The protection of your personal data is very important to us. We treat this topic with a great deal of care and therefore inform you in the following about the handling of your personal data when visiting our website. You can read more about how we approach privacy and security of your data in our Knowledge Base. If you need a Data Processing Agreement with us, please find the already signed version here.

Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. The services of Rows GmbH have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following statements on data protection describe what types of data are collected when accessing our website, what happens with these data and how you may object to data usage.

1. General information on data processing

1.1 Person Responsible (Controller)

Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is: Rows GmbH, Am Märchenbrunnen 5, 10407 Berlin, phone: +49-30-23594633, email: hello@rows.com, website: www.rows.com. We have appointed a data protection officer who can be reached at privacy@rows.com.

1.2 Protection of your data

We have taken technical and organizational measures to ensure that we, as well as external service providers working for us, meet the requirements of the EU General Data Protection Regulation (GDPR). We select external service providers, such as email and hosting providers, in an extensive selection process. In this selection process, we carefully assess providers for their suitability in terms of technical and organizational data protection skills. We only select third- party providers who comply with the requirements of Art. 28 GDPR. We store your information on protected servers. Access to it is only possible for a few authorized employees.

1.3 Deletion of personal data

We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, we delete the data according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

2. Use of data on this website and in logfiles

2.1 Scope

When you visit our website, our web servers temporarily store every access in a log file. The following data is collected and stored until automated deletion:

• IP-address of the requesting computer
• Date and time of access
• Name and URL of the retrieved file
• Message if the retrieval was successful.

We or our partners may process additional data occasionally. You will find information about this below.

2.2 Legal basis

The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) of the GDPR. Our legitimate interest is to make our website accessible for you.

2.3 Purpose

The processing of this data serves: the purpose of enabling the use of the website (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the website. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.

Furthermore, no input of your personal data is required to use our website.

2.4 Duration of storage

As soon as the purpose of the data processing is fulfilled, deletionerasure of the data is carried out. This happens as soon as you close our website. Our hosting service might use data for statistical purposes. Any personal data will be anonymized for this. Our hosting service will delete this data after a period of six weeks.

2.5 Right of objection and deletion

The data processing is necessary in order to present the website and to ensure the website’s operation. Therefore, objecting is impossible.

3. Use of cookies and third-party providers on the website

3.1 Cookies

3.1.1 Scope

Our website is using cookies. Cookies are stored on your computer when you use our website. Cookies are small text files which are stored on your hard drive assigned to your browser which convey data to us or to the party who set the cookie. Cookies cannot run programs on or transmit viruses to your computer. Cookies are used to analyze the use of our website in anonymized or pseudonymized form and to enable personalized advertisements on this website. The following data may be transmitted:

• Frequency of website visits
• Which functions of the website are used by you
• Your cookie-settings
• Language settings
• Items in a shopping basket

When you access our website, a cookie banner informs you about the use of cookies on this website and asks for your consent to the use of cookies. Also, you are pointed to the data privacy statement of this website.

3.1.2 Legal basis

The legal basis for the processing of data by cookies, which only serve the functionality of our website, is Art. 6 para. 1 s. 1 lit. f) GDPR. All other cookies are only set with your consent, Art. 6 para. 1 s. 1 lit. a) GDPR.

3.1.3 Purpose

Our legitimate interests are to provide you with a working website connection and to ensure a comfortable use of this website. Also, we need to process your personal data to solve occurring safety and security issues, as well as to ensure system stability. The data processing takes also place to make a statistical evaluation of our website possible.

3.1.4 Duration of storage

Our website uses transient and persistent cookies:

a) Transient cookies are automatically deleted when you close the browser. This is especially true for session cookies which store your session ID, with which various requests from your browser can be assigned to your session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser. b) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie.

3.1.5 Right to objection and deletion

You have the possibility to revoke your consent to the data processing through cookies, which do not only serve the functionality of the website. In addition, we do not set cookies until you have agreed to set cookies when you visit the site. In this way, you can prevent data processing via cookies on our website. You can also delete the cookies in your browser's security settings at any time. Please note that you may not be able to use all the features of this website. The setting of cookies can also be prevented at any time by appropriate settings in your internet browser.

3.2 Google Analytics

3.2.1 Scope

Our website uses Google Analytics. This is a service of Google Inc. ("Google") to analyze access to websites and allows us to improve our website. Data processing for the European Economic Area and for Switzerland is carried out by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Cookies enable us to analyze your use of our website. The information collected by a cookie are:

• IP address
• Access time
• Access Duration

The information is transmitted to a Google server in the USA and stored there. The evaluation of your activities on our website is transmitted to us in the form of reports. Google may pass on the collected information to third parties, if required by law or if third parties process this data on behalf of Google. The Google tracking codes of our Internet offer use the function "_anonymizeIp ()", thus IP addresses are processed only shortened, in order to exclude a possible direct personal link to you.

Under https://www.google.de/intl/de/policies/ as well as under http://www.google.com/analytics/terms/de.html you can find out more about the terms of use and privacy policy of Google Analytics.

3.2.2 Legal basis

Legal basis for data processing is your consent, Art. 6 para 1 s. 1 lit. a) GDPR.

3.2.3 Purpose

By processing the data, we can analyze how our website is used, so we can improve it for our users. We protect your data by using only anonymized IP addresses.

3.2.4 Duration of storage

The data will be deleted after 26 months or 26 months after your last website visit.

3.2.5 Right to objection and deletion

You have the option to revoke your consent at any time. To do this, please contact our data protection officer. You can prevent the installation of cookies by Google Analytics in your browser settings. In this case, however, it may happen that you cannot fully use all features of our website. Also, through browsers extensions e.g. http://tools.google.com/dlpage/gaoptout?hl=de Google Analytics can be disabled and controlled.

3.3 Google G-Suite and Google Cloud

3.3.1 Scope

We use Google Cloud as our hosting service provider. We also use Google G-Suite to use Google office applications, incl. for email traffic. The data processing for the European Economic Area and for Switzerland is carried out by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

All data sent or received is also stored by Google Inc.

For more information, see Google's privacy policy: https://policies.google.com/privacy?hl=de

3.3.2 Legal basis

The data processing is based on Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest lies in making our services accessible to and perform well for you.

3.3.3 Purpose

We use Google Cloud to host all your account data and all data you enter and store in your spreadsheets. Google G-Suite enables us to manage our organization efficiently across multiple processes and devices. We use the services for internal and external communication as well as for project management. For our website, we use Google Sites to easily create and edit web pages.

3.3.4 Duration of data storage

The data will be deleted as soon as the purpose of the data processing has been fulfilled and no contractual, official or legal retention periods prevent deletion.

3.3.5 Right of objection and deletion

Since the service is used for the organizational management of our website, you cannot remove it. Irrespective of this, you can contact us or Google at any time and exercise your rights, in particular the right to deletion of data. As far as data stored in your spreadsheets is concerned, you can delete is yourself in your account at any time.

3.4 Customer.io

3.4.1 Scope

We use Customer.io services to send contextual emails, for your onboarding and our newsletter. The data processing is carried out by:

Peaberry Software Inc. d/b/a Customer.io, 921 Washington Street, Suite 820, Portland, PRe., 97205 USA.

The personal data (e-mail, first name and last name) that you have provided to us when you registered for the newsletter will be forwarded to the servers of Peaberry Software Inc. in the USA and stored there. European Court of Justice considers that the data protection standard in the US is inadequate and that there is a risk that your data will be processed by US authorities for control and monitoring purposes, possibly without any redress. You can withdraw your consent at any time.

For more information, see customer.io's Privacy Policy: https://customer.io/legal/privacy-policy/ and https://customer.io/legal/dpa/.

3.4.2 Legal basis

This data processing is legally based on our legitimate interests in efficiently and safely sending our newsletter, Art. 6 para. 1 s. 1 lit. a) GDPR.

3.4.3 Purpose

We use customer.io as our sub-processor to support your effective onboarding to our services and to send newsletters to stay in touch with you.

3.4.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal, contractual or official regulations prevent deletion.

3.4.5 Right to objection and deletion

You have the option to revoke your consent at any time. To do this, please contact our data protection officer. In order to unsubscribe from our newsletter, you can do so in any newsletter email by clicking on the unsubscribe link.

3.5 Segment

3.5.1 Scope

Segment is a tool for user data collection and its integration with our website analysis tools. The data processing is carried out by:

Segment.io Inc., 100 California Street Suite 700 San Francisco, CA 94111, USA.

The data processing for the European Economic Area and for Switzerland is carried out by:

Segment Technologies Ireland, Limited, 3rd Floor, Kilmore House, Park Lane, Spencer Dock, Dublin 1, Ireland.

Segment uses cookies and similar technologies to enable cross-device tracking through a unified user ID. This service helps us to analyze data collected when using our services and to use other third-party tools described in this Privacy Policy, notably customer.io, for your effective onboarding. The IP address is truncated after the collection and all other data is processed pseudonymously. Additional information on Segment data processing can be found at: https://segment.com/legal/privacy/.

3.5.2 Legal basis

The legal basis for data processing is your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.

3.5.3 Purpose

We use Segment as our sub-processor to support your effective onboarding to our services and to send newsletters to stay in touch with you.

3.5.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal, official or contractual regulations prevent deletion.

3.5.5 Right to objection and deletion

You have the possibility to revoke your consent to the data processing at any time. For this purpose, please contact our data protection officer. If you have any questions about data protection at segment.io, you can contact Segment at the following e-mail address: privacy@segment.com.

3.6 Adyen

3.6.1 Scope

We use Adyen to process online payments. Data processing is carried out by:

Adyen N.V. German Branch, Friedrichstraße 63, 10117 Berlin, Germany.

If you want to pay with your credit card, Adyen process the following data:

• Credit card number
• Name of credit card holder
• Credit card validity

Your credit card information is not stored by us and is directly transmitted to Adyen via an encrypted connection. For more information: https://www.adyen.com/de_DE/richtlinien-und-haftungsausschluss/privacy-policy

3.6.2 Legal basis

The legal basis for the data processing is Art. 6 para. 1 s. 1 lit. b) GDPR. The processing of your data is required for payment by credit card.

3.6.3 Purpose

The transmission of the data is necessary to prevent any possible misuse and use the data after successful verification to process the agreed payment by credit card.

3.6.4 Duration of storage

Adyen process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, deletion of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

3.6.5 Right to objection and deletion

Data processing is mandatory in order to process your payment, so it cannot be waived if you have chosen this payment method. Therefore, objecting is impossible. If you have any questions about data protection or would like to exercise your rights, please contact our Data Protection Officer or use the following e-mail address to contact Adyen: dpo@adyen.com

3.7 Chargebee

3.7.1 Scope

We use Chargebee for invoicing. The data processing is carried out by:

Chargebee Inc., 340 S Lemon Avenue, #1537, Walnut, California, USA.

If you sign up for a paid plan of our services, you will enter billing information. If necessary for the performance of the contract, data will also be transferred to our payment service provider or the credit institution entrusted with the payment processing. The scope of the data is limited to the minimum required for the purpose of contract processing.

The following data might be processed:

• Account information
• First name
• Last name
• E-mail address
• Phone number
• Organization address
• Billing address
• IP address
• Billing information
• First name
• Surname
• E-mail address
• Company name
• Phone number
• Billing address (company address, city, postal code, state, country)
• VAT identification number
• Credit card information
• First name
• Surname
• Full PAN and card address
• Expiration date
• CCV number
• Custom fields

By using Chargebee, data will be processed in the United States. The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress. For more information on Chargebee's privacy, please visit: https://www.chargebee.com/privacy/

3.7.2 Legal basis

We process this data for the purpose of processing your order. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. b) GDPR.

3.7.3 Purpose

The service processes data to complete payment transactions and enableprocess invoicing. They are also used to reflect the business relationship with us and to meet financial, regulatory and other obligations.

3.7.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal, official or contractual regulations prevent deletion.

3.7.5 Right to objection and deletion

Data processing is mandatory in order to process your payment by credit card, so it cannot be waived if you wish to make a purchase. If you have any questions about data protection or would like to exercise your rights, please contact our Data Protection Officer or use the following e-mail address to contact Chargebee: privacy@chargebee.com

3.8 Help Scout

3.8.1 Scope

We use Help Scout as a customer service software provider to offer a better customer support by connecting customers to our support team faster and hence, solving their requests faster and more effectively. The data processing is carried out by:

Help Scout Inc., 22 Merchants Row Boston, MA 02109, USA.

If necessary data will be transferred to our customer support provider. The scope of the data is limited to the minimum required for the purpose of contract processing. Additional information on Help Scout’s data processing can be found at: https://www.helpscout.com/company/legal/privacy/.

By using Help Scout, data will be processed in the United States The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress.

3.8.2 Legal basis

We process this data for the purpose of processing your order. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. b) GDPR.

3.8.3 Purpose

The service processes data to fulfill the customer support function in handling customer requests and connecting them with our customer support team.

3.8.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal, official or contractual regulations prevent deletion.

3.8.5 Right to objection and deletion

Data processing is mandatory in order to provide you a scalable customer support, so it cannot be waived if you wish to use our product and services. If you have any questions about data protection or would like to exercise your rights, please contact our Data Protection Officer or use the following e-mail address to contact Help Scout at: privacy@helpscout.com

3.9 SparkPost

3.9.1 Scope

We use SparkPost as an email intelligence tool for the signup and password recovery process of our users and customers. The data processing is carried out by:

SparkPost Inc., 9160 Guilford Rd, Columbia, MD 21046, USA.

If necessary data will be transferred to our service provider. The scope of the data is limited to the minimum required for the purpose of contract processing. Additional information on SparkPost’s data processing can be found at: https://www.sparkpost.com/policies/privacy/.

By using SparkPost, data will be processed in the United States The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress.

3.9.2 Legal basis

We process this data for the purpose of processing your order. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. b) GDPR.

3.9.3 Purpose

The service processes data to ensure the signup and password recovery function.

3.9.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal, official or contractual regulations prevent deletion.

3.9.5 Right to objection and deletion

Data processing is mandatory in order to process signups on our website and password recovery requests, so it cannot be waived if you wish to make a purchase. If you have any questions about data protection or would like to exercise your rights, please contact our Data Protection Officer or use the following e-mail address to contact SparkPost at: privacy@sparkpost.com.

3.10 Stripe

3.10.1 Scope

We use Stripe to process online payments. Data processing is carried out by:

Stripe, Inc., 510 Townsend St, San Francisco, USA.

Data processing for the European Economic Area and for Switzerland is carried out by:

Stripe Payments Europe, Ltd., C/O A & L Goodbody, Ifsc, North Wall Quay Dublin D01 H104, Ireland.

If you want to pay with your credit card, Stripe process the following data:

• Cardholder name
• Email address
• Unique customer identifier
• Order ID
• Bank account details
• Payment card details
• Card expiration date
• CVC code
• Date/time/amount of transaction
• Merchant name/ID
• Location

We check this personal data with the data of your order to detect an abusive use of the credit card or the payment possibility with credit card. Hereafter we will use the data to settle the agreed payment by credit card.Your credit card information is not stored by us and is directly transmitted to Stripe via an encrypted connection.

For more information: https://stripe.com/de/privacy

3.10.2 Legal basis of data processing

The legal basis for the data processing is Art. 6 para. 1 s. 1 lit. b) GDPR. The processing of your data is required for payment by credit card.

3.10.3 Purpose of data processing

The transmission of the data is necessary to prevent any possible misuse and use the data after successful verification to process the agreed payment by credit card.

3.10.4 Duration of storage

Stripe processes personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, deletion of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

3.10.5 Right to objection and deletion

Data processing is mandatory in order to process your payment, so it cannot be waived if you have chosen this payment method. Therefore, objecting is impossible. If you have any questions about data protection or would like to exercise your rights, please contact our Data Protection Officer or use the following e-mail address to contact Stripe: dpo@stripe.com

4. Registration on the website

4.1 Scope

You can create an account on our website. This requires the data subject to enter personal data in the registration form. The following data is at least collected for this:

• First name
• Last name
• Email address.

Agree to the Rows Terms and have taken note of the privacy policy.

The information provided by the data subject in the registration mask will be used exclusively for processing and will not be disclosed to third parties.

4.2 Legal basis

If the data subject enters mandatory personal data in the registration form, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. However, if the user also enters personal data in optional input field, the data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

4.3 Purpose

The processing of personal data is used solely for us to finish your registration and organize your Rows account.

4.4 Duration of storage

The data is deleted as soon as the purpose of storage is no longer required. This is the case if you delete your account and no statutory or regulatory retention periods of deletion contradict.

4.5 Right to objection and deletion

During and after the registration, the data subject is free to change, correct or delete their personal data by sending an email to hello@rows.com or legal@rows.com or privacy@rows.com.

5. Newsletter

5.1 Scope

On our website visitors can subscribe to our newsletter. When signing -up to receive a newsletter, we ask for your email address, your first and your last name. This data is necessary to send you the newsletter.

The newsletter will be sent via email only after the sign-up process is completed. In order to meet the requirements of the GDPR, we use DOI (Double Opt-In). If you sign up for our newsletter, we will send a confirmation email to the address you provided us with. This email contains a confirmation link that you must click to complete the sign-up process. Following this procedure, the IP address, date and time of login are stored. This is done to prevent abuses. We won’t transfer the data to third parties.

5.2 Legal basis

This processing is legally based on Art. 6 para. 1 s.1 lit. a) GDPR, i.e. your consent.

5.3 Purpose

The newsletter has the functions of informing you about offers and news on a regular basis.

5.4 Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, deletion of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

5.5 Right to objection and deletion

The consent to receiving the newsletter can be revoked by you at any time. For this purpose, you can click the integrated link in each newsletter to unsubscribe. It is also possible to inform us about the revocation of the consent in any other way, e.g. via mail or email.

6. Payments and billing

6.1 Scope

When you sign up for a paid plan and/or edit your billing information on our website, we will process your first name and last name, address, telephone number, email address and VAT identification number (optional) to complete the purchase agreement with you.

6.2 Legal basis

This processing is legally based on Art. 6 para. 1 s.1 lit. b) GDPR. We are processing your data for the fulfilment of purchase contracts and supply agreements.

6.3 Purpose

We process your data to close the contract, to handle the payment and for billing.

6.4 Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, the data will be deleted according to the standards of the erasure concept - unless legal or contractual regulations oppose this.

6.5 Right to objection and deletion

The data processing is necessary to process your purchase contract, which is why it cannot be waived. Hence, there is no option to object.

7. Contact

7.1 Scope

Via our website you can contact us via email. This will require different data to answer the request, which will be automatically saved for processing. Your data will not be passed on to third parties, unless you have given your consent.

7.2 Legal basis

This processing is legally based on Art. 6 para. 1 s. 1 lit. b) GDPR.

7.3 Purpose

The processing of personal data from the input form is solely used for handling the contact request.

7.4 Duration of storage

Your data will be deleted as soon as the purpose of the data collection has been fulfilled and no legal, contractual or official regulations prevent deletion.

7.5 Right to objection and deletion

You have the right to withdraw your consent to the processing of personal data at any time. By contacting us, you can object to the storage of your personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.

8. Data processing of job applications

8.1 Scope

We offer the opportunity to apply for jobs by email (join@rows.com). For this purpose, personal data is processed and stored for further processing during the respective application process.

8.2 Legal basis

This processing is legally based on Art. 88 GDPR and § 26 BDSG (2018).

8.3 Purpose

We process your data exclusively for the purpose of carrying out the application process.

8.4 Duration and storage

In case of successful application and employment, your personal data is stored in accordance with the legal requirements. In case of unsuccessful application, your personal data will be deleted in accordance with the rules of the local erasure concept. In doing so, the provisions of the AGG (German Employment Law), especially the existing evidence pursuant to § 22 AGG, are taken into account.

This does not apply if we are obliged to any legal deletion periods or if you have given consent to store your personal data for further communication with us (e.g. we have another suitable job in the future). If you have given consent, the legal basis for further storage of your data is legally based on Art. 6 para. 1 s. 1 lit. c) or lit. a) GDPR.

8.5 Right to objection and deletion

You can contact us at any time and object to further processing of your data. All personal data of the application process will be deleted in this case.

9. Forum

9.1 Scope

Rows runs a user forum on forum.rows.com, in which our users can post comments and questions. Other users can reply to these posts, and the forum and each post are publicly visible on the internet. If the user publishes a comment in the forum, the time of publication, the username (or account) are stored and published in addition to the comment content. The IP address of the user is also saved. This happens for security and quality assurance reasons in order to protect the blog posts against abuse. Our blog is hosted by a subprocessor. Data processing is carried out by:

Civilized Discourse Construction Kit, Inc., 410 Clayton Avenue, El Cerrito, California 94530, USA.

By using our forum, you agree in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR that your data will be processed in the United States. The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress. If you only agree to set essential cookies, the transmission will not take place. Consent given may be revoked at any time.

The processor has signed a data processing agreement with Rows. For more information on Discourse's handling of your privacy, please visit: https://www.discourse.org/privacy.

The following data is mandatory to comment:

• Username
• Email address

The following data is optional:

• First name
• Last name
• Comment’s content
• Time of comment
• Avatar (image)

9.2 Legal basis

The processing is based on our legitimate interests, Art. 6 para. 1 s. 1 lit. f) GDPR. All data that you disclose in the context of the commenting function are given voluntarily. Therefore, the legal basis is your consent., Art. 6 para. 1 s. 1 lit. a) GDPR.

9.3 Purpose

We collect this data to ensure the stability and usability of our forum and app, and to prevent misuse of the comment function. This is our legitimate interest. The commenting function shall encourage a mutual exchange of our users’ opinions.

9.4 Duration of storage

Your data will be deleted as soon as the purpose of the data processing has been achieved and no legal, contractual or official regulations prevent deletion.

9.5 Right to objection and deletion

You have the right to object to the data processing, Art. 21 GDPR. When doing so, we will carefully examine your reasons of objection and will either stop or adjust the processing or will inform you why our legitimate interests outweigh your reasons for objection. Furthermore, you can delete your posts yourself when logged in to your account.

10. Social media on our website

We integrated social media platforms on our website via links, which may result in social media providers receiving data from you if necessary. We will break this down for you in the following.

10.1 Twitter

10.1.1 Scope

The Twitter link can be found on the website. Data processing is carried out by:

Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

If you click on the Twitter link, the website of Twitter will be opened. By entering the website of Twitter through our website, Twitter receives the information that you have visited our website.

By clicking on the link, data will be processed in the United States by Twitter. The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress.

For more information on Twitter's handling of your privacy, please visit: https://twitter.com/privacy?lang=de

10.1.2 Legal basis

This processing is legally based on Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interests are to provide information about our company and to keep in contact with our customers and prospective customers.

10.1.3 Purpose

We use social media to promote our company. We also want to give you the opportunity to interact with social media through our website.

10.1.4 Duration of storage

According to Twitter, data will be deleted after a maximum of 30 days. Twitter does not endeavour to collect data from browsers that Twitter believes are in the European Union or in European Free Trade Association (EFTA) countries.

10.1.5 Right to objection and deletion

Other settings and disagreements regarding the use of data for advertising purposes are possible within the Twitter profile settings or via the US page or the EU page of Twitter. The settings are platform independent and adopted for all devices, such as desktop computers or mobile devices.

10.2 YouTube

10.2.1 Scope

We have integrated the services of YouTube on our website. Data processing is carried out by:

YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

Data processing for the European Economic Area and for Switzerland is carried out by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

By clicking on the link, data will be processed in the United States by Google. The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress.

If you click on the YouTube link, a website of YouTube will be opened. This might also happen in the form of a small window in our website (a so-called iframe). By accessing YouTube's website through our website ("per click"), YouTube receives the information that you have visited our website.

For more information on YouTube's handling of your privacy, please visit: https://policies.google.com/privacy?hl=en&gl=de.

10.2.2 Legal basis

This processing is legally based on The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our company better known.

10.2.3 Purpose

We use social media to promote our company. We also want to give you the opportunity to interact with social media through our website.

10.2.4 Duration of storage

Data collected by YouTube (Google) will be deleted by the controller after a fixed retention period of 9 to 18 months.

10.2.5 Right of objection and deletion

Additional settings and objections on the use of data for promotional purposes are available within the YouTube Profile settings.

10.3 GitHub

10.3.1 Scope

We have integrated the services of GitHub on our website. Data processing is carried out by:

GitHub, Inc., 88 Colin P. Kelly Street, San Francisco, CA 94107, USA.

Data processing for the European Economic Area and for Switzerland is carried out by:

GitHub BV, Vijzelstraat 68-72, 1017 HL Amsterdam, The Netherlands.

If you click on “Join Rows” at “About”, the website of GitHub will be opened. By entering the website of GitHub through our website, GitHub receives the information that you have visited our website.

By clicking on the link, data will be processed in the United States by GitHub. The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress.

For more information on GitHub's handling of your privacy, please visit: https://docs.github.com/en/github/site-policy/github-privacy-statement#what-information-github-collects

10.3.2 Legal basis

The processing is legally based on Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our company better known and to attract more applicants.

10.3.3 Purpose

We use social media to promote our company. We also want to give you the opportunity to interact with social media through our website.

10.3.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal, official or contractual regulations prevent deletion. Regularly, deletion takes place 30 days after your deletion request.

10.3.5 Right of objection and deletion

Additional settings and objections on the use of data for promotional purposes are available within the GitHub Profile settings.

10.4 Blog

10.4.1 Scope

We offer a blog through the provider Medium Corporations. A Medium Corporation is a blog that enables users to share and experience knowledge, ideas and stories. Data processing is carried out by:

A Medium Corporation, 760 Medium Street San Francisco, CA 94102, USA.

Data processing for the EEA, Switzerland or the United Kingdom is carried out by:

VeraSafe Ireland, Ltd. Unit 3D North Point House, North Point Business Park, New Mallow, Road Cork T23AT2P, Ireland.

If you click on “Blog”, our blog on the website of Medium will be opened. By entering the website of Medium through our website, Medium receives the information that you have visited our website.

By clicking on the link, data will be processed in the United States by Medium. The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress.

For more information on Medium's handling of your privacy, please visit: https://policy.medium.com/medium-privacy-policy-f03bf92035c9

10.4.2 Legal basis

The processing is legally based on Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our company better known and in enabling our users to participate in an active and fair community.

10.4.3 Purpose

We use social media to promote our company. We also want to give you the opportunity to interact with social media through our website.

10.4.4 Duration of storage

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal, official or contractual regulations prevent deletion.

10.4.5 Right to objection and deletion

Additional settings and objections on the use of data for promotional purposes are available within the YouTube Profile settings. For questions about data protection at Medium or to exercise your rights, please contact Medium at: privacy@medium.com

11. Service providers from third countries

To provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR).

Adequate level of protection: The provider comes from a country whose level of data protection has been recognized by the EU Commission. For more information, see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF

Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR.

Consent: In addition, a transfer of data to a third country without adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.

12. Your rights

You have the following rights with respect to the personal data concerning you:

12.1 Right to withdraw a given consent (Art. 7 GDPR)

If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.

12.2 Right of access (Art. 15 GDPR)

You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:

• the purpose of processing;
• the categories of personal data concerned;
• the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations;
• where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
• all available information on the source of your personal data;
• the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

In the case of such a request, you must provide enough information about your identity to prove that the request concerns your own personal data.

12.3 Right to rectification and deletion (Art. 16, 17 GDPR)

You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.

You may also request the deletion of your personal data if any of the following applies to you:

• the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;
• you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;
• you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;
• the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.

Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we shall take reasonable steps while taking into account available technology and the cost of implementation and including technical measures to inform controllers which are processing the personal data that you have requested to be deleted by such controllers of any links to, or copy or replication of, those personal data.

These rights shall not apply to the extent that processing is necessary:

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health in accordance of Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or.
• for the establishment, exercise or defence of legal claims.

12.4 Right to restriction of processing (Art. 18 GDPR)

You shall have the right to obtain from us restriction of processing where one of the following applies:

• the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the deletion of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.

Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of 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 limitation of the processing is restricted, you will be informed by us before the restriction is lifted.

12.5 Right to information (Art. 19 GDPR)

If you have asserted your right to rectification, deletion or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.

You also have the right to know which recipients have received your personal data.

12.6 Right to data portability (Art. 20 GDPR)

You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where

• the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and
• the processing is carried out by automated means.

In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.

12.7 Right to object (Art. 21 GDPR)

Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue with the data processing.

12.8 Right to lodge a complaint with supervisory authority (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.

12.9 How to exercise your rights

To exercise these rights you may contact us, for example via email to privacy@rows.com.

13. Subject to change

We reserve the right to change this privacy policy in compliance with legal requirements.

November 2020