Privacy Policy

As of February 2022

Table of contents

  1. Identity and contact details of the data controller
  2. Contact details of the data protection officer
  3. General information on data processing
  4. Rights of the data subject
  5. Provision of website and creation of log files
  6. Contact via Email
  7. Corporate web profiles on social networks
  8. Hosting
  9. Content delivery networks
  10. Usage of Plugins
  11.  Integration of plugins via external service providers
  1. Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:

Podnosh Ltd

Moseley Exchange, 149-153 Alcester Rd

Birmingham B13 8JP

United Kingdom

0121 364 1740

hello@podnosh.com

www.podnosh.com

  1. Contact details of the data protection officer

The designated data protection officer is:

DataCo International UK Limited

c/o One Peak Partners, 41 Great Pulteney Street 2nd floor

London W1F 9NZ

United Kingdom

+44 20 3318 17 18

www.dataguard.co.uk

  1. General information on data processing

1. Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

2. Legal basis for data processing

Where consent is appropriate for processing personal data, Art. 6 (1) (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (1) (c) UK GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) UK GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) UK GDPR will serve as the legal basis for the processing of data.

3. Data removal and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfiling the respective contract.

  1. Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:

1. Right to information

You may request the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

  • The purpose for which the personal data is processed.
    • The categories of personal data being processed.
    • The recipients or categories of recipients to whom the personal data have been or will be disclosed.
    • The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
    • The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
    • The existence of the right to lodge a complaint with a supervisory authority.
    • Where personal data are not collected from you any available information as to their source.
    • The existence of automated decision-making including profiling under Article 22 (1) and Article 22 (4) UK GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organization. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 UK GDPR in connection with the transfer.

2. Right to rectification

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay

3. Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

  • If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
    • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
    • The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
    • If you have objected to the processing pursuant to Art. 21 (1) UK GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the processing has been restricted according to the aforementioned conditions, you will be informed by the data controller before the restriction is lifted.

4. Right to erasure

a) Obligation to erase

If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

  • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
    • You withdraw your consent on which the processing is based pursuant to Art. 6 (1) (1) (a) and Art. 9 (2) (a) UK GDPR and where there is no other legal basis for processing the data.
    • According to Art. 21 (1) UK GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) UK GDPR.
    • Your personal data has been processed unlawfully.
    • The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
    • Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) UK GDPR.

b) Information to third parties

If the data controller has made your personal data public and must delete the data pursuant to Art. 17 (1) UK GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.

c) Exceptions

The right to deletion does not exist if the processing is necessary

  • to exercise the right to freedom of speech and information.
    • to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
    • for reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and Art. 9 (2) (i) and Art. 9 (3) UK GDPR.
    • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) UK GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
    • to enforce, exercise or defend legal claims.

5. Right to information

If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You reserve the right to be informed about the recipients of your data by the data controller.

6. Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

  • the processing is based on consent in accordance with Art. 6 (1) (1) (a) UK GDPR or Art. 9 (2) (a) UK GDPR or performance of a contract in accordance with Art. 6 (1) (1) (b) UK GDPR and
    • the processing is done by automated means.

In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.

7. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) UK GDPR; this also applies to profiling based on these provisions.

The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58/EG, you have the option, in the context of the use of information society services, to exercise your right to object to automated decisions that use technical specifications.

8. Right to withdraw the data protection consent declaration

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.

9. Automated decisions on a case-by-case basis, including profiling

You have the right to not be subject to a decision based solely on automated processing – including profiling – that will have a legal effect or substantially affect you in a similar manner. This does not apply if the decision:

  • is required for the conclusion or execution of a contract between you and the data controller,
    • is permitted by the Union or Member State legislation to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
    • is based on your explicit consent.

However, these decisions must not be based on special categories of personal data under Art. 9 (1) UK GDPR, unless Art. 9 (2) (a) or Art. 9 (2) (b) UK GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or his representative, to express your opinion on the matter, and to contest the decision.

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the UK GDPR. If you are located in the United Kingdom, you shall have the right to complain to the ICO if you are unhappy with how we have used you data and/or believe that the processing of the personal data concerning you violates the applicable law. The ICO´s address: Information Commissioner´s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.

  1. Provision of website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

  • Browser type and version used
    • The user’s operating system
    • The IP address of the user
    • Date and time of access
    • Web pages from which the user’s system accessed our website
    • google analytics

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) 1 (f) UK GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (1) (f) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.[BR1] 

5. Objection and removal

The collection of data for the provision of the website as well as the storage of data in log files are essential for the operation of the website. Therefore, the user may not object to the aforementioned processes.

We also use cookies on our website, which enable us to analyse the browsing behaviour of our users.

As a result, the following data will be transmitted:

The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and thus can constantly optimize our offer.

No cookies are used on podnosh.com

The legal basis for the processing of personal data using non-technical cookies is Art. 6 (1) (1) (a) UK GDPR.[BR2] 

1. Description and scope of data processing

You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

If the user has given consent, the legal basis for processing the data is Art. 6 (1)(a) UK GDPR.

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.

If you wish to withdraw your consent for us to store any e-mail you send us please contact us on hello@podnosh.com

In this case, all personal data stored while establishing contact will be deleted.

If you wish to withdraw your consent for us to store any e-mail you send us please contact us on hello@podnosh.com

Use of corporate profiles on social networks

Twitter: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland.


On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

Explain what the company does, where it is and allow people to contact us by e-mail.

Publications on the company profile can contain the following content:

  • Information about products
  • Information about services

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Twitter corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@podnosh.com. For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here:

Twitter: https://twitter.com/de/privacy

YouTube: YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States.


On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

Our website is used to explain what the company does, where it is and allow people to contact us by e-mail.

Publications on the company profile can contain the following content:

  • Information about products
    • Information about services

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.


You can object at any time to the processing of your personal data that we collect within the framework of your use of our YouTube corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@podnosh.com. For further information on the processing of your personal data by YouTube and the corresponding objection options, please click here:

YouTube: https://policies.google.com/privacy?gl=DE&hl=en

The website is hosted on servers of a service provider commissioned by us.

Our service provider is: WPX, K MEDIA TECH, Manastirski Livadi Residential District, Sofia, Bulgaria, UIC 202249002.

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

  • Browser type and version
    • Used operating system
    • Referrer URL
    • Hostname of the accessing computer
    • Time and date of the server request
    • IP address of the user’s device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.

The server of the website is geographically located in Bulgaria.

We also use the following Content Delivery Networks:

WPX (XDN), K MEDIA TECH, Manastirski Livadi Residential District, Sofia, Bulgaria, UIC 202249002.

  1. Description and scope of data processing

On our website we use functions of the content delivery network WPX (XDN), K MEDIA TECH, Manastirski Livadi Residential District, Sofia, Bulgaria, UIC 202249002.

 A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. WPX (XDN) offers web optimization and security services that we use to improve the load times of our website and to protect it from misuse. When you visit our website you will be connected to the servers of WPX (XDN), e.g. to retrieve content. This allows personal data to be stored and evaluated in server log files, the user’s activity (e.g. which pages have been visited) and device and browser information (e.g. IP address and operating system). Further information on the collection and storage of data by WPX (XDN) can be found here: https://wpx.net/page/privacy-policy/

2. Purpose of data processing

The use of WPX (XDN)´s features serves to deliver and accelerate online applications and content.

3. Legal basis for data processing

The data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website -and the server log files are therefore recorded.

4. Duration of storage

Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

5. Objection and removal

Information about objection and removal options regarding WPX (XDN) can be found at:

https://wpx.net/page/privacy-policy/

Through the use of our plugins, some of your personal data is sent to the USA or other third countries outside the UK/EEA. To ensure appropriate guarantees for the protection of the transfer and processing of personal data outside the UK/EEA, the data transfer to and data processing by our plugin operators is based on appropriate guarantees pursuant to Art. 46 UK GDPR in particular by concluding so-called standard data protection clauses pursuant to Art. 46 (2) (c) UK GDPR. A copy of the standard data protection clauses can be requested by sending us an informal email.[BR3] 

We use plugins for various purposes. The plugins used are listed below:

Use of Google Analytics[BR4] 

1. Scope of processing of personal data

We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). Google Analytics examines, among other things, the origin of visitors, their length of stay on individual pages and the use of search engines, thus allowing better monitoring of the success of advertising campaigns. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs). The information generated by the cookie about your use of this website will be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is enabled on this online presence, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
On behalf of the operator of this online presence, Google will use this information to evaluate your use of the online presence, to compile reports on the activities of the online presence and to provide further services associated with the use of the online presence and the Internet use to the operator of the online presence. The IP address transmitted by your browser as part 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 our website. Further information on the collection and storage of data by Google can be found here: https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing

The purpose of processing personal data is to specifically address a target group that has already expressed an initial interest by visiting the site.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google’s own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser, your IP address to Google and to prevent the processing of this data by Google by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en
With the following link you can deactivate the use of your personal data by Google:
https://adssettings.google.com\Further information on objection and removal options against Google can be found at:
https://policies.google.com/privacy?gl=EN&hl=en

XI. Integration of plugins via external service providers[BR5] 

1. Description and scope of data processing

We integrate certain plugins on our website via external service providers in the form of content delivery networks. When you access our website, a connection is established to the servers of the providers used by us to retrieve content and store it in the cache of the user’s browser. This allows personal data to be stored and evaluated in server log files, in particular device and browser information (e.g. IP address and operating system). We use the following services:

  • WPX

2. Purpose of data processing

The use of the functions of these services serves the delivery and acceleration of online applications and content.

3. Legal basis for data processing

This data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a justified interest in the technically correct presentation and optimization of the website.

4. Duration of storage

Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

This privacy policy has been created with the assistance of DataGuard.


 [BR1]Please check (if necessary in consultation with your hosting service provider) whether the deletion periods are actually implemented in this way.

 [BR2]Please, take a second look on that since I can see that you use cookies on your website, e.g Google Analytics.

Image

 [BR3]Please note the information from the email regarding the transfer of personal data to third countries outside the UK/EEA.

 [BR4]Please, make sure to have in place Standard Contractual Clauses (SCC).

We are glad to help you with the topic.

Also take a look on DataGuard´s dashboard under “news” regarding the use of Google Analytics.

https://www.dataguard.co.uk/privacy-dossier/does-google-analytics-violate-the-gdpr

 [BR5]Please, check with the service provider about the topic.

Privacy Policy

As of February 2022

Table of contents

  1. Identity and contact details of the data controller
  2. Contact details of the data protection officer
  3. General information on data processing
  4. Rights of the data subject
  5. Provision of website and creation of log files
  6. Contact via Email
  7. Corporate web profiles on social networks
  8. Hosting
  9. Content delivery networks
  10. Usage of Plugins
  11.  Integration of plugins via external service providers
  1. Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:

Podnosh Ltd

Moseley Exchange, 149-153 Alcester Rd

Birmingham B13 8JP

United Kingdom

0121 364 1740

hello@podnosh.com

www.podnosh.com

  1. Contact details of the data protection officer

The designated data protection officer is:

DataCo International UK Limited

c/o One Peak Partners, 41 Great Pulteney Street 2nd floor

London W1F 9NZ

United Kingdom

+44 20 3318 17 18

www.dataguard.co.uk

  1. General information on data processing

1. Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

2. Legal basis for data processing

Where consent is appropriate for processing personal data, Art. 6 (1) (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (1) (c) UK GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) UK GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) UK GDPR will serve as the legal basis for the processing of data.

3. Data removal and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfiling the respective contract.

  1. Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:

1. Right to information

You may request the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

  • The purpose for which the personal data is processed.
    • The categories of personal data being processed.
    • The recipients or categories of recipients to whom the personal data have been or will be disclosed.
    • The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
    • The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
    • The existence of the right to lodge a complaint with a supervisory authority.
    • Where personal data are not collected from you any available information as to their source.
    • The existence of automated decision-making including profiling under Article 22 (1) and Article 22 (4) UK GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organization. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 UK GDPR in connection with the transfer.

2. Right to rectification

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay

3. Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

  • If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
    • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
    • The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
    • If you have objected to the processing pursuant to Art. 21 (1) UK GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the processing has been restricted according to the aforementioned conditions, you will be informed by the data controller before the restriction is lifted.

4. Right to erasure

a) Obligation to erase

If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

  • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
    • You withdraw your consent on which the processing is based pursuant to Art. 6 (1) (1) (a) and Art. 9 (2) (a) UK GDPR and where there is no other legal basis for processing the data.
    • According to Art. 21 (1) UK GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) UK GDPR.
    • Your personal data has been processed unlawfully.
    • The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
    • Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) UK GDPR.

b) Information to third parties

If the data controller has made your personal data public and must delete the data pursuant to Art. 17 (1) UK GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.

c) Exceptions

The right to deletion does not exist if the processing is necessary

  • to exercise the right to freedom of speech and information.
    • to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
    • for reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and Art. 9 (2) (i) and Art. 9 (3) UK GDPR.
    • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) UK GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
    • to enforce, exercise or defend legal claims.

5. Right to information

If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You reserve the right to be informed about the recipients of your data by the data controller.

6. Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

  • the processing is based on consent in accordance with Art. 6 (1) (1) (a) UK GDPR or Art. 9 (2) (a) UK GDPR or performance of a contract in accordance with Art. 6 (1) (1) (b) UK GDPR and
    • the processing is done by automated means.

In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.

7. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) UK GDPR; this also applies to profiling based on these provisions.

The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58/EG, you have the option, in the context of the use of information society services, to exercise your right to object to automated decisions that use technical specifications.

8. Right to withdraw the data protection consent declaration

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.

9. Automated decisions on a case-by-case basis, including profiling

You have the right to not be subject to a decision based solely on automated processing – including profiling – that will have a legal effect or substantially affect you in a similar manner. This does not apply if the decision:

  • is required for the conclusion or execution of a contract between you and the data controller,
    • is permitted by the Union or Member State legislation to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
    • is based on your explicit consent.

However, these decisions must not be based on special categories of personal data under Art. 9 (1) UK GDPR, unless Art. 9 (2) (a) or Art. 9 (2) (b) UK GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or his representative, to express your opinion on the matter, and to contest the decision.

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the UK GDPR. If you are located in the United Kingdom, you shall have the right to complain to the ICO if you are unhappy with how we have used you data and/or believe that the processing of the personal data concerning you violates the applicable law. The ICO´s address: Information Commissioner´s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.

  1. Provision of website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

  • Browser type and version used
    • The user’s operating system
    • The IP address of the user
    • Date and time of access
    • Web pages from which the user’s system accessed our website
    • google analytics

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) 1 (f) UK GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (1) (f) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.[BR1] 

5. Objection and removal

The collection of data for the provision of the website as well as the storage of data in log files are essential for the operation of the website. Therefore, the user may not object to the aforementioned processes.

We also use cookies on our website, which enable us to analyse the browsing behaviour of our users.

As a result, the following data will be transmitted:

The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and thus can constantly optimize our offer.

No cookies are used on podnosh.com

The legal basis for the processing of personal data using non-technical cookies is Art. 6 (1) (1) (a) UK GDPR.[BR2] 

1. Description and scope of data processing

You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

If the user has given consent, the legal basis for processing the data is Art. 6 (1)(a) UK GDPR.

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.

If you wish to withdraw your consent for us to store any e-mail you send us please contact us on hello@podnosh.com

In this case, all personal data stored while establishing contact will be deleted.

If you wish to withdraw your consent for us to store any e-mail you send us please contact us on hello@podnosh.com

Use of corporate profiles on social networks

Twitter: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland.


On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

Explain what the company does, where it is and allow people to contact us by e-mail.

Publications on the company profile can contain the following content:

  • Information about products
  • Information about services

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Twitter corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@podnosh.com. For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here:

Twitter: https://twitter.com/de/privacy

YouTube: YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States.


On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

Our website is used to explain what the company does, where it is and allow people to contact us by e-mail.

Publications on the company profile can contain the following content:

  • Information about products
    • Information about services

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.


You can object at any time to the processing of your personal data that we collect within the framework of your use of our YouTube corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@podnosh.com. For further information on the processing of your personal data by YouTube and the corresponding objection options, please click here:

YouTube: https://policies.google.com/privacy?gl=DE&hl=en

The website is hosted on servers of a service provider commissioned by us.

Our service provider is: WPX, K MEDIA TECH, Manastirski Livadi Residential District, Sofia, Bulgaria, UIC 202249002.

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

  • Browser type and version
    • Used operating system
    • Referrer URL
    • Hostname of the accessing computer
    • Time and date of the server request
    • IP address of the user’s device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.

The server of the website is geographically located in Bulgaria.

We also use the following Content Delivery Networks:

WPX (XDN), K MEDIA TECH, Manastirski Livadi Residential District, Sofia, Bulgaria, UIC 202249002.

  1. Description and scope of data processing

On our website we use functions of the content delivery network WPX (XDN), K MEDIA TECH, Manastirski Livadi Residential District, Sofia, Bulgaria, UIC 202249002.

 A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. WPX (XDN) offers web optimization and security services that we use to improve the load times of our website and to protect it from misuse. When you visit our website you will be connected to the servers of WPX (XDN), e.g. to retrieve content. This allows personal data to be stored and evaluated in server log files, the user’s activity (e.g. which pages have been visited) and device and browser information (e.g. IP address and operating system). Further information on the collection and storage of data by WPX (XDN) can be found here: https://wpx.net/page/privacy-policy/

2. Purpose of data processing

The use of WPX (XDN)´s features serves to deliver and accelerate online applications and content.

3. Legal basis for data processing

The data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website -and the server log files are therefore recorded.

4. Duration of storage

Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

5. Objection and removal

Information about objection and removal options regarding WPX (XDN) can be found at:

https://wpx.net/page/privacy-policy/

Through the use of our plugins, some of your personal data is sent to the USA or other third countries outside the UK/EEA. To ensure appropriate guarantees for the protection of the transfer and processing of personal data outside the UK/EEA, the data transfer to and data processing by our plugin operators is based on appropriate guarantees pursuant to Art. 46 UK GDPR in particular by concluding so-called standard data protection clauses pursuant to Art. 46 (2) (c) UK GDPR. A copy of the standard data protection clauses can be requested by sending us an informal email.[BR3] 

We use plugins for various purposes. The plugins used are listed below:

Use of Google Analytics[BR4] 

1. Scope of processing of personal data

We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). Google Analytics examines, among other things, the origin of visitors, their length of stay on individual pages and the use of search engines, thus allowing better monitoring of the success of advertising campaigns. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs). The information generated by the cookie about your use of this website will be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is enabled on this online presence, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
On behalf of the operator of this online presence, Google will use this information to evaluate your use of the online presence, to compile reports on the activities of the online presence and to provide further services associated with the use of the online presence and the Internet use to the operator of the online presence. The IP address transmitted by your browser as part 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 our website. Further information on the collection and storage of data by Google can be found here: https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing

The purpose of processing personal data is to specifically address a target group that has already expressed an initial interest by visiting the site.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google’s own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser, your IP address to Google and to prevent the processing of this data by Google by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en
With the following link you can deactivate the use of your personal data by Google:
https://adssettings.google.com\Further information on objection and removal options against Google can be found at:
https://policies.google.com/privacy?gl=EN&hl=en

XI. Integration of plugins via external service providers[BR5] 

1. Description and scope of data processing

We integrate certain plugins on our website via external service providers in the form of content delivery networks. When you access our website, a connection is established to the servers of the providers used by us to retrieve content and store it in the cache of the user’s browser. This allows personal data to be stored and evaluated in server log files, in particular device and browser information (e.g. IP address and operating system). We use the following services:

  • WPX

2. Purpose of data processing

The use of the functions of these services serves the delivery and acceleration of online applications and content.

3. Legal basis for data processing

This data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a justified interest in the technically correct presentation and optimization of the website.

4. Duration of storage

Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

This privacy policy has been created with the assistance of DataGuard.


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 [BR3]Please note the information from the email regarding the transfer of personal data to third countries outside the UK/EEA.

 [BR4]Please, make sure to have in place Standard Contractual Clauses (SCC).

We are glad to help you with the topic.

Also take a look on DataGuard´s dashboard under “news” regarding the use of Google Analytics.

https://www.dataguard.co.uk/privacy-dossier/does-google-analytics-violate-the-gdpr

 [BR5]Please, check with the service provider about the topic.