Datenschutzerklärung

membilla GmbH

Allmendstrasse 98, 8041 Zürich

Switzerland

Email: hello@membilla.com

Website: membilla.com | app.membilla.com

UID: CHE-493.625.862

2. General Information

Based on Article 13 of the Swiss Federal Constitution and the federal data protection provisions (Data Protection Act, DSG), every person is entitled to protection of their privacy and protection against misuse of their personal data. 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.

In cooperation with our hosting providers, we endeavour to protect the databases as best we can against unauthorised access, loss, misuse or falsification.

We take data security seriously and implement appropriate technical and organizational measures to protect your personal data, including:

·       Transport Layer Security (TLS/SSL) encryption for all data transmission

·       Encrypted storage of sensitive data

·       Regular security audits and updates

·       Access controls and authentication measures

·       Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. If you have concerns about the security of your data, please contact us at hello@membilla.com.

By using this website, you acknowledge that you have read and understood this privacy policy. Some data processing is necessary for the operation of our website and services (necessary processing). For other data processing activities that require your consent, we will request your explicit consent through appropriate mechanisms, such as cookie banners, registration forms, or preference settings. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

3. General Information

Personal data is any information relating to an identified or identifiable person. A data subject is a person whose personal data is being processed. Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, deletion, saving, modification, destruction and use of personal data.

4. Legal Basis

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO). In addition, we process personal data in accordance with the General Data Protection Regulation of the EU (GDPR), insofar as and to the extent that the GDPR is applicable.

5. Type, Scope and Purpose

We process the personal data that is necessary to enable us to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Such as:

• Registration data: name, email address, password (hashed), account creation date, user preferences

• Subscription data: subscription provider, subscription name, subscription costs, subscription start, renewal and cancellation date, subscription categories, auto-renew

• Technical data (automatically collected): IP address, browser type and version, operating system, device type, language preferences, time zone

• Usage data: pages visited, features used, search queries within platform

• Communication data: email correspondence, support tickets, feedback submissions

• Uploaded documents and images: files you choose to upload or make available (e.g. invoices, billing confirmations, screenshots) from which subscription-relevant information is extracted, and the information extracted from them

• Subscription analysis data: derived data resulting from the analysis of your subscriptions, including calculated actual costs, cost forecasts, category assignments, tax-display preferences and the reminder/notification settings you configure

Data we do not collect: Credit card or payment information or bank account details (if not directly connected to a service of membilla GmbH), social security numbers or tax IDs, sensitive personal data.

We process personal data for the duration required for the respective purpose or purposes or as required by law. Personal data that no longer needs to be processed is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection with such third parties.

We only process personal data with the consent of the persons concerned. If and to the extent that processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example by post, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information in an address book, a customer relationship management system (CRM system) or similar tools. If we receive data about other persons, the persons transmitting the data are obliged to guarantee data protection for these persons and to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities, provided that such processing is permitted for legal reasons.

6. Legal Basis for Data Processing

We process your personal data based on the following legal grounds:

Contract Performance (GDPR Art. 6(1)(b))

·       Creating and managing your account

·       Providing subscription management services

·       Delivering plugin functionality

·       Processing your requests and communications

·       Providing customer support

Legitimate Interests (GDPR Art. 6(1)(f))

·       Platform security and fraud prevention

·       Technical system maintenance and improvement

·       Anonymous analytics to improve user experience

·       Internal business operations

·       Legal claims defense

Consent (GDPR Art. 6(1)(a))

·       Marketing communications (newsletters)

·       Non-essential cookies (analytics)

·       Social media integration

Legal Obligation (GDPR Art. 6(1)(c))

·       Compliance with tax laws

·       Response to legal requests

·       Statutory retention requirements

·       Regulatory compliance

You may object to processing based on legitimate interests and withdraw consent at any time. This will not affect the lawfulness of processing before withdrawal.

Lawfulness under Swiss law (FADP): Swiss data protection law does not require a statutory legal basis for every processing operation by a private controller in the same way as the GDPR. Under the Federal Act on Data Protection (FADP), we may process personal data provided we comply with the principles of lawfulness, good faith, proportionality, purpose limitation, transparency, data accuracy and security, and provided the processing does not unlawfully breach your personality rights. Where processing could do so, we rely on a justification ground under Art. 31 FADP, in particular your consent, the performance or conclusion of a contract with you, an overriding private or public interest, or a legal obligation. The GDPR legal bases set out above apply in addition, insofar and to the extent that the GDPR is applicable to the processing in question.

7. Plugin Functionality

User subscriptions managed on the website offered by membilla GmbH can be processed automatically. Subscription information may be collected and evaluated in pseudonymised form (linked to your account but not published in a way that identifies you to third parties) for the purpose of improving the customer experience. In particular, but not exclusively, the name of the subscription, its term, cancellation date and costs will be evaluated for this purpose.

The membilla browser plugin (available for Chrome, Firefox, Safari, Edge) helps you identify and track your subscriptions automatically.

7.1 How the Plugin Works

·       The plugin operates ONLY when you click the activation button

·       It scans the currently visible webpage for subscription-related information

·       It does NOT monitor your browsing history or activity in the background

·       It does NOT track websites you visit unless you activate it on that page

7.2 Data the Plugin Collects

When activated on a webpage, the plugin may extract:

·       Subscription service name

·       Subscription price/cost

·       Billing frequency (monthly, annual, etc.)

·       Start date (if visible)

·       Next billing date (if visible)

·       Cancellation date (if visible)

7.3 Data the Plugin NEVER Collects

·       Passwords or login credentials

·       Credit card or payment information

·       Banking details

·       Personal identification numbers

·       Other personal information unrelated to subscriptions

7.4 Data Storage and Syncing

·       Collected data is sent securely (encrypted) to your membilla account

·       Data is stored on our servers in Europe

·       You can view, edit, or delete any collected data at any time

·       Uninstalling the plugin does NOT delete your account data

7.5 Plugin Permissions

The plugin requires the following browser permissions:

·       Active Tab: To read subscription information only on the current page when you click the button

·       Storage: To save your preferences and connection to your membilla account

·       HTTPS Access: To securely communicate with membilla servers

We do NOT request permissions for:

·       Reading browser history

·       Accessing all websites automatically

·       Reading data from all tabs

·       Accessing bookmarks or downloads

7.6 Third-Party Websites: The plugin interacts with third-party subscription provider websites. We are not responsible for the privacy practices of those websites. We only extract publicly visible information that you choose to capture.

To use the plugin, users must connect it to their membilla GmbH account. The data can be supplemented, expanded or adapted by the membilla GmbH database. All this is done in the interest of the users and in compliance with all data protection regulations.

7.7 Automated Processing, Profiling and Subscription Analysis

To provide our core service, we carry out automated processing of your subscription data, including profiling within the meaning of Art. 4(4) GDPR. Specifically:

Cost analysis: We automatically calculate the actual costs of the subscriptions you hold, aggregate them and present them in overviews.

Cost forecasting: We generate forecasts of your future subscription costs based on the subscription data available to us (e.g. prices, billing frequency, renewal dates).

Categorisation: We automatically assign your subscriptions to categories to help you understand and organise your spending.

Tax preference: You can choose whether prices and analyses are displayed inclusive or exclusive of applicable taxes. This is a display preference that we store as part of your user preferences.

These analyses are performed to provide the service you have requested (contract performance, Art. 6(1)(b) GDPR; Art. 31 FADP) and, where they help us improve the service, on the basis of our legitimate interests (Art. 6(1)(f) GDPR). They are decision-support tools for your own use. They do not produce legal effects concerning you or similarly significantly affect you within the meaning of Art. 22 GDPR / Art. 21 FADP, and we do not use them to make automated decisions about you (such as pricing or eligibility decisions). You can access, correct and delete the underlying subscription data at any time, and you may contact us to obtain further information about the logic involved. If we were ever to introduce automated individual decision-making with legal or similarly significant effects, we would inform you in advance and provide the safeguards required by law, including the right to human intervention, to express your point of view and to contest the decision.

The AI-based extraction and evaluation described in Section 16.2 forms part of this processing. Where documents or images you upload are analysed, we process them solely to extract subscription-relevant information and to populate your subscription overview.

8. Personal Data Abroad

We generally process personal data in Switzerland and the European Union. However, we may also disclose or export personal data to other countries, in particular for processing or to have it processed there.

Where we transfer personal data abroad, we do so only on the basis of a lawful transfer mechanism. In the first instance, we transfer personal data to countries that provide an adequate level of data protection, i.e. countries recognised as adequate by the Swiss Federal Council (Art. 16 FADP) and/or by a European Commission adequacy decision (Art. 45 GDPR).

We may disclose personal data in countries whose laws do not guarantee adequate data protection, provided that adequate data protection is guaranteed for other reasons. Adequate data protection may be guaranteed, for example, by appropriate contractual agreements based on standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will gladly provide data subjects with information about any guarantees or provide a copy of guarantees.

9. Rights of Data Subjects

9.1 Data Protection Claims

We grant data subjects all claims in accordance with applicable data protection law. Data subjects have the following rights in particular:

·       Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.

·       Rectification and restriction: Data subjects may rectify inaccurate personal data, complete incomplete data and have the processing of their data restricted.

·       Erasure and objection: Data subjects may have personal data erased ('right to be forgotten') and object to the processing of their data with effect for the future.

·       Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

Withdrawal of consent: Where processing is based on your consent, you may withdraw that consent at any time with effect for the future, without affecting the lawfulness of processing carried out before withdrawal.

Automated decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you, save in the cases permitted by law. We do not currently take such decisions (see Section 7.7).

We may postpone, restrict or refuse the exercise of data subjects rights within the legally permissible framework. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of business secrets or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part on the grounds of statutory retention obligations.

In exceptional cases, we may charge a fee for exercising these rights. We will inform data subjects in advance of any costs.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

9.2 Right to Lodge a Complaint

Data subjects have the right to enforce their data protection claims through legal action or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

10. Data Security

We take appropriate technical and organisational measures to ensure data security commensurate with the respective risk. However, we cannot guarantee absolute data security.

Access to our website is secured by transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Like all digital services, we may be subject to lawful data access requests from government authorities and law enforcement agencies. We will only comply with such requests where:

·       The request is legally valid under Swiss law

·       We are legally compelled to comply

·       The request is sufficiently specific and documented

We commit to:

·       Challenging overly broad or inappropriate requests where possible

·       Notifying affected users unless legally prohibited

·       Publishing transparency reports on government requests (if applicable)

·       Minimizing data disclosed to only what is legally required

We implement encryption and security measures to protect your data from unauthorized access, including by third parties and government surveillance programs. However, we cannot guarantee protection against all forms of lawful government access.

Data breach notification: If a personal data breach occurs that is likely to result in a high risk to your personality or fundamental rights, we will notify the competent supervisory authority and, where required, the affected data subjects. In Switzerland we notify the Federal Data Protection and Information Commissioner (FDPIC) as soon as possible in accordance with Art. 24 FADP. Where the GDPR applies, we notify the competent supervisory authority within 72 hours of becoming aware of the breach where feasible (Art. 33 GDPR) and inform affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms (Art. 34 GDPR).

11. Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us at hello@membilla.com. We will delete such data from our systems.

By creating an account, you confirm that you meet the minimum age requirement for your jurisdiction.

12. Use of the Website

12.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data are not necessarily limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as 'session cookies' or for a specific period of time as so-called permanent cookies. 'Session cookies' are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable us, in particular, to recognise a browser when it next visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be deactivated and deleted in whole or in part at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request – at least where and to the extent necessary – your express consent to the use of cookies.

For cookies used to measure success and reach or for advertising, a general objection ('opt-out') is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

Strictly Necessary Cookies

These cookies are essential for the website to function and cannot be disabled.

Analytics Cookies (Require Consent)

Help us understand how visitors use our website.

You can opt-out of Google Analytics: https://tools.google.com/dlpage/gaoptout

Managing Cookies

You can control cookies through:

• Our cookie consent banner (adjust preferences)

• Browser settings (block/delete cookies)

• Third-party opt-out tools (DAA, NAI, EDAA)

Note: Disabling necessary cookies may affect website functionality.

12.2 Server Log Files

We may collect the following information for each access to our website, provided that it is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-pages of our website accessed including the amount of data transferred, last website accessed in the same browser window (referrer).

We store such information, which may also constitute personal data, in server log files. This information is necessary in order to provide our website in a permanent, user-friendly and reliable manner and to ensure data security and, in particular, the protection of personal data – including by third parties or with the help of third parties.

12.3 Tracking Pixels

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.

13. Notifications and Messages

We send notifications and messages by email and via other communication channels such as instant messaging or SMS.

13.1 Success and Reach Measurement

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels may also record the use of notifications and communications on a personalised basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications in an effective and user-friendly manner that is also permanent, secure and reliable, based on the needs and reading habits of the recipients.

13.2 Consent and Objection

You must expressly consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons.

You can object to receiving notifications and communications such as newsletters at any time. By doing so, you can also object to the statistical recording of usage for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.

13.3 Service and Subscription Notifications

As part of the service, and in order to perform our contract with you, we send you service-related notifications concerning your subscriptions. These may include: notifications about price changes for subscriptions you track; subscription overviews and cost summaries; reminders of upcoming subscription renewal dates and cancellation deadlines; and other notifications necessary to provide the service. Because these notifications are necessary to provide the service you have requested, they are sent on the basis of contract performance (Art. 6(1)(b) GDPR; Art. 31 FADP) rather than consent, and cannot be switched off in the same way as marketing communications, although you can configure the channels and, where offered, the scope of these notifications in your account settings.

Personalised reminders: You can set your own personalised notifications for future events (for example a reminder before a specific renewal or cancellation date). To provide this feature we process the subscription and date information you select, together with the reminder settings you configure, in order to send the reminder at the time you have chosen. You can create, change or delete these personalised notifications at any time.

14. Service Providers for Notifications and Communications

We send notifications and communications with the help of specialised service providers.

15. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland.

The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

16. Third-Party Services

We use specialised third-party services to ensure that our activities and operations are sustainable, user-friendly, secure and reliable. These services enable us to embed functions and content into our website, among other things. When embedding such content, the services used collect the Internet Protocol (IP) addresses of users, at least temporarily, for technical reasons.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to offer the respective service.

16.1 Digital Infrastructure

We use services from specialised third parties to access the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

Hosting Provider:

·       Provider: Laravel Cloud (operated on AWS infrastructure)

·       Location: EU Central (Frankfurt, Germany)

·       Purpose: Application hosting, data processing, log and file storage

·       Data Shared: All application data processed by the platform

·       Safeguards: Data is hosted within the EU and protected under GDPR. Standard Contractual Clauses apply if data is transferred outside the EU/EEA.

·       Privacy Policy: https://laravel.com/privacy

Database Services:

·       Provider: Laravel Cloud Managed MySQL (AWS RDS)

·       Location: EU Central (Frankfurt, Germany)

·       Purpose: Secure storage and management of user accounts, subscription records, and operational data

·       Data Shared: User profile data, subscription data, usage-related metadata

·       Safeguards: Data encrypted at rest (AES-256), Data encrypted in transit (TLS 1.2+), Hosted within the EU/EEA (GDPR compliant)

CDN (Content Delivery Network):

·       Provider: Laravel Cloud Default CDN (Cloudflare)

·       Purpose: Performance optimization, caching, DDoS protection, network security

·       Data Shared: IP addresses, device and browser information, and access logs

·       Privacy Policy: https://www.cloudflare.com/privacypolicy/

16.2 Automation and Integration of Apps and Services

We use an artificial-intelligence service (a large language / document-and-image analysis model) provided by Mistral AI, a company established in the European Union (France), to (i) evaluate subscription data captured by our plugin and (ii) extract subscription-relevant information from documents and images that you upload or make available to us (for example invoices, contract confirmations or screenshots). The AI processes the relevant information (such as provider names, dates, prices and subscription terms) in order to improve the accuracy and categorisation of your subscription data and to populate your subscription overview. Processing takes place on infrastructure located in the EU/EEA. We share only the personal data necessary for this specific purpose. Mistral AI acts as our processor under a data-processing agreement (Art. 28 GDPR / Art. 9 FADP) and is contractually prohibited from using your data to train its own models or for its own purposes. Documents and images you upload may contain personal data of third parties or, exceptionally, special-category data; you should not upload information you are not entitled to share, and we process such content only to provide the extraction function and delete the source files in accordance with Section 5.

16.3 Communication Services

Email Service Provider:

·       Provider: Resend

·       Purpose: Delivery of transactional emails and system notifications

·       Data Shared: Email addresses, user names (if provided), email content

·       Location: United States (data transfer involved)

·       Safeguards: Standard Contractual Clauses (SCCs) for cross-border data transfers in accordance with GDPR

·       Privacy Policy: https://resend.com/legal/privacy

Customer Support:

·       Provider: No external customer support platform is used

·       Purpose: Support is handled directly via email communication

·       Data Shared: Email address and the content of the support request

·       Safeguards: Data remains stored within the company's application environment and email systems

16.4 Analytics

Google Analytics:

·       Purpose: Website usage analytics

·       Data Shared: IP address (anonymized), browsing behavior

·       Retention: 26 months

·       Opt-out: Google Analytics opt-out

·       Privacy Policy: https://policies.google.com/privacy

Google Tag Manager:

·       Purpose: Managing tracking codes

·       Data Shared: As per individual tags

·       Privacy Policy: https://policies.google.com/privacy

17. Contact Options

We use services from selected providers to improve communication with third parties, such as potential and existing customers.

18. Measuring Success and Reach

We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and the impact of third-party links to our website. However, we can also test and compare how different parts or versions of our online offering are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content or make improvements to our online offering.

In most cases, the Internet Protocol (IP) addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are always shortened ('IP masking') in order to comply with the principle of data minimisation through appropriate pseudonymisation.

Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service.

19. Copyright

The copyright and all other rights to content, images, photos or other files on the website belong exclusively to the operator of this website or the specifically named rights holders. The written consent of the copyright holder must be obtained in advance for the reproduction of all files.

Anyone who infringes copyright without the consent of the respective rights holder may be liable to prosecution and, if necessary, liable for damages.

20. General Disclaimer

All information on our website has been carefully checked. We make every effort to ensure that the information we provide is up to date, accurate and complete. Nevertheless, the occurrence of errors cannot be completely ruled out, which means that we cannot guarantee the completeness, accuracy and timeliness of information, including journalistic and editorial content. Liability claims arising from material or immaterial damage caused by the use of the information provided are excluded, unless there is evidence of wilful intent or gross negligence.

The publisher may change or delete texts at its own discretion and without notice and is not obliged to update the content of this website. The use of or access to this website is at the visitor's own risk. The publisher, its clients or partners are not responsible for damages, such as direct, indirect, incidental, pre-determined or consequential damages, allegedly caused by visiting this website and therefore accept no liability for such damages.

The publisher also accepts no responsibility or liability for the content and availability of third-party websites that can be accessed via external links on this website. The operators of the linked sites are solely responsible for their content. The publisher hereby expressly distances itself from all third-party content that may be relevant under criminal or civil law or that violates public decency.

21. Final Provisions

21.1 Changes

We may amend and supplement this privacy policy at any time. We will provide information about such amendments and supplements in an appropriate form, in particular by publishing the current privacy policy on our website.

21.2 Data Protection Officer

If you have any questions about data protection or comments on the privacy policy, please send us an email or contact the person responsible for data protection in our organisation listed at the beginning of the privacy policy.