ESA Digital Ltd.  /  Privacy Policy
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PRIVACY POLICY

This privacy policy explains how we use and protect any and all personal and customer information we hold, whether it relates to our customers, potential customers, job candidates, partners, or third party service providers.

1. Our Commitment to Privacy

ESA Digital is committed to conducting its business in line with all applicable Data Protection laws and regulations. We take responsibility for maintaining and protecting the customer information that we hold. We review this policy and our internal data protection policy and practices on a regular basis to ensure that we are in compliance with applicable legislation and current best practices.

2. What we collect

We may collect the following information:
— Name and job title;
— Business information including postal and billing addresses and website address;
— Contact information including email address and phone number;
— Banking details;
— Demographic information such as postcode, preferences and interests;
— Cookie information (explained in more detail below);
— Other information relevant to a project that we may supply a quote for or information relevant to managing a project that we are contracted to work with you on.

3. We collect customer information for one or more of the following purposes:

— To provide the service we have been contracted to provide;
— To maintain customer relationships, communicate with our customers, and avoid conflicts of interest;
— To understand customer requirements and make information available regarding products and services offered by The ESA Digital;
— To contact you in response to the communications you have directed at us;
— To manage and develop The ESA Digital' business and operations;
— To meet legal and regulatory requirements;
— To gauge website user interest and to enhance future website user experiences.

4. WEB ANALYTICS WITH GOOGLE ANALYTICS


This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, in the event that IP anonymisation is activated on this website, your IP address will be shortened by Google within the United Kingdom or in other signatory states to the Agreement on the United Kingdom before this happens. Only in exceptional cases will the full IP address be transferred 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, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. The IP address transmitted by your browser within the framework of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: optout

This website uses Google Analytics with the extension “anonymizeIP()”, so that the IP addresses are only processed in a shortened form in order to exclude the possibility of direct personal references.


5. USE OF GOOGLE ADWORDS CONVERSION TRACKING


We use the online advertising program “Google AdWords” on our website and in this context conversion tracking. Google Conversion Tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). When you click on an ad placed by Google, a conversion tracking cookie is placed on your computer. These cookies have a limited validity, do not contain any personal data and are therefore not used for personal identification. If you visit certain pages on our site and the cookie hasn’t expired, Google and we can tell that you clicked on the ad and were directed to that page. Each Google AdWords customer receives a different cookie. As a result, there is no way that cookies can be tracked across the websites of AdWords customers. The information collected using the conversion cookie is used to compile conversion

statistics. This tells us the total number of users who have clicked on one of our ads and been redirected to a page with a conversion tracking tag. However, we do not receive information that personally identifies users. The processing is based on Art. 6 (1) lit. f DSGVO from the legitimate interest in targeted advertising and the analysis of the impact and efficiency of this advertising. You have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data based on Art. 6 (1) f DSGVO. For this purpose, you can prevent the storage of cookies by selecting the appropriate technical settings in your browser software. However, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You will then not be included in the conversion tracking statistics. You can find further information and the Google data protection declaration at: https://www.google.de/policies/privacy/


5.1 GOOGLE RECAPTCHA


In order to ensure sufficient data security when transmitting forms, we use the service reCAPTCHA of the company Google Inc. in certain cases, this is mainly to distinguish whether the input is made by a natural person or abusively by machine and automated processing. The service includes the sending of the IP address and possibly other data required by Google for the service reCAPTCHA to Google. For further information on the privacy policy of Google Inc. please visit http://www.google.de/intl/de/privacy or https://www.google.com/intl/de/policies/privacy/.


5.2 USE OF TIKTOK PIXEL & ADS


We use the “TikTok pixel” of the social network TikTok, which is operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (“TikTok”). With the help of the TikTok pixel, it is possible for TikTok to determine the visitors to our website as a target group for the display of advertisements (so-called “TikTok Ads”). Accordingly, we use the TikTok pixel to display the TikTok ads placed by us only to those TikTok users who have also shown an interest in our online offer or who have certain characteristics that we transmit to TikTok. The TikTok pixel also allows us to statistically analyze the TikTok ads that are served. Data processing by TikTok is carried out within the framework of TikTok’s Data Use Policy. You can get specific information and details about the TikTok pixel and how it works in the help section of TikTok: https://www.tiktok.com/legal/privacy-policy?lang=de The use of the TikTok pixel as well as the storage of “conversion cookies” is based on Art. 6 (1) lit. a DSGVO. You can object to the data collection by the TikTok pixel and use of your data to display TikTok ads. You can find an opt-out option in our cookie notice.


6. USE OF Pipedrive


We use Pipedrive, a service of Pipedrive OU. on our websites for analysis purposes. Pipedrive is certified under the UK-US Privacy Shield.


So-called “web beacons” are used and “cookies” are also set, which are stored on your computer and enable us to analyse your use of the website. Pipedrive uses the information collected (e.g., IP address, geographic location, browser type, length of visit and pages viewed) to generate reports on Flash Hub’s visit and pages viewed. If you subscribe to our newsletter and receive studies and other documents, Pipedrive may also associate a user’s visits to Flash Hub sites with personal information (primarily name/email address) based on consent given, thereby collecting personal information and providing users with individualized and targeted information on preferred topics. If you do not want Pipedrive to collect your personal information, you may refuse the use of cookies by selecting the appropriate settings on your browser (see section 3b above). For more information about how Pipedrive works, please see Pipedrive OU’s Privacy Policy, available at https://www.pipedrive.com/en/terms-of-service#notices.


7. LINKEDIN ANALYTICS AND LINKEDIN ADS


We use conversion tracking technology on our website and the retargeting feature of LinkedIn Corporation. This technology allows visitors to this site to see personalized ads on LinkedIn. It also

provides the ability to generate anonymous reports on ad performance and website interaction information. LinkedIn Insight tag is embedded in this website, which connects to the LinkedIn server when you visit this website and are logged into your LinkedIn account. Please see the LinkedIn privacy policy at https://www.linkedin.com/legal/privacy-policy for more information about data collection and use, and the choices and rights you have to protect your privacy. If you are logged in to LinkedIn, you may opt out of the collection of your information at any time by following this link: https://www.linkedin.com/psettings/enhanced-advertising.


8. FACEBOOK ANALYTICS AND FACEBOOK ADS


We use the remarketing function “Custom Audiences” of Facebook Inc. on our website. (1601 S. California Ave, Palo Alto, CA 94304, USA; “Facebook”) and the Facebook tracking pixel. This function serves the purpose of targeting website visitors with interest-based advertising on the social network Facebook and to evaluate conversions. For this purpose, the Remarketing tag and the Facebook tracking pixel were implemented on the website. This tag is used to establish a direct connection to the Facebook servers when visiting the website. Through this, the Facebook server is informed which of our pages you have visited. Facebook assigns this information to your personal Facebook user account. When you visit the social network Facebook, you will then see personalized, interest-based Facebook ads. The processing is based on Art. 6 (1) lit. f DSGVO from the legitimate interest in the above-mentioned purpose. You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you based on Art. 6 (1) f DSGVO. You can find more detailed information on the collection and use of data by Facebook, on your rights in this regard and on ways to protect your privacy in Facebook’s privacy policy at https://www.facebook.com/about/privacy/.


9. SOCIAL MEDIA PLUGINS GENERAL


Social buttons from social networks are used on our website.

This serves to safeguard our legitimate interests, which outweigh the interests of the parties concerned, in the best possible marketing of our products and services in accordance with Art. 6 Para. 1 sentence 1 letter f DSGVO. In order to increase the protection of your data when visiting our website, these buttons are not unrestrictedly integrated into the page as plug-ins, but only by using an HTML link. This integration ensures that when a page of our website containing such buttons is called up, no connection is yet established with the servers of the provider of the respective social network.

Click on one of the buttons, a new window of your browser opens and calls up the page of the respective service provider, where you can (if necessary after entering your login data) press the Like or Share button, for example.

The purpose and scope of data collection and the further processing and use of data by the providers on their sites as well as a contact option and your rights and settings options for the protection of your privacy can be found in the data protection information of the providers. http://www. facebook.com/policy.phphttps://twitter.com/privacy


10. Usage of Hotjar


We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.


11. INFORMATION ABOUT COOKIES


(1) Processing purpose

On this website, technically necessary cookies are used. These are small text files that are not permanently stored in or by your Internet browser on your computer system and only serve to ensure the functionality of the website. Other cookies remain permanently and recognise your browser the next time you visit the website in order to increase the user-friendliness of the website.


(2) Legal bases

The legal basis for the processing is Article 6(1)(f) DPA.


(3) Legitimate interest

Our legitimate interest is the functionality and usability of our website. The user data collected through technically necessary cookies and the long-term cookies described here are not used to create user profiles. Thus your interest in data protection is protected.


(4) Storage duration

The technically necessary cookies are usually deleted when the browser is closed. Permanently stored cookies have a varying lifetime from a few minutes to several years.


(5) RIGHT OF OBJECTION

If you do not wish these cookies to be stored, please deactivate the acceptance of these cookies in your Internet browser. However, this may result in a functional restriction of our website. You can also delete permanently stored cookies at any time via your browser.


12. SERVER-LOG-FILES

(1) On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f DSGVO data on every access to the server on which this service is located (so-called server log files). The access data includes

• Name of the website accessed

• Browser type/ browser version

• Operating system used

• Referrer URL

• Host name of the accessing computer

• Time of the server request

These data cannot be assigned to specific persons. A consolidation of this data with other data sources is not carried out.


(2) For security reasons (e.g. for the investigation of abuse or fraud), log file information is stored for a maximum period of seven days and then deleted. Data whose further storage is required for evidential purposes are excluded from deletion until the respective incident has been finally clarified.


13. NEWSLETTER

(1) Processing purpose

When registering for the newsletter your e-mail address will be used for advertising purposes, i.e. within the scope of the newsletter we will inform you in particular about services of the Flash Hub GmbH. For statistical purposes we can evaluate which links are clicked in the newsletter. It is not possible for us to identify which specific person clicked. You have given the following consent separately or, if applicable, explicitly during the ordering process: Yes, please send me the Flash Hub Newsletter.


(2) Legal basis

The legal basis for this processing is Article 6(1)(a) DPA.


(3) Categories of beneficiaries

Newsletter provider


(4) Storage duration

Your e-mail address will only be stored for the duration of the desired registration.


(5) Right of withdrawal

You can revoke your consent at any time with effect for the future. If you no longer wish to receive the newsletter, you can unsubscribe as follows: Via an unsubscription link in the newsletter.


14. INTEGRATION OF THIRD-PARTY SERVICES AND CONTENT

(1)Within our online offer, we set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. DSGVO) content or service offers from third parties in order to integrate their content and services, e.g. videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of these contents are aware of the IP address of the users, as without the IP address they would not be able to send the contents to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring web pages, visiting time and other details on the use of our online offer, as well as being able to be linked to such information from other sources.

(2) The following presentation offers an overview of third party providers and their contents, including links to their data protection declarations, which contain further information on the

processing of data and, in some cases already mentioned here, the possibility to object (so-called opt-out):

• External fonts from Google, Inc., https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated by a server call to Google (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/ , Opt-Out: https://www.google.com/settings/ads/ .

• Maps provided by the “Google Maps” service of the third party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-Out: https://www.google.com/settings/ads/ .

• Videos from the “YouTube” platform of the third party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-Out: https://www.google.com/settings/ads/


15. ONLINE PRESENCE IN SOCIAL MEDIA

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services.

We point out that user data may be processed outside the United Kingdom. This may result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the UK.

Furthermore, user data is generally processed for market research and advertising purposes. For example, user profiles can be created from the user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

The processing of users’ personal data is based on our legitimate interest in effective information of users and communication with users in accordance with Art. 6, Paragraph 1, Letter f. DSGVO. If the users are asked by the respective providers of the platforms to give their consent to the aforementioned data processing, the legal basis for the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.

For a detailed presentation of the respective processing and the possibilities of objection (opt-out), we refer to the following linked information of the providers.

Also in the case of requests for information and the assertion of user rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

– Facebook, Pages, Groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data , Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAACtatus=Active.

– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Policies: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Policies: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland) – Policies https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.

– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy policy/ Opt-out: https://privacy.xing.com/de/datenschutzerklaerung.


16. Why do we process your information?

We will only collect and use your personal information in accordance with data protection laws. Our grounds for processing your personal information are as follows:

17. Terms

Consent — Where necessary we will only collect and process your personal information if you have consented for us to do so.
Legitimate Interests — We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under UK privacy laws there is a concept of "legitimate interests" as a justification for processing your personal information.

18. Our legitimate interests for processing your personal information are:

— to enable you to access and use our website and other digital tools we may provide as part of our service;
— to communicate with you about our service or make information available regarding products and services offered by ESA Digital;
— to improve our website.
Controlling your information

19. All individuals who are the subject of personal data held by ESA Digital are entitled to:

— Ask what information the company holds about them
— Ask what the purpose of the data is
— Receive a copy of the data
— Be informed how to keep it up to date
— Object to the use of the data
— Request the data is corrected, rectified, restricted, moved, or erased
— Subject access requests must be made in writing to the Sheffield office address, for the attention of the Data Request Team or by email using our form here.

The subject access request will be responded to within 40 days. The company will require proof of identification to verify the subject access request before handing over any information.

20. Data Security and Integrity

Keeping information about you secure is very important to us so we store and process your personal information in accordance with the high standards required under data protection legislation. We only collect customer information as required to meet the purposes that we have identified. We strive to maintain customer information in as accurate, complete and up-to-date a form as necessary to fulfil the purposes for which it was collected.

To the best of our ability, access to customer information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain customer information only for so long as the information is necessary to comply with a customer request.

From time to time and for operational reasons the information we collect from you may be stored in countries outside of the United Kingdom ("UK"). When we appoint our service providers to help us provide services to you, we take care to ensure that they have appropriate security measures in place.

We do our best to keep the information you disclose to us secure. However, security cannot be absolutely guaranteed against all threats. By using our service and website you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

21. Cookies and our website

Our website uses cookies, which are identifying technologies that your computer receives when you visit certain websites. We do not match or correlate this information with any customer information that you submit to ESA Digital. Read more at our Cookies page.

22. Changes to this policy

The ESA Digital may modify this Privacy Statement from time to time to reflect our current privacy practices. You should check this page from time to time to ensure that you are happy with any changes.

RESPONSIBLE FOR DATA PROCESSING:


ESA Digital Ltd.
Company number: 13075096
71-75 Shelton Street
Covent Garden
London

WC2H 9JQ

Contact us page

This privacy policy explains how we use and protect any and all personal and customer information we hold, whether it relates to our customers, potential customers, job candidates, partners, or third party service providers.

1. Our Commitment to Privacy

ESA Digital is committed to conducting its business in line with all applicable Data Protection laws and regulations. We take responsibility for maintaining and protecting the customer information that we hold. We review this policy and our internal data protection policy and practices on a regular basis to ensure that we are in compliance with applicable legislation and current best practices.

2. What we collect

We may collect the following information:
— Name and job title;
— Business information including postal and billing addresses and website address;
— Contact information including email address and phone number;
— Banking details;
— Demographic information such as postcode, preferences and interests;
— Cookie information (explained in more detail below);
— Other information relevant to a project that we may supply a quote for or information relevant to managing a project that we are contracted to work with you on.

3. We collect customer information for one or more of the following purposes:

— To provide the service we have been contracted to provide;
— To maintain customer relationships, communicate with our customers, and avoid conflicts of interest;
— To understand customer requirements and make information available regarding products and services offered by The ESA Digital;
— To contact you in response to the communications you have directed at us;
— To manage and develop The ESA Digital' business and operations;
— To meet legal and regulatory requirements;
— To gauge website user interest and to enhance future website user experiences.

4. WEB ANALYTICS WITH GOOGLE ANALYTICS


This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, in the event that IP anonymisation is activated on this website, your IP address will be shortened by Google within the United Kingdom or in other signatory states to the Agreement on the UK before this happens. Only in exceptional cases will the full IP address be transferred 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, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. The IP address transmitted by your browser within the framework of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: optout

This website uses Google Analytics with the extension “anonymizeIP()”, so that the IP addresses are only processed in a shortened form in order to exclude the possibility of direct personal references.


5. USE OF GOOGLE ADWORDS CONVERSION TRACKING


We use the online advertising program “Google AdWords” on our website and in this context conversion tracking. Google Conversion Tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). When you click on an ad placed by Google, a conversion tracking cookie is placed on your computer. These cookies have a limited validity, do not contain any personal data and are therefore not used for personal identification. If you visit certain pages on our site and the cookie hasn’t expired, Google and we can tell that you clicked on the ad and were directed to that page. Each Google AdWords customer receives a different cookie. As a result, there is no way that cookies can be tracked across the websites of AdWords customers. The information collected using the conversion cookie is used to compile conversion

statistics. This tells us the total number of users who have clicked on one of our ads and been redirected to a page with a conversion tracking tag. However, we do not receive information that personally identifies users. The processing is based on Art. 6 (1) lit. f DSGVO from the legitimate interest in targeted advertising and the analysis of the impact and efficiency of this advertising. You have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data based on Art. 6 (1) f DSGVO. For this purpose, you can prevent the storage of cookies by selecting the appropriate technical settings in your browser software. However, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You will then not be included in the conversion tracking statistics. You can find further information and the Google data protection declaration at: https://www.google.de/policies/privacy/


5.1 GOOGLE RECAPTCHA


In order to ensure sufficient data security when transmitting forms, we use the service reCAPTCHA of the company Google Inc. in certain cases, this is mainly to distinguish whether the input is made by a natural person or abusively by machine and automated processing. The service includes the sending of the IP address and possibly other data required by Google for the service reCAPTCHA to Google. For further information on the privacy policy of Google Inc. please visit http://www.google.de/intl/de/privacy or https://www.google.com/intl/de/policies/privacy/.


5.2 USE OF TIKTOK PIXEL & ADS


We use the “TikTok pixel” of the social network TikTok, which is operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (“TikTok”). With the help of the TikTok pixel, it is possible for TikTok to determine the visitors to our website as a target group for the display of advertisements (so-called “TikTok Ads”). Accordingly, we use the TikTok pixel to display the TikTok ads placed by us only to those TikTok users who have also shown an interest in our online offer or who have certain characteristics that we transmit to TikTok. The TikTok pixel also allows us to statistically analyze the TikTok ads that are served. Data processing by TikTok is carried out within the framework of TikTok’s Data Use Policy. You can get specific information and details about the TikTok pixel and how it works in the help section of TikTok: https://www.tiktok.com/legal/privacy-policy?lang=de The use of the TikTok pixel as well as the storage of “conversion cookies” is based on Art. 6 (1) lit. a DSGVO. You can object to the data collection by the TikTok pixel and use of your data to display TikTok ads. You can find an opt-out option in our cookie notice.


6. USE OF Pipedrive


We use Pipedrive, a service of Pipedrive OU. on our websites for analysis purposes. Pipedrive is certified under the UK-US Privacy Shield.


So-called “web beacons” are used and “cookies” are also set, which are stored on your computer and enable us to analyse your use of the website. Pipedrive uses the information collected (e.g., IP address, geographic location, browser type, length of visit and pages viewed) to generate reports on Flash Hub’s visit and pages viewed. If you subscribe to our newsletter and receive studies and other documents, Pipedrive may also associate a user’s visits to Flash Hub sites with personal information (primarily name/email address) based on consent given, thereby collecting personal information and providing users with individualized and targeted information on preferred topics. If you do not want Pipedrive to collect your personal information, you may refuse the use of cookies by selecting the appropriate settings on your browser (see section 3b above). For more information about how Pipedrive works, please see Pipedrive OU’s Privacy Policy, available at https://www.pipedrive.com/en/terms-of-service#notices.


7. LINKEDIN ANALYTICS AND LINKEDIN ADS


We use conversion tracking technology on our website and the retargeting feature of LinkedIn Corporation. This technology allows visitors to this site to see personalized ads on LinkedIn. It also

provides the ability to generate anonymous reports on ad performance and website interaction information. LinkedIn Insight tag is embedded in this website, which connects to the LinkedIn server when you visit this website and are logged into your LinkedIn account. Please see the LinkedIn privacy policy at https://www.linkedin.com/legal/privacy-policy for more information about data collection and use, and the choices and rights you have to protect your privacy. If you are logged in to LinkedIn, you may opt out of the collection of your information at any time by following this link: https://www.linkedin.com/psettings/enhanced-advertising.


8. FACEBOOK ANALYTICS AND FACEBOOK ADS


We use the remarketing function “Custom Audiences” of Facebook Inc. on our website. (1601 S. California Ave, Palo Alto, CA 94304, USA; “Facebook”) and the Facebook tracking pixel. This function serves the purpose of targeting website visitors with interest-based advertising on the social network Facebook and to evaluate conversions. For this purpose, the Remarketing tag and the Facebook tracking pixel were implemented on the website. This tag is used to establish a direct connection to the Facebook servers when visiting the website. Through this, the Facebook server is informed which of our pages you have visited. Facebook assigns this information to your personal Facebook user account. When you visit the social network Facebook, you will then see personalized, interest-based Facebook ads. The processing is based on Art. 6 (1) lit. f DSGVO from the legitimate interest in the above-mentioned purpose. You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you based on Art. 6 (1) f DSGVO. You can find more detailed information on the collection and use of data by Facebook, on your rights in this regard and on ways to protect your privacy in Facebook’s privacy policy at https://www.facebook.com/about/privacy/.


9. SOCIAL MEDIA PLUGINS GENERAL


Social buttons from social networks are used on our website.

This serves to safeguard our legitimate interests, which outweigh the interests of the parties concerned, in the best possible marketing of our products and services in accordance with Art. 6 Para. 1 sentence 1 letter f DSGVO. In order to increase the protection of your data when visiting our website, these buttons are not unrestrictedly integrated into the page as plug-ins, but only by using an HTML link. This integration ensures that when a page of our website containing such buttons is called up, no connection is yet established with the servers of the provider of the respective social network.

Click on one of the buttons, a new window of your browser opens and calls up the page of the respective service provider, where you can (if necessary after entering your login data) press the Like or Share button, for example.

The purpose and scope of data collection and the further processing and use of data by the providers on their sites as well as a contact option and your rights and settings options for the protection of your privacy can be found in the data protection information of the providers. http://www. facebook.com/policy.phphttps://twitter.com/privacy


10. Usage of Hotjar


We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.


11. INFORMATION ABOUT COOKIES


(1) Processing purpose

On this website, technically necessary cookies are used. These are small text files that are not permanently stored in or by your Internet browser on your computer system and only serve to ensure the functionality of the website. Other cookies remain permanently and recognise your browser the next time you visit the website in order to increase the user-friendliness of the website.


(2) Legal bases

The legal basis for the processing is Article 6(1)(f) DPA.


(3) Legitimate interest

Our legitimate interest is the functionality and usability of our website. The user data collected through technically necessary cookies and the long-term cookies described here are not used to create user profiles. Thus your interest in data protection is protected.


(4) Storage duration

The technically necessary cookies are usually deleted when the browser is closed. Permanently stored cookies have a varying lifetime from a few minutes to several years.


(5) RIGHT OF OBJECTION

If you do not wish these cookies to be stored, please deactivate the acceptance of these cookies in your Internet browser. However, this may result in a functional restriction of our website. You can also delete permanently stored cookies at any time via your browser.


12. SERVER-LOG-FILES

(1) On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f DSGVO data on every access to the server on which this service is located (so-called server log files). The access data includes

• Name of the website accessed

• Browser type/ browser version

• Operating system used

• Referrer URL

• Host name of the accessing computer

• Time of the server request

These data cannot be assigned to specific persons. A consolidation of this data with other data sources is not carried out.


(2) For security reasons (e.g. for the investigation of abuse or fraud), log file information is stored for a maximum period of seven days and then deleted. Data whose further storage is required for evidential purposes are excluded from deletion until the respective incident has been finally clarified.


13. NEWSLETTER

(1) Processing purpose

When registering for the newsletter your e-mail address will be used for advertising purposes, i.e. within the scope of the newsletter we will inform you in particular about services of the Flash Hub GmbH. For statistical purposes we can evaluate which links are clicked in the newsletter. It is not possible for us to identify which specific person clicked. You have given the following consent separately or, if applicable, explicitly during the ordering process: Yes, please send me the Flash Hub Newsletter.


(2) Legal basis

The legal basis for this processing is Article 6(1)(a) DPA.


(3) Categories of beneficiaries

Newsletter provider


(4) Storage duration

Your e-mail address will only be stored for the duration of the desired registration.


(5) Right of withdrawal

You can revoke your consent at any time with effect for the future. If you no longer wish to receive the newsletter, you can unsubscribe as follows: Via an unsubscription link in the newsletter.


14. INTEGRATION OF THIRD-PARTY SERVICES AND CONTENT

(1)Within our online offer, we set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. DSGVO) content or service offers from third parties in order to integrate their content and services, e.g. videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of these contents are aware of the IP address of the users, as without the IP address they would not be able to send the contents to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring web pages, visiting time and other details on the use of our online offer, as well as being able to be linked to such information from other sources.

(2) The following presentation offers an overview of third party providers and their contents, including links to their data protection declarations, which contain further information on the

processing of data and, in some cases already mentioned here, the possibility to object (so-called opt-out):

• External fonts from Google, Inc., https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated by a server call to Google (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/ , Opt-Out: https://www.google.com/settings/ads/ .

• Maps provided by the “Google Maps” service of the third party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-Out: https://www.google.com/settings/ads/ .

• Videos from the “YouTube” platform of the third party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-Out: https://www.google.com/settings/ads/


15. ONLINE PRESENCE IN SOCIAL MEDIA

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services.

We point out that user data may be processed outside the UK. This may result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the UK.

Furthermore, user data is generally processed for market research and advertising purposes. For example, user profiles can be created from the user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

The processing of users’ personal data is based on our legitimate interest in effective information of users and communication with users in accordance with Art. 6, Paragraph 1, Letter f. DSGVO. If the users are asked by the respective providers of the platforms to give their consent to the aforementioned data processing, the legal basis for the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.

For a detailed presentation of the respective processing and the possibilities of objection (opt-out), we refer to the following linked information of the providers.

Also in the case of requests for information and the assertion of user rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

– Facebook, Pages, Groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data , Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAACtatus=Active.

– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Policies: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Policies: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland) – Policies https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.

– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy policy/ Opt-out: https://privacy.xing.com/de/datenschutzerklaerung.


16. Why do we process your information?

We will only collect and use your personal information in accordance with data protection laws. Our grounds for processing your personal information are as follows:

17. Terms

Consent — Where necessary we will only collect and process your personal information if you have consented for us to do so.
Legitimate Interests — We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under UK privacy laws there is a concept of "legitimate interests" as a justification for processing your personal information.

18. Our legitimate interests for processing your personal information are:

— to enable you to access and use our website and other digital tools we may provide as part of our service;
— to communicate with you about our service or make information available regarding products and services offered by ESA Digital;
— to improve our website.
Controlling your information

19. All individuals who are the subject of personal data held by ESA Digital are entitled to:

— Ask what information the company holds about them
— Ask what the purpose of the data is
— Receive a copy of the data
— Be informed how to keep it up to date
— Object to the use of the data
— Request the data is corrected, rectified, restricted, moved, or erased
— Subject access requests must be made in writing to the Sheffield office address, for the attention of the Data Request Team or by email using our form here.

The subject access request will be responded to within 40 days. The company will require proof of identification to verify the subject access request before handing over any information.

20. Data Security and Integrity

Keeping information about you secure is very important to us so we store and process your personal information in accordance with the high standards required under data protection legislation. We only collect customer information as required to meet the purposes that we have identified. We strive to maintain customer information in as accurate, complete and up-to-date a form as necessary to fulfil the purposes for which it was collected.

To the best of our ability, access to customer information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain customer information only for so long as the information is necessary to comply with a customer request.

From time to time and for operational reasons the information we collect from you may be stored in countries outside of the United Kingdom (UK). When we appoint our service providers to help us provide services to you, we take care to ensure that they have appropriate security measures in place.

We do our best to keep the information you disclose to us secure. However, security cannot be absolutely guaranteed against all threats. By using our service and website you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

21. Cookies and our website

Our website uses cookies, which are identifying technologies that your computer receives when you visit certain websites. We do not match or correlate this information with any customer information that you submit to ESA Digital. Read more at our Cookies page.

22. Changes to this policy

The ESA Digital may modify this Privacy Statement from time to time to reflect our current privacy practices. You should check this page from time to time to ensure that you are happy with any changes.

RESPONSIBLE FOR DATA PROCESSING:


ESA Digital Ltd.
Company number: 13075096
71-75 Shelton Street
Covent Garden
London

WC2H 9JQ

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