Privacy Policy

Welcome to Berlin City Whispers and our website at www.city-whispers.com (our “website”). Data protection and data security when using our website and services are very important to us. We would therefore like to inform you which of your Personal Data we collect when you visit our website and for what purposes it is used.

Please note! This Privacy Policy only applies to our website. If you are a user of our IOS and Android mobile App, please refer to our App Privacy Policy. 

WHO IS RESPONSIBLE?

The person responsible in the sense of Germany's Data Protection Act (Bundesdatenschutzgesetz) (“BDSG”) and the EU’s General Data Protection Regulation (“GDPR”) is Berlin City Whispers, Roya Anane, Sole Proprietor, Brennerstraße 83, 13187 Berlin, Germany (“Berlin City Whispers”, “we”, “us”, “our”). If you want to contact us or if you have any questions, you can reach us by email using contact@city-whispers.com or write to us at the above address.

PRINCIPLES OF DATA PROCESSING

a) Personal data

Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behavior.

b) Processing 

The processing of Personal Data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis. 

c) Legal basis

In accordance with the BDSG and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfillment of a contract / pre-contractual measures, iii) the data is necessary for the fulfillment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

d) Retention

Processed Personal Data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.

DATA WE COLLECT

a) Provision and use of the website

When you call up and use our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii)name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.

b) Hosting 

The hosting services used by us for the purpose of operating our website is Squarespace Inc., (225 Varick Street 12th Floor New York, NY 10014 United States). In doing so Squarespace processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests.

c) Content Management System

We also use the Content Management System (CMS) of Squarespace to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to Squarespace. This represents a legitimate interest.

d) Cookies

We use cookies on our website. In accordance with Germany`s Data Protection and the Protection of Privacy in Telecommunications and Digital Services Act ("TDDSG") and the EU`s Privacy and Electronic Communications Directive (“PECD”) we are required to obtain your consent before placing so-called Non-Essential Cookies (Functional cookies, Analysis and Performance Cookies, Advertising Cookies or Targeting Cookies). 

e) Cookie consent 

Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via our cookie consent tool: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

f) Analytics

For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymised values. For this purpose we use Squarespace Analytics which is a web analytics service offered by Squarespace. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.

g) Contacting Us

We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract. As a rule, we do not require any special categories of Personal Data to provide our services. 

h) Get Involved

We process the Personal Data when you become involved in our mission. This includes in particular our support, correspondence with you, fulfillment of our contractual, and legal obligations. The data processed for this purpose may include your full name, your organization or company name, your role, the personal data contained in your project description, your social media handles, your email address, your phone number. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

i) Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our website and services. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy. 

SOCIAL MEDIA

We are present on social media on the basis of our legitimate interest (Instagram (Meta Platforms, Inc., 1601 Willow Road Menlo Park California 94025), TikTok (TikTok Inc, 5800 Bristol Parkway Culver City, Los Angeles, CA 90230, United States), and LinkedIn (LinkedIn Corporation, 605 W Maude Ave, Sunnyvale, CA 94085, USA). If you contact or connect with us via social media, we and Instagram are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

When you visit our social media profile, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

DATA SECURITY

We undertake to protect your privacy and to treat your Personal Data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organizational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).


However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

INTERNATIONAL TRANSFERS

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

HOW WE MAY SHARE YOUR PERSONAL DATA

We may share your Personal Data with our business partners and within Berlin City Whispers for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customizing our business to better meet your needs. We share your Personal Data only with business partners who agree to protect and use your Personal Data solely for the purposes specified by us. 

We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.


WHAT WE DO NOT DO

  • We do not request Personal Data from minors and children;

  • We do not use Automated decision-making including profiling; and

  • We do not sell your Personal Data.


PRIVACY RIGHTS 

Under the BDSG and the GDPR, you can exercise the following rights:

  • Right to information

  • Right to rectification

  • Right to deletion

  • Right to data portability

  • Right of objection

  • Right to withdraw consent

  • Right to complain to a supervisory authority

  • Right not to be subject to a decision based solely on automated processing.


If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.


UPDATING YOUR INFORMATION AND WITHDRAWING YOUR CONSENT 

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us. 

ACCESS REQUEST 

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

COMPLAINT TO A SUPERVISORY AUTHORITY

You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. The Federal Commissioner for Data Protection and Freedom of Information (BfDI) (www.bfdi.bund.de) is the Federal Commissioner for Data Protection. The Berlin DPA is the state Data Protection Authority for the state of Berlin. The Berlin DPA`s contact details can be found on www.datenschutz-berlin.de. However, we would appreciate the opportunity to address your concerns before you contact the BfDI or the Berlin DPA.


HOW DO WE MAKE CHANGES TO THIS POLICY?

We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our website. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes.


EFFECTIVE DATE

Tuesday, 18th of June, 2024