Privacy Policy

Data Protection

We hereby inform you in accordance with the legal requirements of data protection law (in particular pursuant to the new Federal Data Protection Act (BDSG n.F.) and the European General Data Protection Regulation ‘GDPR’) about the nature, scope, and purpose of the processing of personal data by our company. This privacy policy also applies to our websites and social media profiles. For definitions of terms such as “personal data” or “processing,” we refer to Art. 4 GDPR.

ASGARD Group LLC
Didi Digomi, micro/district III, building 8/ N50
Tbilisi, Georgia
Email address: office@cctok.io

Types of Data, Purposes of Processing, and Categories of Data Subjects

 

Below we inform you about the nature, scope, and purpose of the collection, processing, and use of personal data.

1. Types of data we process
Usage data (access times, visited websites, etc.), inventory data (name, address, etc.), contact data (phone number, email, fax, etc.), payment data (bank details, account information, payment history, etc.), communication data (IP address, etc.),

2. Purposes of processing under Art. 13 para. 1 c) GDPR
Processing contracts, technically and economically optimizing the website, optimizing and statistically evaluating our services, supporting the commercial use of the website,

3. Categories of data subjects under Art. 13 para. 1 e) GDPR
Visitors/users of the website,

The data subjects are collectively referred to as “users.”


Legal Basis for Processing Personal Data

 

 

Below we inform you about the legal basis for processing personal data:

  1. If we have obtained your consent for the processing of personal data, Art. 6 para. 1 sentence 1 lit. a) GDPR serves as the legal basis.
  2. If the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures carried out at your request, Art. 6 para. 1 sentence 1 lit. b) GDPR serves as the legal basis.
  3. If the processing is necessary for compliance with a legal obligation to which we are subject (e.g., statutory retention obligations), Art. 6 para. 1 sentence 1 lit. c) GDPR serves as the legal basis.
  4. If the processing is necessary to protect the vital interests of the data subject or another natural person, Art. 6 para. 1 sentence 1 lit. d) GDPR serves as the legal basis.
  5. If the processing is necessary for the purposes of our legitimate interests or those of a third party, and your interests or fundamental rights and freedoms do not override those interests, Art. 6 para. 1 sentence 1 lit. f) GDPR serves as the legal basis.


Disclosure of Personal Data to Third Parties and Processors

Without your consent, we do not generally disclose data to third parties. If this is the case, the disclosure is based on the previously mentioned legal grounds, e.g., when disclosing data to online payment providers for contract fulfillment or due to a court order or legal obligation to disclose the data for law enforcement purposes, to avert danger, or to enforce intellectual property rights.
We also use processors (external service providers, e.g., for web hosting our websites and databases) to process your data. If data is disclosed to processors as part of an agreement on commissioned data processing, this is always done in accordance with Art. 28 GDPR. We carefully select our processors, monitor them regularly, and have been granted the right to issue instructions regarding the data. Additionally, processors must have taken appropriate technical and organizational measures and comply with data protection regulations according to BDSG n.F. and GDPR.


Data Transfers to Third Countries

The adoption of the European General Data Protection Regulation (GDPR) has created a uniform basis for data protection in Europe. Therefore, your data is primarily processed by companies for which GDPR applies. If processing by third-party services outside the European Union or the European Economic Area does occur, they must comply with the special requirements of Art. 44 ff. GDPR. This means the processing is based on specific guarantees, such as an officially recognized level of data protection corresponding to the EU by the EU Commission or compliance with officially recognized special contractual obligations, the so-called “standard contractual clauses”.
Insofar as we obtain your express consent for the data transfer to the USA due to the ineffectiveness of the so-called “Privacy Shield” under Art. 49 para. 1 sentence 1 lit. a) GDPR, we point out the risk of secret access by US authorities and the use of the data for surveillance purposes, potentially without legal remedies for EU citizens.


Deletion of Data and Storage Duration

Unless explicitly stated in this privacy policy, your personal data will be deleted or blocked once the consent given for processing is revoked by you, or the purpose for the storage no longer applies, and the data is no longer required for that purpose, unless further retention is necessary for evidence purposes or legal retention obligations stand in the way. These include commercial retention obligations for business letters under § 257 para. 1 HGB (6 years) and tax retention obligations for records under § 147 para. 1 AO (10 years). When the prescribed retention period expires, your data will be blocked or deleted unless the storage is still required for a contract conclusion or fulfillment.


Existence of Automated Decision-Making

We do not use automated decision-making or profiling.


Provision of Our Website and Creation of Log Files

  1. If you use our website purely for informational purposes (i.e., without registration or otherwise providing information), we only collect the personal data that your browser transmits to our server. If you view our website, we collect the following data:
    • IP address;
    • Internet service provider of the user;
    • Date and time of access;
    • Browser type;
    • Language and browser version;
    • Content of the request;
    • Time zone;
    • Access status/HTTP status code;
    • Data volume;
    • Websites from which the request comes;
    • Operating system.
    This data is not stored together with other personal data of yours.
     
  2. This data serves the purpose of providing a user-friendly, functional, and secure delivery of our website to you with its functions and contents, as well as their optimization and statistical evaluation.
     
  3. The legal basis for this is our legitimate interest in the data processing in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.
     
  4. For security reasons, we store this data in server log files for the duration of days. After this period, it is automatically deleted, unless we need to keep it for evidence purposes in the event of attacks on the server infrastructure or other legal violations.

 


Cookies

  1. We use so-called cookies when you visit our website. Cookies are small text files that your internet browser places and stores on your computer. When you revisit our website, these cookies provide information to automatically recognize you. Cookies also include so-called "user IDs," where user information is stored in pseudonymized profiles. We inform you about the use of cookies for the aforementioned purposes and how you can object to or prevent their storage ("opt-out") when you access our website.

    We distinguish between the following types of cookies:

    • Necessary, essential cookies: Essential cookies are absolutely necessary for the operation of the website to store specific functions such as logins, shopping carts, or user inputs regarding the language of the website.

    • Session cookies: Session cookies are needed to recognize multiple uses of an offer by the same user (e.g., if you have logged in to determine your login status). When you revisit our site, these cookies provide information to automatically recognize you. The information obtained serves to optimize our offers and provide you with easier access to our site. When you close the browser or log out, the session cookies are deleted.

    • Persistent cookies: These cookies remain stored even after you close the browser. They serve to store the login, measure reach, and for marketing purposes. These are automatically deleted after a predetermined duration, which can vary depending on the cookie. You can delete the cookies at any time in your browser's security settings.

    • Third-party cookies (especially from advertisers): You can configure your browser settings according to your wishes and, for example, refuse the acceptance of third-party cookies or all cookies. However, please note that you may not be able to use all functions of this website in that case. For more information about these cookies, refer to the respective privacy policies of the third-party providers.
     
  2. Data categories: User data, cookie, user ID (including visited pages, device information, access times, and IP addresses).
     
  3. Purposes of processing: The information obtained serves the purpose of technically and economically optimizing our web offers and providing you with easier and more secure access to our website.
     
  4. Legal basis: If we process your personal data with the help of cookies based on your consent ("opt-in"), then Art. 6 para. 1 sentence 1 lit. a) GDPR is the legal basis. Otherwise, we have a legitimate interest in the effective functionality, improvement, and economic operation of the website, so in this case, Art. 6 para. 1 sentence 1 lit. f) GDPR is the legal basis. Additionally, Art. 6 para. 1 sentence 1 lit. b) GDPR is the legal basis if the cookies are set for the initiation of a contract, e.g., for orders.
     
  5. Storage duration/deletion: The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of data collection for the provision of the website, this is the case when the respective session is ended.

    Cookies are otherwise stored on your computer and transmitted from there to our site. Therefore, you as the user have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may not be possible to use all functions of the website to their full extent.

    Here you can find information on deleting cookies by browser:

    Chrome: https://support.google.com/chrome/answer/95647

    Safari: https://support.apple.com/guide/safari/sfri11471/mac

    Firefox: https://support.mozilla.org/kb/cookies-und-website-daten-in-firefox-loschen

    Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies

    Microsoft Edge: https://support.microsoft.com/help/4027947/windows-delete-cookies
     
  6. Objection and "Opt-Out": You can generally prevent the storage of cookies on your hard drive independently of consent or legal permission by selecting "do not accept cookies" in your browser settings. However, this may lead to a restriction of our offers' functionality. You can object to the use of cookies from third-party providers for advertising purposes via an "opt-out" through this American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de/praferenzmanagement/).

Newsletter

  1. You can subscribe to our newsletter with your voluntary consent by entering your email address. Only the email address is mandatory. Providing further data is optional and serves only the purpose of personal addressing. We use the so-called "double opt-in procedure" for registration. After you sign up with your email address, you will receive a confirmation email with a link. When you click this confirmation link, your email will be added to the newsletter distribution list and stored for the purpose of sending emails. If you do not click the confirmation link within hours, your registration data will be blocked and automatically deleted after days.
     
  2. We also log the IP address you used during registration and the date and time of the double opt-in (registration and confirmation). The purpose of this storage is to fulfill legal requirements regarding proof of your registration and to prevent misuse of your email address.
     
  3. In the context of your consent, the contents of the newsletter (e.g., advertised products/services, offers, advertising, and topics) are specifically described.
     
  4. When sending the newsletter, we evaluate your user behavior. The newsletters contain so-called "web beacons" or "tracking pixels" that are called up when the newsletter is opened. For the evaluations, we link the web beacons with your email address and an individual ID. Links in the newsletter also contain this ID. The data is collected exclusively in a pseudonymized manner, meaning the IDs are not linked with your other personal data, excluding direct personal reference. With this data, we can determine whether and when you opened the newsletter and which links in the newsletter were clicked. This serves the purpose of optimizing and statistically evaluating our newsletter.
     
  5. The legal basis for sending the newsletter, measuring success, and storing the email is your consent pursuant to Art. 6 para. 1 sentence 1 lit. a) GDPR in conjunction with § 7 para. 2 no. 3 UWG and for logging the consent Art. 6 para. 1 sentence 1 lit. f) GDPR, as this serves our legitimate interest in legal proof.
     
  6. You can object to tracking at any time by clicking the unsubscribe link at the end of the newsletter. In that case, however, receiving the newsletter will also be terminated. If you disable image display in your email software, tracking is also not possible. However, this may restrict the newsletter's functionality, and images may not be displayed.
     
  7. You can revoke your consent to receive the newsletter at any time. You can exercise the revocation by clicking the unsubscribe link at the end of the newsletter, sending an email, or notifying us at the above contact details. We will store your data as long as you are subscribed to the newsletter. After unsubscribing, your data will only be stored anonymously for statistical purposes.
     


Google Analytics

  1. We have integrated the website analysis tool "Google Analytics" (Service Provider: Google Ireland Limited, Registration No.: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) on our website.
     
  2. Data categories and description of data processing: User-ID, IP address (anonymized). When you visit our website, Google sets a cookie on your computer to analyze your use of our website. We have activated IP anonymization ("anonymizeIP"), meaning that IP addresses are processed only in a shortened form. On this website, your IP address will therefore be truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services related to website and internet use to the controller. We have also enabled cross-device analysis of website visitors, which is conducted via a so-called User-ID. The IP address transmitted by your browser within the framework of Google Analytics will not be merged with other data from Google. Further information on data usage by Google Analytics can be found here: https://www.google.com/analytics/terms/de.html (Analytics Terms of Use), https://support.google.com/analytics/answer/6004245?hl=de (Privacy Policy for Analytics) and Google's Privacy Policy https://policies.google.com/privacy.
     
  3. Purpose of processing: The use of Google Analytics serves the purpose of analyzing, optimizing, and improving our website.
     
  4. Legal basis: If you have given your consent for processing your personal data using "Google Analytics" from the third-party provider ("opt-in"), then Art. 6 para. 1 sentence 1 lit. a) GDPR is the legal basis. The legal basis is also our legitimate interest (analysis, optimization, and improvement of our website) in data processing under Art. 6 para. 1 sentence 1 lit. f) GDPR. For services provided in connection with a contract, tracking and analysis of user behavior are carried out under Art. 6 para. 1 sentence 1 lit. b) GDPR to offer optimized services based on the information obtained.
     
  5. Storage duration: The data we send and link to cookies, user identifiers (e.g., User-ID), or advertising IDs will be automatically deleted after months. The deletion of data whose retention period has been reached occurs automatically once a month.
     
  6. Data transfer/recipient category: Google, Ireland and USA. We have also entered into a data processing agreement with Google under Art. 28 GDPR.
     
  7. Opt-out options:
    • You can generally prevent cookies from being stored on your hard drive by selecting "do not accept cookies" in your browser settings. This may, however, result in a restriction of our offers' functionality. You can also prevent the collection of data generated by the cookie and related to your use of the website by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de

    • As an alternative to the above browser plugin, you can prevent Google Analytics from collecting data by clicking [__please insert the Analytics Opt-Out link for your website here]. Clicking this link will set an "opt-out" cookie that will prevent your data from being collected when visiting this website in the future. This cookie applies only to our website and your current browser and will only last until you delete your cookies. In that case, you would need to set the cookie again.

    • You can disable cross-device user analysis in your Google account under "My data > Personal data".
     


YouTube Videos

  1. We have integrated YouTube videos from youtube.com using the embedded function, so they are directly accessible on our website. YouTube belongs to Google Ireland Limited, Registration No.: 368047, Gordon House, Barrow Street, Dublin 4, Ireland.
     
  2. Data category and description of data processing: Usage data (e.g., visited website, contents, and access times). We have integrated the videos in "enhanced privacy mode" without using cookies to track usage behavior to personalize video playback. Instead, video recommendations are based on the currently played video. Videos played in enhanced privacy mode in an embedded player do not affect which videos are recommended to you on YouTube. When starting a video (clicking on the video), you consent to YouTube tracking the information that you have accessed the corresponding subpage or video on our website and using this data for advertising purposes.
     
  3. Purpose of processing: Providing a user-friendly offer, optimizing, and improving our content.
     
  4. Legal basis: If you have given your consent for processing your personal data using "etracker" from the third-party provider ("opt-in"), then Art. 6 para. 1 sentence 1 lit. a) GDPR is the legal basis. The legal basis is also our legitimate interest in data processing for the aforementioned purposes in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR. For services provided in connection with a contract, tracking and analysis of user behavior are carried out under Art. 6 para. 1 sentence 1 lit. b) GDPR to offer optimized services based on the information obtained.
     
  5. Data transfer/recipient category: Third-party providers in the USA. The collected data is transferred to and stored in the USA. This also applies without a user account with Google. If you are logged into your Google account, Google can associate this data with your account. If you do not want this, you must log out of your Google account. Google creates user profiles from such data and uses this data for advertising, market research, or optimizing its websites.
     
  6. Storage duration: Cookies are stored for up to 2 years or until you delete the cookies.
     
  7. Objection: You have the right to object to the creation of user profiles by Google. Please contact Google directly via the privacy policy linked below. You can opt-out of advertising cookies in your Google account at: https://adssettings.google.com/authenticated.
     
  8. For more information on YouTube's terms of use and Google's privacy policy for advertising, visit: https://www.youtube.com/t/terms and https://policies.google.com/technologies/ads.
     
  9. Information on the use of Google cookies and their advertising technologies, storage duration, anonymization, location data, functioning, and your rights can be found in Google's general privacy policy: https://policies.google.com/privacy.
     


Presence in Social Media

  1. We maintain profiles or fan pages on social media platforms. When you use and access our profile on the respective network, the respective network's privacy notices and terms of use apply.
     
  2. Data categories and description of data processing: Usage data, contact data, content data, inventory data. Additionally, user data is typically processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on user behavior and interests. These usage profiles can, in turn, be used to display advertisements inside and outside the networks that presumably match the users' interests. For these purposes, cookies are generally stored on users' devices, in which the users' usage behavior and interests are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them). For a detailed description of the respective processing forms and opt-out options, please refer to the privacy policies and information of the operators of the respective networks. In cases of requests for information and the assertion of user rights, we also point out that these can be most effectively asserted with the providers. Only the providers have access to the users' data and can directly take appropriate measures and provide information. Should you still need assistance, you can contact us.
     
  3. Purpose of processing: Communication with users connected and registered on social networks; information and advertising for our products, offers, and services; external representation and image maintenance; evaluation and analysis of users and content of our presence on social media.
     
  4. Legal basis: The legal basis for processing personal data is our legitimate interest in the aforementioned purposes in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR. If you have given consent to the processing of your personal data by the respective social network provider, the legal basis is Art. 6 para. 1 sentence 1 lit. a) in conjunction with Art. 7 GDPR.
     
  5. Data transfer/recipient category: Social network.
     
  6. The privacy notices, information options, and opt-out options of the respective networks/service providers can be found here:

    Facebook – Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy/, Opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com; Objection: https://www.facebook.com/help/contact/2061665240770586; Agreement on joint processing of personal data on Facebook pages (Art. 26 GDPR): https://www.facebook.com/legal/terms/page_controller_addendum, Privacy notices for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.

    Instagram – Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Privacy policy/Opt-out: https://help.instagram.com/519522125107875, Objection: https://help.instagram.com/contact/186020218683230; Agreement on joint processing of personal data on Instagram pages (Art. 26 GDPR): https://www.facebook.com/legal/terms/page_controller_addendum.

    Twitter – Service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy policy: https://twitter.com/de/privacy, Opt-out: https://twitter.com/personalization.

    LinkedIn – Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy and Opt-out: https://www.linkedin.com/legal/cookie-policy
     


Rights of the Data Subject

  1. Objection or Withdrawal of Consent to Data Processing

    If the processing is based on your consent pursuant to Art. 6 para. 1 sentence 1 lit. a), Art. 7 GDPR, you have the right to withdraw your consent at any time. The legality of the processing carried out based on the consent until the withdrawal is not affected.

    If we base the processing of your personal data on a balancing of interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR, you can object to the processing. This is the case if the processing is not necessary for the performance of a contract with you, which we will indicate in the following description of the functions. When exercising such an objection, please explain why we should not process your personal data as we have done. In the case of your justified objection, we will examine the situation and either stop or adjust the data processing or show you our compelling legitimate reasons for continuing the processing.

    You can object to the processing of your personal data for advertising and data analysis purposes at any time. You can exercise your right to object free of charge. You can inform us of your advertising objection at the following contact details:

    ASGARD Group LLC
    Didi Digomi, micro/district III, building 8/ N50
    Tbilisi, Georgia
    Email: office@cctok.io

     
  2. Right of Access
    You have the right to request confirmation from us as to whether personal data concerning you is being processed. If this is the case, you have a right of access to your personal data stored with us pursuant to Art. 15 GDPR. This includes, in particular, information on the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data, if not collected directly from you.
     
  3. Right to Rectification
    You have the right to correct inaccurate or complete accurate data pursuant to Art. 16 GDPR.
     
  4. Right to Deletion
    You have the right to have your data stored with us deleted pursuant to Art. 17 GDPR unless legal or contractual retention periods or other legal obligations or rights to further storage stand in the way.
     
  5. Right to Restriction
    You have the right to request a restriction on the processing of your personal data if one of the conditions in Art. 18 para. 1 lit. a) to d) GDPR is met:
    • If you dispute the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

    • the processing is unlawful, and you oppose the deletion of the personal data and request the restriction of its use instead;

    • the controller no longer needs the personal data for processing purposes, but you require it to establish, exercise, or defend legal claims; or

    • if you have objected to the processing pursuant to Art. 21 para. 1 GDPR and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.
     
  6. Right to Data Portability
    You have the right to data portability pursuant to Art. 20 GDPR, which means you can receive the personal data we have stored about you in a structured, commonly used, and machine-readable format or request its transfer to another controller.
     
  7. Right to Complain
    You have the right to lodge a complaint with a supervisory authority. You can usually contact the supervisory authority in your place of residence, workplace, or the place of the alleged infringement.
     


Data Security

To protect all personal data transmitted to us and to ensure that data protection regulations are complied with by us and our external service providers, we have taken appropriate technical and organizational security measures. Therefore, all data between your browser and our server is transmitted in encrypted form via a secure SSL connection.

 

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