This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

The zobiki platform is storing Your Personal data to provide the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. With the following privacy policy (hereinafter: “Privacy Policy”), zobiki is informing you about the collection, use and processing of personal data when using zobiki’s website zobiki.com (hereinafter: “Website”) and zobiki’ newsletter.

​Unless explicitly defined otherwise in this Privacy Policy, used terms shall have the meaning ascribed to them in Art. 4 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter: “GDPR”). In accordance with Art. 4 no. 1 GDPR, personal data means all detailed information about personal or factual circumstances of a specific or identifiable natural person, such as e.g. your name, your telephone number or your address.

A data control officer has not been ordered by the Responsible Entity. Please contact the Responsible Entity directly with any questions and to assert data protection rights to which you are entitled.

The responsible entity for the collection, use and processing of your personal data within the meaning of Art. 4 no. 7 GDPR is:

De Lazzari Vermögensverwaltung UG

Prenzlauer Promenade 181, Berlin 13189, Germany

E-Mail: privacy@zobiki.com

Web: zobiki.com

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

​"Account" means a unique account created for You to access our Service or parts of our Service.

"Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to

De Lazzari Vermögensverwaltung UG

Prenzlauer Promenade 181, Berlin 13189 Germany

For the purpose of the GDPR, the Company is the Data Controller.

"Country" refers to Germany.

"Device" means any device that can access the Service such as a computer, a cell phone or a digital tablet.

"Personal Data" is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

"Service" refers to our API, infrastructure and other applications.

"Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

"You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service. zobiki.com relates to all services under zobiki.com/products.

Collecting and Using Data for the Provision of the Website

The data subjects in relation to the provision of the website are the website visitors.

Automated Collection of Data – Server-Log-Files.

When accessing our Website your browser is transmitting the following data for technical reasons:

• Date and time of your access,
• Browser type and version,
• Used operating system,
• URL of the previously visited website,
• Quantity of transmitted data.

This data is stored by zobiki only for technical reasons and will, at no time, be assigned to an individual person. This data processing is carried out on the basis of our legitimate interest in the secure and error-free operation of our IT infrastructure, the fight against misuse, the prosecution of criminal offences and the securing, assertion and enforcement of claims, Art. 6 Para. 1 f) GDPR (legitimate interest).

Consent Management

In order to manage and implement your consent on the Website, we developed the consent management by ourselves. This enables us to obtain, manage and document the consent of our users for the processing of personal data and the use of individual third-party services as well as various web technologies on the website in compliance with the GDPR. The legal basis for this processing is Art. 6 Para. 1 c) GDPR (legal obligation).

Consent Management

In order to manage and implement your consent on the Website, we developed the consent management by ourselves. This enables us to obtain, manage and document the consent of our users for the processing of personal data and the use of individual third-party services as well as various web technologies on the website in compliance with the GDPR. The legal basis for this processing is Art. 6 Para. 1 c) GDPR (legal obligation).

Google : We use Google Tag Manager, a service from Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA hereinafter “Google”), to manage the tracking on the Website using Google Analytics (see below). Google Tag Manager itself does not collect personally identifiable information. You will find more information about Google Tag Manager in the terms of service of Google Tag Manager and in Google’s privacy policy. The legal basis for this processing is Art. 6 Para. 1 f) (legitimate interest).

We use Google Analytics, a web analytics service provided by Google (see above). Google Analytics uses “cookies” to help analysing how users use the Website. The information generated by the cookie about your use of the Website (including your truncated IP-address as described below) will be transmitted to and stored by Google on servers in the United States. Standard data protection clauses have been agreed with Google, which are considered an appropriate safeguard for data transfer to a third country in accordance with Art. 46 GDPR.

As IP-anonymisation is activated on our Website, your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there.

Google will use this information on behalf of zobiki for the purpose of evaluating your use of our Website, compiling reports on website activity and providing us other services relating to website activity and internet usage.

The IP-address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.

You will find more information about Google and Google Analytics in Google’s data privacy and security overview and privacy policy.

Sendgrid : zobiki uses the service Sendgrid of Twilio Germany GmbH, Unter den Linden 10, 10117 Berlin
info@twilio.com

This service allows zobiki to communicate with you via email. The service manages information about when an email was read by you and when you interacted with incoming email messages, for example by clicking on links included in the email. This is done by so-called web beacons, also called tracking pixels. These are small image files that allow us to evaluate user behavior. Sendgrid is certified by the Standard Contractual Clauses drafted by the European Commission, so that an adequate level of data protection according to Art. 45 GDPR is ensured.

Sendgrid processes all data in accordance with European data protection standards.

Further information about data protection at Sendgrid can be found in Sendgrid’s privacy policy.

Amazon Web Services: zobiki uses the service Rekognition of Amazon Web Services Inc, 410 Terry Avenue North, Seattle, WA 98109-5210 U.S.A.

This service allows zobiki to use the AI/ML Face recognition process. The service manages the image of your face to perform the identification algorithm, however no indication of your real identity is performed as we use an hash to connect you with the face data value from the algorithm. Amazon Web Services Inc is certified by the Standard Contractual Clauses drafted by the European Commission, so that an adequate level of data protection according to Art. 45 GDPR is ensured.

Amazon Web Services inc. processes all data in accordance with European data protection standards.

Further information about data protection at Amazon Web Services Inc. can be found in AWS’s privacy policy.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Right of access (Article 15 GDPR)
• Right to rectification (Article 16 GDPR)
• Right to erasure (“right to be forgotten”) (Article 17 GDPR)
• Right to restriction of processing (Article 18 GDPR)
• Right to data portability (Article 20 GDPR)
• Right to object (Article 21 GDPR)
• Right to withdraw consent (Article 7 Para. 3 GDPR)
• Right to lodge a complaint with a supervisory authority (Article 77 GDPR)
• To exercise these rights, the User may contact us via the contact information provided under No. 1.

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data:

Berliner Beauftragte für Datenschutz und Informationsfreiheit

Friedrichstr. 219, Visitors‘ entrance: Puttkamerstr. 16 – 18

10969 Berlin, Germany

Phone: 030 13889-0

E-Mail: mailbox@datenschutz-berlin.de

Web: www.datenschutz-berlin.de

For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

We reserve the right to amend this Privacy Policy at any time to the extent legally possible. The current version of our Privacy Policy is always available at https://zobiki.com/privacy-policy

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

​By email: privacy@zobiki.com

By visiting this page on our website: https://zobiki.com

By post mail: De Lazzari Vermögensverwaltung UG, Prenzlauer Promenade 181, 13189 Berlin, Germany