1) Information on the Collection of Personal Data and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Van Veen Group GbR, Vahrenwalder Straße 205, 30165 Hannover, Deutschland, Tel.: 0176 30881286, E-Mail: support@proxybrothers.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data Collection When You Visit Our Website

2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:

• Our visited website
• Date and time at the moment of access
• Amount of data sent in bytes
• Source/reference from which you came to the page
• Browser used
• Operating system used
• IP address used (if applicable: in anonymized form)

Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

3) Hosting & Content Delivery Network

KeyCDN

We use a content delivery network offered by the following provider: proinity GmbH, Rümikerstrasse 60, 8409 Winterthur, Switzerland

This service enables us to deliver large media files such as graphics, page content or scripts faster via a network of regionally distributed servers. The processing is carried out to protect our legitimate interest in improving the stability and functionality of our website pursuant to Art. 6 (1) point f GDPR. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors’ data and prohibiting unauthorised disclosure to third parties.

In case of data transfer to the provider’s location, an adequate level of data protection is guaranteed by an adequacy decision of the European Commission.

4) Contacting Us

When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.

The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.

5) Data Processing When Opening a Customer Account and for Contract Processing

Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed to the extent required in each case if you provide us with this data when opening a customer account. The data required for opening an account can be found in the input mask of the corresponding form on our website. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the person responsible. After deletion of your customer account, your data will be deleted, provided that all contracts concluded via it have been fully processed, no legal retention periods are opposed and no legitimate interest on our part in the continued storage exists.

6) Processing of Data for the Purpose of Order Handling

6.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Para. 1 lit. b GDPR.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by post or e-mail) about upcoming updates within the legally stipulated period of time within the framework of our statutory duty to inform pursuant to Art. 6 Para. 1 lit. c GDPR. Your contact details will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent that this is necessary for the respective information.

In order to process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.

6.2 Use of Payment Service Providers

– Paypal

Online payment methods from the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg

If you select a payment method of the provider for which you make an advance payment, your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.

When selecting a payment method of the provider with which the provider makes advance payments, you will also be asked to provide certain personal data (first name and surname, street, house number, postcode, city, date of birth, e-mail address, telephone number, if applicable data on alternative means of payment) during the ordering process.

In order to safeguard our legitimate interest in determining the solvency of our customers, this data is passed on to the provider by us for the purpose of a credit check in accordance with Art. 6 (1) point f GDPR. On the basis of the personal data provided by you as well as further data (such as shopping cart, invoice total, order history, payment history), the provider checks whether the payment option selected by you can be granted with regard to payment and/or bad debt risks.

The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data.

You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for the contractual processing of payments.

7) Site Functionalities

reCAPTCHA

On this website, we use the CAPTCHA service of the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data may also be transmitted to: Google LLC, USA. For the visual design of the CAPTCHA window, the provider uses "Google Fonts", i.e., fonts loaded from the Internet by Google. No further information is processed except that mentioned above, which is already transmitted to Google via the functionality of ReCaptcha.

The service checks whether an input is made by a natural person or abusively by machine and automated processing with the aim of blocking spam, DDoS attacks and similar automated malicious attacks. To ensure whether an action is performed by a human being and not by an automated bot, the provider collects the IP address of the end device used, the recognition data of the browser, the operating system type and the date and duration of the visit and transmits these data to the provider’s servers to be evaluated.

This process is based on our legitimate interest in determining individual responsibility when using the Internet and in preventing abuse and spam in accordance with Art. 6 Para. 1 lit. f GDPR.

We have concluded an order processing contract with the provider, ensuring the protection of our site visitors’ data and prohibiting unauthorized disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

8) Tools and Miscellaneous

8.1 – sevDesk

For the execution of the accounting, we use the service of the cloud-based accounting software of the following provider: sevDesk GmbH, Hauptstraße 115, 77652 Offenburg, Germany

The provider processes incoming and outgoing invoices and, if applicable, also the bank transactions of our company in order to automatically record invoices, match them to the transactions and create the financial accounting from this in a semi-automated process.

Insofar as personal data is also processed in this context, the processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in the efficient organisation and documentation of our business transactions.

8.2 Wordfence

For security purposes, this website uses the service of the following provider: Defiant Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA

The provider protects the website and the associated IT infrastructure from unauthorised third-party access, cyber attacks and viruses and malware. The provider collects the IP addresses of users and, if necessary, further data on their behaviour on our website (in particular URLs accessed and header information) in order to detect and defend against illegitimate page accesses and dangers. In doing so, the collected IP address is compared with a list of known attackers. If the captured IP address is identified as a security risk, the provider can automatically block it from accessing the website. The information collected in this way is transferred to a server of the provider and stored there.

The described data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interests in protecting the website from harmful cyber attacks and in maintaining structural and data integrity and security.

If visitors to the website have login rights, the provider also sets cookies (= small text files) on the respective end device used by the visitor. With the help of the cookies, certain location and device information can be read, which makes it possible to assess whether the login-authorised access originates from an authorised person. At the same time, access rights can be evaluated via the cookies and released via a website-internal firewall according to the authorisation level. Finally, the cookies are used to register irregular access by website administrators from new devices or new locations and to notify other administrators of this. These cookies are only set if a user has login rights. The provider does not set cookies for website visitors without login authorisation. Insofar as personal data is processed via the cookies, the processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in preventing illegitimate access to the website administration and in the defence against unauthorised administrator access.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorised disclosure to third parties.

For the transfer of data to the USA, the provider invokes standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

9) Rights of the Data Subject

9.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:

• Right of access by the data subject pursuant to Art. 15 GDPR;
• Right to rectification pursuant to Art. 16 GDPR;
• Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
• Right to restriction of processing pursuant to Art. 18 GDPR;
• Right to be informed pursuant to Art. 19 GDPR;
• Right to data portability pursuant to Art. 20 GDPR;
• Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
• Right to lodge a complaint pursuant to Art. 77 GDPR.

9.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

10) Duration of Storage of Personal Data

The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and – if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).

If personal data is processed basis on an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.

If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.

When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If personal data is processed for the purpose of direct marketing based on Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.

Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.