This privacy notice is maintained and published by Devano GmbH, headquartered in Mitteisstr. 3, 80935 Munich, Germany (hereinafter referred to as “Devano” or “we / us / our”). The purpose of this privacy notice is to describe how Devano processes personal data collected either from website visitors or from users of its RebaseData service platform, publicly available at www.rebasedata.com (hereinafter the “Services”). Devano is responsible for all the processing activities described in this notice. You may contact Devano directly in the following ways:
Telephone: +49 (0)89 21536950
Email:
Further information on Devano can be found on the ‘Imprint’ page, while the Terms and Conditions for the use of RebaseData can be found here.
We collect personal data either passively (automatically, through the delivery of its website to visitors) or actively (on the basis of what You, as a customer or interested party, directly provides Devano).
Devano collects personal data for delivering the website and actions in the website requested by the visitor, or delivering users the requested Services, after agreeing to the General Terms and Conditions of Devano GmbH for its RebaseData Service. Other purposes may be identified on the basis of agreements concluded between You and Devano.
The legal bases for processing the collected personal data range from the fulfillment of direct instructions from the customer -- when delivering Services -- to the fulfillment of legal obligations, to consent -- for instance, when signing up to receive newsletters or consenting to tracking tools which are not strictly necessary for the delivery of the website and/or the Services.
Certain legitimate interests of Devano, such as maintaining security and privacy of the processed personal data or direct marketing to previous customers, may also apply as legal bases depending on the nature of the processing activity.
Devano processes personal data limited to the types and amounts that are strictly necessary for delivering the above-mentioned services in the manner expected by Devano. While further details on the individual use cases can be found further below in this privacy notice, in general, the personal data collected is limited to the data provided while either requesting a RebaseData service, requesting support or signing up to the newsletter, the data required for invoicing and collecting payments, and the device, browser and Internet connection information for both delivering the services and website requested, along with any personal data that may be contained in the database(s) sent to us in the context of using our Services.
Devano makes use of third-party services for certain activities, such as, but not limited to, data hosting, website hosting and payment services. These third-party service providers will receive from Devano only the personal data strictly required for the services to be delivered. The third-party service providers will be identified in this privacy notice in the individual processing activity sections.
If Devano were to transfer personal data to third countries, which do not benefit from an adequacy decision from the European Commission on the basis of Art. 45 (3) GDPR, such transfers would be based upon one of the transfer mechanisms listed under Art. 46 (2) GDPR, thus ensuring that the transferred personal data enjoys the same level of protection as it normally would in the European Economic Area.
Devano retains personal data only for the amount of time strictly necessary to either carry out the requested service or to satisfy legal obligations or legitimate interests, such as those relating to the security of the personal data, or to establish, exercise or defend legal claims.
No, Devano does not make any use of automated decision-making processes.
The answer depends on the type of processing activity the personal data is used for.
For those activities based solely upon consent which require the disclosure of personal data, such as for signing up to the newsletter service or creating an account at rebasedata.com, failure to provide personal data will make the requested action impossible to carry out.
Please make sure that the personal data You provide to Devano in Your account is up to date and relevant, in order to issue accurate and correct invoices and communications. Devano provides automated ways for users to change any incorrect personal data associated with their account, and will assist users in doing so upon request.
If the personal data is instead part of the database to convert using the Services, and are either missing or compromised in any way, the result of the conversion will then vary on the basis of such missing data. Please ensure that the information populating the database is correct, before converting the database using the Services.
When You visit www.rebasedata.com or any of its subpages (hereinafter the “Website”), “server log files” are automatically collected from the Website provider (Devano) and shared with the Website hosting service provider, so that the visitor may access and interact with the Website. These “server log files” contain the following information, relating to your device, browser and connection information:
The legal basis for this activity is Devano’s legitimate interest in publishing an accessible website. The logs may be used further for ensuring the continued security of the Website. The collected information may, however, be used further, when the visitor either creates a RebaseData account on the Website, logs in and performs actions and requests on the Website when logged in -- again, for security purposes.
Server log files are retained for as long as required for security or fraud detection purposes.
| Recipient | Purpose of Processing | Location of Processing |
|---|---|---|
| Hetzner Online GmbH | Website hosting | Germany |
Devano uses cookies for tracking the website visit session on specific activities. The tracking tools used are visible in the cookie declaration, which appears as a pop up the moment the website is first visited. Each tracking tool is divided into a category:
Each tracking tool may store or otherwise transfer information to the tracking tool provider about certain events occurring during the website visit. The content of the information depends on the purpose of each tracking tool deployed, however they likely carry information such as unique identifiers of visitors and/or events, as well as some of the information also found in the server log files.
Further information on each tracking tool can be found in the cookie declaration. The consent settings are also manageable by the visitor from the cookie declaration, which not only appears automatically at the first visit, but can also be accessed at any other time, by clicking on the cookie icon placed on the bottom-left of Your screen during Your Website visit.
The deployment period for each tracking tool is detailed in the cookie declaration. The same applies for recipients of the information contained in the cookie or tracking tool: the recipient will not coincide with the website provider (Devano), if the tracking tool is deployed by third parties.
| Recipient | Purpose of Processing | Location of Processing |
|---|---|---|
|
Objectis Ltd. Laisves st. 60, LT-05120 Vilnius Lithuania cookie-script.com/legal/privacy-policy |
Cookie declaration host, tracking tool consent management system provider | Netherlands |
|
PayPal (Europe) S.á r.l. Et Cie, S.C.A 22-24 Boulevard Royal. L-2449 Luxembourg paypal.com/myaccount/privacy/privacyhub |
Payment services support on website, fraud prevention | United States |
The Website uses SSL or TLS encryption for maintaining the security of the transmission of the information You send us in the context of using our Services or otherwise sending information to us via one of the Website’s forms. An encrypted connection is recognizable from the address bar: the URL should show "https://" and a lock icon should be displayed.
Please beware: if “https://” and the lock icon are missing from Your browser’s address bar, then any information shared with a recipient is in danger of being accessible to unauthorized third parties!
You may decide to register on the Website at Your own discretion. This activity will lead You to create Your own account and profile at rebasedata.com and gives access to the RebaseData Services on the basis of the General Terms. The account profile is created on the basis of the information You provide: unless branded as “optional”, all information requested must be inserted, otherwise the account registration will not be successful.
Personal data collected from registration form:
The registration process is protected from bots by Google’s reCAPTCHA technology. The technology is deployed on the Website thanks to a cookie which remains constantly activated for the entire visit session (see subsection above for more information). The information remains stored in the cookie for 6 months, after which it expires.
Personal data collected from reCAPTCHA:
| Recipient | Purpose of Processing | Location of Processing |
|---|---|---|
|
Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland policies.google.com/privacy |
reCAPTCHA risk analysis, anti-bot form validation | Ireland, United States |
The processing of personal data carried out in the context of the account registration is based on the entry and performance of a contractual agreement with You. You may rectify Your personal data at any time, by accessing Your personal account. We will retain the personal data until the account has not been deleted: this occurs when You expressly request deletion of Your account. The data connected to the account will be immediately deleted from Devano’s databases, unless the data is used on the basis of Devano’s legitimate interest (which may be security or establishment, exercise, defense of legal claims) or towards the fulfillment of a legal obligation, such as in the context of invoicing.
Any data collected for the purposes of providing the Services is hosted in third-party cloud servers. The provider of the hosting services therefore receives any information sent to Devano in the context of the Services. The hosting services provider will not have access to any of the hosted information, unless strictly necessary for the purposes of maintenance and troubleshooting, on the basis of Devano’s explicit request.
| Recipient | Purpose of Processing | Location of Processing |
|---|---|---|
|
Wavecon GmbH Thomas-Mann-Straße 16-20, 90471 Nürnberg, Germany wavecon.de/de/datenschutz (available only in German) |
Data hosting | Germany |
As a user of the RebaseData Services, You must send Devano the database(s) designated for conversion, and select the input and desired output formats. Devano is not in control of the types of information the database(s) contain: Devano encourages to carry out due diligence risk assessments before sending the database(s) over to Devano. Regardless of the contained information, however, Devano has implemented information security systems and practices in order to keep Your information secure.
The RebaseData Security page illustrates the security practices implemented for ensuring Your information remains secure at all times.
Devano utilizes PayPal’s platform for enabling its customers to pay for the Services. Paying for Devano’s Services requires customers to have an active PayPal account. For more information on which personal data PayPal requires for creating and managing an account, and how PayPal uses such information, please visit PayPal’s privacy statement .
From PayPal, Devano receives details about the payment sender, including profile details as contained in the PayPal profile, and payment details, such as amount paid, time and date of payment and object of the payment (likely, the invoice no.).
Devano sends invoices to its customers based on the information found in their user profile, including the recipient email address to send the invoice to.
| Recipient | Purpose of Processing | Location of Processing |
|---|---|---|
|
PayPal (Europe) S.á r.l. Et Cie, S.C.A 22-24 Boulevard Royal. L-2449 Luxembourg paypal.com/myaccount/privacy/privacyhub |
Payment services | United States |
You may send support requests directly to us using the link found in the Support page. Clicking on the “support@rebasedata.com” link automatically sends You to Your email operator of choice in order to type and send the support request. The email operator chosen for routing depends on Your email-related settings on Your device.
For security purposes, please ensure that the email address from which You send the request to Devano matches the email address found in Your RebaseData account!
Devano receives the communication You send in the context of the support request and may choose to answer You using the same instrument. Devano uses Zendesk’s services to handle support requests.
| Recipient | Purpose of Processing | Location of Processing |
|---|---|---|
|
Zendesk, Inc. 989 Market St San Francisco, CA 94103 United States |
Support request management platform | United States |
Devano may send marketing-related communications in different forms, using ActiveCampaign’s services to do so.
The personal data processed for sending marketing communications are limited to:
To recurring customers, Devano may send communications relating to its Services, such as updates or other material that may interest previous users of the Services. These communications are based on Devano’s legitimate interests to sell its Services to recurring and possibly interested returning customers.
Devano may also send newsletters and other forms of marketing-related communications to anyone that has signed up to receive such communications. The sending of these communications is based on the recipient’s individual and freely-given consent, which may be revoked at any time either by unsubscribing to the newsletter (or other marketing-related communication) list using the link found in each communication of this kind, or by sending a consent withdrawal request directly to Devano, using one of its communication channels available on the Website or in this privacy notice. No particular form is required for this type of request: make sure to insert the email address to which to stop sending the marketing-related communications, otherwise we will not be able to fulfill Your request.
| Recipient | Purpose of Processing | Location of Processing |
|---|---|---|
|
ActiveCampaign, LLC 1 N Dearborn St. FI 5, Chicago, IL 60602 United States activecampaign.com/legal/privacy-policy |
Marketing campaign communication and management services | United States |
As a data subject under applicable European data protection law, You have the right to:
In addition, You have the right to lodge a complaint to a supervisory authority of Your choice. We provide a link to the list of the supervisory authorities available in the European Economic Area here.
This following section is designated for consumers of the Website and the Services, as defined previously in this privacy notice, who are located in the US states of California, Colorado, Connecticut, Utah and Virginia.
Disclaimer: as stated in its General Terms, Devano does not seek to provide its services to consumers, intended as natural persons, regardless of where they might be located, instead seeking to provide its Services strictly to legal persons, intended as registered businesses.
The sources of personal data collected and otherwise processed by Devano are either automatic, solely through the use of the Website, or originate directly from the personal data shared with Devano by You, for example in the context of registering an account and/or using the Services.
The possible purposes of processing of the collected personal data are limited to:
Devano has not sold, does not sell and will not sell personal data, nor does Devano share personal data with third parties for cross-context behavioral advertising. Devano does not knowingly share any personal data of minors below the age of 16. Devano may not guarantee that no sensitive personal data, nor personal data of minors below the age of 16, are processed in the context of the provision of its services, since the content of the databases designated for conversion remain under sole responsibility of the user of the Services, and Devano has no interest in identifying any potential data subject from the information contained in the databases subject to its Services.
| Categories of personal data | Purpose of personal data | Recipients of personal data |
|---|---|---|
|
Identifiers (names, contact information, unique online identifiers) |
Account registration, provision of Services, billing, sending communications (incl. Marketing communications -- name and email address only) |
Data hosting service provider Payment service provider |
|
Commercial information (transaction information and purchase history) |
Provision of Services, billing, sending communications (direct marketing communications based on legitimate interest only) |
Data hosting service provider Payment service provider Tax consultants and authorities |
|
Internet or network activity information (IP address, MAC address, browser information, OS information, activity log timestamps) |
Provision of Website, provision of Services | Website hosting service provider Data hosting service provider |
Please refer to the “How long does Devano process the collected personal data for?” section at the beginning of this privacy notice for information on this topic.
If you are a resident of one of the US states mentioned at the beginning of this section, You may make the following requests, subject to applicable law:
We will not unlawfully discriminate against you for exercising your rights under applicable data privacy law.
Please submit any request mentioned in this section to . We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Data subject to the request. We may need to request additional Personal Data from you, such as your name and email address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Data. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Data.
You may choose to designate an authorized agent to make a request under the California Consumer Privacy Act on Your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Agents may be asked to provide proof of their status as an authorized agent. Once a request has been submitted by an authorized agent, we may require additional information from You to verify Your identity as described in this subsection or confirm that you provided the agent permission to submit the request.
For Devano’s contact information, please refer to the imprint page on the Website.
Devano may change or update this privacy notice, or only this specific section of the privacy notice, from time to time. The latest version of this privacy notice will always be posted by default under rebasedata.com/privacy. Previous versions of the privacy notice will be available from the “Previous Versions of this Privacy Notice” section, at the beginning of this page: each version will be defined by their respective date of publication, and will be presumed to have remained in effect until the date in which the newer version has/had been published.