(Status: August the 10th, 2020)
The personal data of our users and the protection of this data is our highest priority. In the context of visiting this online service (www.vlyby.com), we would, therefore, like to provide an overview of how the user's personal data is handled.
If you have any further questions about data privacy, please do not hesitate to contact us.
Table of contents
The controller in the sense of the EU General Data Protection Regulation (GDPR) and other national data protection laws of the member states and other data protection regulations is:
VLYBY Digital GmbH
Schwanthalerstrasse 22
80336 Munich
Phone: +49 89 / 2000067-80
Fax: +49 89 2000067-99
Email: privacy@vlyby.com
Web: www.vlyby.com
In the following also "us", "we" or "VLYBY".
This can be done in different ways:
When you visit the www.vlyby.com website, the systems used automatically collect data. These primarily technical data include, for example, the operating system used by the website visitor, the Internet browser he or she uses or the time at which the page is called up.
The collection of your data takes place here, for example, when you enter your name and e-mail address in the contact form at https://vlyby.com/contact.
As a matter of principle, we process personal data of our users only to the extent necessary to provide a functional website and our contents and services. The processing of personal data of our users regularly only takes place with the user's consent. An exception is made in those cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.
The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided by the European or national legislator in EU regulations, laws or other regulations to which the data controller is subject. Data will also be blocked or deleted when a storage limitation prescribed by the above-mentioned norms expires unless there is a need for further storage of the data to conclude or fulfil a contract.
Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a GDPR serves as the legal basis.
In the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to process operations which are necessary to carry out pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 letter f GDPR serves as the legal basis for the processing.
If personal data is processed from you, you are a data subject within the meaning of the GDPR and you are naturally entitled to rights against the data controller:
VLYBY uses an external hosting provider or service provider to host the website www.vlyby.com or to provide the online service. The personal data collected on the website is stored on the hosting provider's servers when you visit the website.
The data include, for example:
VLYBY has signed a data processing agreement with the service provider. This serves the purpose of ensuring that data processing is correct under data protection laws or complies with data protection regulations. Personal data will only be processed within the scope of our data-related instructions to the hosting service provider and to fulfil the service provider's service obligations.
The hosting provider is used for the following purposes:
The protection of your data has the highest priority for us. For this reason, this data is always handled confidentially and always under all applicable legal data protection laws and this privacy policy.
Personal data: When using the website www.vlyby.com various personal data is collected. In essence, this is data that makes it possible to personally identify a natural person.
Which data is collected via this website and for what purpose and what it is used for is explained in this privacy policy.
In the context of data transfer on the Internet (e.g. e-mail communication), it should be noted at this point that this may have security gaps. It follows that complete protection of data against access by third parties is not possible.
This is a legal or natural person who, together with others or alone, decides on all purposes and all means of processing personal data (e.g. e-mail address).
The data controller for data processing at www.vlyby.com is:
VLYBY Digital GmbH
Schwanthalerstrasse 22
80336 München
Germany
Phone: +49 89 / 2000067-80
Email: privacy@vlyby.com
Web: www.vlyby.com
In principle, if SSL or TLS encryption is activated, data transmitted to us by the user is so secure that it cannot be read by third parties. For security reasons and to protect the transmission of confidential content (e.g. inquiries sent to the site operator), TLS or SSL encryption is used on this website. Such an encrypted connection can be recognized by the lock symbol in the browser line and by the fact that the browser address line changes from "http://" to "https://".
If personal data are processed from you, you are a data subject within the meaning of the GDPR and you are entitled to the following rights against the data controller:
You have the right to receive the personal data relating to you that you have provided to the data controller in a structured, common and machine-readable format. You also have the right to have this data communicated to another data controller without interference from the data controller to whom the personal data has been made available, provided that
In exercising this right, you also have the right to obtain that the personal data relating to you be transferred directly from one data controller to another data controller, insofar as this is technically possible. The freedoms and rights of other persons must not be affected by this.
The right to data transferability shall not apply to the processing of personal data which is necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the data controller.
You may request confirmation from the data controller as to whether personal data relating to you is being processed by us.
In the event of such processing, you may request the following information from the data controller:
You have the right to request information as to whether personal data relating to you is transferred to a third country or an international organisation. In this context, you may request to be informed of the appropriate guarantees under Art. 46 GDPR in connection with the transfer.
You have the right to ask the data controller to rectify and/or complete any personal data processed regarding you if it is incorrect or incomplete. The data controller shall correct without delay.
You may request the data controller to delete the personal data relating to you without delay and the data controller is obliged to delete such data without delay if one of the following reasons applies:
If the data controller has made public the personal data relating to you and is obliged to delete them under Art. 17 para. 1 GDPR, he shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as a data subject, have requested them to delete all links to these personal data or copies or replications of these personal data.
The right of erasure does not exist insofar as the processing is necessary
Under the following conditions, you may request the restriction of the processing of personal data relating to you:
Where the processing of personal data relating to you has been restricted, such data may be processed, except for storage, only with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.
If the restriction on processing has been restricted under the above conditions, you will be informed by the data controller before the restriction is removed.
You have the right to object at any time, for reasons relating to your particular situation, to the processing of personal data relating to you which is carried out based on Art. 6 para. 1 lit. e or f of the GDPR; this also applies to profiling based on these provisions.
The data controller will no longer process the personal data relating to you unless it can demonstrate compelling legitimate reasons for processing which outweigh your interests, rights and freedoms, or unless the processing serves to assert, exercise or defend legal claims.
If the personal data relating to you are processed for the purpose of direct marketing, you have the right to object, at any time, to the processing of your data for the purpose of such marketing, including profiling, insofar as it relates to such direct marketing.
If you object to processing for the purposes of direct marketing, the personal data relating to you will no longer be processed for those purposes.
You can exercise your right of objection with the use of information society services, without prejudice to Directive 2002/58/EC, by using automated procedures involving technical specifications.
You have the right to revoke your data privacy consent at any time. Revocation of your consent does not affect the legality of the processing that has taken place based on your consent until revocation.
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you are resident, your place of work or the place of the alleged breach, if you consider that the processing of personal data relating to you is in breach of the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.
Whenever our website is called up, our system automatically collects data and information from the computer system of the calling computer.
The following data is collected:
This data is not merged with other data sources. These data are collected based on Art. 6 para. 1 lit. f GDPR.
The data is stored in log files to ensure the functionality of the website. Also, the data serves us to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
If the user sends enquiries to VLYBY via the contact form, the information given in the enquiry form, including the contact details provided by the user there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We will not pass on this data without the user's consent.
This data is processed based on Art. 6 para. 1 lit. b GDPR, insofar as the user's enquiry is related to the fulfilment of a contract or is necessary for the execution of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on
Consent (Art. 6 para. 1 lit. a GDPR) of the user, provided this has been requested.
The data entered by the user in the contact form will remain with VLYBY until the user requests us to delete it, revokes his consent to its storage or the purpose for which the data is stored no longer applies (e.g. after completion of the processing of his request). Mandatory legal provisions - especially retention periods - remain unaffected.
If the user contacts us by e-mail, telephone or fax, his enquiry including all personal data (e.g. name, enquiry) coming from it will be stored and processed by us for the purpose of processing his request. We will not pass on this data without his consent. The processing of this data is based on Art. 6 para. 1 lit. b GDPR, if his enquiry is related to the fulfilment of a contract or is necessary for the execution of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on his consent (Art. 6 para. 1 lit. a GDPR), insofar as this has been requested. The data sent to us by the user via contact requests remain with us until the user requests us to delete it, revokes his consent to its storage or the purpose for which the data was stored no longer applies (e.g. after his request has been processed). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
We offer you the opportunity to apply for a job with us (e.g. by e-mail or by post). In the following, we will inform you about the scope, purpose and use of your data collected during the application process. We assure you that the collection, processing and use of your data will be under the applicable data protection laws and all other legal requirements and that your data will be treated in strict confidence.
If you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes taken during job interviews, etc.) to the extent that this is necessary to decide whether to establish an employment relationship.
The legal basis for this is § 26 BDSG-new under German law (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and - if you have given your consent - Art. 6 para. 1 lit. a GDPR. Consent may be revoked at any time. Within our company, your data will only be passed on to persons involved in the processing of your application.
If the application is successful, the data submitted by you will be stored in our data processing systems based on § 26 BDSG-new and Art. 6 Para. 1 lit. b GDPR for the purpose of carrying out the employment relationship.
If we are unable to offer you a job, if you reject a job offer, withdraw your application, revoke your consent to data processing or request us to delete the data, the data you have submitted, including any remaining physical application documents, will be stored or retained for a maximum of 6 months after completion of the application process (retention period) to be able to trace the details of the application process in the event of discrepancies (Art. 6 para. 1 lit. f GDPR).
YOU MAY OBJECT TO THIS STORAGE IF YOU HAVE LEGITIMATE INTERESTS THAT OUTWEIGH OUR OWN.
After expiry of the retention period, the data will be deleted, unless there is a legal obligation to retain the data or any other legal reason for further storage. If it is evident that the storage of your data will be necessary after the end of the storage period (e.g. due to an imminent or pending legal dispute), the data will only be deleted when it has become obsolete. Other legal storage obligations remain unaffected.
On our website, we offer users the possibility to register by providing personal data. The data is entered into an input mask, transmitted to us and stored. The data will not be passed on to third parties. The following data is collected during the registration process:
The following data is also stored in the second point of the registration:
The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given his consent. If the registration serves the fulfilment of a contract to which the user is a party or the implementation of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 para. 1 lit. b GDPR.
Registration of the user is required for the fulfilment of a contract with the user or the implementation of pre-contractual measures.
If a user enters into a service relationship with VLYBY, the User will receive regular reporting values as a customer, which are generated within the service relationship. After registering on the website, he/she then has the opportunity to view the performance values that have been generated within the scope of the cooperation in the form of figures and graphics ("dashboard"). The dashboard function on www.vlyby.com is therefore necessary within the scope of the service or customer relationship. For a correct allocation of the user to the performance values, an identification based on his entered data is necessary.
This is the case for the data collected during the registration process for the fulfilment of a contract or the implementation of pre-contractual measures if the data are no longer required for the execution of the contract. Even after conclusion of the contract, it may still be necessary to store personal data of the contractual partner to comply with contractual or legal obligations.
As a user, you have the possibility to cancel the registration at any time. You can have the data stored about you changed at any time. For deletion of the account or a change of data, you can contact us under point 6 of this privacy policy mentioned contact options.
If the data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, early deletion of the data is only possible if no contractual or legal obligations prevent a deletion.
For all questions and information regarding data privacy, you can reach us at the following contact details:
VLYBY Digital GmbH
Schwanthalerstrasse 22
80336 München
Germany
Phone: +49 89 / 2000067-80
Email: privacy@vlyby.com
Web: www.vlyby.com
