Privacy Policy

1. Responsible Party

The responsible party for data processing is:

Sapere Partners FZCO
Dubai Silicon Oasis
DDP Building A1 – Unit No. 001
P.O.BOX: 341444 Dubai – U.A.E.

Data Protection Officer:

You can reach our data protection officer at the above address or by email at datenschutz@sapere-partners.com.

2. Scope and Purpose of Data Processing

We only process personal data of our users insofar as this is necessary to provide our online offer and the associated services and benefits. The processing of personal data regularly only takes place with the user’s consent. An exception applies only in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

2.1 Access Data

When accessing our website, we collect the following data, which is necessary for the technical operation of the website:

  • Date and time of access
  • Accessed page or file
  • Transferred data volume
  • Notification of successful retrieval
  • Browser type
  • Operating system
  • IP address of the requesting computer

The processing of this data is justified according to Art. 6 Para. 1 S. 1 lit. f DSGVO. Our legitimate interest arises from the data collection purposes listed above.

The IP address is only stored for the duration of the respective use and is then deleted or anonymized. This data is not merged with other data sources.

The data will be deleted as soon as they are no longer required for the purpose of their collection.

2.2 Contact Form

For any questions, we offer the opportunity to contact us via a form provided on our website. A valid email address is required so that we know who the request is from and can respond to it. Further information can be provided voluntarily. It is up to you to decide whether you want to enter this data in the contact form.

The processing of the data entered into the contact form is exclusively for the purpose of establishing contact and the related communication with you. The legal basis for this is Art. 6 Para. 1 S. 1 lit. a DSGVO.

The data will be deleted as soon as they are no longer required for the purpose of their collection. For personal data from the input mask of the contact form, this is the case when the respective conversation with you is over. The conversation is considered over when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

Mandatory legal provisions – especially retention periods – remain unaffected.

2.3 Newsletter

For sending the newsletter, we use the so-called double opt-in procedure, i.e., after your registration, you will receive an email asking you to confirm your registration. You will then receive the newsletter on the specified topics.

The personal data collected during registration for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by email if this is necessary for the operation of the newsletter service or a corresponding registration.

The legal basis for processing the data after registering for the newsletter is Art. 6 Para. 1 S. 1 lit. a DSGVO.

The collection of the user’s email address serves to deliver the newsletter. The collection of other personal data during the registration process serves to prevent misuse of the services or the email address used.

The data will be deleted as soon as they are no longer required for the purpose of their collection. The user’s email address will therefore be stored as long as the newsletter subscription is active.

The subscription to the newsletter can be canceled by the affected user at any time. For this purpose, there is a corresponding link in every newsletter.

2.4 Registration

You have the opportunity to register on our website. The personal data collected during registration is used exclusively for the provision or administration of the registered services and benefits.

The processing is based on your consent (Art. 6 Para. 1 S. 1 lit. a DSGVO).

The data provided during registration will be stored by us as long as you are registered on our website and will then be deleted. Legal retention periods remain unaffected.

2.5 Comments

When users leave comments on our website, in addition to this information, the time of their creation and the username previously chosen by the website visitor are saved. This serves our security, as we can be held responsible for illegal content on our website, even if it was created by users.

The legal basis for this is Art. 6 Para. 1 S. 1 lit. f DSGVO. Our legitimate interest arises from the data storage purposes listed above.

3. Transfer of Data

Your personal data will not be transferred to third parties for purposes other than those listed below. We only share your personal data with third parties if:

  • You have given your express consent in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO,
  • the transfer is necessary for the assertion, exercise, or defense of legal claims and there is no reason to assume that you have an overriding legitimate interest in not disclosing your data,
  • in the event that there is a legal obligation for the transfer according to Art. 6 Para. 1 S. 1 lit. c DSGVO, and
  • this is legally permissible and necessary for the processing of contractual relationships with you in accordance with Art. 6 Para. 1 S. 1 lit. b DSGVO.

4. Cookies

We use cookies on our website. These are small files that your browser automatically creates and stores on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do not harm your device and do not contain viruses, Trojans, or other malicious software.

The cookie stores information related to the specific device used. However, this does not mean that we immediately become aware of your identity.

The use of cookies serves to make our offer more pleasant for you. For instance, we use so-called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted after you leave our site.

Furthermore, to optimize user-friendliness, we also use temporary cookies stored on your device for a specific period. If you revisit our site to use our services, it will automatically recognize that you have been with us before and which entries and settings you have made, so you don’t have to re-enter them.

Additionally, we use cookies to statistically record the use of our website and evaluate it for the purpose of optimizing our offer for you (see section 6). These cookies allow us to automatically recognize that you have already visited our site when you return. These cookies are automatically deleted after a defined period.

The data processed by cookies are necessary for the mentioned purposes to protect our legitimate interests and those of third parties according to Art. 6 Para. 1 S. 1 lit. f DSGVO.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, completely deactivating cookies may result in not being able to use all the functions of our website.

5. Right to Object

If your personal data is processed based on legitimate interests according to Art. 6 Para. 1 S. 1 lit. f DSGVO, you have the right, according to Art. 21 DSGVO, to object to the processing of your personal data, provided there are reasons arising from your particular situation or if the objection is against direct advertising. In the latter case, you have a general right to object, which we will implement without specifying a particular situation.

If you wish to exercise your right of revocation or objection, an email to datenschutz@sapere-partners.com is sufficient.

6. Analysis Tools

The tracking measures listed below and used by us are carried out based on Art. 6 Para. 1 S. 1 lit. f DSGVO. With the tracking measures used, we aim to ensure a needs-based design and continuous optimization of our website. On the other hand, we use tracking measures to statistically record the use of our website and evaluate it for the purpose of optimizing our offer for you. These interests are considered legitimate within the meaning of the aforementioned regulation.

The respective data processing purposes and data categories can be taken from the corresponding tracking tools.

6.1 Google Analytics

For the purpose of the needs-based design and continuous optimization of our pages, we use Google Analytics, a web analysis service of Google LLC (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”). In this context, pseudonymized usage profiles are created and cookies (see section 4) are used. The information generated by the cookie about your use of this website, such as:

  • Browser type/version,
  • Operating system used,
  • Referrer URL (the previously visited page),
  • Hostname of the accessing computer (IP address),
  • Time of the server request,

are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activities, and to provide other services related to website and internet use for market research purposes and to tailor these internet pages to meet requirements. This information may also be transferred to third parties if required by law or if third parties process this data on behalf of Google. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that an assignment is not possible (IP masking).

You can prevent the installation of cookies by adjusting the browser software accordingly; however, we would like to point out that in this case, not all functions of our website may be fully usable.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent data collection by Google Analytics by clicking on the aforementioned link. An opt-out cookie will be set, which prevents the future collection of your data when visiting our website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

Further information on data protection in connection with Google Analytics can be found in the Google Analytics help under the following link: https://support.google.com/analytics/answer/6004245?hl=de

6.2 Google Adwords Conversion Tracking

To statistically record the use of our website and to evaluate it for the purpose of optimizing our website for you, we also use Google Conversion Tracking. In this case, a cookie (see section 4) is set on your computer by Google Adwords if you have accessed our website via a Google ad.

These cookies expire after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer’s website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page.

Each Adwords customer receives a different cookie. Cookies cannot be tracked across Adwords customers’ websites. The information obtained using the conversion cookie is used to create conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can personally identify users.

If you do not wish to participate in the tracking process, you can also refuse the setting of a cookie required for this – for example, by setting your browser to deactivate the automatic setting of cookies in general. You can also deactivate cookies for conversion tracking by setting your browser to block cookies from the domain “www.googleadservices.com”. Google’s data protection instructions for conversion tracking can be found under the following link: https://services.google.com/sitestats/de.html

6.3 Matomo

We use the open-source software Matomo for analyzing and statistically evaluating the use of the website. For this purpose, cookies are used (see section 4). The information generated by the cookie about the use of the website is transmitted to our servers and summarized in pseudonymous user profiles. The information is used to evaluate the use of the website and to enable a needs-based design of our website. The information is not passed on to third parties.

In no case will the IP address be linked with other data concerning the user. The IP addresses are anonymized so that an assignment is not possible (IP masking).

Your visit to this website is currently recorded by Matomo web analysis. Click here (https://matamo.org/docs/privacy/) to ensure that your visit is no longer recorded.

7. Social Media Plugins

Based on Art. 6 Para. 1 S. 1 lit. f DSGVO, we use social plugins from the social networks Facebook, Twitter, and Instagram on our website to make our company better known through them. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of the DSGVO. The responsibility for data protection-compliant operation must be ensured by the respective provider. We integrate these plugins using the so-called two-click method to protect visitors to our website as best as possible.

a) Facebook

We integrate the social media buttons of Facebook based on Art. 6 Para. 1 S. 1 lit. f DSGVO to make our company better known through Facebook. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of the DSGVO. The responsibility for data protection-compliant operation lies with Facebook.

b) Twitter

Our website includes functions of the Twitter service. These functions are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and made known to other users. Data is also transferred to Twitter. We would like to point out that, as the provider of the pages, we 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 at http://twitter.com/privacy.

You can change your privacy settings on Twitter in the account settings at http://twitter.com/account/settings.

c) Instagram

On our website, we also use so-called social plugins (“plugins”) from Instagram, operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”). The plugins are marked with an Instagram logo, for example, in the form of an “Instagram camera”. An overview of the Instagram plugins and their appearance can be found here: http://blog.instagram.com/post/36222022872/introducing-instagram-badges

When you access a page of our website that contains such a plugin, your browser establishes a direct connection to Instagram’s servers. The content of the plugin is transmitted directly from Instagram to your browser and integrated into the page. Through this integration, Instagram receives the information that your browser has accessed the corresponding page of our website, even if you do not have an Instagram profile or are not currently logged into Instagram. This information (including your IP address) is transmitted directly from your browser to an Instagram server in the USA and stored there.

If you are logged into Instagram, Instagram can directly associate your visit to our website with your Instagram account. If you interact with the plugins, for example by pressing the “Instagram” button, this information is also transmitted directly to an Instagram server and stored there. The information is also published on your Instagram account and displayed to your contacts.

For the purpose and scope of data collection and the further processing and use of data by Instagram, as well as your rights and setting options for protecting your privacy, please refer to Instagram’s privacy policy: https://help.instagram.com/519522125107875

If you do not want Instagram to directly associate the data collected through our website with your Instagram account, you must log out of Instagram before visiting our website. You can also completely prevent the loading of Instagram plugins with add-ons for your browser, e.g., with the script blocker “NoScript” (http://noscript.net/).

8. Rights of the Data Subject

You have the right to:

  • Request information about your personal data processed by us in accordance with Art. 15 DSGVO. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to correction, deletion, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it was not collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
  • Request the correction of incorrect or complete personal data stored by us in accordance with Art. 16 DSGVO without delay;
  • Request the deletion of your personal data stored by us in accordance with Art. 17 DSGVO, unless processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or to assert, exercise or defend legal claims;
  • Request the restriction of the processing of your personal data in accordance with Art. 18 DSGVO if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse its deletion and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have objected to the processing in accordance with Art. 21 DSGVO;
  • Receive your personal data that you have provided to us in a structured, common, and machine-readable format or request its transfer to another responsible party in accordance with Art. 20 DSGVO;
  • Revoke your consent given to us at any time in accordance with Art. 7 Para. 3 DSGVO. As a result, we may no longer continue the data processing based on this consent in the future, and
  • Complain to a supervisory authority in accordance with Art. 77 DSGVO. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters for this purpose. 

If you have any questions regarding the collection, processing or use of your personal data, for information, correction, blocking or deletion of data as well as revocation of consent given or objection to a specific use of data, please contact us directly using the contact details in point 1.

Validity and Changes to this Privacy Policy

This privacy policy is currently valid and has the status as of August 2023.

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