Legal
Privacy policy
How we handle your data when you visit this website or contact us. We are a company based in Germany, so the EU General Data Protection Regulation (GDPR) applies to all data we process, wherever you live.
Draft: this privacy policy will be reviewed by counsel before publication.
1. Controller
The controller responsible for processing personal data on this website is FNLY Social UG (haftungsbeschränkt), Am Kraftwerk 23, 34582 Borken, Germany, represented by its managing director Alina Schmid.
Phone: +49 5682 7369200, email: info@fnly-group.com. You can reach us at this address with any question about data protection and to exercise your rights.
2. Data protection officer
We are not required to appoint a data protection officer under Art. 37 GDPR and German data protection law. Our management handles your data protection requests directly.
3. Hosting
This website runs on servers we operate ourselves. The servers are located in the data center of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, at its Falkenstein site in Germany. Hetzner provides the data center, power and network. We have a data processing agreement with Hetzner under Art. 28 GDPR.
The connection to this website is encrypted with TLS. You can tell by the lock icon and “https” in the address bar.
4. Website access
Each time you open this website, your browser sends technical data to our server, including:
- IP address of your device
- date and time of access
- page or file requested
- the website you came from (referrer)
- browser and operating system
- amount of data transferred and response status code
Our server processes this data only to deliver the requested page. The legal basis is Art. 6(1)(f) GDPR, our legitimate interest being the technical delivery of the website. We do not store access logs with this data.
If you open fnly-social.com without a language in the address, we forward you to the matching version of the site. To do this we derive your country from your IP address and take your browser's language setting into account. The lookup uses a database on our own server (IP geolocation by DB-IP, https://db-ip.com, license CC BY 4.0). Your IP address is not shared with anyone for this purpose and is not stored. The legal basis is our legitimate interest in showing you the site in your language and with the prices and services for your market (Art. 6(1)(f) GDPR).
If you pick a language version yourself in the language selector, we store that choice in a cookie ("fnly_social_locale", kept for one year) so we do not redirect you again on your next visit. The cookie is required for this function you requested (Section 25(2) no. 2 TDDDG) and only contains the code of the version you chose.
5. Consent and local storage
We do not set advertising cookies without your consent. We store your choice in the consent banner in your browser's local storage (localStorage, entry “fnly-consent”) so the banner does not reappear on every page. This storage is strictly necessary for the service you requested.
We load all services that are not strictly necessary only with your consent under Art. 6(1)(a) GDPR. You can change or withdraw your consent at any time via the “Cookie settings” link in the footer of every page. Withdrawal takes effect for the future.
6. Website statistics with Matomo
If you consent to the “Statistics” category, we use the open-source software Matomo to measure how our website is used. The statistics server at statistik.fnly-group.com is run by FNLY Group in Germany, and the data is not shared with third parties.
We process your IP address, shortened by the last two bytes before storage, the pages you view and how long you stay, the website you came from, information about your device, browser and screen size, and actions such as submitting a form. Matomo sets the cookies “_pk_id” (stored for 13 months) and “_pk_ses” (30 minutes).
We use the results to improve our content and to understand which pages lead to requests. The legal basis is your consent under Art. 6(1)(a) GDPR. Raw data is deleted after 395 days.
7. Advertising and ad measurement
If you consent to the “Marketing” category, we use services of the ad platforms where we run ads: Google Ads (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), the LinkedIn Insight Tag (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland), the Meta Pixel for Facebook and Instagram (Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland) and the TikTok Pixel (TikTok Technology Limited, Dublin, Ireland). Without your consent, these services are not loaded.
These services set cookies or similar identifiers and transmit data such as your IP address, device and browser information, the pages you view and whether you sent a request or booked a call. This lets us measure which ads lead to requests and show ads on these platforms to visitors of our website. The legal basis is your consent under Art. 6(1)(a) GDPR. For data collected through the Meta Pixel, we and Meta are joint controllers under Art. 26 GDPR.
The providers may transfer data to the US. Google LLC, Meta Platforms, Inc. and LinkedIn Corporation are certified under the EU-US Data Privacy Framework, which is covered by an adequacy decision under Art. 45 GDPR. You can withdraw your consent at any time via “Cookie settings” in the footer.
If you reach us through an ad and send a request, we send the campaign details from the page address, such as utm_campaign or gclid, along with your request. This shows us which campaign led to which request. The legal basis is our legitimate interest in measuring the success of our advertising under Art. 6(1)(f) GDPR.
8. Contact form and project request
When you write to us through the contact form or the project request, we process the information you enter: name, email address, company, phone number, the selected topic, details about your project such as channels, scope, timeline and budget, and your message.
We use this data to answer your request and, if applicable, to prepare a quote. The legal basis is Art. 6(1)(b) GDPR where your request aims at a contract, and otherwise our legitimate interest in answering requests under Art. 6(1)(f) GDPR.
Our server sends your information as an email to our Microsoft 365 mailbox through the Microsoft Graph interface. We do not run a database for form entries. To prevent abuse, the server briefly processes your IP address in memory to limit too many requests in a short time. It is not stored permanently and is discarded after one hour at the latest.
We delete your request once it is completed, unless legal retention obligations apply. If your request leads to a contract, commercial and tax retention periods of up to ten years apply.
9. Contact by email and phone
When you contact us by email or phone, we process your information to handle your request. The same legal basis and retention period apply as for the contact form.
10. Microsoft 365
We use Microsoft 365 from Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, for email, calendar and call booking. We have a data processing agreement with Microsoft under Art. 28 GDPR.
Microsoft generally processes data for EU customers within the EU. A transfer to the US cannot be ruled out. Microsoft Corporation is certified under the EU-US Data Privacy Framework, which is covered by an adequacy decision of the European Commission under Art. 45 GDPR.
11. Call booking with Microsoft Bookings
We use Microsoft Bookings for online call booking. Your browser does not connect to Microsoft: the time picker on this page asks our server for open times, and only your booking is sent from our server to Microsoft Bookings. No cookies are set. Times are shown in your local time, which your browser determines on your device.
When you book a call, we process your name, email address, company, phone number, your optional message and the chosen time to hold the call and send you a confirmation. The legal basis is Art. 6(1)(b) GDPR. To prevent abuse, the server briefly processes your IP address in memory, as with the contact form. We delete the data once it is no longer needed for the call and a possible collaboration.
12. UGC price calculator
The UGC price calculator runs entirely in your browser. Your entries are neither stored nor sent to us.
13. Fonts, images and external content
Without your consent we do not load fonts, scripts or images from third-party servers; ad tags load only after you consent to the “Marketing” category. The content of this website is delivered from our own servers.
14. Links to other providers
This website contains links to other providers, such as the websites of our sister brands FNLY IT and FNLY Agency or map services for directions. Data is only transferred when you click such a link. The respective provider is responsible for processing on the linked pages.
15. Recipients of your data
Your data is only received by those who need it for the purposes above: our staff who handle your request and the processors named above, Hetzner and Microsoft. We do not sell your data or pass it on for advertising purposes.
16. Your rights
Under the GDPR you have the following rights regarding your personal data, wherever you live:
- access under Art. 15 GDPR
- rectification under Art. 16 GDPR
- erasure under Art. 17 GDPR
- restriction of processing under Art. 18 GDPR
- data portability under Art. 20 GDPR
- withdrawal of consent under Art. 7(3) GDPR, effective for the future
Right to object under Art. 21 GDPR
Where we process data based on a legitimate interest under Art. 6(1)(f) GDPR, you can object at any time on grounds relating to your particular situation. We will then stop processing the data unless we can demonstrate compelling legitimate grounds.
17. Complaints to a supervisory authority
You can lodge a complaint with a data protection supervisory authority. The authority responsible for us is the Hessian Commissioner for Data Protection and Freedom of Information (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit), Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany, www.datenschutz.hessen.de.
18. Obligation to provide data and automated decisions
You are not obliged to provide us with data. Without the required fields in the contact form, however, we cannot handle your request. We do not use automated decision-making, including profiling, under Art. 22 GDPR.
19. Changes
We update this privacy policy when the website or the legal situation changes. The version published here applies.
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