Remagine

Privacy Policy

CONSCIOUSGROWTH

Last amended: January 19th, 2021

We respect your privacy and the privacy of your users. This Privacy Policy explains how ConsciousGrowth GmbH (collectively “Conscious Growth“, or “we“, or “us“, or “our“) under its brand “Remagine” collects, uses and shares your personal information in connection with your use of our website www.remagine.io and our internet-platform “Remagine-Platform” and explains your choices for how we handle your personal information. For convenience, the site and the services regarding our platform are collectively also referred to as the “Service.”

1. Contact details of the controller

The website www.remagine.io and the Remagine-Platform are provided by ConsciousGrowth GmbH, HRB 210504, Schönhauser Allee 149, 10435 Berlin. ConsciousGrowth is also the controller within the meaning of the EU General Data Protection Regulation (GDPR) for the collection, processing and use of personal data of website visitors and users of the Remagine-Platform (hereinafter referred to as “you”). Please be advised that when using the Remagine-Platform also other controllers might process your personal data. These service providers will make their respective privacy policy accessible for you.

Should you have any questions or suggestions regarding data privacy, please do not hesitate to contact us. You are welcome to direct your data privacy related questions to our data privacy team by sending an email to [email protected] Our full contact details as data controller are:

ConsciousGrowth GmbH / Remagine

Schönhauser Allee 149

10435 Berlin

Germany

Data Privacy Officer of ConsciousGrowth GmbH/ Remagine

Mr. Bertrand Delain

Email: [email protected]

2. Data processing when you use our website

2.1 Visiting the site

In the context of visiting the site and using the Remagine-Platform personal data is only collected if this is necessary for technical reasons to use our website or if you use certain functions or services offered on our website, e.g. the contact form or the sign up process.

The following log- data is automatically recorded every time the service is accessed:

  • date and time of access (“time stamp”)
  • name of the file requested
  • website from which the file was requested
  • access status (e.g. file transferred, file not found)
  • Browser type / version
  • used operating system

It is necessary to process this data to make it possible to visit the website or Remagine-Platform and to guarantee the long-term functionality, availability and security of our systems. The legal basis for this data processing is Art. 6(1) (b) GDPR.

2.2 Sign-up and login

To use our service, you first need to set up a user account for the Remagine-Platform. This requires you to provide a business name, your company’s website and an email address. We also ask you to provide additional information about your company (e.g. industry, registered office, monthly online revenue and the monthly budget for ads as well as the return on advertising spend. These categories are also summarized below as “company data”). We also collect your first and last name, a phone number and your title / role with your company. A password will be required to login to your Remagine account. We process this data in order to create and manage the Remagine account. The legal basis for this data processing is Art. 6(1) (b) GDPR. The data collected when you use the sign-up form will be stored for the duration of our business relationship.

2.3 Application

In order to apply for Remagine funding you need to provide us with company data and connect your aggregated sales, marketing, and bank account data with the Remagine-Platform. We need an insight into this information in order to assess the state of growth of your business and the risks associated with a potential funding.

For accessing the bank account data, we do not look into specific transactions of your users but the analysis focuses on the categorization and data enrichment of transactions in your account history. For this purpose we use the P.S.D.true software of Geldspeicher GmbH, c/o rent24, Oberwallstraße 6, 10117 Berlin. In addition, bank account information is processed with the help of subcontractors of Geldspeicher GmbH, (finAPI GmbH, Adams-Lehmann-Str. 44, 80797 München, their privacy policy can be found here, finAPI is an account information service provider regulated by BaFin). The account information is only collected if you instruct to transmit the bank account information by entering your bank account access information in the corresponding input mask. The enriched information is used for risk assessment purposes.

We will review your application based on your company data and the aggregated data mentioned above and send you several funding offers, from which you can pick the one that matches best your sales and marketing needs. All data regarding your application is stored with your Remagine account. Only aggregated or anonymized data is processed in the application and review process. The legal basis for this data processing is Art. 6(1) (b) GDPR.

2.4 Using the Remagine-Platform

When you login to your Remagine account, you can examine your funded budget, account balance, repayment history and the repayment terms we agreed on. This information and data about your related use of the Remagine-Platform (e.g. timestamps, changes to your account, settings and status) is stored in connection with your Remagine account. The legal basis for this data processing is Art. 6(1) (b) GDPR.

2.5 Repayment

In the context of the repayment of your funding, we process your company data and data on the funding and the repayment plan we agreed to as well as information on your bank account to coordinate and control the repayment. The legal basis is Art. 6 (1) (b) GDPR.

2.6 Support

We process information you provide in the support contact form to respond to your support request. In the context of your support request, we also collect your account name and other account related data. We will process this data and, if necessary, data regarding your funding or other company data stored in your Remagine account to answer your request. The legal basis is Art. 6 (1) (b) GDPR.

2.7 Controlling, reporting and analytics

We also use information on transactions for internal cost and performance accounting, controlling and internal reporting, which serves us for corporate management and planning. The legal basis is Art. 6 (1) (b) GDPR. In this context, no personal data is processed.

We also use aggregated information on applications, ongoing and completed fundings, as well as anonymized company data for analysis and marketing purposes, as well as improving our internal processes and the Remagine-Platfrom in general. The legal basis is Art. 6 (1) (f) GDPR, based on our aforementioned legitimate interests. We will not use or disclose your confidential information.

2.8 Remagine newsletter

You have the opportunity to subscribe to our Remagine newsletter, which informs you regularly about our release notes, new features and updates regarding our service. When registering for the Remagine newsletter, we ask you to provide your email address so that we can send you the newsletter. We will also ask you during the sign-up process, if you would like to subscribe to the Remagine newsletter. We will then use the email address from your account.

For newsletter subscriptions we use the so-called double opt-in procedure, which means that we will only send you Remagine newsletters by email if you click on a link in our notification email to confirm that you are the owner of the email address provided. If you confirm your email address, we will store your email address, the time of registration and the IP address you used when registering until you unsubscribe from the Remagine newsletter. The sole purpose of storing this data is to be able to send you the newsletter and prove that you registered.

You can unsubscribe from the Remagine newsletter at any time. An unsubscribe link can be found in every newsletter. It is of course also sufficient if you notify us using the contact details provided above or in the newsletter (e.g. by email or letter). The legal basis of the above processing is your consent pursuant to Art. 6(1)(a) GDPR.

2.9 Customer and partner management

For the administration of our business contacts we process information about your company (in particular address, branches, authorized representatives and their contact data) as well as information about the respective contact persons (in particular name, position, professional contact information) and any communication with you. We use this data in order to be able to contact the contact persons with your company and to process your requests appropriately and to maintain our business relationship. The legal basis is Art. 6(1)(b) GDPR.

2.10 Cookies, marketing and analytics tools

2.11 General use of cookies

When you visit and use our website and the Remagine-Platfrom, we may store a variety of cookies. Cookies are small text files stored in your web browser’s memory which contain information that can be used to recognize you when you visit web servers later on. However, this does not mean that we are immediately aware of your identity. Cookies cannot execute any programs or transfer viruses to your computer.

The primary purpose of our own cookies is rather to make using our service as time-saving and user-friendly as possible.

We use cookies in particular

  • for load balancing;
  • to store language settings;
  • to store form data; and
  • to note that information placed on our website has been displayed to you, so that it will not be displayed again the next time you visit the website.
 

For example, we use so-called session cookies to recognize that you have already visited individual pages on our website. These cookies expire at the latest one month after you stop interacting with our website. In addition, to improve usability, we also use temporary cookies that are stored on your device for a specified period of time. If you visit our site or platform again to take advantage of our services, it will automatically recognize that you have already been with us and what inputs and settings you have made, so you do not have to re-enter them.

We do this to be able to make your use of our website more convenient and personalized. The processing of the respective cookies is based on our aforementioned legitimate interests, meaning the legal basis is Art. 6(1) (f) GDPR.

You can prevent the storage of cookies by adjusting your browser settings to disable the acceptance of cookies via this website. If you do not accept cookies, however, this may in some cases lead to considerable functional restrictions on our website.

2.12 Web analytics by Matomo NOT Google Analytics

On our website we use the open source software tool Matomo that we host on-premise to analyze the surfing behaviour of our users. This is an open source web analysis tool. Matomo does not transfer any data to servers outside of our control. Matomo does not record any session data without your consent.

Matomo uses cookies. These text files are saved on your computer and enable us to analyse how the Remagine.io-website is used. The information on usage collected by the cookie is transferred to our servers and saved there so that we can analyse user behaviour. For us, your IP address is an anonymous code. This means we have no technical means of identifying you as a registered user. You will remain anonymous as a user.

We regard this analysis as an integral part of our service. Its aim is to consistently improve the website and align it more closely with user needs.

The analysis software runs exclusively on the servers of our website. Storage of the user’s personal data only takes place there. The data is not passed on to third parties.

You can decide here whether or not to allow a web analysis cookie to be stored in your browser to enable us to gather and analyse statistical data.

If you decide against this, click on the link below to store the Matomo deactivation cookie in your browser.

You can decide here whether or not to allow a web analysis cookie to be stored in your browser to enable the website operator to gather and analyse statistical data. If you decide against this, remove the tick from the box following the link below to store the Matomo deactivation cookie in your browser.

Currently your visit to this website is being recorded by Matomo web analysis. If you do not wish your visit to be recorded in future and for the general management of your cookies via Matomo, click here.

The legal basis for processing personal data of users is Art. 6 (1) (a) GDPR.

The processing of personal data of users enables us to analyse the surfing behaviour of our users. By evaluating the collected data, we are able to generate information about the use of the individual components of our website. This helps us to continually improve our website and its user-friendliness. By anonymising the IP address, the interests of the users regarding protection of personal data are sufficiently taken into account.

The data is deleted as soon as it is no longer needed for our record-keeping purposes. The generated statistics and underlying data are not deleted.

Cookies are stored on the user’s computer and transmitted to our site from there. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transfer of cookies. Previously stored cookies can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, you might not be able to fully use all of the website’s functions.

More information about the privacy settings of the Matomo software can be found here.

3. Links to other websites and online content

Our website may contain links to websites and online content of other providers not affiliated with us. If you activate these links, we naturally no longer have any influence on which data is collected by the respective providers and which data they record. For more detailed information on data collection and use, please refer to the privacy policies of the respective providers. Since the collection and processing of data by third parties is beyond our control, we cannot assume any responsibility for this.

4. Our social media profiles

We are represented in various social networks.

  • Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, D2 Dublin, Ireland), Privacy Policy
  • Twitter (Twitter, Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA), Privacy Policy
  • Instagram (Facebook Ireland Ltd., 4 Grand Canal Square, D2 Dublin, Ireland), data protection notices
  • LinkedIn (LinkedIn Corporation, 2029 Stierlin Ct. Ste. 200 Mountain View, California 94043, USA), privacy policy
 

On our website we link to our company profiles on the respective social networks. Please note, that when you activate a link to a social network, data is transferred to servers of the respective provider. If you are logged in to the respective social network at that moment with your username and password, the information that you are visiting our website will be transferred to the social network and the respective provider may assign this information to your user account.

Basically, we have no way of influencing the data processing regarding the social networks. But we do receive statistics about usage and visits of our company profiles on the social networks (e.g., information about the number of views, interactions such as likes, comments and retweets, and aggregated demographic and other information or statistics). For this purpose, we submit certain parameters regarding our company and the services and content we offer on our company profile to the social network. This information is used by the providers to create more detailed statistics. In addition, the providers may use data they collect when you visit the social network for their own purposes beyond our control. For more detailed information, please refer to the providers’ privacy notice linked above.

If we receive your personal data via our social media profiles (e.g. via direct messages), you are entitled to the rights set out in this privacy policy (see section 8 “Your rights”). You can send us your inquiries to gain access to stored personal data with regard to data processing in the context of our company profiles using contact data specified in section 1. We will then inform you about the data we have collected on our own and data which was transmitted to us to comply with the rights you have exercised against us.

If you also intend to assert rights against the social network provider, the easiest way to do so is to directly contact the respective provider. The provider knows the details on the technical operation of the platform and the associated data processing as well as the concrete purposes of data processing and can put appropriate measures into practice to comply with your inquiry. The contact details can be found in the privacy notice linked above. We gladly support you in asserting your rights to the extent of our competence.

The legal basis for linking and operating our company social media profiles is Art. 6(1) (f) GDPR based on our legitimate interest in our corporate communications in the respective social networks.

5. Disclosure of data

In principle, we will only pass on the data we collect if:

  • you have given your explicit consent pursuant to Art. 6(1) (a) GDPR;
  • disclosure is necessary pursuant to Art. 6(1) (f) GDPR in order to establish, exercise or defend legal claims and there is no reason to assume that you have an overriding legitimate interest in your data not being disclosed;
  • we are legally obliged to do so under Art. 6(1) (c) GDPR; or
  • this is permitted by law and is required under Art. 6(1) (b) GDPR for the processing of contractual relationships with you or for taking steps at your request prior to entering into a contract.

 

Part of the data processing may be carried out by our service providers. In addition to the service providers mentioned in this privacy policy, this may in particular include data centers that store our website and databases, IT service providers that maintain our systems or provide CRM functionalities and consulting firms. If we pass data on to our service providers, they may use the data only for the fulfilment of their tasks. We have carefully selected and commissioned the service providers. They are contractually bound by our instructions, have appropriate technical and organizational measures in place to protect the rights of data subjects and are carefully monitored by us.

In addition, data may be disclosed in connection with official requests, court orders and legal proceedings if this is necessary to pursue or enforce rights.

6. Security

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. Our security is subject to constant improvement and our privacy policies are constantly being revised.

7. Personal data retention

We store personal data only for as long as is necessary to fulfil contractual or statutory duties for which the data were collected. We then erase or anonymize the data immediately, unless we still need it until expiry of the statutory period of limitation for purposes of evidence in civil claims or due to statutory duties of storage. For purposes of evidence, we must still store data for three years from the end of the year in which business relations with you end or an Remagine account is deleted. We are also required to store some of your data for accounting purposes. We have an obligation to do so under statutory duties of documentation which may arise under the German Commercial Code (HGB), the German Tax Code (AO) or the German Anti-Money Laundering Act (GwG). The retention periods are up to 10 years.

8. Your rights

You have the right to information about how we process your personal data at any time. When providing this information, we will explain the data processing and provide you with an overview of the data stored about you.

If data stored by us is incorrect or no longer up to date, you have the right to have this data corrected.

You may also demand that your data be erased. Should the erasure not be possible in exceptional cases due to other legal regulations, the data will be blocked so that it is only available for that legal purpose.

You are also entitled to have the processing of your data restricted, e.g. if you believe that the data we have stored is incorrect.

You also have the right to data portability, which means that on request we will send you a digital copy of the personal data you have provided on the basis of consent or a contractual relationship.

In order to assert your rights described here, you can contact us at any time using the contact details provided in Section 1 above.

In addition, you have the right to object to data processing if it is based on Art. 6(1) (f) GDPR or for marketing purposes. Finally, you have the right to lodge a complaint with our competent data protection supervisory authority. You can assert this right by contacting a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement. The supervisory authority in Berlin is: Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin, E-Mail: [email protected], Internet: http://www.datenschutz-berlin.de.

Right of withdrawal and objection. Pursuant to Art. 7(3) GDPR, you have the right to withdraw consent you gave us at any time. As a result of this, we will cease the data processing based on this consent with future effect. This withdrawal of your consent will not affect the lawfulness of the processing carried out on the basis of the consent prior to the withdrawal.

If we process your data on the basis of legitimate interests pursuant to Art. 6(1)(f) GDPR, you have the right under Art. 21 GDPR to object to the processing of your data, and to give us reasons which arise from your particular situation which, in your opinion, show that your legitimate interests override ours. If your objection is to data processing for direct marketing purposes, you have a general right of objection, which we will implement without requiring you to give reasons.

If you would like to make use of your right of withdrawal or objection, it is sufficient to simply notify us using the contact details provided above.

9. Updates to this Privacy Policy

This privacy policy is currently valid. As a result of the further development of our website and platform or due to changed legal or official requirements, it may be necessary to change this privacy policy. The current privacy policy can be found on our website www.remagine.io/privacy-policy.