Privacy Policy

Subtalks Interactive e.K. – Privacy Policy

Last Updated: 08/04/2024

Your privacy is important to us. It is Subtalks Interactive e.K (hereinafter referred to as “Subtalks”) policy to respect your privacy regarding any information we may collect from you across our website, https://react-to.com, and other sites we own and operate.

This privacy policy is intended to inform users of this website about the nature, scope, and purpose of the collection and use of personal data by the website operator Subtalks.

The website operator takes your data protection seriously and treats your personal data confidentially and in accordance with legal regulations. Please note that data transmission over the Internet can generally be subject to security vulnerabilities. Complete protection against access by third parties is not feasible.

1. Information we collect

The website operator or page provider collects data on access to the site and stores it as “server log files.” The following data is logged:

• Visited website
• Time of access
• Amount of data sent in bytes
• Source/reference from which you accessed the site
• Used browser
• Used operating system
• Used IP address

The collected data serves solely for statistical evaluations and the improvement of the website. However, the website operator reserves the right to retrospectively check the server log files if there are concrete indications of illegal use.

1.1 Handling of Personal Data

The website operator collects, uses, and discloses your personal data only when permitted by law or when you consent to data collection. Personal data includes all information that serves to identify you and can be traced back to you—such as your name, email address, and telephone number.

Order Process
All data entered by customers during the order processing is stored. This includes:

• Name, first name
• Address
• Payment data
• Email address

Data that is essential for delivery or order processing will be passed on to third-party service providers. Once the retention of your data is no longer necessary or legally required, it will be deleted.

Payment Providers

We collaborate with the following payment providers:

• Stripe: Visa, Mastercard, American Express, Maestro, Paypal: https://www.stripe.com/privacy

Stripe is a payment provider and receives payment-relevant information as part of your selection and charge you for the order amount. The privacy policies can be accessed through the links provided above. 

Payout Process
All data entered by users, in this case users with a creator page and earned revenue, during payout reqests processing is stored. This includes:

• Name, first name
• Address
• Payment data
• Email address
• Tax ID
• VAT ID

Data that is essential for delivery or payout processing will be passed on to third-party service providers. Once the retention of your data is no longer necessary or legally required, it will be deleted.

Payout Providers

We collaborate with the following payment providers to process payouts:

• Wise: (International) Bank Transfers: https://wise.com/gb/legal/global-privacy-policy-en

These providers receive payment-relevant information as part of your selection and fulfill your payout amount. The privacy policies can be accessed through the links provided above.

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

• it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
• it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
• you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
• we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

3. Collection and use of information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

• to enable you to customise or personalise your experience of our website https://react-to.com;
• to attribute any content (eg. creator pages) you submit that we publish on our website;
• to deliver products and/or services to you;
• to process payout requests;
• to enable you to access and use our website, associated applications and associated social media platforms;
• to contact and communicate with you;
• for internal record keeping and administrative purposes;
• for analytics, market research and business development, including to operate and improve our website and associated social media platforms;
• for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
• to comply with our legal obligations and resolve any disputes that we may have.

3.1. Handling of Contact Information

When you contact us through the provided contact options, your information is stored so that it can be accessed for the processing and response to your inquiry. Without your consent, this data will not be disclosed to third parties.

4. Disclosure of personal information to third parties

We may disclose personal information to:

• third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
• our employees, contractors and/or related entities;
• courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
• third parties to collect and process data.

For the provision of our website, we utilize the services of a provider whose servers store our website and make it available for retrieval on the internet (hosting). In this process, the provider may process data transmitted via the browser you use when accessing our website. This includes, in particular, your IP address, which the provider requires to deliver our online offering to the browser you are using, as well as all inputs made by you through our website. Additionally, the provider we use may collect:

• Date and time of access to our website
• Time zone difference to Greenwich Mean Time (GMT)
• Access status (HTTP status)
• Transferred data volume
• Internet service provider of the accessing system
• Browser type and its version
• Operating system used by you
• The website from which you may have accessed our website
• The pages or subpages you visit on our website.

The aforementioned data is stored as log files on the servers of our provider. This is necessary to ensure the stability and security of the operation of our website.

Affected Data:

• Content data (e.g., photos, messages, comments)
• Usage data (e.g., access times, clicked web pages)
• Communication data (e.g., information about the device used, IP address)

Processing Purpose: Rendering our website, ensuring the operation of our website

Web Hosting Provider Commissioned by Us:

Constant Company LLC

• Service Provider: Constant Company, LLC
• Address: 319 Clematis St. Suite 900. FL, 33401 West Palm Beach UNITED STATES
• Server Location: Frankfurt, Germany
• Privacy Policy: https://www.vultr.com/legal/privacy/

4.1. Google Ads

We use the online advertising service Google Ads on this website.

By visiting our website, the provider is informed that you have accessed our website. The provider places a cookie on your computer for this purpose. The data mentioned under Section 1 of this statement is transmitted. In addition, so-called web beacons are used, which are invisible graphics that evaluate your user behavior on this website. The IP address transmitted by your browser as part of these services is not merged with other data from the provider. We have no control over the data collected, nor do we know the full extent of data collection. This data is transferred to the USA and analyzed there. It is possible that this data may be disclosed to the provider’s contractual partners and authorities.

You can prevent the installation of Google Ads cookies in various ways: a) by adjusting your browser software accordingly, in particular, suppressing third-party cookies will result in you not receiving ads from third-party providers; b) by deactivating interest-based ads on Google via the link http://www.google.de/ads/preferences, with this setting being deleted when you delete your cookies; c) by deactivating interest-based ads from providers that are part of the “About Ads” self-regulatory campaign via the link http://www.aboutads.info/choices, with this setting being deleted when you delete your cookies; d) by permanently deactivating them in your browsers Firefox, Internet Explorer, or Google Chrome via the link http://www.google.com/settings/ads/plugin. However, we would like to point out that in this case, you may not be able to fully use all the functions of this offer.

For more information on the purpose and scope of data collection and processing, as well as additional information on your related rights and options for protecting your privacy, please contact:

Google Inc., 1600 Amphitheater Parkway, Mountain View, California 94043, USA; Advertising Privacy Policy: http://www.google.de/intl/de/policies/technologies/ads and information on DoubleClick cookies: https://support.google.com/dfp_premium/answer/2839090?hl=de

4.2. Reddit Ads

We use the online advertising service Reddit Ads on this website.

By visiting our website, the provider is informed that you have accessed our website. The provider places a cookie on your computer for this purpose. The data mentioned under Section 1 of this statement is transmitted. Additionally, web beacons are used, which are invisible graphics that evaluate your user behavior on this website. The IP address transmitted by your browser as part of these services is not merged with other data from the provider. We have no control over the data collected, nor do we know the full extent of data collection. This data is transferred to the USA and analyzed there. It is possible that this data may be disclosed to the provider’s contractual partners and authorities.

You can prevent the installation of Reddit Ads cookies in various ways: a) by adjusting your browser software accordingly, in particular, suppressing third-party cookies will result in you not receiving ads from third-party providers; b) by deactivating interest-based ads on Reddit via the link https://www.reddit.com/personalization, with this setting being deleted when you delete your cookies; c) by deactivating interest-based ads from providers that are part of the “About Ads” self-regulatory campaign via the link http://www.aboutads.info/choices, with this setting being deleted when you delete your cookies; d) by permanently deactivating them in your browsers Firefox, Internet Explorer, or Google Chrome via the link http://www.aboutads.info/pmc. However, we would like to point out that in this case, you may not be able to fully use all the functions of this offer.

For more information on the purpose and scope of data collection and processing, as well as additional information on your related rights and options for protecting your privacy, please contact:

Reddit Inc., 548 Market Street, San Francisco, California 94104, USA; Advertising

Privacy Policy: https://www.redditinc.com/policies/privacy-policy

4.3. Quic.Cloud

Subtalks employs the services of QUIC.cloud, a third-party Content Delivery Network (CDN) provider. A CDN is a network of distributed servers that helps enhance the performance and delivery of web content, including but not limited to images, scripts, and stylesheets.

By utilizing QUIC.cloud’s CDN services, we aim to optimize the loading speed of our website, ensuring a better user experience. When you access our website, your web browser may interact with QUIC.cloud’s servers to retrieve certain assets, leading to reduced latency and improved content delivery. QUIC.cloud may collect certain information, such as IP addresses and device characteristics, to facilitate the efficient distribution of content.

By continuing to use our website, you acknowledge and consent to the use of QUIC.cloud’s CDN services as described. If you have any concerns or questions about the privacy practices of QUIC.cloud, please refer to their privacy policy or contact them directly: https://www.quic.cloud/privacy-policy/

4.4. hCaptcha

We use the hCaptcha service on this website specifically only when processing orders, to protect against spam and abuse.

By interacting with our order forms, the provider is informed that you have accessed our website. The provider places a cookie on your computer for this purpose. The data mentioned under Section 1 of this statement is transmitted. hCaptcha may also use invisible graphics (web beacons) to evaluate your user behavior on this website. The IP address transmitted by your browser as part of these services is not merged with other data from the provider. We have no control over the data collected, nor do we know the full extent of data collection. This data is transferred to the USA and analyzed there. It is possible that this data may be disclosed to the provider’s contractual partners and authorities.

You can prevent the installation of hCaptcha cookies in various ways: a) by adjusting your browser software accordingly, in particular, suppressing third-party cookies will result in you not receiving captcha challenges from third-party providers; b) by configuring your browser settings to notify you when a cookie is set and decide on a case-by-case basis whether to accept or reject the cookie. However, we would like to point out that in this case, you may not be able to fully use all the functions of this offer.

For more information on the purpose and scope of data collection and processing, as well as additional information on your related rights and options for protecting your privacy, please contact:

Intuition Machines, Inc., 350 Alabama St, San Francisco, CA 94110, USA;

Privacy Policy: https://www.hcaptcha.com/privacy

5. International transfers of personal information

The personal information we collect is stored and processed in the Federal Republic of Germany, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

6. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 13 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Deletion: You can request your personal information to be deleted by contacting us or by deleting your account within your account settings at any time, but when doing so we are obliged to inform you that we may not be able to provide our services to you. If you want your information to be deleted, please use the contact details below or visit your account settings tab as a logged-in user.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication and your account settings (“Email Notifications”).

7. Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

9. Children’s Privacy

Our website may contain content appropriate for children under the age of 13. As a parent, you should know that through the Service children under the age of 13 may participate in activities that involve the collection or use of personal information. We use reasonable efforts to ensure that before we collect any personal information from a child, the child’s parent receives notice of and consents to our personal information practices.

We also may limit how we collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means we will be unable to provide certain functionality of the Service (such as buying virtual curreny “coins”) to these Users, as mentioned in our terms of use. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

We may ask a User to verify its date of birth before collecting any personal information from them. If the User is under the age of 13, functionality of this website will be either blocked or redirected to a parental consent process.

9.1. Information Collected from Children Under the Age of 13

We may collect and store persistent identifiers such as cookies or IP addresses from Children without parental consent for the purpose of supporting the internal operation of the Service. We may collect and store other personal information about children if this information is submitted by a child with prior parent consent or by the parent or guardian of the child.

We may collect and store the following types of personal information about a child when submitted by a child with prior parental consent or by the parent or guardian of the child:

• First and/or last name
• Date of birth
• Email address
• Telephone number
• Parent’s or guardian’s name
• Parent’s or guardian’s email address

For further details on the information we might collect, you can refer to the “Collection and use of information” section of this Privacy Policy. We follow our standard Privacy Policy for the disclosure of personal information collected from and about children.

9.2. Parental Access

A parent who has already given us permission to collect and use his child’s personal information can, at any time:

• Review, correct, or delete the child’s personal information
• Discontinue further collection or use of the child’s personal information

To make such a request, you can write to us using the contact information provided in this Privacy Policy.

10. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

11. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

Service provider according to § 5 of the Telemedia Act:

Subtalks Interactive e.K.

Address:
Dreschbogen 12
24943 Flensburg, Germany

Commercial Register:
Local Court Flensburg – HRA 11214 FL
VAT Identification Number:
DE366063984

Authorized to represent:
Lasse Boderius

Contact:
Email: hello@react-to.com
Phone: +49 40 23969749

Dispute resolution
The European Commission provides a platform for online dispute resolution, which you can find at the
Internet address https://ec.europa.eu/consumers/odr/.

We are not willing and not obliged to participate in a dispute resolution procedure before a consumer arbitration board

This policy is effective as of 04 August 2024.