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Data protection

1. Controllers

We, refive GmbH (hereinafter also “refive”, “we”, “us”), would like to inform you about the processing of your personal data when you visit our website / app www.refiveapp.com / refive.io / stammi.de (“Website”).

If you have further questions about data protection in connection with our website or the services offered, please contact the following address:

Contact details for exercising the rights of data subjects: support@refive.io

refive GmbH Angermünder Str. 12 10119 Berlin

2. Scope, purpose and legal basis of the processing of personal data

We collect and use personal information directly from our users and other sources (identified below) in the following situations:

2.1. Provision of website and log file creation

When visiting our website, the system automatically records data and information about the user’s computer system each time the website is accessed. The following data (“technical information”) is recorded:

  1. Information on browser type and version used
  2. The user’s operating system
  3. The user’s internet service provider
  4. The user’s IP address
  5. Date and time of access
  6. Websites from which the user’s system accesses our website
  7. Websites that the user’s system can access through our website

The data is also stored in the log files of our system. These data are not stored together with other personal data of the user. We collect and use this technical information for (network) security purposes (e.g. to defend against cyber attacks), for marketing and to better understand the needs of our users and to continuously improve our website and enable access to the website from their computers.

The data is stored in log files to ensure the functionality of the website. The data also helps us to improve the website and secure our information technology systems. In this context, the data will not be evaluated for marketing purposes. Art. 6 (1) (f) The GDPR forms the legal basis for the temporary storage of the data and log files.

2.1.1. Use of cookies

Our website uses cookies. Cookies are text files that are stored in the web browser or by the web browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a unique character string that enables the browser to be uniquely identified when the website is called up again.

Cookies are stored on the user’s computer, which transmits them to our website. Therefore, users have full control over the use of cookies. You can disable or restrict the transmission of cookies by changing your web browser settings. Previously saved cookies can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, you may no longer be able to use all functions.

2.1.2. tracking tools

Google Analytics (visitor measurement on the website);

Link for more information: https://www.google.com/analytics

Segment.io – Data Hub Service for statistical evaluation of user behavior (website and app);

Link for more information: https://segment.com/product

Amplitude.com – behavioral platform for product analytics;

Link for more information: https://amplitude.com/behavioral-analytics-platform

Our legitimate interest according to Art. 6 (1) (f) GDPR to increase the efficiency of our website and (direct) marketing is the legal basis for using the listed tools.

2.1.3. Social Media Plugins

On our website we use a “two-click solution” for the following social media plugins:

  • Facebook
  • GooglePlus

With the two-click solution, your data will only be saved after the first activation (approval) of the respective plug-in button, Art. 6 (1) (a) GDPR. The basic configuration of the plugin on our website is based on our legitimate interest for marketing purposes, Art. 6 (1) (f) GDPR.

2.2. Use of the services offered on our website and in the app

We offer various services on our website. For this purpose we need to collect and process personal data from users or customers.

2.2.1 Newsletters / Mailjet

In connection with the processing of data for sending newsletters, there is no transfer to third parties. The data will only be used to send the newsletter. The legal basis for processing the data after the user has registered for the newsletter is the user’s consent. Art. 6 para. 1 lit. a GDPR.

2.3. Our legitimate interest in processing personal data

If Art. 6 (1) (f) GDPR forms the legal basis for the processing. In addition to the above purposes, our legitimate interests include: To protect the company from material and immaterial damage Professionalism (of our products and services) Cost optimization (control and minimization)

2.4. Obligation to provide personal data

The input fields to be filled in to perform the requested service are marked accordingly on the website. Entry is mandatory due to legal or contractual requirements.

3. Duration of data processing

Your personal data will be deleted as soon as they are no longer required for the stated purposes. Under certain circumstances, personal data is stored for the period in which claims can be asserted against refive GmbH (statutory limitation period of three to thirty years). Personal data is also stored to the extent that and to the extent that refive GmbH is legally obliged to do so. Corresponding evidence and storage obligations result from the Commercial Code, tax legislation and the Money Laundering Act, among other things. These prescribe retention periods of up to ten years.

4. Right of objection according to Art. 21 GDPR

You have the right to object at any time to the processing of personal data relating to you on grounds relating to your particular situation based on Article 6 letter e or f (1) GDPR including profiling based of these provisions.

The controller will no longer process your personal data unless the controller has compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defense of legal claims required. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data, including profiling, where it is related to such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes. In connection with the use of information society services, notwithstanding Directive 2002/58 / EC, you can exercise your right of objection in an automated manner with technical specifications.

5. Disclosure of Personal Information to Third Parties

In order to be able to offer our products and services to you, based on our contractual obligations or in line with our legitimate interests, we may need to disclose your personal data to third parties inside or outside refive gmbH. These recipients can be classified as follows:

refive GmbH

Personal data can be transmitted to third countries or international organizations. For your protection and to protect your personal data, suitable protection mechanisms for such data transmissions are provided in accordance with the statutory provisions (in particular the use of EU standard contractual clauses) or an adequacy decision has been issued by the EU Commission (Article 45 GDPR).

Information on the EU standard contractual clauses can be found at [https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en] A copy of the security measures used can also be requested from .

We are also legally obliged to provide personal data to German and international authorities. 6 (1) (c) GDPR together with local and international regulations and agreements.

6. Rights of data subjects

refive GmbH is committed to fair and transparent processing. It is therefore important to us that the data subjects can not only exercise their right to object, but also the following rights if the respective legal requirements are met:

  • Right of access, Art. 15 GDPR
  • Right to rectification, Art. 16 GDPR
  • Right to erasure (“right to be forgotten”), Art. 17 GDPR
  • Right to restriction of processing, Art. 18 GDPR
  • Right to data portability, Art. 20 GDPR

To exercise your right, please send an email to info@refive.io . In order to process your request and for identification purposes, please note that we process your personal data in accordance with Art. 6 (1) (c) GDPR. You also have the right to lodge a complaint with a supervisory authority. The competent supervisory authority of refive GmbH is:

Berlin Commissioner for Data Protection and Freedom of Information

Friedrichstr. 219 Visitor entrance: Puttkamerstr. 16 – 18 (5th floor) 10969 Berlin Telephone: 030 13889-0 Fax: 030 2155050 Email: mailbox@datenschutz-berlin.de

7. Consent

If you give us your consent to process your personal data, please note that you can withdraw this consent at any time. If you gave this consent on the website, please visit the page where you originally gave your consent or log in to withdraw consent in settings.

If you have agreed to receive our newsletter, you can withdraw this consent by using the “unsubscribe” link in the newsletter. In all other cases or in case of problems with the withdrawal of your consent on the website, you can contact info@refive.io .

Please note that your consent can only be withdrawn with effect for the future and that such withdrawal will not affect the lawfulness of previous processing. In some cases, despite your revocation, we may be entitled to continue processing your personal data on another legal basis, e.g. B. for contract processing.

8. Disclaimer and Limitations of this Privacy Notice

These data protection notices only apply to the processing of the websites refive.io, get.refive.io, www.refiveapp.com. Other websites are not covered by this privacy notice and their own websites provide specific privacy notices.

Appendix – Notes on Social Media Plugins

refive GmbH uses remarketing services to advertise to you on third party websites after you have visited our service. We and our third parties use cookies to inform, optimize and serve ads based on your previous visits to our service.


Google AdWords remarketing service is provided by Google Inc. provided. You can opt out of Google Analytics for Display Advertising and customize Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics browser add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. The Google Analytics Options browser add-on gives visitors the ability to prevent their data from being collected and used by Google Analytics. If IP anonymization is activated on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the agreement in the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

For more information about Google’s privacy practices, visit the Google Privacy Policy and Terms of Service website: http://www.google.com/intl/de/policies/privacy/


Facebook remarketing service is provided by Facebook Inc. provided. You can learn more about Facebook’s interest-based advertising by visiting this page: https://www.facebook.com/help/164968693837950 Follow these instructions from Facebook to opt out of interest-based Facebook ads: https://www.facebook.com/about/ads/#568137493302217

Facebook adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. You can also opt out of Facebook and other participating companies through the Digital Advertising Alliance in the US http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or opt out of the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or disable them using your mobile device settings.

For more information on Facebook’s privacy practices, see Facebook’s privacy policy: https://www.facebook.com/privacy/explanation


Mailjet’s email marketing service is provided by Mailjet GmbH. Further information on the e-mail marketing solution can be found on this page: https://www.mailjet.de By registering with refive you will receive email information and an email newsletter. We use MailJet services to manage mailing lists and send newsletters. Subscribers to the newsletter collect the IP address, the emails you open and the links you click on in those emails so that we can better recommend and optimize content. It is therefore important that we provide MailJet with your email address, first name and last name (if the latter is provided). First and last name are used for the personal address in the mail. MailJet’s data protection declaration can be found under the following link: https://www.mailjet.de/privacy-policy/


Segment Data Hub Service is provided by Segment.io, Inc. made available. This service supports us in analyzing user behavior, which can improve the user experience. You can find more information about the Data Hub Service on this page: https://segment.com Segment’s privacy policy can be found at the following link: https://segment.com/docs/legal/privacy/

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. IP anonymization is activated for this website, ie your IP address will be shortened beforehand by Google within the European Union or in another state party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there.

Google will use this information as a processor according to Art. 28 DS-GVO to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can prevent the storage of cookies by setting your browser software accordingly. You can prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the available browser plug-in. Alternatively, you can also set a so-called opt-out cookie, which will prevent your data from being recorded when you visit this website in the future.

Google Dynamic Remarketing

On this website, Google Dynamic Remarketing, a web analysis service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”) collects and stores data from which usage profiles are created using pseudonyms. For this purpose, cookies are used in the user’s browser, which collect and analyze data on user behavior. This technology enables users who have already visited a website or online service to see targeted advertising on other websites in the Google partner network. Personal data stored by setting the cookie are stored and processed in pseudonymised form.

Users who do not wish to receive interest-based advertising can disable the use of cookies by Google for these purposes by following the instructions at https://www.google.de/settings/ads/onweb#display_optout .

Google Tag Manager

This website also uses the Google Tag Manager. Website tags can be managed with this service. Google Tag Manager only sets up tags – tags are code used to measure visitor traffic and behavior. The tags come from Google Analytics (see above). These tags are only managed via the Google Tag Manager, no cookies are set and no personal data is collected. If tracking has been deactivated , this also applies to all tracking tags managed with Google Tag Manager.

Google Ads

This website uses Google’s “Ads Conversion” tool to track which users click on an ad placed by Google. Users are not identified by name. The conversion cookies are valid for 30 days. If the user visits certain pages of the Ads customer’s website and the cookie has not yet expired, Google and the respective customer can recognize that the user clicked on the ad and was redirected to this page. Each AdWord customer receives an individual cookie, so it is not possible to track users across the websites of other Ads customers. The cookie is used to create conversion statistics in “Google Ads”. These statistics record the number of users who clicked on one of the ads. In addition, it is counted how many users have reached a target page that has been provided with a “conversion tag”. However, the statistics do not contain any data that could be used to identify individual users. Users can prevent the storage of cookies on the hard drive by selecting “do not accept cookies” in their browser settings (in MS Internet Explorer under “Extras > internet options > privacy > Attitude”; in Firefox under “Extras > settings > privacy > Cookies”); In this case, however, not all functions of the website may be fully usable. More information about how Google uses conversion data and Google’s privacy policy is available at: https://support.google.com/adwords/answer/93148?ctx=tltp http://www.google.de/policies/privacy/


This website uses the DoubleClick tracker, an analysis service provided by Google. The technology is used to transmit information about the use of the website (e.g. IP address of the site visitor, search terms used) so that interest-based advertisements can be placed and displayed for visitors to this and other websites. A pseudonymous identification number (ID) is assigned to your browser in order to check which ads have been displayed in your browser and which ads have been viewed. The use of the DoubleClick cookie enables Google to place targeted ads based on previous visits to this or other websites. Users can prevent the cookies used in this tool from being saved by setting their browser accordingly, by deactivating the execution of Java Script in your browser or by installing a tool such as ‘NoScript’.

Users can also prevent the processing of the data generated by the cookies and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available under the following link: https:// www.google.com/settings/ads/plugin?hl=de


This website uses Hotjar, an analysis service provided by Hotjar Ltd. (“Hotjar”) ( http://www.hotjar.com , 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta). Hotjar technology is used to transmit information about the use of the website (e.g. how much time users spend on which pages, which links they click, what they like and don’t like, etc.). This information is used to tailor the offer on the website to user feedback. Hotjar works with cookies and other technologies to collect information about the behavior of the end devices used (in particular the IP address of the device (is only recorded and stored in anonymous form), screen size, device type (unique device identifiers), information about the browser used). , Location (country only), to show the preferred language). Hotjar stores this information in a pseudonymised user profile. The information is not used to identify individual users or combined with other data about individual users. Further information is available in Hotjar’s data protection declaration . Users can deactivate the storage of information about Hotjar’s visit to the website and the setting of Hotjar tracking cookies on other websites by clicking on this opt-out link .

Facebook tracking pixels

This website uses Facebook Tracking Pixel, an analysis tool provided by Facebook Ireland Ltd., Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland. This pixel establishes a direct connection to the Facebook servers and transmits the information that you have visited our website. Facebook assigns this information to your personal Facebook user account if you have such an account and are logged in to it. If you are not logged in to Facebook while visiting our website or are not a Facebook user, your visit to the website will not be assigned to a Facebook user account. You can manage what information you have shared through your use of Facebook via the “Activity log” tool or download it via Facebook’s “Download your data” tool.

Users can disable tracking via the Facebook tracking pixel by clicking this opt-out link. Reactivation is possible via this opt-in link.