Last Changed: 24.05.2018
HMD Speakeasy GmbH understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1.) Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 11, below
|"Our Site"|| |
means this website, www.speakeasy.eu
|"EU Cookie Law"|| |
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015
means HMD Speakeasy GmbH, a limited company registered in Germany under HRB 176462 B, whose registered address is Torstraße 110, 10119 Berlin.
2.) Information About Us
2.1) Our Site, www.speakeasy.eu, is owned and operated by HMD Speakeasy GmbH, a limited company registered in Germany under HRB 176462 B, whose registered address is Torstraße 110, 10119 Berlin. Our VAT number is DE306452593
2.2) HMD Speakeasy GmbH is represented by Marc Metz & David Bregler
3.) Scope – What Does This Policy Cover?
4.) What Data Do We Collect?
- Email address
- IP address (automatically collected)
5.) How Do We Use Your Data?
5.1) All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2) We use your data to provide the best possible services to you. This includes:
5.2.1) Personalising and tailoring your experience on Our Site
5.2.2) Responding to communications from you
5.2.3) Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience
5.3) In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.4) Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract
c) processing is necessary for compliance with a legal obligation to which we are subject
d) processing is necessary to protect the vital interests of you or of another natural person
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child
6.) How and Where Do We Store Your Data?
6.1) We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an review to ascertain whether we need to keep your data. The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations.
6.2) Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
6.3) Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7.) Do We Share Your Data?
7.1) We may contract with third parties to supply services to you on Our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.2) We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3) In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8.) Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
8.1) You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
8.3) You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 14, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
9.) How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 14.
10.) Which services of third parties are used?
11.) What Cookies Do We Use and What For?
11.2) By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for analytics services, advertising service and payment processing. For more details, please refer to section 5, above, and to section 11.4 below. These Cookies are not integral to the functioning of Our Site.
11.3) Certain features of Our Site depend on Cookies to function. EU Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 11.8, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
11.4) The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Persistent or Session|
|speakeasy_session||Provides a unique session identifier||Session|
|cookie_bar||Checks if the cookie bar was closed||Persistent|
and the following third party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
| _ga |
|Google (Google Analytics)||Used for analytics and service improvements|
11.5) Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
11.6) The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 11.8.
11.7) The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|_ga||Third||Google Analytics||Used to distinguish users|
|_gid||Third||Google Analytics||Used to distinguish users|
|_gat||Third||Google Analytics||Used to throttle request rate|
11.8) You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
11.9) You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
11.10) It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12.) Summary of Your Rights under GDPR
Under the GDPR, you have:
12.1) the right to request access to, deletion of or correction of, your personal data held by Us;
12.2) the right to complain to a supervisory authority;
12.3) be informed of what data processing is taking place;
12.4) the right to restrict processing;
12.5) the right to data portability;
12.6) object to processing of your personal data;
12.7) rights with respect to automated decision-making and profiling (see section 13 below).
13.) Automated Decision-Making and Profiling
We do not use automatic decision-making or profiling.
14.) Contacting us