1. Introduction
Welcome to PlamCore. The protection of your personal data is important to us. This privacy policy provides detailed information about the nature, scope, and purpose of the collection, processing, and use of personal data (“data”) within our online offerings, services, and external online presences, such as our social media profiles. Data will be processed as part of the use of our website and services, particularly in relation to future offerings, such as personality analyses that involve the processing of sensitive data, including birth data.
By using our website or availing of our services, you agree to the collection and processing of your data in accordance with this privacy policy.

2. Controller for Data Processing
The responsible party for data processing within the meaning of the General Data Protection Regulation (GDPR) is:

PlamCore UG (haftungsbeschränkt), Münchner Str. 80, 85774 Unterföhring
Email: plamcore@plamcore.com

As we are not currently required by law to appoint a data protection officer, the management will act as your point of contact for data protection matters.

3. Legal Basis for Data Processing
We process your personal data based on the following legal grounds:

• Consent (Art. 6(1)(a) GDPR): If you have given us consent to process your data, e.g., for sending newsletters or using specific analysis tools.
• Contract Fulfillment (Art. 6(1)(b) GDPR): When we need your data to fulfill a contract with you or to carry out pre-contractual measures.
• Legal Obligation (Art. 6(1)(c) GDPR): When we are legally obligated to process data, e.g., due to tax regulations.
• Legitimate Interest (Art. 6(1)(f) GDPR): In certain cases, we process your data to protect our legitimate interests (e.g., for the security and optimization of our website).

4. Collection and Processing of Personal Data
We only process your personal data if it is legally permitted or if you have given us your explicit consent for data processing. Personal data includes information such as name, email address, telephone number, IP address, and, if applicable, sensitive data such as birth data for services like personality analyses.

A) Types of Processed Data
We process the following personal data:

• Inventory data (e.g., names, addresses)
• Contact data (e.g., email addresses, phone numbers)
• Content data (e.g., text input, photographs, videos)
• Contract data (e.g., subject matter of the contract, duration)
• Usage data (e.g., visited websites, access times)
• Meta/communication data (e.g., IP addresses)

B) Automatically Collected Data When Using Our Website
When visiting our website, the following data is automatically collected by our IT systems:

• IP address of the requesting device
• Date and time of access
• Browser type and version
• Operating system
• Referrer URL (the previously visited page)
• Accessed pages and subpages

This data is processed to ensure the smooth operation of the website and to analyze system security. The legal basis for this processing is Art. 6(1)(f) GDPR (legitimate interest).

C) Data You Voluntarily Provide to Us
We collect personal data that you actively provide to us, such as by filling out contact forms or booking services. This data includes:

• Name, email address, telephone number
• Address data
• Birth data (particularly for personality analyses)

5. Specific Provisions for Sensitive Data (Birth Data for Personality Analyses)
We may offer services in the future that collect and process sensitive personal data, particularly birth data, for personality analyses. Since this involves sensitive data as defined by Art. 9 GDPR, your explicit consent will be required before processing.

A) Legal Basis for Processing
The legal basis for processing this sensitive data is your explicit consent in accordance with Art. 6(1)(a) GDPR and Art. 9(2)(a) GDPR. We will obtain this consent separately before collecting birth data.

B) Purpose of Processing
Sensitive data will only be used for the purpose of conducting personality analyses and creating individual profiles based on this data. Your data will be processed for the following purposes:

• Fulfilling our services and offers: This includes all aspects of contract fulfillment, such as handling your bookings, orders, and inquiries.
• Personalization of offers and services: This specifically relates to the use of personal data for future services, such as personality analyses, for which we will explicitly obtain your consent (see Section 7).
• Optimization and security of our website: We collect data on usage behavior to analyze and continuously improve the use of our website. We also use cookies and tracking tools for this purpose.
• Marketing and advertising: If you have given your consent, we use your contact data to send you newsletters or other promotional content. You may object to this use at any time.
• Fulfillment of legal obligations: We process your data to fulfill legal obligations, such as tax or accounting regulations.

C) Consent Declaration
When collecting birth data and other sensitive data, we ask for your explicit consent before processing. You have the right to withdraw this consent at any time. The withdrawal of consent can be sent to us via email. The withdrawal of consent does not affect the legality of the processing carried out until the point of withdrawal.

6. Data Processing in Connection with Contracts
If you use any of our services or products, we process personal data that is necessary to fulfill the respective contract. This includes the processing of:

• Name and contact details
• Payment information
• Data necessary for the provision of the service

The legal basis for this processing is Art. 6(1)(b) GDPR (contract fulfillment).

7. Data Disclosure to Third Parties
We only disclose your personal data to third parties when it is necessary to fulfill a contract with you, when we are legally required to do so, or when you have expressly given us your consent. Recipients of the data may include:

• Payment service providers for processing payments
• IT service providers for maintaining and supporting our systems
• Providers of analysis tools

Marketing and Form Processing Platforms:
We use Brevo, MailerLite, and Bit Form as our platforms for marketing and form processing. By submitting forms on our website, you agree that the personal data you provide will be transferred to these platforms for processing in accordance with their respective Privacy Policies.

For sensitive data, particularly birth data, your data will only be disclosed to third parties if you have expressly agreed to this.

Data Transfers to Third Parties
If personal data is transferred to countries outside the European Economic Area (EEA), such as the USA or other countries where there is no equivalent level of data protection, we ensure that these transfers are protected by appropriate safeguards. These safeguards typically include the European Commission’s standard contractual clauses, which ensure that your data is processed in accordance with European data protection standards.

Additional Safeguards for Third Countries
In cases where we transfer personal data to countries that do not have adequate data protection laws, we will obtain your explicit consent before the transfer (under Art. 49(1)(a) GDPR). This consent ensures that you are informed about the risks of such transfers and that you expressly agree to them.

8. Data Processing When Using Our Website (Cookies)
Our website uses cookies to improve user experience and provide certain functionalities. Cookies are small text files stored on your device. We use the following types of cookies:

• Necessary Cookies: These are essential for the operation of the website. These cookies are required to ensure the basic functions of the website.
• Analytics Cookies: These enable us to analyze your behavior on the website to make improvements.
• Statistics Cookies: These cookies help us understand how visitors use our website by collecting information anonymously.
• Marketing Cookies: These cookies are used to track visitors across websites. The aim is to show you targeted advertising.

The legal basis for the use of cookies is your consent in accordance with Art. 6(1)(a) GDPR, which you provide through our cookie banner.
When you access our website, you will be informed about the use of cookies and asked for your consent to use non-essential cookies.

Tracking Tools: We use various tracking tools to analyze user behavior on our website and improve our offerings. These include:

• Google Analytics: This tool helps us analyze visitor behavior and compile reports on website activity. Processing is based on your consent under Art. 6(1)(a) GDPR. More information about how Google Analytics works and its privacy measures can be found here.

You can opt out of Google Analytics by installing this browser add-on.

9. Consent for Personal Data and Sensitive Data
By using our website and submitting your data (particularly via forms), you agree to the processing of your personal data in accordance with this privacy policy.
As part of our future personality analysis services, we may process sensitive personal data, such as birth data. These data are classified as special categories of personal data under Art. 9 GDPR and require your explicit consent.
Purpose of Processing: Birth data will be used to gain deeper insights into personality analyses and provide personalized recommendations.
Legal Basis for Processing: The processing of these data will only occur with your explicit consent under Art. 6(1)(a) GDPR and Art. 9(2)(a) GDPR. This consent will be obtained separately before we collect and process your data for such analyses.
To process sensitive data, such as birth data for personality analyses, you will provide your explicit consent by checking the relevant consent box.

Consent Declaration: Before collecting your sensitive data, you will be directed to a separate consent page where you can agree to this specific processing or be prompted to confirm via a consent field on the website or in a form.
Example Consent Field on the Website: “I agree to the processing of my personal data, including sensitive data (e.g., birth data), in accordance with PlamCore’s privacy policy.”

Processing of Sensitive Data (e.g., birth data for personality analyses): As part of future services, particularly personality analyses based on birth data, we will process sensitive personal data. We require your explicit consent before collecting the data.

Purpose of Processing: These sensitive data will be used solely to gain deeper insights for personality analyses and provide you with personalized recommendations. These data will not be shared with third parties without your explicit consent.

Legal Basis for Processing: The legal basis for processing these sensitive data is Art. 6(1)(a) GDPR in conjunction with Art. 9(2)(a) GDPR. We will explicitly and separately obtain your consent before collecting and processing your birth data.

10. Data Transfers to Third Parties
Your personal data will only be disclosed to third parties in the following cases:

• Processors: We work with selected service providers who process data on our behalf (e.g., hosting providers, email service providers). These processors are contractually obligated to process your data only in accordance with our instructions and to comply with security measures.
• Legal Grounds: Disclosure is based on Art. 6(1)(a), (b), and (f) GDPR when it is necessary to fulfill a contract, to protect our legitimate interests, or to comply with legal obligations.

Data Transfer to Third Countries: If data are transferred to third parties in countries outside the European Economic Area (EEA), we ensure that the transfer is carried out in accordance with applicable data protection regulations. We use the European Commission’s standard contractual clauses or obtain your consent.

11. International Data Transfers and Third Country Regulations
Explanation of Standard Contractual Clauses:
When personal data are transferred to countries outside the European Economic Area (EEA) (e.g., the USA or other third countries), we ensure that these transfers are based on the European Commission’s standard contractual clauses or other appropriate safeguards. This protects your personal data and ensures an adequate level of data protection.

Additional Agreements for Third Countries:
In cases where we transfer personal data to countries without a level of data protection comparable to the EU, we will obtain your explicit consent before the transfer (Art. 49(1)(a) GDPR). This consent ensures that you are informed about the risks of such transfers and agree to them.

Data Transfers in Connection with US Services:
If we use US-based service providers, such as cloud providers, payment services, or analytics tools, the data transfer will be based on standard contractual clauses or your explicit consent. These measures ensure that your data are handled in accordance with European data protection standards, even when stored or processed in the USA.

12. Withdrawal of Consent and Rights of the Data Subject
You have the right to withdraw your consent to the processing of your data at any time. Additionally, you have the following rights:

• Right to access information about the personal data we process (Art. 15 GDPR)
• Right to rectification of incorrect data (Art. 16 GDPR)
• Right to deletion (“right to be forgotten”) of your data, provided there are no legal retention obligations (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object to data processing based on legitimate interests (Art. 21 GDPR)
• Withdrawal of Consent: You can withdraw any consent given at any time with future effect. You have the right to withdraw your consent to the processing of sensitive data at any time. The withdrawal can be sent to us via email, and we will cease further processing of your sensitive data. Please note that withdrawal may affect the provision of certain services, particularly personalized offerings such as personality analyses that rely on such sensitive data.

13. Security Measures
We implement technical and organizational security measures to protect your personal data from unauthorized access, loss, or destruction. This includes the use of SSL encryption during data transmission.

14. Data Retention
We store your personal data only as long as it is necessary to fulfill the purposes for which it was collected. After these purposes have been fulfilled, the data will be deleted in accordance with legal regulations.

15. Changes to the Privacy Policy
We reserve the right to update this privacy policy at any time. The latest version can always be found on our website.

16. Consent and Contact
By using our website and submitting your data, you agree to this privacy policy.

Additional Consent for Specific Data Processing

Consent for Processing of Sensitive Data: By agreeing, you give us permission to process your sensitive data (such as birth data) for the purpose of future personality analyses. This consent is voluntary and can be withdrawn at any time. However, without this consent, we may not be able to offer you certain personalized services.

Specific Consent Declarations for Forms
Clear Consent Texts: When collecting sensitive personal data, particularly birth data for personality analyses, an explicit consent field will be included in the relevant forms. This ensures that the user actively agrees to the processing of their data before submitting.

Example Consent Text for Forms: “By submitting this form, I agree that my personal data, including my birth data, may be processed by PlamCore in accordance with the privacy policy for the purpose of personality analyses. I am aware that I can withdraw this consent at any time.”

Consent Checkbox: A consent checkbox will be implemented on the website’s forms, particularly for booking services, where users must actively check the box to confirm their consent to the processing of personal and sensitive data. Without this consent, the use of the corresponding services will not be possible.

This privacy policy was last updated on October 1, 2024.