Notes on data protection

The guppyi.com platform gives you an excellent way to control visuals for your live stream, create teams and share team data.

The offer to participate in the guppyi.com – Internet platform is made available by incast GmbH, Kleine Weinbergstrasse 7, 14943 Luckenwalde, Germany, (District Court Potsdam) under the domain guppyi.com within the scope of the technical and operational possibilities. Incast GmbH understands that it is part of its responsibility to protect the information and data entrusted to it with state-of-the-art technology. Data protection principles such as data minimization, transparency and security therefore have the highest priority at incast GmbH. In order to enable participation in the guppyi.com community and to ensure the best possible use of the individual functionalities, we must, among other things, also provide personal,i.e. collect, store and process personal data of you for these purposes. The protection and security of personal information is a matter of serious concern to us. Therefore, we process your personal data only under consideration of the relevant legal provisions.

If you have any questions about privacy, feel free to email info@guppyi.com.

 

Data protection

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as «Data») within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the «Online Offering»). With regard to the terminology used, e.g. «Processing» or «Responsible», we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible

Responsible for the processing of your personal data is incast GmbH, Kleine Weinbergstr. 7, 14943 Luckenwalde, Germany, +49 (0) 3371 4039577, info@guppyi.com

Types of processed data:

When you visit our website, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected and stored until automated deletion:

– Inventory data (e.g., names, addresses).
– contact information (e.g., e-mail, phone numbers).
– content data (e.g., text input, photographs, videos).
– usage data (e.g., websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).

Categories of affected persons

Visitors and users of the online offer (hereinafter we refer to the affected persons as «users»).

Purpose of processing

– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach Measurement / Marketing

Used terms

«Personal data» means any information relating to an identified or identifiable natural person (hereinafter the «data subject»); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

«Processing» means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.

«Pseudonymisation» means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

«Profiling» means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.

«Responsible person» means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.

«Processor» means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.

Safety measures

We take appropriate technical measures in accordance with Art. 32 DSGVO, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 DSGVO).

Collaboration with processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (eg if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to a legal obligation or based on our legitimate interests (eg the use of agents, webhosters, etc.).

If we commission third parties to process data on the basis of a so-called «contract processing contract», this is done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called «standard contractual clauses»).

Rights of data subjects

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.

According to Art. 77 GDPR, they also have the right to lodge a complaint with the competent supervisory authority.

Withdrawal

Sie haben das Recht, erteilte Einwilligungen gem. Art. 7 Abs. 3 DSGVO mit Wirkung für die Zukunft zu widerrufen

right of objection

You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right to object in direct mail

«Cookies» are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or «session cookies» or «transient cookies», are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term «permanent» or «persistent» refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A «third-party cookie» refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called «first-party cookies»).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general contradiction against the use of the cookies used for the purpose of online marketing can in a variety of services, especially in the case of tracking, on the US sidehttp://www.aboutads.info/choices/ or the EU sidehttp://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.

Deletion of data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That The data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, relevant for taxation Documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).

According to legal regulations in Austria the storage takes place especially for 7 years according to § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.

Business-related processing

In addition we process
– contract data (e.g., subject, term, customer category).
– Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Order processing in the online shop and customer account

We process the data of our customers as part of the ordering process in our online shop to allow them to select and order the selected products and services, as well as their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, payment data and persons affected by the processing belong to our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery and customer service. Here we use session cookies for the storage of the shopping cart contents and permanent cookies for the storage of the login status.

Processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The information marked as required for the establishment and fulfillment of the contract is required. We disclose the data to third parties only in the context of extradition, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if necessary for the fulfillment of the contract (for example, on customer’s request upon delivery or payment).
Users can optionally create a user account, in particular by being able to view their orders. As part of the registration, the necessary mandatory information will be communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. Information in the customer account remains until its deletion with subsequent archiving in case of a legal obligation. It is the responsibility of the users to secure their data upon termination before the end of the contract.

As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO.

The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation).

External payment service providers

We use external payment service providers through whose platforms users and we can make payment transactions (for example, with a link to the privacy policy,
Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full),
Klarna (https://www.klarna.com/de/datenschutz/),
Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/),
Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/),
Visa (https://www.visa.de/datenschutz),
Mastercard (https://www.mastercard.de/de-de/datenschutz.html),
American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)

As part of the fulfillment of contracts, we set the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Incidentally, we use external payment service providers on the basis of our legitimate interests. Art. 6 para. 1 lit. f. DSGVO in order to offer our users effective and secure payment options.

Amongst the data processed by the payment service providers are inventory data, e.g. the name and the address, bank data, such as Account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, summary and recipient-related information. The information is required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. That We do not receive any account or credit card information, but only information with confirmation or negative disclosure of the payment. The data may be transmitted by the payment service providers to credit reporting agencies. This transmission aims at the identity and credit check. For this we refer to the terms and privacy policy of payment service providers.

For the payment transactions, the terms and conditions and the privacy notices of the respective payment service providers, which are available within the respective websites, or transaction applications apply. We also refer to these for further information and assertion of rights of withdrawal, information and other data subjects.

Registration function

Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and based on Art. 6 para. 1 lit. b DSGVO processed for purposes of providing the user account. The processed data include in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.

Users may have access to information relevant to their user account, e.g. technical changes, be informed by e-mail. If users have terminated their user account, their data will be deleted with respect to the user account, subject to a statutory retention requirement. It is the responsibility of the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

In the context of the use of our registration and registration functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c. DSGVO. The IP addresses will be anonymized or deleted after 7 days at the latest.

Comments and posts

If users leave comments or other contributions, their IP addresses may be based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO be stored for 7 days. This is for our own safety, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, in accordance with our legitimate interests. Art. 6 para. 1 lit. f. DSGVO to process the information of users for the purpose of spam detection.

On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for the duration of their use and to use cookies to avoid multiple votes.

The data provided in the comments and contributions are stored by us permanently until the users object.

contact

When contacting us (for example, by contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its processing in accordance with. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) DSGVO processed .. User information can be stored in a Customer Relationship Management System («CRM System») or similar request organization.

We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter «newsletter») only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us.

Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.

Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.

The dispatch of the newsletter and the associated performance measurement are based on a consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 DSGVO i.V.m § 7 Abs. 2 No. 3 UWG or if consent is not required, based on our legitimate interests in the direct marketing acc. Art. 6 para. 1 lt. F. DSGVO i.V.m. § 7 Abs. 3 UWG.

The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent.

Termination / Revocation – You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Hosting and e-mailing

The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services we use to operate this online service.

Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of data processing).

Collection of access data and log files

We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider ,

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.

Google Analytics

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), Google Analytics uses a web analytics service provided by Google LLC («Google»). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available under the following link:http://tools.google.com/dlpage/gaoptout?hl=de.

For more information about Google’s data usage, hiring and opt-out options, please refer to Google’s Privacy Policy(https://policies.google.com/technologies/ads) as well as in the settings for the display of advertising impressions by Google(https://adssettings.google.com/authenticated).

The personal data of users will be deleted or anonymized after 14 months.

Integration of services and contents of third parties

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Services, such as Include videos or fonts (collectively referred to as «content»).

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as «web beacons») for statistical or marketing purposes. The «pixel tags» can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.

Youtube

We embed the videos on the YouTube platform of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Created with Datenschutz-generator.de (and translate by google) RA Dr. Thomas Schwenke

 

Affected rights and right of appeal

As a person concerned with the processing of personal data, you have the right

  1. a) in accordance with Art. 15 DSGVO, to request information about your personal data processed by us. In particular, you may provide information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned retention period, the right to rectification, deletion, limitation of processing or opposition, the existence of a The right to complain, the origin of your data, if it was not collected from us, as well as the existence of an automated decision-making including profiling and, if necessary, meaningful information about their details;
  2. b) in accordance with Art. 16 DSGVO, to demand the rectification of incorrect or completed personal data stored by us immediately;
  3. c) in accordance with Art. 17 DSGVO, to request the deletion of your personal data stored by us, except where the processing is for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of the public interest or for the assertion, exercise or defense of legal claims is required;
  4. d) in accordance with Art. 18 GDPR to demand the restriction of the processing of your personal data, as far as the accuracy of the data is disputed by you, the processing is unlawful, but you reject their deletion and we no longer need the data, but you to assert, exercise or defense of legal claims or you have objected to processing pursuant to Art. 21 GDPR;
  5. e) in accordance with Art. 20 DSGVO to receive your personal data that you have provided us in a structured, common and machine readable format or to request the transfer to another person responsible and
  6. f) according to Art. 77 GDPR to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or work or our place of business. The supervisory authority responsible for our place of business is «Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg» Stahnsdorfer Damm 77
    14532 Kleinmachnow – Germany.

To assert your rights, please send an e-mail to info@guppyi.com

Right of revocation in case of processing on the basis of a consent

If your personal data are based on consent in accordance with Art. 6 (1) sentence 1 lit. A DSGVO be processed (for example, the newsletter), you have the right at any time to revoke your consent without giving any reason. As a result, we are no longer allowed to continue the data processing based on this consent for the future. However, the revocation of your consent does not affect the legality of the processing carried out on the basis of the consent until the revocation. If you would like to exercise your right of withdrawal, please send an e-mail to info@guppyi.com

right of objection

If your personal data based on legitimate interests in accordance with Art. 6 para. 1 p. 1 lit. f DSGVO are processed, you have the right to file an objection against the processing of your personal data in accordance with Art. 21 DSGVO, provided there are reasons for this arising from your particular situation. If your objection to direct mail is directed, you have a general right of opposition; a justification is not required for these cases.

If you want to exercise your right to object, just send an e-mail to info@guppyi.com.

data security

Within the site visit where personal information is processed, we use the popular Secure Socket Layer (SSL) technology combined with the highest level of encryption supported by your browser. Whether a single page of our website is encrypted transmitted, you can see the closed representation of the bowl or lock icon in the lower status bar of your browser. We also take appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or total loss, destruction or against unauthorized access by third parties. We adapt our security measures according to the technological development continuously.

Up-to-dateness and change of this data protection explanation

This Privacy Policy is as of July 2018. Due to the evolution of our website and offers, or due to changed legal or regulatory requirements, it may be necessary to change this privacy policy. The latest privacy policy can be accessed and printed by you at any time at https://guppyi.com/datenschutz .