Privacy

Privacy policy

How WhiteWhiteWeb Limited collects, processes and protects your personal data when you use this website.

1. Data protection at a glance

General notes

The following notes give a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. Detailed information on data protection can be found in the full privacy policy below.

Data collection on this website

Who is responsible for data collection on this website? Data processing on this website is carried out by the website operator. You can find their contact details in the "Controller" section of this privacy policy.

How do we collect your data? Some data is collected when you provide it to us — for example, data you enter into a contact form.

Other data is collected automatically, or with your consent, when you visit the website through our IT systems. This is primarily technical data (e.g. internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for? Some data is collected to ensure error-free provision of the website. Other data may be used to analyse your usage behaviour. Where contracts are concluded or initiated via the website, the transmitted data is also processed for contract offers, orders or other service requests.

What rights do you have regarding your data? You have the right at any time to receive free information about the origin, recipients and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke it at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. You further have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this or any other questions about data protection.

2. Hosting

We host the contents of our website with the following provider:

External hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

External hosting takes place for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6(1)(f) GDPR). Where corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user's end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent is revocable at any time.

Our host will only process your data to the extent necessary to fulfil its performance obligations and will follow our instructions regarding this data.

We use the following host:

Base44 Inc.
Backend-as-a-service platform
SOC 2 Type II and ISO 27001 certified

Data Processing Agreement: base44.com/dpa

Order processing (AVV)

We have concluded a contract for order processing (AVV) with Base44 for the use of the hosting service. This is a contract required by data protection law that ensures the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR. When an account is deleted, Base44 carries out a GDPR-compliant deletion process across all systems and sub-processors.

3. General notes and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We point out that data transmission over the internet (e.g. when communicating by email) can have security gaps. Complete protection of data against access by third parties is not possible.

Controller

The controller for data processing on this website is:

White White Web LTD
zh.k. Lazur Bl. 12, Et. 16, Ap. 96
8000 Burgas, Bulgaria

Phone: +49 151 52883076
Email: martin@whitewhiteweb.com

The controller is the natural or legal person who, alone or jointly with others, decides on the purposes and means of the processing of personal data (e.g. names, email addresses or similar).

Storage period

Unless a more specific storage period is stated in this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate deletion request or revoke consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial retention periods); in the latter case, deletion will take place once these reasons no longer apply.

Legal bases for data processing on this website

If you have consented to the data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, insofar as special categories of data under Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information in your end device (e.g. via device fingerprinting), the data processing is additionally based on § 25(1) TDDDG. Consent is revocable at any time. If your data is necessary for the fulfilment of a contract or for carrying out pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if this is necessary to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also take place on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. The relevant legal basis in each individual case is informed in the following paragraphs of this privacy policy.

Note on data transfer to third countries without an adequate level of data protection and to non-DPF-certified US companies

We use, among other things, tools from companies based in third countries without an adequate level of data protection and US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data can be transferred to and processed in these countries. We point out that in third countries without an adequate level of data protection, a level of data protection comparable to the EU cannot be guaranteed.

We note that the USA, as a safe third country, generally offers a level of data protection comparable to the EU. Data transfer to the USA is therefore permissible if the recipient has certification under the "EU-US Data Privacy Framework" (DPF) or has suitable additional safeguards. Information on transfers to third countries, including data recipients, can be found in this privacy policy.

Recipients of personal data

In the course of our business we work with various external parties. This sometimes requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary as part of contract fulfilment, if we are legally obliged to do so (e.g. transfer of data to tax authorities), if we have a legitimate interest under Art. 6(1)(f) GDPR in the transfer, or if another legal basis permits the data transfer. When using processors, we pass on personal data of our customers only on the basis of a valid contract for order processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to data processing

Many data processing operations are only possible with your explicit consent. You can revoke consent that has already been given at any time. The lawfulness of the data processing carried out up to the revocation remains unaffected by the revocation.

Right to object to data collection in particular cases and to direct advertising (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED IN ORDER TO OPERATE DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING INsofar AS IT IS CONNECTED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to complain to the competent supervisory authority

In the event of infringements of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged infringement. This right to complain exists without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only take place insofar as it is technically feasible.

Information, correction and deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this or any other questions about personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was/is unlawful, you can request restriction of data processing instead of deletion.
  • If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your and our interests must be carried out. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may — apart from its storage — only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is active, the data you transmit to us cannot be read by third parties.

4. Data collection on this website

Cookies

Our website uses so-called "cookies". Cookies are small data packets and cause no harm to your end device. They are either stored temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or automatic deletion is carried out by your web browser.

Cookies can come from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third parties within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies can be used to evaluate user behaviour or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions desired by you (e.g. for the shopping cart function) or to optimise the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is given. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing takes place exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent is revocable at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

If further cookies and services are used on this website, you can find this in this privacy policy.

Real Cookie Banner

Our website uses the consent technology of Real Cookie Banner to obtain your consent for the storage of certain cookies on your end device or for the use of certain technologies and to document this in a data-protection-compliant manner. The provider of this technology is devowl.io GmbH, Tannet 12, 94539 Grafling (hereinafter "Real Cookie Banner").

Real Cookie Banner is installed locally on our servers, so no connection is made to the servers of the provider of Real Cookie Banner. Real Cookie Banner stores a cookie in your browser in order to be able to assign the consents given or their revocation to you. The data collected in this way is stored until you request us to delete it, delete the Real Cookie Banner cookie yourself, or the purpose for the data storage no longer applies. Mandatory statutory retention periods remain unaffected.

The use of Real Cookie Banner serves to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Hostname of the accessing computer
  • Time of the server request
  • IP address

This data is not merged with other data sources.

The collection of this data takes place on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website — for this purpose, the server log files must be collected.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you provide there, will be stored in order to process the enquiry and for follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your enquiry is related to the fulfilment of a contract or is necessary for pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent is revocable at any time.

The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions — in particular retention periods — remain unaffected.

Enquiries by email, telephone or fax

If you contact us by email, telephone or fax, your enquiry, including all personal data arising from it (name, enquiry), will be stored and processed for the purpose of processing your request. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your enquiry is related to the fulfilment of a contract or is necessary for pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent is revocable at any time.

The data you send us via contact enquiries will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions — in particular statutory retention periods — remain unaffected.

5. Plugins and tools

Wordfence

We have integrated Wordfence on this website. The provider is Defiant, Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter "Wordfence").

Wordfence serves to protect our website from unwanted access or malicious cyber attacks. For this purpose, our website establishes a permanent connection to the servers of Wordfence so that Wordfence can compare its databases with the accesses made on our website and, if necessary, block them.

The use of Wordfence is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the most effective possible protection of its website against cyber attacks. If corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user's end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent is revocable at any time.

The transfer of data to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/.

6. eCommerce and payment providers

Processing of customer and contract data

We collect, process and use personal customer and contract data for the establishment, content design and amendment of our contractual relationships. We collect, process and use personal data about the use of this website (usage data) only insofar as this is necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.

The collected customer data will be deleted after completion of the order or termination of the business relationship and expiry of any existing statutory retention periods. Statutory retention periods remain unaffected.

7. Own services — handling of applicant data

Scope and purpose of data collection

If you submit an application to us, we will process the related personal data (e.g. contact and communication data, application documents, notes from interviews, etc.) insofar as this is necessary for a decision on establishing an employment relationship. The legal basis is § 26 BDSG under German law (initiation of an employment relationship), Art. 6(1)(b) GDPR (general contract initiation) and — if you have given consent — Art. 6(1)(a) GDPR. Consent is revocable at any time. Your personal data will be passed on within our company exclusively to persons involved in the processing of your application.

If the application is successful, the data you submitted will be stored in our data processing systems on the basis of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of carrying out the employment relationship.

Within the framework of the application process, we may also carry out an internet search of your person. This mainly includes Google search, LinkedIn and Xing. The legal basis for this type of processing is our legitimate interest in obtaining an overall impression of publicly accessible information about you in accordance with Art. 6(1)(f) GDPR.

Retention period of data

If we are unable to make you a job offer, you reject a job offer, or you withdraw your application, we reserve the right to retain the data you transmitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. The retention serves in particular evidentiary purposes in the event of a legal dispute. If it is apparent that the data will be required after expiry of the 6-month period (e.g. due to an imminent or pending legal dispute), deletion will only take place once the purpose for the further retention no longer applies.

Longer retention may also take place if you have given corresponding consent (Art. 6(1)(a) GDPR) or if statutory retention obligations oppose deletion.

8. Operation via the Base44 platform

This website is built and operated on the Base44 platform. In addition to the hosting described in section 2, Base44 provides authentication, database storage, file storage, email delivery, analytics and other infrastructure for this website. The further legal aspects relevant to Base44 are set out below.

Sub-processors

In operating this website, Base44 works with sub-processors who may process personal data. These include, in particular:

  • SendGrid — used for the delivery of transactional and system emails (e.g. email verification, password reset). SendGrid is a US-based provider; data transfer to the US is carried out on the basis of standard contractual clauses or the EU-US Data Privacy Framework.
  • Stripe — used for the processing of payments. Stripe acts as the payment service provider; the data processed is limited to what is necessary to carry out the payment transaction.

All service providers receiving personal data are bound by strict data processing agreements governing data transfer to the US, using approved mechanisms such as standard contractual clauses (SCCs) or the Data Privacy Framework.

Authentication

This website uses Base44's built-in authentication. Depending on configuration, the following sign-in methods may be available: email and password, as well as single sign-on via Google, Microsoft, Facebook, Apple and SSO (OIDC). When you register or log in, your email address and — for email/password sign-in — a securely hashed password are processed. Authentication tokens are stored in your browser's local storage for the duration of your session. If you sign in via a third-party provider (Google, Microsoft, Facebook, Apple), that provider processes the data necessary for the sign-in in accordance with its own privacy policy.

Processing for authentication is based on the performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR) and, where applicable, on your consent (Art. 6(1)(a) GDPR).

Analytics

This website uses Base44's app analytics. Analytics tracks visits, visitors, custom events (e.g. page views, button clicks) and, where applicable, sales, in order to analyse and improve the use of the website. The data collected for this purpose is aggregated and does not include identifying personal data beyond what is necessary for the measurement. Retention depends on the plan (Free: 7 days, Starter and above: 30 days, Enterprise: 365 days).

Processing for analytics is based on our legitimate interest in understanding how the website is used and improving it (Art. 6(1)(f) GDPR) or, where consent has been requested, on your consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the end device); consent is revocable at any time.

Data transfer to the US

The operation of this website via the Base44 platform and the use of the sub-processors named above involve the transfer of personal data to the United States. We point out that the USA is regarded as a safe third country with a level of data protection comparable to the EU where the recipient holds certification under the EU-US Data Privacy Framework (DPF) or has suitable additional safeguards (e.g. standard contractual clauses). Information on the recipients can be found in the sub-processors section above.

Your rights

The rights set out in section 3 of this privacy policy — information, correction, deletion, restriction of processing, data portability, objection, revocation of consent and the right to complain to a supervisory authority — apply in full to the processing carried out via the Base44 platform. You can exercise these rights with us as the controller at any time using the contact details in the Controller section.