow a conclusion to be drawn about a tester and make this tester identifiable, the processing of this information regularly takes place on the basis of the consent given to Userlutions GmbH. All testers grant Userlutions GmbH, among others, consent to the processing for (market) research and usability test purposes. In this regard, the consent also includes the transfer of personal data from Userlutions GmbH to its customers. The testers will be informed of the scope of processing by Userlutions GmbH in accordance with legal regulations, so that it is also ensured that they can assert their data subject rights against Userlutions GmbH.
- Google Analytics
9.2. We have worked with Google an order data processing contract concludedwhich complies with the European level of protection through the addition of the EU standard contractual clauses.
9.3. Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Pseudonymous usage profiles of the users can be created from the processed data.
9.4. We use Google Analytics to display the ads placed within advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “remarketing”, or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to make sure that our ads match the potential interest of the users and are not harassing.
9.5. We use Google Analytics only with IP anonymization enabled. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there.
9.6. The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link:
9.7. You can find out more information about the use of data by Google, and about setting and objection options on the Google website:
(“Data use by Google when you use our partners’ websites or apps”),
(“Data Use for Advertising Purposes”),
(“Manage information Google uses to serve ads to you”).
- Google Re/Marketing Services
10.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the marketing and remarketing services (in short “Google Marketing Services”) of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
10.2. We have concluded an order data processing contract with Google, which complies with the European level of protection through the addition of the EU standard contractual clauses.
10.3. Google’s marketing services allow us to display advertisements for and on our website in a more targeted manner to present users with only ads that potentially match their interests. If, for example, a user is shown ads for products in which he has shown interest on other websites, this is referred to as “remarketing”. For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservice.com. This file records which web pages the user has visited, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring web pages, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform you within the scope of Google Analytics that the IP address is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is transmitted in full to a Google server in the USA and shortened there. The IP address is not merged with data of the user within other offers of Google. The above information may also be combined by Google with information from other sources. When the user subsequently visits other websites, he can be shown ads tailored to his interests.
10.4. User data is processed pseudonymously as part of Google’s marketing services. I.e. Google does not store and process e.g. the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about users by Google marketing services is transmitted to Google and stored on Google’s servers in the USA.
10.5. The Google marketing services we use include the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information obtained with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information with which users can be personally identified.
10.6. Furthermore, we may use the “Google Tag Manager” to integrate and manage Google analytics and marketing services on our website.
10.7. For more information about Google’s use of data for marketing purposes, please visit the overview page:
10.8. If you wish to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google:
11.2. Hubspot will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The processed data can be used to pseudonymised usage profiles of the users are created.
11.3. Notwithstanding the possibility of revoking their consent to the use of their data at any time, users can technically exclude the collection of their user data by adjusting the cookie settings of their browser and deleting the respective cookies. You can find more information about the cookies used by HubSpot here & here.
11.4. You can find out more information about Hubspot’s use of data, setting and objection options on Hubspot’s websites:
- Hubspot Cookies
- Hubspot & EU Data Protection Regulation EU-DSGVO
12We use social plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd. DSGVO) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are attached to one of the Facebook logos recognizable (white “f” on blue tile, the terms “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here:
12.2 We have concluded an order data processing contract withFacebook, which complies with the European level of protection through the addition of the EU standard contractual clauses .
12.3. When a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated by the user into the online offer. In doing so, usage profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our state of knowledge.
12.4. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to obtain and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.
12.6. If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored with Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings:
or via the US-American site
or the EU site
. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
13.1. With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
13.2. Newsletter content: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described within the scope of a registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our products, offers, promotions and our company.
13.3. Double-Opt-In and logging: The registration for our newsletter takes place in a so-called Double-Opt-In procedure. I.e. after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.
. The Rocket Science Group LLC d/b/a MailChimp and Userlutions have entered into an order data processing agreement that complies with the European level of protection through the addition of the EU standard contractual clauses.
13.5. Furthermore, according to its own information, the dispatch service provider may use this data in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties.
13.6. Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name for the purpose of a personal address in the newsletter.
13.7. Statistical collection and analyses – The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor that of the shipping service provider to monitor individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
13.8. The use of the dispatch service provider, the performance of statistical surveys and analyses as well as the logging of the registration process are carried out on the basis of our justified interests in accordance with the German Data Protection Act. Article 6(2) 1 lit. f GDPR. We are interested in providing a user-friendly and secure newsletter system that serves our business interests and meets the expectations of our users.
13.9. Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consent to its dispatch by the dispatch service provider and the statistical analyses will expire. A separate revocation of the dispatch by the dispatch service provider or the statistical evaluation is unfortunately not possible. You will find a link to cancel the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and have cancelled this subscription, their personal data will be deleted.
- Integration of services and contents of third parties
14.1. Within our online offer, we use content or service offers of third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service offers from third party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always assumes that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content. We endeavour to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party vendors may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring Web pages, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.
14.2. The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in part already mentioned here, options for objection (so-called opt-out):
– If our customers and testers use the payment services of third parties (e.g. PayPal), the terms and conditions and the data protection information of the respective third party providers apply, which are available within the respective websites or transaction applications.
– External fonts from Google, Inc.,
- Rights of users
15.1. Users have the right, upon request and free of charge, to obtain information about the personal data that we have stored about them.
15.2. In addition, users have the right to rectification of inaccurate data, restriction of processing and erasure of their personal data, where applicable, to exercise their rights to data portability and, in the event that unlawful data processing is suspected, to lodge a complaint with the competent supervisory authority.
15.3. Likewise, users can revoke consent, in principle with effect for the future.
- Deletion of data
16.1. The data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data of the users are not deleted because they are required for other and legally permissible purposes, then their processing restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for reasons of commercial or tax law.
16.2. According to legal requirements, the storage takes place for 6 years in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) as well as for 10 years pursuant to § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
- Right of objection
Users may object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against the processing for purposes of direct advertising.
In addition, the person affected by the collection and processing of his or her personal data has, in principle, the right to lodge a complaint with the competent state office for data protection supervision.
18.1. We reserve the right to change the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. Insofar as user consent is required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes shall only be made with the consent of the users.
18.2. Users are requested to inform themselves regularly about the content of the data protection declaration.