Privacy Policy

PrivacyPolicy

 

The protection of your personal data is of particular concern to us at ABEL. Therefore, we
comply with the legal requirements when we collect and process your personal data. Below
you will find extensive information about the scope and purpose of collecting data.

Principle of anonymous data use
In principle, our offers can be used without providing personal data. The use of individual
services on our website can therefore entail divergent regulations which in this case are
explained separately below. The legal basis for data protection can be found in the General
Data Protection Regulation (GDPR).

When you access our website or App, some information, such as IP address, is transferred.
You are also providing information about the end device used (computer, smartphone, tablet
etc.), the browser used (Internet Explorer, Safari, Firefox etc.), time of visit to the website, the
so-called referrer and volume of data transferred.

We cannot use this data to identify an individual user. We only use this information to determine
how attractive our offers are and to improve their performance or content, if necessary, and
make their design even more appealing to you.

Please bear in mind, however, that in the case of a static IP address, personal identification is
possible by RIPE query in individual cases, although we do not perform this. Nevertheless, this
website is accessible for both static and dynamic IP addresses assigned.

Collection and processing of personal data
We only collect personal data if you provide it to us, for example when you contact us, in
particular by registering an ABEL account, placing an order, requesting information or
publishing personal data in our ABEL App in your profile or in the feed.
We use the personal data you provide only to the extent that your data is necessary for
rendering or processing our services.

We store your data for as long as is necessary to achieve the intended purpose or until you
delete your account or for as long as legal retention periods require data to be stored. Your
data is subsequently deleted in accordance with legal requirements or processing is restricted.
In the case of use purely for information, i.e. if you do not register or send us information
another way, we only collect personal data which your browser transfers to our servers. If you
want to view our website, we collect the following data, which we require for technical
purposes in order to show you our content and guarantee stability and security (legal basis is a
legitimate interest pursuant to Article 6 (1) (f) GDPR).

In the context of the balance of interests in accordance with Article 6 (1) (f) GDPR, we have
considered and weighed up our interest in website provision and your interest in data
protection compliant processing of your personal data. As the data below is technically
required for the provision of our service in order to offer you our website and also guarantee
stability and security, in particular protection against misuse, we have reached the conclusion
that, with a state-of-the-art oriented data security guarantee, this data can be processed
whereby appropriate consideration will be given to your interest in data protection compliant
processing.

The collection of data for website provision and the storage of data in log files is imperative for
website operation. Consequently, users may not object to this.

Registering an ABEL Account
Using our login system, you can create a ABEL account for yourself that you can use to log in
to all of our services (. In the process, we use cookies – small files – on your browser in order to
identify you. All data that you save to your account is stored at a ABEL Technologies AS,
Stakkevollvegen 186, 9010 Tromsø, Norway. Some of our services are only accessible if you
have set up your ABEL account. We will request the following data when registering (some of it
is required). In addition, you must take note of our Data Protection Statement, as well as
accept our General Terms and Conditions of Business and Cancellation Policy.

Registering with Facebook or Google
We also offer you the opportunity to create your ABEL account using your Facebook or Google
account, or to link your ABEL account to your Facebook or Google account. You can register
or log in to ABEL using your Facebook or Google account if you simply use Facebook or
Google instead of the other options while registering your ABEL account. You will then be
forwarded to Facebook or Google (where you must be logged in or require an account) and
receive an explanation of which of your data we need from Facebook or Google, namely your
public profile information such as first and last name, gender, and the email address you are
using there. This information is required for identification purposes in order to create a secure
ABEL account for you. When you log in using your Facebook account, this allows us to show
you which of your friends are already with ABEL. Your Facebook or Google account and your
ABEL account will be permanently linked using your email address. We store your email
information in-house and will send you information using this address as needed. We can also
tell that you have logged in using Facebook or Google. As soon as you log in to Facebook or
Google, you can log in to ABEL. We will not submit any information on you to Facebook or
Google without your consent.

Important: We do not record your Facebook or Google login data in any way, and cannot post
anything to your Facebook or Google profile without your having expressly consented to this.
You can learn how Facebook handles privacy settings using Facebook’s privacy policy (https://
www.facebook.com/policy.php) and terms of use (https://www.facebook.com/legal/terms);
these also include the applicable conditions for the previously specified option of logging in
and registering to ABEL. You can learn how Google handles privacy settings using Google’s
privacy policy (https://policies.google.com/privacy) and terms of use (https://
policies.google.com/terms); these also include the applicable conditions for the previously
specified option of logging in and registering to ABEL.

Data collection, processing and use in the context of ABEL Service

Community Profile
You need a ABEL account in order to use our ABEL Apps. The data collected for this purpose
has already been explained above. To provide you with the best ABEL experience possible, our
approach is partly based on publishing specific information relating to our users within the
ABEL community, i.e. even your information. We are going to introduce our program to you in
more detail below so that you can decide for yourself whether and which data you want to
publish. This introduction includes the following data in particular which is visible to other
users:

– Public profile (photo, first name, surname, training location, motivation, ABEL level)
– Fitness (progress, desired objective, skills)
– Training information (duration and type of training unit, total number of training
sessions, notes, photo)
– Social media profile (Facebook, Twitter, Instagram)
– Food intake (meal type, notes, photo)
– Followed by/follows (persons who follow the user, persons followed by the user)

You become visible in ABEL Apps with the data in your public profile. This information helps
other users to find you in ABEL Apps. At the same time, other users can see your name and
surname (if provided), your training location, your motivation and your profile photo and they
can recognize you using this information if necessary. You have already agreed under our
General Terms and Conditions of Business that upon beginning your ABEL journey and
provided that you make no changes to your privacy settings, all ABEL users will be able to view
your profile, your training data, your posts, your training spots, etc., without special consent.
This is designed to make it easier to follow you and/or support you during your journey with
comments and motivation. If you do not want this anymore, you can set your privacy settings
to ‘private’ at any time, which only allows select athletes to access the information referred to
above.

ABEL Apps save all your successfully completed training units or the meals you have
consumed as well as related information such as self-uploaded photos or notes. Other users
can see this data and can consider them as incentive for themselves, leave comments or
decide whether they want to follow you.

Moreover, our ABEL Apps also provide users with the option to be followed (‘followed by’) to
support or encourage them in their training experiences, or to compete with one another. For
this purpose, users can be searched for by the name registered in the public profile or, after
linking a ABEL account to a Facebook account, via their Friends list. You will be notified about
new followers in the mobile app and by push notification where applicable.
Consequently, some of your information is available to other users in ABEL Apps. Our aim is
that nobody is left alone with their training. Instead, users’ performance is appreciated and can
become an incentive for new members.

If you do not want to make it possible to link your performance to yourself, you are free to
refrain from providing any personal data on your profile or training sessions and linking your
account to Facebook. Moreover, you should not save any training photos or enter any notes in
this case. For this reason, we have ensured that each user can change their personal
information, which can be viewed by other users, and each user is free to use their own name
or a fictitious name in their ABEL Apps.

 

ABEL Coach

Personalized training and nutrition plans
When using the ABEL app, the ABEL Coach will continuously send you customized training
and nutrition plans based on your personal information, training or nutritional preferences, as
well as the units you have completed successfully. Here we use a complex algorithm to
analyze, among other things, your workout performance (type of exercise, time needed per set,
time needed overall) and compare this with the workout performance of other users, in order to
offer you perfectly customized training units.

Limitations
Moreover, users can enter physical limitations, such as ‘no trunk muscles’ training, when
defining the next Coach week. We process this entry to generate training for our users, taking
the limitation into account. Data is processed and saved only for the current Coach week.
If you have sustained a serious injury and therefore cannot do any training, you can suspend
your Coach for the period of your injury. You can notify our support team about your injury on a
voluntary basis. This information merely serves as the basis for the relevant deferment or
suspension of your Coach and is subsequently anonymized.

Please bear in mind when entering or notifying limitations that we process special categories of
personal data, in particular data relating to your health. Special categories of personal data
require particular protection. The processing of special categories of personal data is therefore
based on your consent which you can withdraw with future effect at any time.

Analysis of location data
For some purposes, we need access to location data. This data allows us to calculate
distances covered at the relevant time and thereby correctly determine the end for predefined
distances or determine distances covered.

Based on your location, you can also find training spots and users near you, as well as adjust
your training plan to your current environment. At training spots, you can check in after your
workout and show the other users in your community where you exercised. To determine the
parts of the world in which most users are based, we perform a statistical analysis of your
location data.

Access rights
We require these access options and information to ensure the technical function of our app
and to provide the services offered with the app, in particular to access your camera or your
photos, to determine your running distances and your activity calories or to send you push
notifications to inform you about new followers or comments. During the installation procedure
or before you use the app for the first time, we request permission to access individual
functions and information. We will only access these functions with your approval. You can
revoke access rights manually in the settings for each operating system. You can find out how
this works in the manufacturer instructions for your mobile OS. However, please note that you
can only use the app to a limited extent or you cannot use it at all without the relevant
approval.

Before you use the app for the first time, we will request the following permissions for the
purpose described below:

Contact form

You can contact us by e-mail or using the contact form.
Obviously, we will use the personal data provided in this way only for the purpose for which
you make it available to us when you contact us.
If we request entries in our contact form which are required for establishing contact, we have
marked them as compulsory (*). Any information without an asterisk is optional. We use this
data to put your query into specific terms and handle your issues more effectively. Providing
this data is entirely voluntary and with your consent. If the data in question refers to
communication channels (for example, e-mail address, phone number), you also give consent
for us to contact you or resolve your issue via these communication channels.
Obviously, you can withdraw your declarations of consent for the future at any time. If you wish
to withdraw your consent, please contact the data controller indicated at the end of this
statement.

Push notifications as part of the user experience
We require your consent if you wish to receive our push notifications on your mobile iOS device
even if the app is not open. Our app only uses push notifications if you have given your explicit
consent to these. You can disable push notifications in settings at any time. If you use an
Android device, push notifications are permitted automatically unless you disable this in your
settings.

Push notifications for marketing purposes
We require your consent if you wish to receive our push notifications for marketing purposes on
your mobile iOS device even if the app is not open. Our app only uses push notifications for
marketing purposes if you have given your explicit consent to these. You can disable push
notifications in settings at any time. If you use an Android device, push notifications are
permitted automatically unless you disable this in your settings.

Newsletter, newsletter personalization and analysis of user behavior
You can subscribe to our newsletter if you want to receive regular updates or information about
topics and products that are referred to in the declaration of consent.
We need a valid email address for you for subscription purposes.
The provision of other separately highlighted data is voluntary and will be used in order to
address you personally. This will only happen if you give separate consent.
Please bear in mind that when we send the newsletter, we analyze your user behavior, i.e.
opening and click behavior. Technically, your user behavior is analyzed by Episerver GmbH. We
are able to draw conclusions regarding your user behavior in order to improve our newsletter
and ensure that you only receive newsletters that are of interest to you. Your user behavior is
tracked only with your separate consent.

To make doubly sure that you actually want to receive information from us, we use the double
opt-in procedure. Once you have subscribed, you will receive a link by email which you can
use to activate the newsletter service. In other words, we will send an email to the address
given when you subscribed in which we ask for confirmation that you want to receive the
newsletter. If you do not confirm your subscription, your data will not be saved by Episerver in
our email dispatch tool. In addition, we save your IP address and dates of newsletter
subscription and confirmation. The purpose of this procedure is to verify your subscription and,
where appropriate, shed light on any misuse of your personal data.
Naturally, you can unsubscribe from the newsletter at any time. The unsubscribe link can be
found in the masthead of every email or in your profile settings.
If you want to prevent personalization and tracking, or you do not agree to processing for the
purposes indicated, you can refuse this by sending an email to privacy@ABEL.com or
changing your profile settings accordingly.

Cookies and tracking pixels
We use cookies to improve our web service and make your use as easy as possible. Cookies
are small text files which are saved on your computer when you visit our website. They
facilitate the repeated allocation of your browser. Cookies save information, such as your
language settings, duration of the visit to our website or the entries you made there. This
means that the required data does not need to be entered again each time the service is used.
Moreover, cookies help us to recognize your preferences and adjust our website to your areas
of interest.

Most browsers accept cookies automatically. If you want to prevent cookies from being saved,
you can select the ‘Accept no cookies’ option in your browser settings. To find out exactly how
this works, you can consult your browser manufacturer’s instructions. You can delete cookies
that have already been saved on your computer at any time. Please bear in mind, however, that
our website service can only be used to a limited extent without cookies.
Moreover, every time our website is loaded, we record how often it is visited and clicked on by
using tags on our website, so-called tracking pixels, likewise without any interference and
intervention for your computer.

Google Analytics
We use the Google Analytics service from Google Inc. (1600 Amphitheatre Parkway, Mountain
View, CA 94043, USA) to analyze our website visitors. Google uses cookies to track the use of
the online product or service by users and the information is generally transferred to a Google
server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our online products and
services by users, to compile reports on the activities within these online products and services
and to provide us with further services associated with the use of these online products and
services and the use of the internet. Pseudonymous user profiles can be created from the
processed data.

We use Google Analytics only with IP anonymization enabled. This means that Google will
truncate the IP address of users within Member States of the European Union or in other states
that are 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. The IP
address transmitted by the user’s browser is not merged with other Google data. Users can
prevent cookies from being stored by adjusting the settings to their browser software
accordingly.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. Users
can prevent the collection of data generated by cookies by downloading and installing the
browser plug-in that is available at the following link: http://tools.google.com/dlpage/gaoptout?
hl=en. Google is certified under the Privacy Shield Agreement and thus guarantees compliance
with European data protection legislation (https://www.privacyshield.gov/participant?
id=a2zt000000001L5AAI&status=Active)
AppsFlyer
Our apps are analyzed with technologies from AppsFlyer Inc. (111 New Montgomery St, San
Francisco, CA 94105, United States). Various session and interaction data are collected from
you and stored for this purpose. We need this information to improve the content and usability
of our apps and to optimize the user experience for you. The session and interaction data are
at no time processed in personalized form, but under a pseudonym. For more information on
data processing by AppsFlyer, please refer to the privacy policy of the provider: https://
www.appsflyer.com/privacy-policy/.
The legal basis for use is Art. 6 paragraph 1 sentence 1 letter f GDPR. AppsFlyer is certified
under the Privacy Shield Agreement and thus guarantees compliance with European data
protection legislation https://www.privacyshield.gov/participant?
id=a2zt0000000GnUZAA0&status=Active. If you do not wish to be tracked by AppsFlyer in the
future, you can opt out at any time by writing an email to privacy@ABEL.com.
Google Marketing Services
On our apps we use the marketing and re-marketing services of Google Inc. (1600
Amphitheatre Parkway, Mountain View, CA 94043, USA) that allow us to display
advertisements in a more targeted manner in order to present advertisements of interest to
users. Through (re-)marketing ads and products are displayed to users relating to an interest
established by activity on other apps within the Google Network. For these purposes, a code is
used by Google when our app is accessed and what are referred to as (re-)marketing tags are
incorporated into the app. With their help, an individual cookie, i.e. a small file, is stored on the
user’s device (comparable technologies may also be used instead of cookies). Cookies can be
set by various domains. This file records which apps users have visited, which content they are
interested in and which offers have been used. In addition, technical information about the
browser and operating system, referring apps, the length of the visit as well as any additional
data about the use of the online products and services are stored. The IP address of users is
also recorded, although we would like inform you that within the framework of Google
Analytics, IP addresses within Member States of the European Union or in other contracting
states to the Agreement on the European Economic Area are truncated.

All user data will only be processed as pseudonymous data. Google does not store any names
or email addresses. All displayed ads are therefore not displayed specifically for a person, but
for the owner of the cookie. This information is collected by Google and transmitted to and
stored by servers in the USA.

One of the Google marketing services we use is the online advertising program Google
AdWords. In the case of Google AdWords, each AdWords customer receives a different
conversion cookie. Cookies can therefore not be tracked through the apps of AdWords
customers. The information collected by the cookie is used to generate conversion statistics
for AdWords customers who have opted for conversion tracking. AdWords customers see the
total number of users who clicked on their ad and were redirected to a page with a conversion
tracking tag. However, they will not receive any information that personally identifies users.
We may include third-party advertisements based on the Google Marketing Service called
DoubleClick. DoubleClick uses cookies to enable Google and its partner apps to place ads
based on users’ visits to this app or other apps on the Internet.

Google services make use of Google’s Tag Manager. For more information about Google’s use
of data for marketing purposes, please see the summary page: https://www.google.com/
policies/technologies/ads, Google’s privacy policy is available at https://www.google.com/
policies/privacy.

The legal basis for the use of this service is Article Art. 6 paragraph 1 sentence 1 letter f GDPR.
If you wish to object to interest-based advertising by Google marketing services, you can do so
using the settings and opt-out options provided by Google: http://www.google.com/ads/
preferences. Google is certified under the Privacy Shield Agreement and thus guarantees
compliance with European data protection legislation (https://www.privacyshield.gov/
participant?id=a2zt000000001L5AAI&status=Active).

Facebook Marketing Services
We use the “visitor action pixels” from Facebook Inc. (Menlo Park, California) on our website so
that user behavior can be tracked after users have been redirected to the provider’s website by
clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for
statistical and market research purposes. The data collected in this way is anonymous to us,
i.e. we do not see the personal data of individual users. However, this data is stored and
processed by Facebook, which is why we are informing you, based on our knowledge of the
situation. Facebook may link this information to your Facebook account and also use it for its
own promotional purposes, in accordance with Facebook’s Data Usage Policy https://
www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on
and off Facebook. A cookie may also be stored on your computer for these purposes. You can
object to the collection of your data by Facebook pixel, or to the use of your data for the
purpose of displaying Facebook ads by contacting the following address: https://
www.facebook.com/settings?tab=ads.

We also use Facebook’s Software Development Kit (SDK) within our apps, in order to link
various Facebook services with our apps. For example, this enables users to be able to use the
Facebook SDK to share content from our apps within their Facebook timeline or to send
messages to other Facebook users. Further information about the Facebook SDK within iOS
can be found here: https://developers.facebook.com/docs/ios. For Android, please refer
to: https://developers.facebook.com/docs/android. Facebook App Events: We use the
Facebook App Events service though the Facebook SDK to track the reach of our advertising
campaigns and the use of the Facebook SDK. Facebook merely provides us with an
aggregated analysis of user behavior with our app. We have no influence beyond that on the
information that will be processed through App Events by Facebook. In our app settings, you
can opt out of using App Events for these purposes.

Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance
with European data protection legislation (https://www.privacyshield.gov/participant?
id=a2zt0000000GnywAAC&status=Active). The legal basis for this processing is Art. 6
paragraph 1 sentence 1 letter b and f GDPR.

Facebook Custom Audience
As part of usage-based online advertising, the Custom Audience product from Facebook
(Facebook Custom Audience 1601 S. California Avenue, Palo Alto, CA, 94304) is also used on
the website. Generally speaking, a non-reversible and non-personal checksum (hash value) is
generated from your usage data which can be sent to Facebook for analysis and marketing
purposes. In doing so, a tracking pixel from Facebook is set on our website. This collects
information on your activity on the website (such as surfing behavior, subpages visited, etc.).
Your IP address is stored and used to direct geographically-based advertising.
You have the option of objecting to targeting by Facebook using the link (https://
www.facebook.com/ads/website_custom_audiences). You can also send us an email directly
at privacy@ABEL.com.

You can learn more about the purpose and scope of data collection and further processing and
utilization of data, as well as privacy settings, using the Facebook’s privacy policy (https://
www.facebook.com/policy.php).

Quality assurance
When using our website and apps, data is collected and stored which is used to generate
information using pseudonymous usage profiles for purposes of web analysis. These usage
profiles serve to analyze visitor behavior and are evaluated to improve and design our services
based on demand. In addition, we measure and analyze technical performance data (e.g.
response and load times) and application data (hardware and software used) in order to
improve the performance of our products. Cookies are used to do so. These are text files
saved on your computer that allow us to analyze how you use our website. The pseudonymous
usage profiles are not associated with personal data on the bearer of the pseudonym without
the concerned party’s express consent. You can object to future data collection and storage
for the purpose of web analysis at any time by deactivating cookies in your browser settings.
You can find the individual privacy notices for the providers here:

New Relic: https://newrelic.com/privacy.
Crashlytics: https://firebase.google.com/terms/data-processing-terms
Rollbar: https://rollbar.com/privacy/

Social Plugins
This website uses social plugins from providers:
Facebook (Betreiber: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA)
Twitter (Betreiber: Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107,
USA)

These plugins normally collect your data and transmit it to the server of the respective provider.
After being activated, these plugins also record personal data, such as your IP address, and
send this to the server of the respective provider where it is stored. Active social plugins also
create a cookie with a unique identifier when accessing the respective website. This allows the
provider to create profiles on your usage behavior. This also happens when you are not a
member of the social network of the respective provider. If you are a member of the provider’s
social network, and if you are logged in to the social network while visiting this website, your
data and visit information can be associated with your profile on the social network. We cannot
influence the exact scope of the data collected on you by the respective provider. Please refer
to the privacy policies of the respective social network providers for more detailed information
on the scope, manner, and purpose of data processing, and on your rights and setting options
to protect your privacy. These can be found in the table above. They are also available at the
following addresses:

Facebook: http://www.facebook.com/policy.php
Twitter: http://twitter.com/privacy/

Integrating Spotify
You can play your Spotify playlists directly via our apps without having to leave the ABEL app.
To do so, log in to Spotify (Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden)
using your Spotify account. This service is available to Spotify Premium customers only. We
do not receive any data from Spotify and neither do we pass data on to Spotify. Spotify simply
provides us with a token which we use to access and integrate your playlists. Further
information on data protection at Spotify is available here https://www.spotify.com/de/legal/
privacy-policy/.

Convert
We also use the Convert service on our website. Convert provides testing methods to improve
website design. To do so, an original version of our website is tested against a modified version
in order to find out which is more effective.

When you visit our website, technical information submitted by your browser (such as browser
type/version, operating system used, our websites visited incl. duration of stay, previously
visited websites) is evaluated by Convert. Your IP address is only stored in an anonymous form.
You can object to future tracking at any time by deactivating it using the following link: https://
www.convert.com/opt-out/

You can view Convert’s privacy policy here: https://www.convert.com/privacy-policy/

Shopify
ABEL Technologies AS forwards your data to Shopify. Shopify is a cloud shopping system for
online retailers and is used by our subsidiary, ABEL Apparel AS, to sell our Wear products.
When you buy ABEL products from ABEL Apparel AS and are logged in to with your ABEL user
ID, your ABEL user profile is used to fill out the order form and make your purchase easier. This
refers to your ABEL user ID, name, email address, Coach status, and date of birth.
Consent to direct marketing pursuant to Section 7 (3) UWG [German Fair Trade Practices Act]
Email addresses collected when a ABEL product (subscription) is purchased on our website
are used for direct marketing of our own and similar products and/or services. If you no longer
wish to receive direct marketing, you can refuse to allow the use of your email address at any
time.

Applications and applicant portal from Lever
You can apply to our company using electronic means.
Obviously, we will use your information only to process your application and not pass it on to
third parties.

Please note that e-mails sent without encryption are not access-protected. Unfortunately, we
do not currently offer encryption for e-mail applications. However, encrypted transfer of your
application is possible via our applicant portal.
You can apply to our company online via our applicant portal. Your online application will be
sent directly to the HR department via an encrypted connection and obviously treated
confidentially.

Your personal data will be deleted at the end of the application process, either immediately or
after no more than six months, unless you have given us your explicit consent for longer
storage of your data.

Further information on data processing in the context of application processes can be found in
the data privacy statement of our applicant portal available here: https://frltcs.com/
hr_datasecurity_de
Transfer of data to third parties
We only pass your personal data on to third parties if:
you have given your explicit consent to this,
forwarding data is necessary for the assertion, exercise or defense of legal claims and
there is no reason to assume you have an overriding legitimate interest in your data not being
passed on,
in the event that we have a legal obligation to forward data, and
this is legally permissible and required for the performance of the contractual
relationship with you.

In the case of data transfer outside the European Union, the high European level of data
protection essentially does not exist. It may be the case with a transfer that an EU Commission
adequacy decision in accordance with Article 45 (1) (3) GDPR is not currently in place. This
means the EU Commission has not yet decided that the level of data protection in the
respective country corresponds to the level of protection in the European Union based on the
GDPR. Consequently, we have put the appropriate guarantees referred to above in place.
Potential risks, which cannot be ruled out completely in connection with data transfer, are in
particular:
Your personal data could be processed over and above the intended purpose.
Moreover, there is a possibility that you may not be able to exercise your rights in
relation to data protection, for example your right of access, to rectification, erasure or data
portability, on a consistent basis and enforce these.

It may also be highly likely that data is processed incorrectly and in quantitative and
qualitative terms, the protection of personal data fails to meet the requirements of the GDPR in
full.

Your rights

Information on the rights of data subjects
Each data subject has the right of access in accordance with Article 15 GDPR, the right to
rectification in accordance with Article 16 GDPR, the right to erasure in accordance with Article
17 GDPR, the right to restriction of processing in accordance with Article 18 GDPR, the right to
object in Article 21 GDPR and the right to data portability in Article 20 GDPR. The limitations
according to Articles 34 and 35 BDSG apply to the right of access and to the right to erasure.

Information on the option to lodge a complaint
You also have the right to lodge a complaint with the competent data protection authority
about our processing of your personal data.

Information on withdrawal of consent
You can withdraw your consent with us to process personal data at any time. This also applies
to withdrawals of a declaration of consent that were given to us before the General Data
Protection Regulation came into effect, i.e. before May 25, 2018. Please note that this
withdrawal will only apply prospectively. This does not affect processing that took place prior
to a withdrawal.

Right in the event that data is processed for direct marketing purposes
You have the right pursuant to Article 21 (2) GDPR to object to the processing of personal data
concerning you. In the event that you object to processing for direct marketing purposes, we
will no longer process your personal data for this purpose. Please note that this withdrawal will
only apply prospectively. This does not affect processing that took place prior to a withdrawal.

Information on right to object in the case of balance of interests
If we process your personal data based on a balance of interests, you can object to such
processing. If you exercise this right to object, please state the reasons why we should not
process your data as we have described. If your objection is justified, we will review the
situation and either stop or adjust data processing or explain our compelling legitimate reasons
for processing to you.

Links to other websites
Our website may contain links to the websites of other providers. Please note that this Data
Privacy Statement applies only to the website of ABEL. We have no influence on or control
over the compliance of other providers with applicable data protection regulations.

Amendments to the Data Privacy Statement
We reserve the right to amend or adjust this Data Privacy Statement at any time subject to
compliance with applicable data protection regulations.

Controller and data protection officer
Alternatively, you may contact our external data protection officers at any time if you have any
questions regarding the collection, processing or use of your personal data or in the case of
access, rectification, blocking or erasure:

Personal/Confidential