Privacy policy

1Overview

This privacy policy explains which personal data we process when you visit poleplace.com, subscribe to our newsletter or contact us, why we do so and what rights you have. Personal data is any information that can identify you personally, for example your name, e-mail address or IP address.

This website is a static website. It has no user accounts and no shop. Sign-up, subscription, payment and watching the classes take place on our streaming platform at watch.poleplace.com, which has its own privacy policy (see section 9).

Google Analytics 4 and the Meta Pixel load on every page visit, without asking for your consent first (see sections 7 and 8). All other services that are not required to run the website (further statistics and marketing tools via Google Tag Manager, external media) are only loaded after you have given your consent in the consent banner. You can change that choice at any time via the "Cookie settings" link in the footer of every page.

2Controller

The controller responsible for data processing on this website is:

POLEPLACE GmbH
Danziger Straße 1-3
88250 Weingarten
Germany

Represented by the managing directors Carmen Binder, Stefan Binder, Irina Mauch

Phone: +49 751 977 045 05
E-mail: support@poleplace.com

The controller is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.

3Legal bases

We process personal data on the following legal bases:

• Consent (Art. 6(1)(a) GDPR). Where information is stored on or read from your device (e.g. cookies, local storage, pixels), also Sect. 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG). You can withdraw your consent at any time with effect for the future.
• Contract and pre-contractual measures (Art. 6(1)(b) GDPR), e.g. when you contact us about a subscription.
• Legal obligation (Art. 6(1)(c) GDPR), e.g. retention duties under tax and commercial law.
• Legitimate interests (Art. 6(1)(f) GDPR), e.g. in providing the website securely and quickly. Storage on your device that is strictly necessary for a service you have requested is based on Sect. 25(2) no. 2 TDDDG.

The legal basis that applies in each case is stated in the relevant section.

4Recipients and transfers to third countries

We use service providers who process data on our behalf (processors under Art. 28 GDPR). We have concluded data processing agreements with them. We also share data where we are legally required to (e.g. with tax authorities) or where you have consented.

Some providers are based in the USA or transfer data there. The European Commission has adopted an adequacy decision for US companies certified under the EU-US Data Privacy Framework (DPF). You can check whether a provider is certified at https://www.dataprivacyframework.gov/list. For providers that are not certified, we base the transfer on the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR). Each service section states which basis applies.

5Hosting and delivery of the website

Cloudflare (hosting, CDN, DNS, security)

This website is delivered via Cloudflare Pages. Cloudflare also provides DNS, a content delivery network (CDN) and protection against attacks. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA.

When you open the website, your request passes through Cloudflare servers, usually one close to you. Cloudflare processes in particular:

• IP address
• date and time of the request
• requested URL and referrer URL
• browser type and version, operating system (user agent)
• amount of data transferred and HTTP status code

This data (server logs) is required to deliver the website, find errors and fend off attacks. We do not combine it with other data sources.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in providing the website securely, quickly and reliably. Necessary cookies are set on the basis of Sect. 25(2) no. 2 TDDDG.

Cloudflare is certified under the EU-US Data Privacy Framework. More information: https://www.cloudflare.com/privacypolicy/.

Cloudflare Web Analytics

We use Cloudflare Web Analytics to analyse use of the website in aggregated form (e.g. page views, country of origin, device type). According to Cloudflare, Web Analytics does not set cookies, does not use local storage and does not create user profiles. Provider and third-country transfer as above. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in improving our website.

Supabase (images)

Images on this website are loaded from the storage service Supabase Storage. The provider is Supabase, Inc., 970 Toa Payoh North #07-04, Singapore 318992. When an image is loaded, your browser sends technical data to Supabase, in particular your IP address, the requested file, date and time and the user agent.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in delivering images quickly and reliably. More information: https://supabase.com/privacy.

Fonts

The fonts Inter and Work Sans are hosted locally on our server. No connection to servers of Google or other font providers is made when the website loads.

SSL/TLS encryption

For security reasons this website uses SSL/TLS encryption. You can recognise an encrypted connection by "https://" in your browser's address bar. Data you send to us cannot be read by third parties.

6Cookies and consent management

Cookies and similar technologies

Cookies are small text files that your browser stores on your device. Local storage, pixels and scripts that read information from your device work in a similar way. Apart from Google Analytics 4 and the Meta Pixel (sections 7 and 8), we only use such technologies where they are strictly necessary (Sect. 25(2) no. 2 TDDDG) or you have consented (Sect. 25(1) TDDDG). You can set your browser to block cookies or delete them when you close it. Some features may then not work.

Consent banner (cookieconsent)

To obtain and manage your consent we use the open-source software "cookieconsent" (version 3, Orest Bida, MIT licence). The software is hosted on our own server. No data is sent to the developer or to third parties.

In the banner you can accept or reject the following categories:

We store your choice in a cookie named cc_cookie in your browser. It contains the selected categories, a randomly generated consent ID, the time of consent and the version of the banner configuration. If we change the services we use, we ask again.

The legal basis is Art. 6(1)(c) GDPR in conjunction with Sect. 25(1) TDDDG (obligation to obtain and document consent) and Sect. 25(2) no. 2 TDDDG for storing the cookie.

You can change or withdraw your consent at any time via the "Cookie settings" link in the footer.

Google Tag Manager and Google Consent Mode

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

Google Tag Manager is a tool we use to embed and control other services (e.g. analytics and marketing tools) on the website. It does not set cookies or create user profiles itself. When it loads, however, Google collects your IP address and technical data about your browser; this may be transferred to Google LLC in the USA.

We use Google Consent Mode (version 2). Google Analytics storage (analytics_storage) is active from your first page visit. Google advertising functions (ad_storage, ad_user_data, ad_personalization) are set to "denied" until you consent to the "Marketing" category. Tag Manager and the services embedded via it are only loaded after you have consented to "Statistics" or "Marketing".

The legal basis for Tag Manager and the services embedded via it is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG).

Google is certified under the EU-US Data Privacy Framework (https://www.dataprivacyframework.gov/participant/5780). More information: https://policies.google.com/privacy?hl=en.

7Analytics and statistics

Google Analytics 4

We use Google Analytics 4 to understand how visitors use our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics collects, for example, pages viewed, time on page, clicks and scroll depth, source of the visit (referrer, campaign parameters), approximate location (derived from the IP address), device type, browser and operating system. For this, cookies (e.g. _ga, _ga_<ID>) are stored on your device. According to Google, IP addresses are not stored in Google Analytics 4. Data may be transferred to servers of Google LLC in the USA.

We use the property with the ID G-ME4JPVV0DN.

Google Analytics 4 loads on every page visit without prior consent. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in measuring the reach of our website and our campaigns and improving our offer. You can object to this processing at any time (Art. 21 GDPR) by e-mail to support@poleplace.com, or prevent it with the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) or a content blocker.

We have concluded a data processing agreement with Google. Google is certified under the EU-US Data Privacy Framework (https://www.dataprivacyframework.gov/participant/5780); the Standard Contractual Clauses also apply (https://privacy.google.com/businesses/controllerterms/mccs/). More information: https://support.google.com/analytics/answer/6004245?hl=en.

8Marketing and advertising

Meta Pixel

We use the Meta Pixel (pixel ID 1093534765158260) to measure the effect of our ads on Facebook and Instagram and to target ads (e.g. to people who have visited our website). The provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

The pixel loads on every page visit. It collects, for example, pages viewed, offers viewed, sign-ups to our waiting lists (without your e-mail address), clicks on app store and partner links, IP address, browser and device information and cookie identifiers (e.g. _fbp, _fbc). If you are logged in to Facebook or Instagram, Meta can link this data to your account and use it for its own purposes.

The Meta Pixel loads without prior consent. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in measuring the success of our ads and showing them to people who are interested in our offer. You can object to this processing at any time (Art. 21 GDPR) by e-mail to support@poleplace.com, adjust your ad preferences at Meta (link below) or block the pixel with a content blocker.

We and Meta are joint controllers for collecting the data and transmitting it to Meta (Art. 26 GDPR). Any subsequent processing by Meta is not part of the joint responsibility. The joint controller agreement is available at https://www.facebook.com/legal/controller_addendum. Under it, Meta is responsible for informing you about processing at Meta and for handling your data subject rights; you can also contact us.

Meta is certified under the EU-US Data Privacy Framework (https://www.dataprivacyframework.gov/participant/4452). More information: https://www.facebook.com/privacy/policy/. Ad preferences at Meta: https://www.facebook.com/adpreferences/.

Google Ads and conversion tracking

We use Google Ads (account ID AW-621314011) to run ads on Google and measure their success. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

If you reach our website via a Google ad, Google stores a cookie (e.g. _gcl_au, conversion linker). This lets Google and us see that someone clicked an ad and then completed a certain action (conversion). We only receive aggregated statistics, no data that identifies you.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "Marketing". Google is certified under the EU-US Data Privacy Framework (https://www.dataprivacyframework.gov/participant/5780). More information: https://policies.google.com/technologies/ads?hl=en. Ad settings: https://adssettings.google.com/.

Pinterest Tag

We use the Pinterest Tag to measure the effect of our ads on Pinterest and to build audiences. The provider is Pinterest Europe Limited, Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

The tag collects, for example, page views, clicks on sign-up links and purchases, IP address, browser and device information and cookie identifiers (e.g. _pin_unauth, _epik). Pinterest may link this data to your Pinterest account. Data may be transferred to Pinterest, Inc. in the USA.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "Marketing". More information: https://policy.pinterest.com/en/privacy-policy.

TikTok Pixel

We use the TikTok Pixel to measure the effect of our ads on TikTok and to build audiences. The provider is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland.

The pixel collects, for example, page views and clicks, IP address, browser and device information and cookie identifiers (e.g. _ttp). TikTok may link this data to your TikTok account. According to TikTok, data may also be processed in third countries, including the USA, Singapore and China.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "Marketing". Transfers to third countries are covered by the European Commission's Standard Contractual Clauses. More information: https://www.tiktok.com/legal/page/eea/privacy-policy/en.

Vibetrack

We use Vibetrack to measure which campaigns and ads bring visitors to our website and whether they then take out a subscription (attribution). Vibetrack is embedded via the subdomain vt.poleplace.com.

Vibetrack processes, for example, IP address, browser and device information, pages viewed, campaign parameters (vt_campaign, vt_adset, vt_ad, utm_*) and an identifier used to match a later purchase to the visit.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "Marketing".

Storage of campaign parameters (own feature)

If you reach our website via a link with campaign parameters (e.g. utm_source, utm_campaign, vt_campaign), we store these parameters in your browser's local storage (entry poleplace_attribution) and append them to links to watch.poleplace.com. This lets us see which campaign led to a subscription. When you click a link to watch.poleplace.com, it is sent to Uscreen.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "Marketing".

Brevo tracking and web push

We use the Brevo tracking script to record which pages newsletter subscribers view after clicking a link in the newsletter, and to tailor content accordingly. The provider is Brevo (Sendinblue SAS), 106 Boulevard Haussmann, 75008 Paris, France. Pages viewed, time, browser information and a cookie identifier (e.g. sib_cuid) are processed. If you are known to us as a newsletter subscriber, Brevo may link this data to your contact record.

If you allow web push notifications (prompt from your browser), we store a push identifier for your browser in order to send you notifications. You can revoke this permission at any time in your browser settings.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "Marketing", or the browser permission for web push. Data is processed in the EU. We have concluded a data processing agreement.

9Streaming platform watch.poleplace.com (Uscreen)

Accounts, sign-up, subscriptions, payment, classes and the iOS and Android apps run on our platform at watch.poleplace.com. We use Uscreen as a processor.

No account or payment data is collected on poleplace.com itself. When you click a link to watch.poleplace.com (e.g. "Start now"), you move to the platform. Your IP address, the referrer URL and, if applicable, campaign parameters (see "Storage of campaign parameters") are transmitted.

Which data is processed on watch.poleplace.com (e.g. account and contract data, payment, video usage data, tracking services used there) is explained in the platform's privacy policy: https://watch.poleplace.com/privacy.

10Newsletter (Brevo)

Sign-up and double opt-in

If you subscribe to our newsletter, we need your e-mail address. We use the double opt-in procedure: after signing up you receive an e-mail with a confirmation link. You are only added to the list after clicking this link. We store the time of sign-up and confirmation and your IP address so that we can prove the sign-up.

Mailing service Brevo

We use Brevo to send the newsletter. Brevo stores your data on servers in the EU. We have concluded a data processing agreement with Brevo.

Newsletter analytics

Our newsletters contain tracking pixels and personalised links. This shows us whether and when an e-mail was opened and which links were clicked. We use this to improve content and to group recipients by interest. If you do not want this analysis, you can unsubscribe from the newsletter.

Legal basis, unsubscribing and retention

The legal basis is your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time, e.g. via the unsubscribe link in every e-mail or by e-mail to support@poleplace.com. The lawfulness of processing up to that point remains unaffected.

We store your data until you unsubscribe. We then remove it from the mailing list. We may keep your e-mail address on a block list so that you receive no further newsletters and so that we can prove your earlier consent (Art. 6(1)(f) and (c) GDPR). We use this data only for that purpose.

Newsletter to customers

If you have taken out a subscription with us and provided your e-mail address, we may send you e-mails about our own similar offers (Sect. 7(3) UWG, Art. 6(1)(f) GDPR). You can object at any time without incurring costs other than transmission costs at basic rates. Every e-mail contains an unsubscribe link.

Spam protection in forms

Cloudflare Turnstile: To protect our forms from spam and automated requests we use Cloudflare Turnstile (provider as in section 5). Turnstile checks technical characteristics of your browser (e.g. IP address, browser and device information) to determine whether the input comes from a human. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in preventing misuse. For reading the required information from your device we rely on Sect. 25(2) no. 2 TDDDG.

Google reCAPTCHA: To protect our forms we use Google reCAPTCHA (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). reCAPTCHA evaluates, among other things, IP address, time on page and mouse movements and sets cookies. We only load reCAPTCHA after your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG). Google is certified under the EU-US Data Privacy Framework.

11Videos and external content

We only load external videos and widgets once you have consented to the "External media" category or clicked the preview image and thereby agreed. Until then we only show a locally stored preview image; no connection to the provider is made.

YouTube

We embed videos from YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We use the privacy-enhanced mode (youtube-nocookie.com). After your consent, a connection to YouTube servers is established. YouTube learns, among other things, your IP address and which page you visited. At the latest when a video is played, YouTube may use cookies or similar technologies. If you are logged in to YouTube or Google, YouTube may link this to your account.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "External media". Google is certified under the EU-US Data Privacy Framework (https://www.dataprivacyframework.gov/participant/5780). More information: https://policies.google.com/privacy?hl=en.

Vimeo

We embed videos from Vimeo. The provider is Vimeo.com, Inc., 330 West 34th Street, 5th Floor, New York, NY 10001, USA. After your consent, a connection to Vimeo servers is established; your IP address and the page visited are transmitted, among other things. We use the "Do Not Track" parameter (dnt=1) so that Vimeo does not set cookies for recognition. If you are logged in to Vimeo, Vimeo may link this to your account.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "External media". More information: https://vimeo.com/privacy.

Wistia

We embed videos from Wistia, Inc., 120 Brookline Street, Cambridge, MA 02139, USA. After your consent, a connection to Wistia servers is established. Wistia collects, among other things, IP address, browser and device information and how long a video was watched, and may use cookies or local storage for this.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "External media". More information: https://wistia.com/privacy.

WebinarJam (live class)

For our free live class we use WebinarJam. When you register, WebinarJam processes your name, e-mail address, IP address and attendance data.

The legal basis for registration is Art. 6(1)(b) GDPR (participation in the live class), and for loading the content your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG). More information: https://home.webinarjam.com/privacy.

Trustpilot

We show reviews via a Trustpilot widget. The provider is Trustpilot A/S, Pilestræde 58, 5th floor, 1112 Copenhagen K, Denmark. After your consent, the widget loads content from Trustpilot servers; your IP address, browser information and the page visited are transmitted, among other things, and Trustpilot may set cookies.

The legal basis is your consent (Art. 6(1)(a) GDPR, Sect. 25(1) TDDDG), category "External media". Without consent we show a plain link to our Trustpilot profile. More information: https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms.

12Affiliate links

Lupit Pole

Some pages contain advertising links (affiliate links) to Lupit Pole and the discount code POLEPLACE10. If you buy through one of these links or with the code, we earn a commission. The price stays the same for you.

Our links first pass through a redirect on our own domain (poleplace.com/go/lupit). When you click, Cloudflare (see section 5) processes the usual server log data.

You are then forwarded to the Lupit Pole website. Lupit receives, among other things, your IP address, the referrer URL and possibly a partner ID in the link used to attribute a purchase to us.

The legal basis for the redirect is Art. 6(1)(f) GDPR. Our legitimate interest lies in attributing commissions correctly.

13Contact by e-mail or phone

If you contact us by e-mail or phone, we process your details (e.g. name, e-mail address, phone number, content of the request) to handle your request. The legal basis is Art. 6(1)(b) GDPR where your request concerns a contract or pre-contractual measures, otherwise our legitimate interest in handling enquiries (Art. 6(1)(f) GDPR).

We delete the data once your request has been fully handled and no statutory retention obligations apply (e.g. 6 years for business letters under Sect. 257 HGB).

14Links to social networks

On our website we link to our profiles on social networks and to our apps in the App Store and on Google Play. These are plain links. Data is only transmitted when you click a link and open the provider's page.

15Retention

Unless a more specific retention period is stated in this policy, we store your data until the purpose of processing no longer applies, you withdraw your consent or you object to the processing with good reason. Where statutory retention obligations apply (in particular under Sect. 147 AO and Sect. 257 HGB), we delete the data once these periods have expired.

Cookie lifetimes: the lifetime of the cookies of the services used is set by the respective provider.

16Your rights

You have the following rights towards us:

• Access to your data stored by us (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Withdrawal of consent with effect for the future (Art. 7(3) GDPR), e.g. via the cookie settings or the unsubscribe link in the newsletter
• Objection to processing (Art. 21 GDPR, see below)

To exercise these rights, contact support@poleplace.com or the address in section 2.

Right to object (Art. 21 GDPR)

Where we process your data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you may object at any time on grounds relating to your particular situation. We will then stop processing the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims.

Where we process your data for direct marketing, you may object at any time without giving reasons. We will then stop processing the data for this purpose.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. The authority responsible for us is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg (State Commissioner for Data Protection and Freedom of Information Baden-Württemberg)
Lautenschlagerstraße 20
70173 Stuttgart, Germany
Phone: +49 711 615541-0
E-mail: poststelle@lfdi.bwl.de
Website: https://www.baden-wuerttemberg.datenschutz.de

17Automated decision-making

We do not make automated decisions within the meaning of Art. 22 GDPR.

18Obligation to provide data

You are not obliged to provide us with personal data. Without your IP address and technical data, however, the website cannot be delivered, and without an e-mail address we cannot send you the newsletter.

19Changes to this privacy policy

We update this privacy policy when the website, the services we use or the legal situation change. The version published here applies. If a processing activity you have consented to changes significantly, we will ask you again.