Privacy policy

Preamble

With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender-specific.

As of: 20. August 2024

Overview

• Preamble
• Controller
• Overview of processing
• Relevant legal bases
• Security measures
• Transfer of personal data
• International data transfers
• General information on data storage and erasure
• Rights of data subjects
• Business services
• Provision of the online service and web hosting
• Use of cookies
• Blogs and publication media
• Contact and request management
• Change and update
• Definitions

Controller

DESSOS DEVELOPMENT CORP
10 Elvira Mendez Street, Top Floor
Panama City
Panama

E-mail address: info@dessos-corp.com

Imprint: www.dessos-corp.com

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

• Inventory data.
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication and process data.
• Log data.

Categories of data subjects

• Recipients and clients.
• Interested parties.
• Communication partners.
• Users.
• Business and contractual partners.

Purposes of processing

• Provision of contractual services and performance of contractual obligations.
• Communication.
• Security measures.
• Office and organizational procedures.
• Organizational and administrative procedures.
• Feedback.
• Provision of our online services and user-friendliness.
• Information technology infrastructure.
• Business processes and business management procedures.

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Applicable legal bases

Applicable legal bases under the GDPR: The following is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes.
• Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Third country (outside the EU and Switzerland): The data protection regulations in the country in which the controller is based apply in addition to or alongside the data protection regulations of the GDPR. These regulations may contain specific provisions that go beyond or deviate from the requirements of the GDPR. These include, among other things, regulations on protection against misuse of personal data, regulations on rights of access and erasure, rights of objection, processing of special categories of personal data, processing for other purposes, transfer and automated decision-making including profiling.

Security measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transfer of personal data

When we process personal data, it may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data

International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=en.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10.07.2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

General information on data storage and erasure

We erase personal data that we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

If more than one retention period or deletion period is specified for a date, the longest period shall always apply.

If a period does not expressly begin on a specific date and is at least one year, it shall automatically start at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the deadline is the date on which the termination or other termination of the legal relationship takes effect.

Data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, will only be processed for the reasons that justify its storage.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

• Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right to information: You have the right to request confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements.
• Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
• Data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
• Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "Contractual Partners"), in the context of contractual and comparable legal relationships and related measures and with regard to communication with the Contractual Partners (or pre- contractual), for example to respond to inquiries.

We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes,as part of this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
• Persons concerned: Service recipients and clients; interested parties. Business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
• Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, purchase or commission the selected services or works and associated activities as well as their payment and provision or execution or performance.

• The required information is marked as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Technical services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, purchase or commission the selected services or works and related activities as well as their payment and provision or execution or performance.
  
  The required information is marked as such in the context of the conclusion of the contract, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal basis: contract fulfillment and pre- contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)

Provision of online services and web hosting

We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

• Types of data processed: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication data and process data (e.g. IP addresses, time data, identification numbers, persons involved). e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
• Persons concerned: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online services and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
• Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
• E-mail dispatch and hosting:The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore assume no responsibility for the transmission path of the emails between the sender and receipt on our server; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 1 lit. f) GDPR).
• ALL-INKL: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM - Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://all-inkl.com/; Privacy Policy: https://all-inkl.com/datenschutzinformationen/. Processing agreement:Provided by the service provider.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyze visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to them and contains the information on the respective use of cookies.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask for their consent. If users accept, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and the improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: A distinction is made between the following types of cookies with regard to the storage period:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their end device (e.g. browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed.
• Permanent cookies: Permanent cookies remain stored even after the end device has been closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

• Types of data processed: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Persons concerned: Users (e.g. website visitors, users of online services).
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

• Processing of cookie data on the basis of consent: We use a consent management solution in which the consent of users to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which, together with the time of consent, the information on the scope of consent (e.g. categories of cookies and/or service providers concerned), is stored for up to two years. relevant categories of cookies and/or service providers) as well as information about the browser, the system and the terminal device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In all other respects, we refer to the information on the processing of visitors to our publication medium in this data protection notice.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions and information relating to them, such as content data (e.g. text or image messages and contributions and the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Affected parties Persons: Users (e.g. website visitors, users of online services).
• Purposes of processing: Feedback (e.g. collecting feedback via online form). Provision of our online offer and user- friendliness.
• Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)

Contact and inquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions and information relating to them, such as content data (e.g. text or image messages and contributions and the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Persons concerned: Communication partners.
• Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
• Retention and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure".
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR). Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

• Contact form: When you contact us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)

Change and update

We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data can Includes personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities or systems by enabling unique assignment and communication.
• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
• Contact data: Contact data is essential information that enables communication with people or organizations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information on file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Process data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review processes.
• Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they use to navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in recognizing trends, preferences and potential problem areas within digital offerings
• Personal data: "Personal data" means all data that is Information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Log data: Log data is information about events or activities that have been logged on a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
• Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, analysis, storage, transmission or erasure.
• Contractual data: Contractual data is specific information relating to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
• Payment data: Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e- commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorizations and fees.

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