Privacy Policy

Privacy Policy for our Website

Hereinafter we inform you about the nature, scope and purpose of the processing of your personal data in connection with using our website. Personal data is any information that relates to an identified or identifiable natural person.

1  –  Introduction

In the following, we provide information about the collection of personal data when using

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Sharpist GmbH, Karl-Marx-Straße 58, 12043 Berlin, Germany, email: mail@sharpist.com. We are legally represented by Hendrik Schriefer, Fabian Niedballa.

Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfil a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2  –  Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

We send newsletters with the tools

  • SendGrid of the provider Twilio, Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA (privacy policy: https://www.twilio.com/legal/privacy). The provider processes content, usage, meta/communication data and contact data in the process in the USA.
  • HubSpot of the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: https://legal.hubspot.com/privacy-policy). The provider processes content, usage, meta/communication data and contact data in the process in the EU.

3  –  Data processing on our website

3.1. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2. Web hosting and provision of the website

Our website is hosted by Webflow, Inc. 208 Utah, Suite 210, San Francisco, CA 94103, USA (privacy policy: https://webflow.com/legal/eu-privacy-policy) on the basis of a data processing agreement (Art. 28 GDPR). The provider thereby processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

We use a content delivery network to help provide our website. The provider is Webflow CMS​. The provider thereby processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

3.3. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR.
We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

3.4. Vacant positions

We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.

The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.

3.5. Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfil the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

  • PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxemburg 
  • Stripe Payments Europe, Ltd., Ireland

3.6. Webinars

Interested parties may participate in free webinars. In return for the free webinars, we may contact the interested parties by email and telephone in order to offer them a contract. The legal basis for the data processing is the contract concluded with the participant for the free subscription to the webinar and the use for advertising purposes of their contact data. Participants may object free of charge at any time to the use, e.g. by sending an email to the above-mentioned email address.

3.7. Whitepapers

Interested parties may obtain free whitepapers. In return for providing the free whitepapers , we may contact the interested parties by email and telephone in order to offer them a contract. The legal basis for the data processing is the contract concluded with the interested party for the free subscription of the whitepaper and the use of their contact data for advertising purposes. Participants may object free of charge at any time to the use, e.g. by sending an email to the above email address.

3.8. Demo Accounts

Interested parties can use demo accounts free of charge. In return for the free use, we may process the data of the interested parties in order to offer them a contract. The legal basis for the data processing is the contract concluded with the interested party for the free use of the account and the use of their contact data for advertising purposes.

Participants may object free of charge at any time to the use, e.g. by sending an email to the above email address.

We process the following data:

  • Name and surname
  • Email address
  • Phone number
  • Company name
  • Size of the company
  • Job title
  • Background of interest

3.9. Contractual relationships

If you conclude a contract with us concerning the use of the Sharpist App(whether as a Web App, Mobile App or in any other form), we shall retain the data collected for the offer for the duration of the contractual relationship.

During the ongoing cooperation, contact data of further representatives of your company may be added, e.g. for technical or content-related questions; § 3 par. 3 applies accordingly.

The purpose of processing is the fulfillment of the contract (Article 6 para. 1 s. 1 lit. b GDPR).

We shall delete the data collected in accordance with paragraphs 1-2 as soon as they are no longer required for the fulfillment of the contract in the specific case. Insofar as personal data are contained in contractual documents, commercial letters, invoices or comparable documents or files, we shall delete them as soon as the retention periods under commercial and tax law applicable to them have expired.

We do not take automated decisions on the conclusion of contracts; nor do we use profiling technology.

3.10. Third parties

3.10.1. ​HubSpot​

We use HubSpot for customer relationship management. The provider is HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), content data (e.g. entries in online forms), and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in managing data in a simple and inexpensive way.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://legal.hubspot.com/de/privacy-policy.

3.10.2. ​Weglot​

We use Weglot for translations. The provider is Weglot, 138, rue Pierre Joigneaux in BOIS-COLOMBES (92270), France. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in automatically translating information on our website.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://weglot.com/de/privacy/.

3.10.3. ​Iubenda​

We use Iubenda to manage consents. The provider is iubenda s.r.l, Via San Raffaele, 1 - 20121 Milan, Italy. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. c DSGVO. The legal basis is Art. 6 para. 1 s. 1 lit. c GDPR, as the processing is necessary for the fulfillment of a legal obligation to which we are subject.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.iubenda.com/privacy-policy/94654098.

3.10.4. ​Google Tag Manager​

We use Google Tag Manager and for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3.10.5. ​Google Conversion Tag​

We use Google Conversion Tag for conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en https://support.google.com/tagmanager/answer/9323295?hl=en&ref_topic=3441532.

4  –  Data processing on social media platforms

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

4.1. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

4.2. Xing

We maintain a profile on Xing. The operator is XING AG, Dammtorstraße 29-32, 20354 Hamburg. The privacy policy is available here: https://privacy.xing.com/de/datenschutzerklaerung.

5  –  Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6  –  Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.