data protection
Data protection
Table of contents
- Responsible
- Overview of processing
- Relevant legal bases
- Safety measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Rights of the data subjects
- Business Services
- Provision of the online offer and web hosting
- Use of cookies
- Contact and inquiry management
- Newsletters and electronic notifications
- Presences in social networks (social media)
Responsible
Jona Krochmalnik / MORE MIDWIVES (SOLID PROPERTY)
Klettwitzer Str. 1
12681, Berlin, Germany
Email address: info@more-midwives.com
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
Types of data processed
- Inventory data.
- Payment details.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Log data.
Categories of data subjects
- Service recipient and client.
- Interested persons.
- communication partner.
- users.
- Business and contractual partners.
Purposes of processing
- Provision of contractual services and fulfilment of contractual obligations.
- Communication.
- Safety measures.
- direct marketing.
- Office and organizational procedures.
- Organisational and administrative procedures.
- Feedback.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Public relation.
- Business processes and business procedures.
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Article 6 (1) sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) - the processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). The BDSG contains in particular special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. In addition, state data protection laws of the individual federal states may apply.
Note on the validity of the GDPR and the Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to the broader spatial application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "personal data requiring particular protection" used in the Swiss DSG, the terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss DSG within the scope of the validity of the Swiss DSG.
Safety measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to it, input, transfer, ensuring availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Transmission of personal data
As part of our processing of personal data, it may happen that these are transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 Para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transmission (Art. 49 Para. 1 GDPR). Furthermore, we will inform you of the basis for third-country transfers for the individual providers from the third country, with the adequacy decisions taking priority as the basis. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we inform you which service providers we use are certified under the Data Privacy Framework.
General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consent is revoked or there are no further legal bases for the processing. This applies to cases in which the original processing purpose no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require the data to be stored or archived for a longer period.
In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal proceedings or to protect the rights of other natural or legal persons must be archived accordingly.
Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
If there are several specifications regarding the retention period or deletion period for a date, the longest period always applies.
If a period does not expressly begin on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the time at which the termination or other termination of the legal relationship takes effect.
We process data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons, only for the reasons that justify its storage.
Further information on processing procedures, methods and services:
- Storage and deletion of data: The following general periods apply to storage and archiving under German law:
- 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organizational documents, accounting documents and invoices required for their understanding (Section 147 Paragraph 3 in conjunction with Paragraph 1 Nos. 1, 4 and 4a AO, Section 14b Paragraph 1 UStG, Section 257 Paragraph 1 Nos. 1 and 4, Paragraph 4 HGB).
- 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents, insofar as they are relevant for taxation, e.g. hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register slips (Section 147 Paragraph 3 in conjunction with Paragraph 1 Nos. 2, 3, 5 AO, Section 257 Paragraph 1 Nos. 2 and 3, Paragraph 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights as well as to process related inquiries based on previous business experience and standard industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Rights of the data subjects
Rights of the data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
- Right to withdraw consent: You have the right to withdraw consent at any time.
- Right to information: You have the right to request confirmation as to whether or not data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you violates the provisions of the GDPR.
Business Services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), within the framework of contractual and comparable legal relationships and associated measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.
We use this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and company organization. In addition, we process the data on the basis of our legitimate interests in both proper and economical business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners are informed about other forms of processing, such as for marketing purposes, in this data protection declaration.
We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and similar obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes, usually ten years). We delete data that was disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved).
- Affected persons: service recipients and clients; interested parties; business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and commercial procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
Further information on processing procedures, methods and services:
- Online shop, order forms, e-commerce and delivery: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as to pay for and deliver or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery, provision and billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
Provision of the online offer and web hosting
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
- Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved). Protocol data (e.g. log files relating to logins or the retrieval of data or access times).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.). Security measures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for various purposes, such as the functionality, security and convenience of online services and the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless it is not required by law. Permission is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service that they have expressly requested (i.e. our online offering). The revocable consent will be clearly communicated to them and will contain information on the respective cookie usage.
Notes on data protection legal bases: The data protection basis on which we process users' personal data using cookies depends on whether we ask them for consent. If users accept, the legal basis for the use of their data is their declared consent. Otherwise, the data used using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, if this is done as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to meet our contractual obligations. We will explain the purposes for which we use cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. If we do not provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, including by means of the privacy settings of their browser.
- Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).
Further information on processing procedures, methods and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers named in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. The consent declarations are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The data is stored on the server side and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information is available about the providers of consent management services, the following general information applies: The consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of the consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the end device used; Legal basis: consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).
Contact and inquiry management
When you contact us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent that this is necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
- Affected persons: communication partners.
- Purposes of processing: communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
Further information on processing procedures, methods and services:
- Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data sent to us in order to answer and process the respective request. This usually includes details such as name, contact information and, if applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
Newsletters and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter "newsletters") only with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned when registering for the newsletter, these contents are decisive for the consent of the user. To register for our newsletter, it is usually sufficient to provide your email address. However, in order to be able to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter or for further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called "block list") for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Affected persons: communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or post).
- Retention and deletion: 3 years - Contractual claims (AT) (Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and usual industry practices, will be stored for the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).). 10 years - Contractual claims (CH) (Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and usual industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of 5 years applies, which is relevant in certain cases (Art. 127, 130 OR)).
- Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
- Opt-out option: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
- Measurement of opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or its server when the newsletter is opened, if we use a shipping service provider. As part of this retrieval, technical information, such as details about the browser and your system, as well as your IP address and the time of retrieval, are initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of the opening and click rates as well as the storage of the measurement results in the user profiles and their further processing are based on the consent of the users. Unfortunately, a separate revocation of the success measurement is not possible; in this case, the entire newsletter subscription must be canceled or revoked. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).
Presences in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because it could, for example, make it more difficult to enforce user rights.
Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user's usage behavior and the resulting interests. The latter can then be used to place advertisements within and outside the networks that presumably correspond to the user's interests. Cookies are therefore usually stored on users' computers in which the user's usage behavior and interests are stored. In addition, data can also be stored in the user profiles regardless of the devices used by the users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: communication; feedback (e.g. collecting feedback via online form). Public relations.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Instagram: Social network, enables sharing of photos and videos, commenting and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website:https://www.instagram.com ; Privacy policy: https://privacycenter.instagram.com/policy/ . Basis for third country transfers: Data Privacy Framework (DPF).