1. INTRODUCTION

Distribusion Technologies GmbH ("we" or “DT”) offers the opportunity to offset the carbon emissions (hereinafter “CO2 Emissions”) associated with Your planned trip. You may contribute to a reduction in emissions in a climate protection project by adding a chosen contribution to Your trip details within the booking procedure (“hereinafter “Our Service”). The Terms and Conditions for the offsetting of CO2 emissions are available here.

 

This notice (the “Privacy Notice”) states the basis and purposes in which Your personal data will be collected, processed, saved, and used to enable Our Service. Furthermore, we state which rights you, as our customers, are entitled to protect and enforce your data protection.

 

2. TERMS

For your better understanding we would like to explain the terms used in this Privacy Notice in simple words in advance:

1. Personal data: any information relating to a Data subject.
 

2. Controller:

Company: Distribusion Technologies GmbH ("we")

Address: Wattstrasse 10, 13355 Berlin

Phone: +49-30-3465507-50

e-mail: dataprotection@distribusion.com

3. Data subject: any natural person using Our Service, that is identified, or directly or indirectly identifiable on the basis of his/her personal data.
 

4. Processing: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data;
 

5. Consent: any freely given, specific, informed and unambiguous indication of the Data subject's intention, by which the Data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her, comprehensively, or for certain operations;
 

6. Transfer: the disclosure of data to a to third countries or international organizations outside the EU;
 

7. Applicable legislation: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, and the Bulgarian data protection legislation (the Personal Data Protection Act and any other relevant laws or secondary legislation), as well as any laws prescribing data retention obligations or other data processing obligations;

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3. PROCESSING

The personal data that We process have been provided by You. Your personal data will be processed and stored by us in compliance with data protection regulations. 

 

Personal data

To process your transaction and provide a receipt for Our service and to allocate the exact offset to your particular journey, We need to collect the following information:

• Your names: an invoice requirement.

• Email address: where You will receive receipt (invoice).

• Payment details: may differ in accordance to the preferred payment method.

Purposes

We collect, process, and use Your personal data only to provide Our service and fulfill all related legal obligations. 
 

Legal Basis 

We process personal data that We require to fulfill or conclude a contract with You or to carry out pre-contractual measures based on Art. 6 para. 1 lit. b GDPR.

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In addition, it may be necessary to process personal data in order to fulfill a legal obligation that We are subject to (Art. 6 para. 1 lit. c GDPR) e.g. to fulfill our tax obligations.

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Duration of Storage

Your personal data will be kept as long as it is necessary for the purposes established in this policy. However, We are obliged by commercial and tax law to store your payment data for the applicable statutory period. This means that your data will then only be stored separately to comply with the statutory retention periods and will be deleted immediately after these periods have expired.

 

Recipients

We will not disclose Your personal data to third parties, except when necessary for Our service or We are obliged to transfer data due to legal provisions and/or official or court directions. This may refer to cases including but not limited to public administrations, including courts, when it is required in accordance with the current legislation in force. 

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Since Our service is ancillary, some personal data might be shared with the carrier of Your booked to allocate the purchased offset to that journey. We encourage you to consult and understand the carrier’s terms & conditions and privacy notice in that case.

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Additionally, companies that provide services to us and are contracted by us may have access to Your personal data. The data will only be passed on to Our Payment Service Provider, depending on the chosen payment method:
 

• Adyen N.V. Simon Carmiggeltstraat 6-50, 1011 DJ The Netherlands.  Adyen’s privacy policy can be found here: https://www.adyen.com/policies-and-disclaimer/privacy-policy 

• Stripe, Inc. 185 Berry Street, Suite 550 San Francisco, CA 94107, USA. If You decide to pay via Stripe, the data You enter will be transmitted to Stripe for payment during sign-up. Stripe stores Your payment data itself. Stripe's privacy policy can be found here: https://stripe.com/de/privacy. Stripe Inc. complies with the U.S. Data Privacy Framework (“EU-U.S. DPF”). This ensures an adequate level of protection for the data when transferred to the USA. More information can be found here: https://stripe.com/en-bg/legal/data-privacy-framework  

 

4. YOUR RIGHTS

1. Right to information acc. Art. 13 GDPR:  to be informed about the collection and use of Your personal data what the purpose of this Privacy Policy is.

2. Right to withdraw Your consent acc. Art. 7 para. 3 GDPR: In cases where the processing of Your personal data is only possible with Your consent, You can revoke this consent at any time in the future. "For the Future" means that Your revocation has no effect on the processing of data that We have made between the granting of Your consent and Your revocation. You do not have to justify Your withdrawal. An informal message via e-mail to dataprotection@distribusion.com is sufficient.

3. Right of access in acc. Art. 15 GDPR: You may request confirmation from us at any time whether We process personal information concerning You.

4. Right to rectification acc. Art. 16 GDPR: You can request correction and supplementation of Your personal data at any time free of charge. 

5. Right to erasure acc. Art. 17 GDPR: You can view Your personal data at any time free of charge and request cancellation if: these are no longer needed for the purpose for which they were processed; You have revoked Your consent and there is no other legal basis for the processing; You have filed an objection against the processing of Your data acc. Art. 21 GDPR,; We have processed Your data unlawfully; the deletion is required to fulfill a legal obligation under EU or national law.

6. Right to restriction of processing acc. Art. 18 GDPR: You can view Your personal data at any time free of charge and, if necessary, request their blocking if: You deny their accuracy; the processing is illegal, but You reject the deletion of the data; We no longer need the data, but You need it for the assertion, exercise or defense of legal claims; You have filed an objection against the processing of Your data acc. Art. 21 GDPR, but it is not yet certain whether our interests in processing outweigh Your interests.

7. Right to data portability acc. Art. 20 GDPR: At our request, We are required to provide You with data that We process automatically based on Your consent or in fulfillment of a contract in a portable and secure format. The direct transfer of data to another controller is also possible at Your request. However, it only takes place if technically feasible. 

8. Right to object acc. Art. 21 GDPR: on grounds relating to Your particular situation, You can object to the processing of personal data carried out on the basis of Our legitimate interest or performed for direct marketing purposes.

9. Right to object to automatic decision-making, including profiling acc. Art. 22 GDPR: to object to a decision-making that is based solely on automated processing, including profiling, which produces legal effects concerning You or in any other similar way significantly affects You.

10. Right to lodge a complaint with a supervisory authority acc. Art. 77 GDPR: Right to lodge a complaint with a supervisory authority acc. Art. 77 GDPR: If You think that We have violated data protection regulations, You can contact a regulatory authority for data protection in the non-public area, in particular the supervisory authority of your habitual residence, your work place or the location of such violation.
     

For more information or to exercise any of Your rights, please contact us via dataprotection@distribusion.com. We may contact and/or request additional information from You, if necessary, to verify Your identity.