1. Introduction

We would like to use the information below to provide you “data subject” with an overview of our processing of your personal data and your rights under data protection law. It is generally possible to use our website without entering personal data. However, if you wish to make use of special services offered by our company through our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we will generally obtain your consent. Personal data, such as your name, address or email address, is always processed in accordance with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the “The PaperClip Project”. The aim of this Privacy Notice is to inform you about the scope and purpose of the personal data we collect, use and process. As the data controller, we have implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps so that absolute protection cannot be guaranteed. For this reason, you are free to submit personal data in alternative ways, such as by phone or by post to us.

2. Data controller

The data controller, as defined by the GDPR, is:

The IP Paperclip Project Ltd.
Office 102
169 Athalassas Avenue
Strovolos 2025
Nicosia, Cyprus

Email: info@thepaperclipproject.eu

Data controller’s representatives:
Christos Christou, Roman Shaposhnik, Tatyana Dadasheva, Michael Bielicki

3. Data protection officer

You can reach the data protection officer as follows:

The Data Protection Officer
Email: dpo@thepaperclipproject.eu

You may contact our data protection officer directly at any time if you have any questions or suggestions regarding data protection.

4. Definitions

This Privacy Notice is based on the terminology used by the European legislature and legislature in the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand, both for the public and for our customers and business partners. To ensure this, we would like to explain in advance the terminology used. Among other things, we use the following terms in this privacy policy. We use the following terms in this Privacy Notice, among others:

  1. Personal data Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  2. Data subject A data subject is any identified or identifiable natural person whose personal data is processed by the data controller (our company).
  3. Processing Processing means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  4. Restriction to processing Restriction to processing means marking stored personal data with the aim of limiting its processing in future.
  5. Profiling Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  6. Pseudonymisation Pseudonymisation is the processing of personal data in such a way that the data can no longer be assigned to a specific data subject without additional information being provided, given that such additional information is kept separate and subject to appropriate technical and organisational measures that ensure that personal data cannot be attributed to an identified or identifiable natural person.
  7. Data processor The processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  8. Recipient Recipient means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
  9. Third parties Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
  10. Consent Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

5. Legal basis for processing

Article 6 Paragraph 1(a) GDPR serves as our company’s legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or considerations, processing is based on Article 6 Paragraph 1(b) GDPR. The same applies to those processing operations required to carry out pre-contractual measures, such as in cases of queries regarding our products or services. If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfilment of tax obligations, processing is based on Article 6 Paragraph 1(c) GDPR. In rare cases, processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if someone visiting our business were to be injured and their name, age, health insurance data or other vital information needed to be disclosed to a doctor, hospital or other third parties. Processing would then be based on Article 6 Paragraph 1(d) GDPR. Finally, processing operations could be based on Article 6 Paragraph 1(f) GDPR. Processing operations not based on any of the above-mentioned legal bases may be carried out on the basis of Article 6 Paragraph 1(f) GDPR if processing is necessary to safeguard the legitimate interests of our company or those of a third party, provided the interests and fundamental rights and freedoms of the data subject do not take precedence. We are permitted to engage in such processing operations in particular because they have been specifically mentioned in European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47 Sentence 2 GDPR).

6. Technology

6.1 SSL/TLS encryption

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login details or contact requests that you send to us as the website operator. You can recognise an encrypted connection by your browser’s address bar reading “https://” instead of “http://” and the lock symbol in the browser bar. We use this technology to protect your transmitted data.

6.2 Data collection when visiting the website

If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (in what is known as “server log files”). Our website collects a range of general data and information each time you access a website or an automated system. This general data and information are stored in the server’s log files. It may be collected

  1. the types and versions used,
  2. the operating system used by the accessing system,
  3. the website from which an accessing system accesses our website (called a referrer),
  4. the sub-pages accessed via an accessing system on our website,
  5. the date and time the website is accessed,
  6. a truncated internet protocol address (anonymised IP address) and
  7. the accessing system’s internet service provider.

No conclusions are drawn about you when using this general data and information. Instead, this information is needed

  1. to properly deliver our website content,
  2. to optimise the content of our website as well as to advertise it,
  3. to ensure the continued functioning of our IT systems and our website’s technology
  4. as well as to provide the information necessary for law enforcement authorities to prosecute in the event of a cyber attack.

This collected data and information is therefore statistically analysed and further analysed by us with the aim of increasing data protection and data security within our company to ultimately ensure an optimum level of protection for the personal data being processed by us. The anonymous data from the server log files are stored separately from all personal data provided by a data subject. The legal basis for data processing is Article 6 Paragraph 1 Sentence 1(f) GDPR. Our legitimate interest is based on the purposes listed above for the collection of data.

7. Cookies

7.1 General information about cookies

We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our website. The information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity. The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are erased automatically when you leave our website. We also use temporary cookies to optimise user-friendliness. These cookies are stored on your device for a specific period of time. If you return to our website to use our services, cookies allow us to automatically recognise that you have visited our website previously and remember the inputs and settings you have made so that you do not have to enter them again. We also use cookies to statistically record the use of our website and analyse it for the purpose of optimising our services. These cookies allow us to automatically recognise that you have already visited our website when you visit our website again. These cookies are automatically erased after a defined period of time.

7.2 Legal basis for the use of cookies

The data processed by cookies, which are required for the proper functioning of the website, are to safeguard our legitimate interests pursuant to Article 6 Paragraph 1 Sentence 1(f) GDPR. For all other cookies, you have given your consent to this through our opt-in cookie banner in accordance with Article 6 Paragraph 1(a) GDPR.

8. Contents of our website

8.1 Data processing when opening a customer account and for contract execution

Pursuant to Article 6 Paragraph 1(b) GDPR, personal data is collected and processed if you provide it to us for the execution of a contract or when opening a customer account. The data collected is shown in each input form. You may erase your customer account at any time by sending a message to the data controller’s address as stated above. We store and use the data you provide to execute contracts. After complete execution of the contract or erasure of your customer account, your data will be blocked, taking into account tax and commercial retention periods, and erased once these periods have expired unless you have expressly consented to the further use of your data or we are legally permitted to further use your data, about which we will inform you below.

8.2 Contact/contact form

Personal data is collected when you contact us (e.g. using our contact form or by email). If you use a contact form to get in touch with us, the contact form you use will indicate the data being collected. This data is stored and used exclusively for the purpose of responding to your query or establishing contact and the associated technical administration. The legal basis for data processing is our legitimate interest in responding to your request pursuant to Article 6 Paragraph 1(f)f GDPR. If the aim of you contacting us is to conclude a contract, processing is also legally based on Article 6 Paragraph 1(b) GDPR. Your data will be erased once we have finished processing your query. This is the case when it can be inferred from the circumstances that the relevant facts have been clarified in a conclusive manner and there are no statutory retention obligations in place that prevent its erasure.

8.3 Application management/job exchange

We collect and process the personal data of applicants for the purpose of carrying out the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents to us electronically, for example by email or via a web form on the website. If we conclude an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If we do not conclude an employment contract with the applicant, the application documents will be automatically erased two (2) months after notification of the rejection decision, provided that no other legitimate interests of ours prevent their erasure. Legal basis for the processing of the data is Article 88 GDPR.

9. Newsletters

9.1 Newsletter for regular customers

If you have provided us with your email address when purchasing goods or services, we reserve the right to send you regular emails with offers on products or services from our collection similar to those you have already purchased.  The sole basis for the data processing is our legitimate interest in personalised direct marketing in line with article 6, paragraph 1 lit. f GDPR. We will not send you any emails should you expressly object to the use of your email address for that purpose. You are entitled to object to the use of your email address for the aforementioned purpose at any time with immediate effect by notifying the data controllers listed in the opening of this statement. By taking this action, you will incur submission fees only in line with basic rates. After receipt of your objection, your email address will immediately be removed for marketing purposes.

9.2 Marketing newsletter

You can subscribe to our newsletter via our website. The input screen determines which personal data are shared with us when subscribing to the newsletter. We use our newsletter to regularly communicate our offers to our customers and business partners. You can, therefore, only receive our company’s newsletter if

  1. you have a valid email address and
  2. have registered for the newsletter.

For legal reasons, as part of the double opt-in procedure a confirmation email will be sent to the email address you provided when registering for the newsletter. This confirmation email is sent to check if you are the holder of the email address and have authorised the newsletter. When you register for the newsletter we also save the IP address used by your IT system at the time of registration, which is issued by your Internet Service Provider (ISP) as well as the date and time of registration. We must collect this data to investigate any (possible) misuse of your email address at a later stage and it is therefore lawful for the purposes of our security. The personal data collected during registration are used solely for sending our newsletter. Furthermore, subscribers to the newsletter may receive information via email if this is required in order to administer the newsletter service for registration purposes, which may be the case if our newsletter is amended or technical circumstances change. Personal data collected for our newsletter service are not shared with third parties. You may terminate your subscription to our newsletter at any time. You can at any time withdraw your consent to the storage of the personal data you shared during registration. A link is provided in each newsletter to allow you to withdraw your consent. It is also possible to unsubscribe from our newsletter directly through the website or to contact us in another manner. The legal basis for data processing for the purposes of sending a newsletter is article 6, paragraph 1 lit. a GDPR.

10. Our activities in social networks

To allow us to communicate with you on social networks and inform you about our services, we run our own pages on these social networks. If you visit one of our social media pages, we and the provider of the social media network are joint controllers (Art. 26 GDPR) regarding the processing operations triggered thereby, which concern personal data. We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers We would therefore like to point out as a precautionary measure that your data may also be processed outside of the European Union or the European Economic Area. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your rights to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behaviour by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behaviour may be assigned directly to your own member profile on the respective social network (if you are logged in). The processing operations of personal data described are carried out in accordance with Article 6 Paragraph 1(f) GDPR on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you have to grant your consent to the respective providers to process your data as a user, the legal basis for this processing is Article 6 Paragraph 1(a) GDPR in conjunction with Article 7 GDPR. Since we have no access to these providers’ databases, we would like to point out that you would be best placed to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider. More information on the processing of your data on social networks and your options for exercising your right to object or your right of revocation (opt-out) is listed below for each of the social network providers we use:

10.1 Facebook

(Jointly) Data controller responsible for data processing in Europe: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland Privacy Notice (Data Policy): https://www.facebook.com/about/privacy Opt-out and advertising settings: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen https://facebook.com/about/privacy/

10.2 Instagram

(Jointly) Data controller responsible for data processing in Europe: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland Privacy Notice (Data Policy): http://instagram.com/legal/privacy/ Opt-out and advertising settings: https://www.instagram.com/accounts/privacy_and_security/

10.3 LinkedIn

(Jointly) Data controller responsible for data processing in Europe: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland Privacy Notice: https://www.linkedin.com/legal/privacy-policy Opt-out and advertising settings: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

10.4 Twitter

(Jointly) Data controller responsible for data processing in Europe: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland Privacy Notice: https://twitter.com/en/privacy Information about your data: https://twitter.com/settings/your_twitter_data Opt-out and advertising settings: https://twitter.com/personalization

10.5 YouTube

(Jointly) Controller responsible for data processing in Europe: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland Privacy Notice: https://policies.google.com/privacy Opt-out and advertising settings: https://adssettings.google.com/authenticated

11. Social media plugins

11.1 2-click solution

Our website uses social plugins from the providers listed below. You can recognise these plugins by the fact that they are marked with a corresponding logo. These plugins may be used to send information, including personal data, to the service provider and may be used by the service provider. We prevent the automatic and inadvertent collection and transfer of data to the service provider through a two-click solution. To activate the chosen social plugin, it must first be activated by clicking on the corresponding button. Only when the plugin is activated will the collection of information and its transmission to the service provider be triggered. We do not collect any personal data ourselves through social plugins or their use. We have no influence on what data an activated plugin collects and how it is used by the provider. We must currently work on the assumption that a direct connection to the services of the provider will be established and that your IP address and device-related information will be recorded and used at a minimum. It is also possible that service providers may attempt to store cookies on the computer being used. Please see the privacy policy of the respective service provider to find out what data specifically is collected and how it is used. We have included the social media buttons of the following companies on our website: Social media buttons are used on the basis of Article 6 Paragraph 1 Sentence 1(f) GDPR. The promotional purpose behind this is deemed a legitimate interest as defined by the GDPR.

12. Plugins and other services

12.1 Google Maps

We use Google Maps (API) on our website, provided through Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Maps is a web service for displaying interactive maps to visually display geographic information. For example, by using this service, you can view our location and make it easier for you to reach us. When you access sub-pages in which a Google Maps map is integrated, information about your use of our website (such as your IP address) is transferred to Google’s servers in the US and stored there. This occurs regardless of whether Google provides a user account that you are logged in to or whether you have no user account with them at all. When you are logged in to Google, your information will be directly associated with your account. If you do not want your profile associated with Google, you will need to log out of your Google account. Google stores your data (even for users who are not logged in) as usage profiles and analysis it. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right. If you do not agree with the future transmission of your data to Google as part of your use of Google Maps, you have the option of completely deactivating the Google Maps web service by switching off the JavaScript application in your browser. You will then be unable to use Google Maps and therefore the map displayed on this website. These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR. The Google terms of use can be found at https://www.google.com/policies/terms/regional.html, and the additional Google Maps terms of use can be found at https://www.google.com/help/terms_maps/. Detailed information on data protection with respect to the use of Google Maps is available on Google’s website (“Google Privacy Policy”): https://www.google.com/policies/privacy.

12.2 Google reCAPTCHA

This website also uses the reCAPTCHA feature provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). This feature is primarily used to differentiate whether an entry is made by a natural person or whether the function is being misused through mechanical and automated processing. Use of the service also involves sending the IP address and any other data required by Google for the reCAPTCHA service to Google. These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR. Further information about Google reCAPTCHA and Google’s privacy policy can be found at: https://www.google.com/policies/privacy/.

12.3 YouTube (videos)

We have integrated YouTube components on this website. YouTube is an online video portal that allows video publishers to freely place video clips and allows others to view, rate and comment on videos free of charge. YouTube allows the publication of all types of videos. Both full film and television broadcasts, as well as music videos, trailers and user-generated videos, are available via the online portal. YouTube is operated by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Each time a visitor opens an individual page of the website run by us and on which a YouTube component (YouTube video) is integrated, the YouTube component in question will trigger the browser on your IT system to download a representation of the corresponding YouTube component from YouTube. Additional information on YouTube can be found at https://www.youtube.com/yt/about/. As part of this technical process, YouTube and Google will receive information about the specific sub-page of our website you visit. If the data subject is logged onto YouTube at the same time as they visit our website, YouTube identifies the specific sub-page of our website your visit when a sub-page containing a YouTube video is accessed. This information is collected through YouTube and Google and assigned to your YouTube account. Through the YouTube component, YouTube and Google receive information that you have visited our website whenever you are logged in to YouTube at the same time as accessing our website, regardless of whether you click on a YouTube video or not. If you do not want this information transferred to YouTube and Google, you can prevent this by logging out of your YouTube account before visiting our website. These processing operations only take place if express consent is granted in accordance with Article 6 Paragraph 1(a) GDPR. YouTube’s privacy policy, available at https://www.google.com/intl/gb/policies/privacy/, provides information on the collection, processing and use of personal data by YouTube and Google.

13. Your rights as a data subject

13.1 Right to confirmation

You have the right to request confirmation from us as to whether personal data relating to you will be processed.

13.2 Right to information (Article 15 GDPR)

You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us, in accordance with the statutory provisions.

13.3 Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

13.4 Erasure (Article 17 GDPR)

You have the right to demand that we erase the personal data relating to you be deleted without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required.

13.5 Restriction to processing (Article 18 GDPR)

You have the right to request that we restrict the processing of your data if one of the legal requirements is met.

13.6 Data transferability (Article 20 GDPR)

You have the right obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 Paragraph 1(a) GDPR or Article 9 Paragraph 2(a) GDPR or on a contract pursuant to Article 6 Paragraph 1(b) GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us. Furthermore, when exercising your right to data transferability pursuant to Article 20 Paragraph 1 GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.

13.7 Objection (Article 21 GDPR)

You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1(e) (data processing in the public interest) or (f) (data processing on the basis of the weighing of legitimate interests) GDPR. This also applies to profiling based on these provisions pursuant to Article 4 Number 4 GDPR. Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims. In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose. In addition, you have the right to object to our processing of your personal data for scientific or historical research purposes or for statistical purposes pursuant to Article 89 Paragraph 1 GDPR for reasons arising from your particular situation, unless such processing is necessary for the performance of a task in the public interest. You are free to exercise your right to lodge an objection in relation to the use of information society services, Directive 2002/58/EC notwithstanding, by means of automated procedures using technical specifications.

13.8 Revocation of consent regarding data protection

You have the right to revoke any consent to the processing of personal data at any time with future effect.

13.9 Lodging a complaint with a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

14. Duration of storage of personal data

The criterion for the duration of the retention of personal data is the respective legal retention period. Once this period expires, the data in question will be routinely erased, provided it is no longer required for the fulfilment or initiation of the contract.

15. Version and amendments to the Privacy Notice

This Privacy Notice is currently valid and was last updated on April 2022. It may be necessary for us to amend this Privacy Notice in the process of further developing our website and the services we offer through our website or due to changes in legal or regulatory requirements. You can view and print our current Privacy Notice on the website at any time by visiting “https://www.thepaperclipproject.eu/privacy-policy”.

Employees, workers and contractors, please refer to the following page ==> Privacy notice for employees, workers and contractors.