Privacy Policy

Overview


Last updated June 3, 2024

With this Privacy Policy, we inform you about our handling of your personal data and your rights under the European General Data Protection Regulation (GDPR). Our Privacy Policy consists of two parts. Part A provides you with general information on data protection at our company and explains, among other things, what rights you have and how you can assert them. Part B is dedicated to the various groups of data subjects and explains in detail what data we collect and process about you. We address you in your role as:


a. Website visitors,


b. Contact persons at service providers, suppliers, and business partners,


c. Social media visitors.


General information

1. Our contact details

If you have any questions or suggestions regarding this information or would like to contact us to assert your rights, please send your request to:


Pana Investments UG (haftungsbeschränkt)
Starstrasse 2, 22305 Hamburg, Germany
Email: hello@actmeraki.com


2. On what basis do we process your data?

"Personal data" refers to any information relating to an identified or identifiable person. We process personal data in compliance with the relevant data protection regulations, particularly the GDPR. We only process personal data based on legal authorization. This means we process your data only with your consent (Art. 6 (1) (a) GDPR), for the performance of a contract to which you are a party or at your request to implement pre-contractual measures (Art. 6 (1) (b) GDPR), to comply with a legal obligation (Art. 6 (1) (c) GDPR), or if the processing is necessary to protect our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data, prevail (Art. 6 (1) (f) GDPR).


3. Your rights

You decide on your data! As a data subject, you have the right to assert your data subject rights against us. You have the following rights within the scope of the data protection laws applicable to you:

  • In accordance with Art. 15 GDPR, you have the right to request information as to whether or not we process personal data relating to you and, if so, to what extent.
  • You have the right to demand that we rectify your data in accordance with Art. 16 GDPR.
  • You have the right to demand that we erase your personal data in accordance with Art. 17 GDPR.
  • You have the right to restrict the processing of your personal data in accordance with Art. 18 GDPR.
  • In accordance with Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and to transmit those data to another controller.
  • If you have given us separate consent to process your data, you can withdraw this consent at any time in accordance with Art. 7 (3) GDPR. Such a revocation does not affect the legality of the processing that was carried out on the basis of the consent until the revocation.
  • If you believe that the processing of your personal data violates the provisions of the GDPR, you have the right to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR.


In accordance with Art. 21 (1) GDPR, you have the right to object to processing based on the legal basis of Art. 6 (1) (e) or (f) GDPR on grounds relating to your particular situation. If we process personal data about you for the purpose of direct marketing, you can object to this processing in accordance with Art. 21 (2) and (3) GDPR.


If you exercise your rights in accordance with Art. 15 to 22 GDPR, we process the personal data transmitted for the purpose of implementing these rights and in order to provide proof of this. We will only process data stored for the purpose of providing information and its preparation for this purpose and for the purposes of data protection monitoring and otherwise restrict processing in accordance with Art. 18 GDPR. This processing is based on the legal basis of Art. 6 (1) (c) GDPR in conjunction with Art. 15 to 22 GDPR.


4. Where do we process your data?

In principle, we process your data on European servers with the highest security standards. In providing our services, we are supported by external service providers to whom we send your data. Some data processing may involve the transfer of certain personal data to third countries, i.e., countries in which the GDPR is not applicable law. Such a transfer is permitted if the European Commission has determined that an adequate level of data protection is provided in such a third country. This applies to all transfers to countries listed here: Adequacy Decisions.

If there is no such adequacy decision by the European Commission, personal data will only be transferred to a third country if there are suitable guarantees in accordance with Art. 46 GDPR or if one of the requirements of Art. 49 GDPR is met.

Unless there is an adequacy decision and unless otherwise stated below, we use the EU standard data protection clauses as appropriate safeguards for the transfer of personal data from the scope of the GDPR to third countries. You have the option of obtaining or viewing a copy of these EU standard data protection clauses. Please contact us at the address provided under Contact.

If you consent to the transfer of personal data to third countries, the transfer takes place on the legal basis of Art. 49 (1) (a) GDPR.


5. To whom and why do we pass on your personal data?

To provide our services and operate economically as a company, we use various external companies to whom we transfer personal data in some cases. If specific recipients receive personal data for certain groups of data subjects, we will inform you about this in Part B.

Recipient and reason for disclosure:

Hosting provider: We do not have our own servers, so we commission service providers to host our IT systems, including the website.


IT service provider and SaaS provider: We use the services of various providers who help us as processors to provide you with our services.


Authorities: To comply with legal requirements or to respond to court orders or other similar official requests.


6. How long do we store your data?

Unless otherwise stated in the following information, we only store the data for as long as necessary to achieve the purpose of processing or to fulfill our contractual or legal obligations. Such statutory retention obligations may arise, in particular, from commercial or tax law regulations. From the end of the calendar year in which the data was collected, we will store such personal data contained in our accounting data for ten years and personal data contained in commercial letters and contracts for six years. Additionally, we will retain data related to consents requiring proof and complaints and claims for the duration of the statutory limitation periods. We will delete data stored for advertising purposes if you object to processing for this purpose.


7. How do we use "cookies" and other tracking technologies?

We use cookies and similar technologies on our website and in the provision of our services. Unless we only use cookies that do not require consent due to their technical necessity, we will obtain your consent via a cookie banner. There, you will also find a list of other companies that place cookies on our websites, a list of cookies that we place, and an explanation of how you can refuse certain types of cookies. No cookie banner means no cookies requiring consent 😊.

B. Special section - How and why we process your data

a. Visitors to our website


What do we record and for what purposes do we use the collected data?

Data that you provide to us in contact forms about yourself or the company in which you work, such as your name, email address, and telephone number.:
Acquisition and customer acquisition; Support and communication: answering inquiries. Legal basis: Art. 6 (1) (f) GDPR

Pseudonymous information about the device and browser you are using, server log files, your network connection, and your IP address.: Ensuring the security, operability, and stability of our services, including defence against attacks; Integration of third-party content (ratings, videos, questionnaires). Legal basis: Art. 6 (1) (f) GDPR


b. Contact person for service providers/suppliers/business partners


What do we record and forwhat purposes do we use the collected data?

Data that you provide to us about yourself and the company you work for, such as your name, email address, and telephone number.:
Fulfillment of the contract with the company you work for (this includes contract management, billing, and communication). Legal basis: Art. 6 (1) (f) GDPR


c. Social media visitors


Controller: Social media provider
Data processing: When you visit our social media pages (Instagram, LinkedIn), which we use to present our company or individual products from our range, certain information about you is processed.

Instagram: Privacy Policy of Meta Platforms Ireland Limited; Opt-out option
LinkedIn: Privacy Policy of LinkedIn Ireland Unlimited Company


Controller: Social media providers and us (joint controllers)

Data processing: The social media providers provide us with statistics and insights for our pages in anonymized form, with the help of which we gain knowledge about the types of actions that people take on our site (so-called "page insights"). These Page Insights are created based on certain information about people visiting our site.

Instagram: Joint Controller Agreement; Data subject rights can also be asserted against Meta. Further information can be found in Meta's privacy policy.
LinkedIn: Joint Controller Agreement; Data subject rights can be asserted against LinkedIn via this contact form. You can contact the data protection officer via this link. We have agreed with LinkedIn that the Irish Data Protection Commission is the lead supervisory authority overseeing processing for Page Insights. You can lodge your complaint with the Irish Data Protection Commission (see www.dataprotection.ie) or any other supervisory authority.