Privacy Policy

1. Overview of Data Protection

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can personally identify you. Detailed information on the subject of data protection can be found in the privacy policy set out below.

Data Collection on This Website

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. The operator’s contact details can be found in the section “Information on the Responsible Party” of this privacy policy.

How do we collect your data?

Some of your data is collected when you provide it to us. This may include, for example, data you enter in a contact form.
Other data is automatically collected or obtained with your consent by our IT systems when you visit the website. This includes primarily technical data (e.g., web browser, operating system, or time of page access). The collection of this data occurs automatically as soon as you enter the website.

What do we use your data for?

Part of the data is collected to ensure the website is provided without errors. Other data may be used to analyze user behavior. If contracts can be concluded or initiated via the website, the data provided will also be processed for contract offers, orders, or other business inquiries.

What rights do you have regarding your data?

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

Analysis Tools and Third-Party Tools

When visiting this website, your browsing behavior may be statistically analyzed. This is primarily done using so-called analytics programs.
Detailed information on these analytics tools can be found in the following privacy policy.

2. Hosting

We host our website with the following provider:

Mittwald

Provider: Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, Germany (hereinafter "Mittwald").
For more information, see Mittwald's privacy policy: 
https://www.mittwald.de/datenschutz.

Mittwald is used based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable presentation of our website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) as defined by the TTDSG. Consent can be revoked at any time.

3. General Information and Mandatory Disclosures

Data Protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We point out that data transmission over the Internet (e.g., communication via email) may have security gaps. A complete protection of the data from access by third parties is not possible.

Information on the Responsible Party

The party responsible for data processing on this website is:

Patron Astra S.à.r.l.
6 Avenue Pasteur
2310 Luxembourg

Phone: (+352) 26 26 89 1
Email: geraldine@patroncapital.lu

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

Storage Period

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

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

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or, if special categories of personal data are processed under Art. 9(1) GDPR, on the basis of Art. 9(2)(a) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g., via device fingerprinting), the data processing is additionally based on § 25(1) TDDDG. Consent may be withdrawn at any time.
If your data is necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data based on Art. 6(1)(b) GDPR.
Furthermore, we process your data if it is required for compliance with a legal obligation based on Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR. Specific legal bases relevant to each individual case are explained in the following sections of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, it may be necessary to transmit personal data to these external parties.
We only share personal data with external parties if this is necessary for the fulfillment of a contract, if we are legally obliged to do so (e.g., disclosure to tax authorities), if we have a legitimate interest in the disclosure under Art. 6(1)(f) GDPR, or if another legal basis permits the data transfer.
When using processors, we only share personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement will be concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You may revoke consent at any time. The legality of the data processing carried out before the withdrawal remains unaffected by the withdrawal.

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

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

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING.
IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with a Supervisory Authority

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

Right to Data Portability

You have the right to receive data that we process automatically based on your consent or in fulfillment of a contract, in a structured, commonly used, and machine-readable format, and to have it transmitted to yourself or to a third party. If you request the direct transfer of the data to another controller, this will only be done where it is technically feasible.

Right of Access, Rectification, and Erasure

Within the scope of applicable legal provisions, you have the right at any time to obtain free information about your stored personal data, its origin and recipient, and the purpose of the data processing. You may also have the right to rectification or erasure of this data. For this purpose and for any further questions regarding personal data, you can contact us at any time.

Right to Restriction of Processing

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

  • If you contest the accuracy of your personal data stored by us, we usually need time to verify this. During the verification period, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was or is unlawful, you may request the restriction of data processing instead of erasure.
  • If we no longer need your personal data, but you require it for the establishment, exercise, or defense of legal claims, you have the right to request the restriction of the processing of your personal data instead of its deletion.
  • If you have objected to processing pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it is not yet determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data—apart from being stored—may only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL or TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries you send to us as the site operator. You can recognize an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the lock symbol in your browser bar.
When SSL or TLS encryption is enabled, the data you transmit to us cannot be read by third parties.

4. Data Collection on This Website

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These include:

  • Browser type and version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is not merged with other data sources.
The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of the website—for this purpose, the server log files must be collected.

Contact Form

If you submit inquiries to us via the contact form, the information you provide—including the contact details you enter in the form—will be stored by us for the purpose of processing your inquiry and for follow-up questions. We do not disclose this data without your consent.

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

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

Inquiry by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry including all resulting personal data (e.g. name, request) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

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

The data you send to us via contact inquiries will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for its storage no longer applies (e.g. once your request has been fully resolved). Mandatory legal provisions—especially statutory retention periods—remain unaffected.

5. Analytics Tools and Advertising

Matomo

This website uses the open-source web analytics service Matomo.

Matomo enables us to collect and analyze data about the use of our website by its visitors. This allows us to, for example, identify when particular page views occurred and from which region they originated. We also collect various log files (e.g. IP address, referrer, browser and operating system used) and can measure whether users perform specific actions on our site (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

IP Anonymization

We use IP anonymization with Matomo. This means your IP address is truncated before analysis, so it can no longer be clearly associated with you.

Cookie-Free Analytics

We have configured Matomo in such a way that it does not store any cookies in your browser.

Hosting

We host Matomo with the following third-party provider:
jan pietruska INTERNETAGENTUR
Am Mühlentor 1
17489 Greifswald