Privacy policy

To see our data processing agreement please visit this page.

I. General Information

Riddle Technologies AG, Lenaustr. 1, 66125 Saarbrücken, and its Management Board attach great importance to protecting the personal data of users of the www.riddle.com website. We would therefore like to inform you in detail below about what data we collect from you when you visit our website and use our offers there, how we process or use this data, and what rights you have in this respect.

We will only process your personal data based on statutory data protection laws, namely the EU General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG-new), and the Digital Services Act (DDG).

The scope of the data collected and processed by us differs depending on whether you visit our website only to retrieve information or also use services offered by us via our website.

II. Person Responsible

The controller, within the meaning of the General Data Protection Regulation and other data protection regulations, is

Riddle Technologies AG, Lenaustr. 1, 66125 Saarbrücken,
represented by the Management Board, ibid.
Phone: 06897-9392500
E-mail: hello@riddle.com

III. Our Data Protection Officer

The company data protection officer of Riddle Technologies AG can be contacted at the above address for the attention of Mr. Pikolleck or at datenschutz@riddle.com.
Any data subject can contact our data protection officer directly at any time with any questions or suggestions relating to data protection.

IV. Definitions

Our privacy policy uses the terms of the EU General Data Protection Regulation (GDPR), which we would like to briefly explain for you for easier understanding. These and other definitions can be found in Art. 4 GDPR.

Personal Data
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Person Concerned
"Data subject" means any identified or identifiable natural person whose personal data are processed by the controller.
Processing
"Processing" means any operation or set of operations that are performed on personal data or sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of Processing
"Restriction of processing" means marking stored personal data to restrict its future processing.
Pseudonymization
"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Responsible Person
"Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processors
"Processor" means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
Recipient
"Recipient" means a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.
Third Party
"Third party" means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent
"Consent" of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

V. General Information on Data Processing

Categories of Personal Data
We process the following categories of personal data:
- Inventory data (e.g., names, addresses, functions, organizational affiliation, etc.);
- Contact details (e.g., e-mail, telephone/fax numbers, etc.);
- Content data (e.g., text entries, image files, videos, etc.);
- Usage data (e.g., access data);
- Meta/communication data (e.g., IP addresses).
Recipients or Categories of Recipients of Personal Data
If we disclose data to other persons and companies, such as web hosts, contract processors, or third parties as part of our processing, transfer it to them, or otherwise grant them access to the data, this is done based on legal permission (e.g. if a transfer of the data to third parties according to Art. 6 para. 1 lit. b GDPR is necessary for the fulfillment of the contract), if the data subjects have consented or if a legal obligation provides for this.
Duration of the Storage of Personal Data
The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period, the corresponding data will be deleted if it is no longer required to achieve the purpose, fulfill the contract, or initiate a contract.
Transfers to Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre-)contractual obligations, based on your consent, based on a legal obligation or based on our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR, i.e., the processing takes place, for example, based on special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

VI. Data Processing in the Context of Visiting Our Website

Log Files
Every time a data subject accesses our website, general data, and information is stored in the log files of our system:
- Date and time of retrieval (timestamp);
- Request details and destination address (protocol version, HTTP method, referer, user agent string);
- Name of the retrieved file and amount of data transferred (requested URL incl. query string, size in bytes);
- Message indicating whether the request was successful (HTTP status code).
When using this general data and information, we do not draw any conclusions about the data subject. There is no personal evaluation or evaluation of the data for marketing purposes or profiling. The IP address is not stored in this context.
The legal basis for the temporary storage of data is Art. 6 para. 1 lit. f GDPR. The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the secure operation of our website . Consequently, the data subject has no option to object.
Malware Detection and Log Data Analysis
We collect log data that is generated during the operation of our company's communication technology and evaluate it automatically, insofar as this is necessary for the detection, limitation or elimination of malfunctions or errors in communication technology or the defense against attacks on our information technology or the detection and defense against malware.
The legal basis for the temporary storage and analysis of the data is Art. 6 para. 1 lit. f GDPR. The storage and analysis of the data is absolutely necessary for the provision of the website and for its secure operation. Consequently, the data subject has no option to object.
Cookies
Cookies are used on our website. Cookies are small text files that are exchanged between the web browser and the hosting server. Cookies are stored on the user's computer and transmitted by it to our website. In the web browser you are using, you can restrict or prevent the use of cookies by selecting the appropriate settings. Cookies that have already been saved can be deleted at any time. If cookies are deactivated for our website, this may mean that the website cannot be displayed or used to its full extent.
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.
Hosting
The hosting services we use provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services, and technical maintenance services for the purpose of operating our website.
In doing so, we or our processor process inventory data, contact data, content data, contract data, usage data, meta and communication data of users of our website on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a contract for order processing).
Use of a Registration Function
Our website offers you the opportunity to register. The data you enter will only be collected and stored for the use of our website. It will not be passed on to third parties.
Use of Google Analytics and Google Tag Manager
1. This website uses Google Analytics, a web analysis service of Google Inc ("Google"). Google Analytics uses "cookies," which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, your IP address will first be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services relating to website activity and internet usage to the website operator.
2. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
3. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this, you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
4. This website uses Google Analytics with the extension "_anonymizeIp()." This means that IP addresses are further processed in abbreviated form, thus excluding the possibility of personal references. If the data collected about you is personally identifiable, it is immediately excluded, and the personal data is deleted immediately.
5. We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained can be used to improve our offer and make it more interesting for you as a user.
6. Information from the third-party provider: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of use: http://www.google.com/analytics/terms/de.html, an overview of data protection: https://www.google.com/intl/de/analytics/learn/privacy.html, and the privacy policy: https://www.google.de/intl/de/policies/privacy.
7. This website also uses Google Analytics for a cross-device analysis of visitor flows carried out via a user ID. You can deactivate the cross-device analysis of your usage in your customer account under "My data" and "Personal data."
8. Use of the Google Tag Manager application: Google Tag Manager is an application with which website tags can be managed via an interface. The Google Tag Manager application itself (which implements the tags) is a cookie-free domain and does not collect personal data. The application triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If deactivation has been carried out at the cookie or domain level, this remains in place for all tracking tags implemented with Google Tag Manager. http://www.google.de/tagmanager/use-policy.html
  The legal basis for processing personal data using Google Analytics and Google Tag Manager is Art. 6 para. 1 lit. a GDPR.
Use of Matomo
1. This website uses the web analysis service Matomo to analyze and regularly improve the use of our website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. The legal basis for the use of Matomo is Art. 6 para. 1 sentence 1 lit. f GDPR.
2. Cookies are stored on your computer for this analysis. You can adjust the analysis by deleting existing cookies and preventing the storage of cookies. If you prevent the storage of cookies, we would like to point out that you may not be able to use this website to its full extent. You can prevent cookies' storage by changing your browser's settings.
3. This website uses Matomo with the "AnonymizeIP" extension. This means that IP addresses are further processed in abbreviated form, so they cannot be directly linked to individuals. The IP address transmitted by your browser using Matomo has not been merged with other data we collected.
4. The Matomo program is an open-source project. Information on data protection from the third-party provider can be found at https://matomo.org/privacy-policy/.
Integration of YouTube Videos
We have integrated YouTube videos into our online offering, which are stored on http://www.YouTube.com and can be played directly from our website. These are all integrated into "extended data protection mode," i.e., no data about you as a user is transferred to YouTube if you do not play the videos. Only when you play the videos will the data mentioned in paragraph 2 be transmitted. We do not influence this data transfer (please ensure appropriate implementation!).
By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the above-mentioned server data is transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or if no user account exists. If logged in to Google, your data will be assigned directly to your account. Log out before activating the button if you do not wish your data to be associated with your YouTube profile. YouTube stores your data as usage profiles and uses them for advertising, market research, and/or the needs-based design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and inform other social network users about your activities on our website. You have the right to object to creating these user profiles, and you must contact YouTube to exercise this right.
Further information on the purpose and scope of data collection and its processing by YouTube can be found in the privacy policy. You will also find further information on your rights and setting options to protect your privacy: https://www.google.de/intl/de/policies/privacy.

VII. Data Processing in the Context of Establishing Contact

Contact by E-Mail
You can contact our company by e-mail using the e-mail addresses published on our website.
If you use this contact channel, the data you provide (e.g., surname, first name, address), but at least the e-mail address, as well as the information contained in the e-mail and any personal data you provide, will be stored to contact you and process your request. The following data is also collected by our system:

IP address of the calling computer;

Date and time of the e-mail.

The legal basis for processing personal data in the context of e-mails sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.

Contact via Website Contact Form
If you use the contact form on our website to communicate, you must provide your surname and first name as well as your e-mail address. Without this data, your request cannot be processed. Providing your address is optional and enables us to process your request by post if you wish.
In addition, the following data is collected by our system:

IP address of the calling computer;

Date and time of registration.

The legal basis for processing personal data in the context of e-mails sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.

Contact by Letter and Fax
If you send us a letter or fax, the data you transmit (e.g., surname, first name, address) and the information contained in the letter or fax, together with any personal data you transmit, will be stored to contact you and process your request.
The legal basis for processing personal data in the context of letters and faxes sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.

Contact via Chat
If you contact us via our chat service, the communication service of the third-party provider Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, is integrated. This is an instant messaging service. The integration takes place within the framework of framing. Framing is providing content or services from a third-party provider within a so-called "frame." These frames are a "direct window" to the third-party provider's online offering. As a result, all communication within the chatbox takes place via a sendinblue GmbH server. Data collected by Sendinblue GmbH during use is processed exclusively by Sendinblue GmbH and is not passed on to Riddle.
Privacy policy: https://www.sendinblue.com/legal/privacypolicy/

VIII. Data Processing When Subscribing to Our Newsletter

If you subscribe to our newsletter mailing list, your e-mail address and the newsletter you have selected will be stored by us on a server.
In addition, the following data is collected by the system during registration:

IP address of the calling computer;

Date and time of registration.

Your consent is obtained for the data processing as part of the registration process, and reference is made to this privacy policy. The data is processed based on your consent in accordance with Art. 6 para. 1 lit. a GDPR and within the scope of the legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.
We use this data exclusively to send the newsletter. The registration system, with an additional confirmation message containing a link to the final registration (double opt-in), ensures that the newsletter was requested by you and not by a third party. When you register, your data is stored on our servers, and a confirmation message with a link to the final registration is generated and sent to the e-mail address you provided. Only when you confirm the link in the email will your data for sending the newsletter be stored for your use of our service.
If you no longer agree to store your data for this purpose and no longer wish to use our services, you can unsubscribe from our newsletter anytime. Every newsletter has a corresponding link for this purpose. The personal data you have provided to subscribe to the newsletter will then be deleted.
Use of the German Shipping Service Provider "Sendinblue/Brevo."
Our newsletter is sent using "Brevo," an application of the German company Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin. The email addresses of our newsletter recipients and their other data described in this data protection notice are stored on the servers of Sendinblue GmbH. Sendinblue uses this information to send and analyze the newsletter on our behalf. Sendinblue provides information on the functions used here: https://de.sendinblue.com/funktionen/.
Furthermore, Sendinblue will use the above-mentioned data to optimize its own services. However, Sendinblue does not use the personal data of the recipients of our newsletter to contact them or to pass it on to unauthorized third parties. Please refer to Sendinblue's privacy policy: https://de.sendinblue.com/legal/privacypolicy/. Sendinblue is a TÜV Rheinland certified service provider with certified data protection management (certificate: https://de.sendinblue.com/wp-content/uploads/sites/3/2020/07/Tuev_Zertifikat_Newsletter2Go.pdf).
The legal basis for the processing of personal data in the context of the described newsletter dispatch via Sendinblue, including performance measurement, is Art. 6 para. 1 lit. a) Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, in the event that consent is not required, based on our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f) GDPR in conjunction with § 7 para. 3 UWG. § Section 7 (3) UWG.
We have concluded an order processing agreement with Sendinblue in accordance with Art. 28 GDPR, in which Sendinblue undertakes to protect the data of our users, to process it on our behalf in accordance with applicable data protection regulations and, in particular, not to pass it on to third parties. This agreement can be viewed at the following link: https://de.sendinblue.com/wp-content/uploads/sites/3/2020/10/AV_Muster_DE-aktuell.pdf.
Unsubscribe from the Newsletter.
You can unsubscribe from our newsletter at any time. At the same time, your consent to receive the newsletter via Brevo and the statistical analyses will expire. Unfortunately, it is not possible to unsubscribe from the Brevo newsletter or the statistical analysis separately. You will find a link to unsubscribe at the end of each newsletter.
The legal basis for the processing of personal data in the context of sending newsletters via Brevo is Art. 6 para. 1 lit. a GDPR.

IX. Further Data Processing

Use of Google Workspace API / Sheets API
We use the Google Workspace or Sheets API to synchronize lead data between Riddle and Google. If there is no active Google connection, there is no synchronization. Information received from Google APIs is subject to the Google API Services User Data Policy, including the Restricted Use Requirements. Google Workspace APIs are not used to develop, improve, or train general/non-personalized AI and/or ML models. Google user data is also not transferred or sold to third-party AI tools.
Riddle's use and transfer of information received from Google APIs to other apps is governed by the Google API Services User Data Policy including the limited terms of use.

X. Your Rights

As a data subject, you have the following rights in connection with the processing of your personal data:

Right to Information

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

The purposes of the processing;

The categories of personal data that are processed;

The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

The existence of a right of appeal to a supervisory authority;

If the personal data are not collected from the data subject, all available information about the origin of the data;

The existence of automated decision-making, including profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

Right to Rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to Erasure

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

Personal data are no longer necessary for the purposes for which they were collected or otherwise processed.

The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Art. 21 (1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.

The personal data have been processed unlawfully.

Deleting personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Paragraphs 1 and 2 shall not apply if the processing is necessary

To exercise the right to freedom of expression and information;

For compliance with a legal obligation that requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

For reasons of public interest in the area of public health pursuant to Art. 9 para. 2 lit. h) and i) and Art. 9 para. 3 GDPR;

For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

For the assertion, exercise, or defense of legal claims.

Right to Restriction of Processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject for a period, enabling the controller to verify the accuracy of the personal data,

The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims or

The data subject has objected to processing pursuant to Art. 21 (1) GDPR pending the verification of whether the legitimate grounds of the controller override those of the data subject.

Where processing has been restricted pursuant to paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

Right to Data Portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where

The processing is based on consent pursuant to Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and

The processing is carried out by automated means.

In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of other persons.
This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right of Objection
The data subject has the right to object, on grounds relating to his or her particular situation, at any time to the processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.
In the context of using information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

Right of Withdrawal
Under data protection law, the data subject has the right to withdraw their declaration of consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work, or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

XI. Changes to This Privacy Policy

We reserve the right to amend these data protection provisions at any time with effect for the future. A current version is always available on the website. Please visit the website regularly and inform yourself about the applicable data protection provisions.

Publish date: June 26th, 2024