Privacy Policy

1. Introduction

In the following, we provide information about the collection of personal data when using:

  • Our website after.life

  • Our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1 Contact Details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Encode Talent GmbH, Koppenstraße 93, 10243 Berlin, Germany, email: info@encodetalent.com. We are legally represented by Aurelia S. Ortiz.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2 Scope of Data Processing, Processing Purposes, and Legal Bases

We detail the scope of data processing, processing purposes, and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.

  • Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g., if a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing necessary for pre-contractual measures, such as inquiries about our products or services.

  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.

  • Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g., for cookies necessary for the technical operation of our website.

1.3 Data Processing Outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g., for Great Britain, Canada, and Israel) (Art. 45 para. 3 GDPR).

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU-US Data Privacy Framework.

In other cases (e.g., if no adequacy decision exists), the legal basis for the data transfer is usually standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4 Storage Duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e., the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5 Rights of Data Subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access

  • Right to correction or deletion

  • Right to limit processing

  • Right to object to the processing

  • Right to data transferability

  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at this link.

1.6 Obligation to Provide Data

Within the scope of the business or other relationships, customers, prospective customers, or third parties need to provide us with personal data necessary for the establishment, execution, and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or provide a service or will no longer be able to perform an existing contract or other relationships. Mandatory data are marked as such.

1.7 No Automatic Decision-Making in Individual Cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with Article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8 Making Contact

When contacting us, e.g., by e-mail or telephone, the data provided to us (e.g., names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9 Customer Surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Data Processing on Our Website

2.1 Notice for Website Visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g., cookies) or accesses information already stored in the terminal equipment (e.g., IP addresses). What information this is in detail can be found in the following sections.

This storage and access are based on the following provisions:

  • Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Digital Services Data Protection Law (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz, "TDDDG").

  • Otherwise, this storage or access takes place on the basis of the website visitor's consent (Section 25 para. 1 TDDDG).

The subsequent data processing is carried out in accordance with the following sections and based on the provisions of the GDPR.

2.2 Informative Use of Our Website

During the informative use of the website, i.e., when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server to ensure the stability and security of our website. This is our legitimate interest, so the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

  • IP address

  • Date and time of the request

  • Time zone difference to Greenwich Mean Time (GMT)

  • Content of the request (specific page)

  • Access status/HTTP status code

  • Amount of data transferred in each case

  • Website from which the request comes

  • Browser

  • Operating system and its interface

  • Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

2.3 Web Hosting and Provision of the Website

Our website is hosted by Squarespace. The provider is Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland. In doing so, the provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data in the USA. Further information can be found in the provider's privacy policy at Squarespace Privacy.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR. The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We use a content delivery network to help provide our website. The provider is Mailchimp. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data. It is our legitimate interest to provide a website, so the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

We use the content delivery network Squarespace for our website. The provider is Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data in the USA. Further information can be found in the provider's privacy policy at Squarespace Privacy.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR. The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We use the content delivery network Shopify for our website. The provider is Shopify International Limited, Victoria Buildings, 2. Etage, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data in the USA. Further information can be found in the provider's privacy policy at Shopify Privacy.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR. The legal basis of the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

2.4 Vacant Positions

We publish positions that are vacant in our company on our website, on pages linked to the website, or on third-party websites. The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.

Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR). We ask applicants to refrain from providing information on political opinions, religious beliefs, and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR). Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting, and to the employees otherwise involved in the application process. If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant. If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.

2.5 Payment Processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

  • American Express Europe S.A.

  • Klarna Bank AB (publ), Sweden (for "Klarna Sofort")

  • Mastercard Europe SA, Belgium

  • PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg

  • Visa Europe Services Inc., Great Britain

2.6 Technically Necessary Cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective, and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.

Specifically, we set technically necessary cookies for the following purpose or purposes:

  • Cookies that store log-in data.

2.7 Third Parties

2.7.1 Shopify

We use Shopify to maintain an online store. The provider is Shopify International Limited, Victoria Buildings, 2. Etage, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland. The provider processes meta/communication data (e.g., device information, IP addresses) in the EU. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at Shopify Privacy.

2.7.2 Google Conversion Tag

We use Google Conversion Tag for conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) in the USA. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider. The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at Google Privacy and Google Tag Manager Support.

2.7.3 Meta Pixel

We use Meta Pixel for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) in the USA. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider. The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at Facebook Privacy.

2.7.4 Facebook Conversion API

We use Facebook Conversion API for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider. The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at Facebook Privacy.

2.7.5 Google Tag Manager

We use Google Tag Manager for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) in the USA. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider. We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at Google Privacy.

2.7.6 Twitter Tweet Button

We use Twitter Tweet Button to share interests in social media. The provider is Twitter International Company, 26 Fenian St, Dublin, D02 FX09, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is consents. We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at Twitter Privacy.

2.7.7 Mailchimp

We use Mailchimp to manage emails and for email marketing. The provider is Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. The provider processes usage data (e.g., web pages visited, interest in content, access times), content data (e.g., entries in online forms), contact data (e.g., e-mail addresses, telephone numbers), and meta/communication data (e.g., device information, IP addresses) in the USA. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider. The data is deleted when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at Mailchimp Privacy.

2.7.8 Squarespace

We use Squarespace to create websites. The provider is Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland. The provider processes meta/communication data (e.g., device information, IP addresses) in the USA. The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider. The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at Squarespace Privacy.

3. Data Processing on Social Media Platforms

We are represented in social media networks to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so they process data there. This may result in risks for users, e.g., because it is more difficult to enforce their rights or because government agencies access the data. If users of the networks contact us via our profiles, we process the data provided to us to respond to the inquiries. This is our legitimate interest, so the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

3.1 Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: Facebook Privacy. A possibility to object to data processing arises via settings for advertisements: Facebook Settings.

We are joint controllers for processing the data of visitors to our profile based on an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at Facebook Data Processing. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

3.2 Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: Instagram Privacy.

4. Changes to This Privacy Policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

5. Questions and Comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.