Privacy Policy

1. Privacy at a Glance

General Information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is all data with which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. Their contact details can be found in the section “Note on the Responsible Party” in this privacy policy.

How do we collect your data?

Your data is collected on the one hand by you communicating it to us. This could, for example, be data that you enter into a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. These are primarily technical data (e.g. internet browser, operating system, or the time the page was accessed). The collection of this data occurs automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to obtain free information about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right to request the restriction of the processing of your personal data under certain circumstances. You also have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the topic of data protection.

Analysis Tools and Tools from Third Parties

When visiting this website, your surfing behavior may be statistically evaluated. This is done primarily using so-called analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. Hosting

We host the contents of our website with the following provider:

External Hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access, and other data generated via a website.

External hosting is carried out for the purpose of fulfilling our contractual obligations towards our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a secure, fast, and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR). If consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfill their service obligations and will follow our instructions regarding this data.

We use the following host(s):

Netlify, Inc.
44 Montgomery Street Suite 300
San Francisco
California 94104

3. General Information and Mandatory Disclosures

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various pieces of personal data are collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this occurs.

We point out that data transmission on the internet (e.g., communication by email) can have security vulnerabilities. Complete protection of the data from access by third parties is not possible.

Note on the Responsible Party

The responsible party for data processing on this website is:

Dragos Lapusneanu
Grouplunch Luxembourg S.à r.l.
Rue de Bitbourg
1273 Luxembourg

Telephone: +352 20 33 272
Email: sales@foozo.lu

The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).

Storage Duration

Unless a more specific storage period is stated in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial retention periods); in the latter case, deletion will take place once these reasons no longer apply.

General Information on the Legal Bases for Data Processing on This Website

If you have consented to data processing, we process your personal data based on Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data are processed according to Art. 9(1) GDPR. In the case of express consent to the transfer of personal data to third countries, data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your end device (e.g., via device fingerprinting), data processing is additionally based on § 25(1) TTDSG. Consent can be revoked at any time. If your data is required to fulfill a contract or carry out pre-contractual measures, we process your data based on Art. 6(1)(b) GDPR. Furthermore, we process your data if required to fulfill a legal obligation based on Art. 6(1)(c) GDPR. Data processing may also be carried out based on our legitimate interest pursuant to Art. 6(1)(f) GDPR. The respective legal basis in each individual case is explained in the following paragraphs of this privacy policy.

Note on Data Transfer to the USA and Other Third Countries

We use tools from companies based in the USA or other non-secure third countries in terms of data protection. When these tools are active, your personal data may be transferred to and processed in these third countries. We would like to point out that in these countries, a level of data protection comparable to that in the EU cannot be guaranteed. For example, US companies are obligated to hand over personal data to security authorities without you, as the data subject, being able to take legal action against this. Therefore, it cannot be ruled out that US authorities (e.g., intelligence services) process, evaluate, and permanently store your data located on US servers for surveillance purposes. We have no influence on these processing activities.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out up to the time of revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

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 CONCERNING YOU FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL THEN NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged violation. The right to lodge a complaint is without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to receive data that we process automatically based on your consent or in fulfillment of a contract, in a common, machine-readable format either for yourself or for a third party. If you request the direct transfer of the data to another controller, this will only be done to the extent technically feasible.

Right to Access, Rectification and Erasure

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, their origin and recipient, and the purpose of the data processing and, if applicable, a right to correction or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time regarding this. The right to restriction of processing applies in the following cases:

If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you require it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection under Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from being stored – may only be processed with your consent or for the establishment, exercise or defense 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 European Union or a Member State.

SSL or TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to Promotional Emails

We hereby object to the use of contact data published within the scope of the legal notice obligation for the purpose of sending unsolicited advertising and information materials. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited promotional information, such as spam emails.

4. Data Collection on This Website

Contact Form

If you send us inquiries via the contact form, your information from the inquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your request is related to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this was requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Calendly

On our website, you have the opportunity to schedule appointments with us. We use the tool “Calendly” for booking appointments. The provider is Calendly LLC, 271 17th St NW, 10th Floor, Atlanta, Georgia 30363, USA (hereinafter “Calendly”).

For the purpose of booking an appointment, you enter the requested data and preferred appointment time into the form provided. The entered data will be used for planning, execution, and, if necessary, follow-up of the appointment. The appointment data will be stored on Calendly's servers for us. You can view their privacy policy here: https://calendly.com/de/pages/privacy.

The data you enter remains with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies. Mandatory legal requirements – in particular retention periods – remain unaffected.

The legal basis for data processing is Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the most uncomplicated possible appointment scheduling with interested parties and customers. If consent has been requested, processing is based exclusively on Art. 6(1)(a) GDPR and § 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information in the user's terminal device (e.g., device fingerprinting) as defined by TTDSG. Consent can be revoked at any time.

The data transfer to the USA is based on the EU Commission’s Standard Contractual Clauses. Details can be found here: https://calendly.com/pages/dpa.

5. Social Media

Facebook

Elements of the social network Facebook are integrated on this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook, the collected data is also transferred to the USA and other third countries.

An overview of the Facebook social media elements can be found here: https://developers.facebook.com/docs/plugins/?locale=de_DE.

When the social media element is active, a direct connection between your device and the Facebook server is established. Facebook thereby receives information that you have visited this website with your IP address. If you click the Facebook "Like button" while logged into your Facebook account, you can link the content of this website to your Facebook profile. This allows Facebook to associate the visit to this website with your user account. We point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or how it is used by Facebook. Further information can be found in Facebook’s privacy policy at: https://de-de.facebook.com/privacy/explanation.

If consent (consent) has been obtained, the use of the above service is based on Art. 6(1)(a) GDPR and § 25 TTDSG. Consent can be revoked at any time. If no consent has been obtained, the service is used based on our legitimate interest in the widest possible visibility in social media.

If, with the help of the tool described here, personal data is collected on our website and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). This joint responsibility is limited solely to the collection of the data and its transfer to Facebook. The processing carried out by Facebook after the transfer is not part of the joint responsibility. The obligations jointly incumbent on us have been set out in a joint processing agreement. You can find the wording of the agreement here: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data protection information when using the Facebook tool and for the secure implementation of the tool on our website in accordance with data protection law. Facebook is responsible for the data security of Facebook products. Data subject rights (e.g., requests for information) regarding data processed by Facebook can be asserted directly with Facebook. If you assert the data subject rights with us, we are obligated to forward them to Facebook.

Data transfer to the USA is based on the EU Commission’s Standard Contractual Clauses. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.

Twitter

This website integrates functions of the Twitter service. These functions are provided by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

When the social media element is active, a direct connection between your device and the Twitter server is established. Twitter thereby receives information about your visit to this website. By using Twitter and the "Re-Tweet" function, the websites you visit are linked to your Twitter account and made known to other users. We point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Twitter. Further information can be found in Twitter's privacy policy: https://twitter.com/de/privacy.

If consent has been obtained, the use of the above service is based on Art. 6(1)(a) GDPR and § 25 TTDSG. Consent can be revoked at any time. If no consent has been obtained, use is based on our legitimate interest in ensuring the broadest possible visibility on social media.

Data transfer to the USA is based on the EU Commission's Standard Contractual Clauses. Details can be found here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html.

You can change your privacy settings on Twitter in your account settings: https://twitter.com/account/settings.

Instagram

This website integrates functions of the Instagram service. These functions are provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

When the social media element is active, a direct connection between your device and the Instagram server is established. Instagram thereby receives information about your visit to this website.

If you are logged into your Instagram account, clicking the Instagram button allows you to link the content of this website to your Instagram profile. Instagram can then associate your visit to this website with your user account. We point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Instagram.

If personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). This joint responsibility is limited solely to the collection of the data and its transfer to Facebook or Instagram. Processing after transfer is not part of the joint responsibility. The obligations jointly incumbent upon us have been set out in an agreement on joint processing. You can find the wording of the agreement here: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using Facebook or Instagram tools and for the data protection-compliant implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. Data subject rights (e.g., access requests) regarding the data processed by Facebook or Instagram can be asserted directly with Facebook. If you assert the rights with us, we are obliged to forward them to Facebook.

Data transfer to the USA is based on the EU Commission's Standard Contractual Clauses. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875, and https://de-de.facebook.com/help/566994660333381.

Further information can be found in Instagram's privacy policy: https://instagram.com/about/legal/privacy/.

This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Each time a page on this website that contains LinkedIn elements is accessed, a connection to LinkedIn's servers is established. LinkedIn is informed that you have visited this website with your IP address. If you click the LinkedIn "Recommend" button while logged into your LinkedIn account, LinkedIn can associate your visit to this website with you and your user account. We point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn.

Data transfer to the USA is based on the EU Commission's Standard Contractual Clauses. Details can be found here: https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de.

Further information can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.

6. Analytics Tools and Advertising

Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies into our website. Google Tag Manager itself does not create user profiles, store cookies, or perform independent analyses. It only manages and plays out the tools integrated via it. However, Google Tag Manager does collect your IP address, which may also be transferred to Google's parent company in the United States.

The use of Google Tag Manager is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and easy integration and administration of various tools on their website. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, provided that the consent includes the storage of cookies or access to information in the user's terminal device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

Google Analytics

This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data such as page views, time spent on the site, operating systems used, and the origin of the user. These data may be compiled by Google into a profile that is assigned to the respective end device of the user. No assignment to a user ID takes place.

Furthermore, we can use Google Analytics to record your mouse and scroll movements and clicks, among other things. Google Analytics also uses various modeling approaches to supplement the collected datasets and applies machine learning technologies in data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is usually transmitted to a Google server in the USA and stored there.

The use of this service is based on your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Consent can be revoked at any time.

Data transfer to the USA is based on the EU Commission's Standard Contractual Clauses. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

Browser Plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

More information on how Google Analytics handles user data can be found in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.