This policy explains how personal data is processed within our social media funnel, from the interaction on Instagram through sign-up to delivery of the free download. The German version is the legally binding one; this English version is provided for convenience.
1. Controller
Quace World GmbH
Schloss Kränzlin, Darritzer Straße 6, 16818 Kränzlin, Germany
You have the right to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and the right to object (Art. 21). You may withdraw any consent given at any time with effect for the future (Art. 7(3)). You also have the right to lodge a complaint with a supervisory authority.
3. Competent supervisory authority
The State Commissioner for Data Protection and the Right to Inspect Files of Brandenburg (LDA Brandenburg)
Our landing and download pages are provided on the HighLevel platform. When you access them, technically necessary data such as IP address, date and time, browser type and the page requested are processed to deliver and secure the page. The legal basis is our legitimate interest in stable and secure operation (Art. 6(1)(f) GDPR).
5. Instagram interaction and comment-to-message
If you comment on one of our Instagram posts, an automated direct message containing a link may be triggered. This automated message is sent via the Instagram platform and the systems we use (see section 7). Your interaction on Instagram is additionally subject to Meta’s own processing. The legal basis for the message we initiate is the interest you express through your comment together with our legitimate interest in responding (Art. 6(1)(f) GDPR).
6. Sign-up and newsletter with double opt-in
To provide the free download and the subsequent newsletter we collect your email address. Sign-up uses the double opt-in procedure: after submitting, you receive an email with a confirmation link, and we only send the download and further information once you confirm. We store the time of sign-up and of confirmation in order to evidence consent. The legal basis is your consent (Art. 6(1)(a) GDPR). You can unsubscribe at any time via the link in every email.
7. Service providers and transfers to third countries
We share personal data with the following recipients, who act as processors on our behalf under data processing agreements pursuant to Art. 28 GDPR.
• HighLevel, Inc., 1801 N. Lamar, Suite 600, Dallas, Texas 75202, USA: provision of our CRM, the landing and download pages, email dispatch, and hosting and delivery of the download files.
• Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland: operation of the Instagram platform, where the interaction and the automated direct message take place. Meta additionally processes data under its own responsibility and privacy policy.
Processing by HighLevel also takes place in the United States. The transfer is based on HighLevel’s certification under the EU-US Data Privacy Framework, supplemented by EU Standard Contractual Clauses.
8. Retention
We retain your data for as long as your consent is in place and the respective purpose requires it. After a withdrawal or unsubscribe, your data is removed from the active distribution list; evidence of the original consent may be retained to comply with legal obligations.
9. Updates
We will update this privacy policy whenever changes to our processing or to the legal framework make it necessary.