Privacy Policy

Data Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection provisions is:

CamperaMedia Inh. Rahim Erbil
Wiesenstr. 12
61184 Karben
Germany
Email: contact@camperamedia.com

1. What is personal data?

The concept of personal data is defined in the EU GDPR. This includes all information relating to an identified or identifiable natural person (Art. 4 No. 1 GDPR) – for example your name, address, telephone number, or IP address.

2. Web Hosting (ALL-INKL)

We host our website with the provider ALL-INKL.COM - Neue Medien Münnich, owner René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany (hereinafter: ALL-INKL). To ensure compliance with data protection laws, we have concluded a Data Processing Agreement (DPA) pursuant to Art. 28 GDPR with ALL-INKL. When you visit our website, your data is processed on ALL-INKL's servers in Germany.

3. Scope of Data Collection

When you access our website, our hosting provider ALL-INKL automatically collects server log files (see Section 6). Beyond this, we only process data if you actively communicate it to us (e.g. by email or contact forms) or if you consent to the use of analytics tools (Google Analytics) via our cookie banner.

4. Legal Basis of Processing

The processing of your data is always carried out in accordance with the GDPR:

• Consent (Art. 6 (1) lit. a GDPR): For optional cookies (e.g. Google Analytics).
• Performance of a contract or pre-contractual measures (Art. 6 (1) lit. b GDPR): For processing project inquiries or booking meetings.
• Legal obligation (Art. 6 (1) lit. c GDPR): If we are legally required to store data.
• Legitimate interests (Art. 6 (1) lit. f GDPR): For the secure and error-free operation of our website (server log files).

5. Cookies & Cookie Management

Our website uses cookies. Cookies are text files stored on your device. We use a privacy-compliant first-party consent procedure. Your decision is saved in a local cookie named cm_cookie_consent on your browser, so that the banner does not reappear on every page visit.

Overview of Cookies Used:

• cm_cookie_consent: Local first-party cookie storing your consent status (value: 'all' or 'essential'). Lifetime: 1 year (365 days). Legal basis: Art. 6 (1) lit. c GDPR in conjunction with § 25 (2) No. 2 TDDDG (technically necessary).
• Google Analytics Cookies (only after consent): _ga (lifetime: 2 years, used to distinguish users), _gid (lifetime: 24 hours, used to distinguish users), _gat (lifetime: 1 minute, used to throttle request rate). Legal basis: Art. 6 (1) lit. a GDPR in conjunction with § 25 (1) TDDDG.
• Meta Pixel cookie (only after consent): _fbp (lifetime: 3 months, used to distinguish visitors for ad measurement, see Section 10). Legal basis: Art. 6 (1) lit. a GDPR in conjunction with § 25 (1) TDDDG.

You can revoke or adjust your cookie consent at any time. Simply click on the link Privacy Settings in the footer of our website to reopen the consent banner.

6. Server Log Files

The hosting provider ALL-INKL automatically collects and stores the following information in server log files whenever you visit our website:

• Browser type and version used
• Operating system of the user
• Referrer URL (the previously visited page)
• Hostname of the accessing computer (anonymized IP address)
• Date and time of the server request

Processing this data is technically necessary to operate the website safely and reliably (legal basis: Art. 6 (1) lit. f GDPR). For security reasons, server log files are stored for a maximum of 7 days and then automatically deleted.

7. Contacting Us (Email & Forms)

If you contact us by email or via a contact form, the data you transmit (e.g. name, email address, message content) will be stored for the purpose of processing your inquiry. We delete this data as soon as your request has been finaly resolved, provided that no statutory commercial or tax retention obligations (e.g. 6 years for business letters, 10 years for tax records) prevent deletion. Legal basis: Art. 6 (1) lit. b or lit. f GDPR.

7.1 Contact via WhatsApp

If you contact us via WhatsApp, we process your phone number, name, and message content based on Art. 6 (1) lit. f GDPR (legitimate interest in efficient communication) or Art. 6 (1) lit. b GDPR. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (a subsidiary of Meta Platforms Inc., USA). Data transfers to Meta Platforms Inc. in the USA may occur. Meta is certified under the EU-U.S. Data Privacy Framework (DPF), and Standard Contractual Clauses (SCCs) are concluded. For details, see WhatsApp's privacy policy: https://www.whatsapp.com/legal/privacy-policy-eea

8. Meeting Booking System (Cal.com)

For online booking of consultation slots, we use Cal.com, provided by Cal.com, Inc., 13895 Biscayne Blvd, Suite 105, North Miami, FL 33181, USA. When you book a slot, the details you enter (name, email, phone number, date/time, and description of your request) are transferred to and processed on Cal.com's servers. Processing is carried out for contract performance or pre-contractual measures (Art. 6 (1) lit. b GDPR). We have concluded a Data Processing Agreement (DPA) including EU Standard Contractual Clauses (SCCs) with Cal.com to secure the international transfer of data.

9. Google Analytics

If you grant your consent (Art. 6 (1) lit. a GDPR in conjunction with § 25 (1) TDDDG), we use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google). Google Analytics uses cookies to analyze website usage. The information generated by the cookie is typically transferred to and stored on Google LLC servers in the USA. We have enabled IP anonymization so that Google shortens your IP address within the EU prior to transfer.

Google processes this data on our behalf under a DPA (Art. 28 GDPR). Google LLC (USA) is certified under the EU-U.S. Data Privacy Framework (DPF) and Standard Contractual Clauses are concluded. Data is automatically deleted after 14 months. You can revoke your consent at any time by opening the Privacy Settings link in the footer and updating your choices, or by installing the Google Opt-out Browser Add-on: tools.google.com/dlpage/gaoptout

10. Meta Pixel

If you grant your consent (Art. 6 (1) lit. a GDPR in conjunction with § 25 (1) TDDDG), we use the Meta Pixel provided by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter: Meta). The pixel is only loaded after you accept in the cookie banner. Before that, no Meta code is embedded and no cookie is set. After consent, the pixel records page views and certain actions, such as requesting an audit or booking an intro call, and sets the cookie _fbp with a lifetime of 3 months. Your name, your email address and the content of your request are not sent to Meta.

We use this data to measure the performance of our ads on Facebook and Instagram and to show ads to people who have already visited our website or who resemble those visitors (Custom Audiences and Lookalike Audiences). For the collection of data on our website and its transfer to Meta, we and Meta are joint controllers (Art. 26 GDPR). Any further processing by Meta, including for its own purposes, is Meta's sole responsibility. Data may be transferred to Meta Platforms Inc. in the USA. Meta Platforms Inc. is certified under the EU-U.S. Data Privacy Framework (DPF).

You can revoke your consent at any time by opening the Privacy Settings link in the footer and declining cookies. You can manage your ad settings with Meta at facebook.com/ads/preferences. More information: facebook.com/privacy/policy.

11. YouTube with Enhanced Privacy

We embed videos from YouTube, operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We use YouTube's enhanced privacy mode (youtube-nocookie.com), which means Google only sets cookies and registers data (such as your IP address) when you click play. Data transfers to Google LLC in the USA may occur; Google LLC is DPF certified and Standard Contractual Clauses are in place. The legal basis for data transmission upon clicking the video is your consent (Art. 6 (1) lit. a GDPR).

12. Click Measurement in Our Emails

Links in the emails we send may carry an identifier for the campaign, the linked page and the audience addressed (example: campera.media/k/campaign/page/audience). If you open such a link, you are forwarded to the linked page immediately. We record only the campaign, the page opened, the audience label and the point in time. We do not store your email address, your IP address, your browser identification or any identifier of your device. No profile is created and no link to you as a person is established. No cookie is set for this purpose, and no information is accessed on your device.

To tell a repeated opening of the same link apart from a first one, we derive a check value from your IP address and your browser identification. It is generated using a random value that changes daily and cannot be reversed. The check value and the random value are deleted after two days at the latest; after that, the check value can no longer be reproduced, not even by us. The IP address itself is never stored. The remaining entries (campaign, page, audience, point in time) do not permit any link to you as a person and are kept for statistical analysis.

The purpose is to measure the success of our outreach at campaign level. The legal basis is our legitimate interest in an economical organisation of our communication (Art. 6 (1) lit. f GDPR). You may object to this processing at any time (see section 13.6), informally by email to contact@camperamedia.com.

Campaign parameters are appended to the target address (utm_source, utm_medium, utm_campaign, utm_content, utm_term). Google Analytics evaluates these only if you have previously consented to the use of Google Analytics (see section 9).

Recognition on the website after a click from our email. If a link in one of our emails leads to this website, the redirect appends a random identifier to the address (parameter cmk, twelve characters). The identifier is tied to the individual email we sent you, and therefore to you as a person. As long as you move on via our internal links, it stays in the address bar, and on every page view your browser reports the identifier, the path of the page, the language, the time the page was visible, and whether you interacted with the page (yes or no only: scrolled, tapped, clicked or moved the mouse, with no positions and no input) to our own system at cma.campera.media. This tells us which of our pages you looked at after the click and for how long, and we shape the content of our further outreach accordingly. The interaction flag serves only to tell a visit by a person apart from one by an automated link scanner. No cookie is set and nothing is stored on or read from your device. If you open an address without the identifier, the association ends. As the identifier is part of the page address, Google Analytics and the Meta Pixel receive it together with the page address if you have consented to these services (see sections 9 and 10); neither Google nor Meta can link it to any email or person, that link exists only in our system. Your IP address is kept only as a check value that cannot be reversed, and your browser identification for two days at most; the page views themselves are deleted no later than 180 days after the visit. The legal basis is our legitimate interest in aligning our outreach with the interest you have shown (Art. 6 (1) lit. f GDPR). You may object to this processing at any time (see section 13.6), informally by email to contact@camperamedia.com; we will then delete the page views.

13. Your Rights as a Data Subject (Art. 15-22 GDPR)

You can exercise your data subject rights at any time, free of charge, by emailing us at contact@camperamedia.com. You have the following rights under the GDPR:

13.1 Right of Access (Art. 15 GDPR)

You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and to receive information about the purposes, categories, recipients, and planned storage duration of the data.

13.2 Right to Rectification (Art. 16 GDPR)

You have the right to obtain the rectification of inaccurate or completion of incomplete personal data stored by us without undue delay.

13.3 Right to Erasure (Art. 17 GDPR)

You have the right to request the deletion of your personal data stored by us, unless a statutory exception (such as legal retention requirements) applies.

13.4 Right to Restriction of Processing (Art. 18 GDPR)

You have the right to restrict processing if you contest the accuracy of the data, the processing is unlawful, we no longer need the data but you require it for legal claims, or you have objected to processing pursuant to Art. 21 GDPR.

13.5 Right to Data Portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you, which you provided to us, in a structured, commonly used, and machine-readable format, or to demand transfer to another controller, provided the processing is based on consent or a contract.

13.6 Right to Object (Art. 21 GDPR)

If your data is processed based on legitimate interests (Art. 6 (1) lit. 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. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests. You may object to processing for direct marketing purposes at any time.

13.7 Right to Withdraw Consent

You have the right to withdraw your consent (e.g. for Google Analytics) at any time with effect for the future. The lawfulness of processing based on consent before its withdrawal remains unaffected.

13.8 Right to Lodge a Complaint with a Supervisory Authority (Art. 77 GDPR)

You have the right to lodge a complaint with a data protection authority concerning the processing of your personal data by us, e.g., in the member state of your residence or where our business is located.

14. Data Security

We use SSL/TLS encryption for all data transfers on our website. Furthermore, we implement appropriate technical and organizational measures (TOMs) to secure your data against accidental manipulation, loss, destruction, or unauthorized access by third parties. Our security procedures are regularly reviewed and updated in line with technological progress.

15. Review Page and Writing Aid

After a project is finished we occasionally ask clients by email for a review on Google or Trustpilot. The link in that email contains a random identifier. On our server we keep the company name, the project, its scope and, where applicable, a result, so that the page can name the project. We also record how often the page was opened through this link, how many drafts were created and whether Google, Trustpilot or the direct feedback route was clicked. We do not store IP addresses for this. The link is valid for 60 days, and we delete the record 30 days after that. The legal basis is our legitimate interest in feedback on our work (Art. 6(1)(f) GDPR). If you would rather not receive such requests, reply briefly to the email or write to contact@camperamedia.com.

On request the page creates a draft text. This happens only after you click "Create draft". For this we send the project details, the selected keywords, tone, length and an optional note to the Gemini API service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which creates the draft with an AI language model. Processing may take place on servers of Google LLC in the USA. We do not transmit names of people or email addresses. Please do not enter personal data in the note. We use the paid version of the service: Google processes the data on our behalf under its data processing addendum, does not use it to improve its products according to its terms, and logs requests and responses only for a limited period to detect abuse. We do not store the draft itself. Whether and what you publish is your decision. Reviews on Google or Trustpilot are subject to the privacy terms of the respective platform.

If you have given your consent, Trustpilot A/S, Pilestræde 58, 5th Floor, 1112 Copenhagen K, Denmark, additionally invites you by email to leave a review. For this we pass your email address, your name and a project reference number to Trustpilot. This is the only way Trustpilot can link the review to an actual engagement and mark it as verified. Trustpilot processes this data on our behalf under a data processing agreement. The legal basis is your consent (Art. 6(1)(a) GDPR, Section 7(2) no. 2 German Unfair Competition Act), which you can withdraw at any time with effect for the future, by email to contact@camperamedia.com or via the unsubscribe link in the email from Trustpilot. We ourselves only store the time of the invitation and the reference number.

For questions regarding data protection, please contact: contact@camperamedia.com