Privacy Policy
This Policy includes the Company’s data protection and information security policy, and applies to the Company’s Users. The Company will only process Personal Data in a lawfull and reasonable manner in order not to infringe on the privacy of the Company‘s Users.
Should any of the provisions of this Policy conflict with any terms and conditions contained in the Company‘s Terms and Conditions, then the terms and conditions, to the extent of any conflict, contained in this Policy shall prevail.
Biding Acceptance of Policy
By accessing, using and/or interacting with the Website in any way, each User signifies his/her agreement: i) with this Policy (and its entire content), and ii) to be bound by the terms and conditions of this Policy (and its entire content).
Using, accessing and/or interacting with the Website indicates and records the User’s acceptance of this Policy. If a User does not accept this Policy in full, and/or does not agree to be bound by the terms and conditions as recorded in this Policy in full, he/she must not continue to access, use and/or interact with the Website (or any part thereof).
1- Introduction
The Company takes the processing and privacy of Personal Data very seriously, and therefore only process Personal Data in accordance with the contents of this Policy and applicable privacy laws, such as the GDPR.
In this Policy, we indicate which Personal Data we process when a User is accessing / making use of the Website, for what purpose and according to which legal basis the Personal Data processing is being permitted.
The purpose if this Policy is to ensure that Personal Data is lawfully processed by a controller/responsible party under and in terms of applicable legislation.
2- Definitions
In this Policy, and unless the context clearly indicates a different intention, the following expressions bear the meanings given to them below and equivalent expressions will have similar meanings:
“Application” – means the mobile application known as Lemonade, through which Registered Users can access the Services;
“Domain Name” – means the domain name/s and/or internet address/es via which the Website is accessible, and more specifically www.stoltzonz.com;
“GDPR“ – means the General Data Protection Regulation;
“IP” – means internet protocol;
“Company” – means Stoltzone;
“Personal Data” – means personal data as defined in terms of article 4 of the GDPR, or as indicated in the body and context of this Policy;
“Policy” – means this privacy policy;
“Registered User” – means individuals who sign up via the Company’s Website in order to make use of the Services;
‘’Services’’ – means the Company’s Website, software and/or other products/services, utilized by Registered Users from time to time in order to lend and/or borrow money to and/or from other Registered Users;
“Users” – means individuals who access, use and/or interact with the Website from time to time, including Registered User/s;
“Website” – means and includes the website accessible via the Domain Name, each associated microsite and each sub-page as well as the Application, owned, operated and maintained by the Company.
3- Data Processing When You Access The Website
The Company automatically collects and stores certain information in its server log files that the User’s browser transmits back to the Company. This data cannot be assigned by the Company to specific individuals. This data is not merged with other data sources. The following data is collected:
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Browser type/version;
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Operating system used;
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Referrer URL (the previous page visited);
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Host name of the accessing computer (IP addresses) v4 and v6 are anonymized); and
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Time of the server request.
The IP address is valid worldwide and uniquely identifies the User’s computer at the time of allocation by the User’s internet provider. IP, in its most common form (IPv4), consists of four blocks of digits separated by dots or extended by additional digits (IPv6). In most cases, as a private user, the User will not use a constant IP address, as this is only temporarily assigned to the User by the respective User’s internet provider (referred to as a "Dynamic IP Address"). With permanently assigned IP addresses (referred to as "Static IP Addresses"), a clear assignment of user data via this feature is technically quite straightforward.
The aforementioned data will be processed by the Company for the following purposes:
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Ensuring a smooth connection to this Website;
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Ensuring convenient use of this Website;
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Evaluation of system security and system stability; and
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For further administrative and statistical purposes.
The Personal Data in the server log files is processed on the basis of Art. 6(1)(f) of the GDPR. This authorization allows the processing of Personal Data for the purpose of a “legitimate interests” pursued by the controller/responsible party, except where such interests are overridden by your fundamental rights, freedoms or interests. The Company’s legitimate interest is the facilitation of administration and the ability to detect and track hacking. Our legitimate interest is based on the aforesaid purposes. Under no circumstances do we use the data collected for the purpose of drawing conclusions about you personally.
The server log files containing the aforementioned data are automatically deleted after 30 (thirty) days, or anonymized if used for statistical purposes. We reserve the right to store the server log files for a longer period, if facts are present which could lead us to assume that unauthorized access has taken place (such as, including but not limited to attempted hacking or a “ distributed denial of service attack “DDOS attack”).
4- Use and Verification of Personal Data
The Personal Data you provide, which you consent to being processed by the Company, include:
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Your name;
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Your address (postcode, city, street and house number, other address details);
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Your email address;
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Your telephone number and/or mobile number; and/or
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Your search history pertaining to our website.
When you provide the Company with the data as recorded in this clause 4, we use it to facilitate the Company’s Services and/or to respond to your enquiries, for technical administration, for login activities and/or for the services provided within the Website. The legal basis for this point is Art. 6(1)(a) of the GDPR, in terms of which the User’s consents to the processing of Personal Data. You can revoke your consent to the use of the Personal Data you have provided at any time. To do so, please contact: yahya@stoltzone.com.
5- Google Analytics
The Website uses Google Analytics, a web analysis service from Google Inc. (“Google”). Google Analytics uses cookies – text files that are stored on the User’s computer and enables an analysis of how the User used the Website. The information gathered by the cookie about the User’s usage of this website is generally transferred to a Google server in the United States of America (“USA”) and stored there. However, if IP anonymization is activated on the Website, Google will first shorten your IP address if you belong to an EU member state or another country, which country is a contracting party to the Agreement on the European Economic Area. In exceptional cases only, the full IP address is transferred to a Google server in the USA and shortened there. On behalf of the operator of the Website, Google will use this information to analyze the User’s usage of the Website, compile reports about Website activities and provide the Website operator with further services related to the Website and internet usage. The IP address transferred by the User’s browser as part of Google Analytics is not combined with other Google data. The User can prevent cookies being stored by adjusting his/her browser software accordingly, however, we would then inform the User that he/she may then not be able to make use of the full scope of functions available on the Website. Furthermore, the User can prevent Google recording the data generated by the cookie and related to the User’s usage of the Website (including your IP address) by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de. On the Website, Google Analytics has been supplemented with the code “gat._anonymize IP();” to ensure that IP addresses are recorded anonymously (known as IP masking). Moreover, the Company uses Google Analytics for the statistical analysis of Personal Data from DoubleClick cookies and Adwords. If you do not agree to this, you can switch it off via the Ad Settings at http://www.google.com/settings/ads/onweb/?hl=de. Further information on data protection and terms of use can be found at http://www.google.de/intl/de/policies/privacy/.
6- Google Remarketing
This Website uses Google remarketing. Google remarketing is an advertising service of Google Inc. ("Google", Mountain View, USA), with which the Company can provide the User with targeted adverts of presumed interest, based on the User’s usage behavior during previous visits to the Website. Such adverts only appear on Google advertising spaces, either those of Google Adwords or the Google Display Network.
The User can object to Google remarketing in the Google Ad Settings or edit his/her settings. Alternatively, the User can prevent remarketing by deactivating cookies in his/her browser settings.
7- Facebook Remarketing
This Website uses the "Custom Audiences" remarketing function from Facebook Inc. ("Facebook"). This function is used to present interest-based adverts ("Facebook ads") to visitors to this Website when the said visitors visit the social network Facebook. For this purpose, Facebook's remarketing tag has been implemented on this Website. This tag establishes a direct connection to the Facebook servers when you visit the Website. The fact that the User visited this Website is then transmitted to the Facebook server and Facebook assigns this information to the User’s personal Facebook user account. Further information about how Facebook collects and uses data, as well as your rights and options in this regard for protecting the User’s privacy, can be found in Facebook's privacy policy at https://www.facebook.com/about/privacy/. Alternatively, the User can deactivate the "Custom Audiences" remarketing function at https://www.facebook.com/settings/?tab=ads#_=_. The User must be logged into Facebook to do this.
8- Google reCAPTCHA service
The Company uses the Google reCAPTCHA service to determine whether certain data entered in our online forms comes from an actual person or a computer. Google uses the following information to determine whether the Users of this Website are humans or a computer, IP address of the device the Users are using, the website the Users are visiting in which the CAPTCHA is integrated, the date and duration of the Users’ visit, the identification data of the browser and operating system the Users are using, Google account if the Users are logged into Google, mouse movements on the reCAPTCHA images and tasks where the Users have to identify images. The legal basis for the data processing described above is Art. 6(1)(f) of the GDPR. The Company has a legitimate interest in this data processing to ensure the security of the Website and to protect the Company from automated input (attacks). Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
9- Further Processing and Deletion of Data
Personal Data will not be passed on/transferred or sold to third parties, i.e. people or companies that do not belong to the Company. Stored Personal Data will be deleted should the User revoke his/her consent to its storage, or if the Personal Data is no longer required for the processing purpose, or if its storage is inadmissible for other legal reasons.
10- Communication with Us
Advertising and advertising consent.
The Company will only inform the User or send the User surveys about the Services from the Company by email, post or telephone, provided that the user has expressly given the Company his/her consent to use the User’s Personal Data for advertising purposes (opt-in) by actively consenting thereto on the Website. The User can revoke this consent at any time.
Please note that the text the User may see on the Website may also list different companies if they are relevant to the User’s enquiry.
If the User gave the Company his/her consent for such use but no longer wishes to receive advertising or surveys from the Company in the future, the User can at any time revoke his/her consent. The User’s Personal Data will then be deleted. You can email us about this at yahya@stoltzone.com
11- Contact
The User can contact the Company via email or by registered mail. Should the User wish to use one of these contact options, we record the Personal Data transmitted to the Company via the selected contact option. This may include the User’s name, address, email address and telephone number. The User can decide which information he/she wants to send us via the contact options.
We process this data exclusively for the purpose of being able to respond to and process your enquiry or request.
If you wish to use the contact form on the Website, we record the Personal Data you provide in the contact form. We also store the IP address and the date and time of the enquiry. We process the data submitted in the contact form exclusively for the purpose of being able to respond to your enquiry or request.
12- Social Media
On the Website you will find links to the social networks, Facebook and Instagram. You can recognize the links by the respective provider's logo. We do not process any data in this regard.
By clicking on the links, the corresponding social media pages are opened, to which this Policy does not apply. Please refer to the privacy policies of the individual providers for details of the provisions applicable there; you will find these under:
Facebook: https://www.facebook.com/privacy/explanation
Instagram: https://help.instagram.com/519522125107875
13- Information about the rights of data subject - Your Identity
In order to comply with the rights of the data subject, it may be necessary for the Company to request further information to verify your identity.
14- Minors
The Website is not targeted at children under the age of 18. The Company will not knowingly collect information from persons under the age of 18.
15- Right of Access, Right of Rectification, Right of Erase
Users have the right to obtain access to his/her Personal Data processed by the Company. In particular, you may obtain information about the purposes of the processing, the categories of Personal Data concerned, the categories of recipients to whom your data has been or will be disclosed, the envisaged storage/retention period, the existence of the right to request rectification/correction, erasure/deletion, restriction of processing or the right to object, the prohibition on processing of special Personal Data and the restrictions thereon, the source of your data if not collected from yourself, and the existence of automated decision making, including profiling, and if applicable, meaningful information about the details involved;
To exercise these rights, please contact:
The Company at the following address/contact details.
- Regisetered Address:
STOLTZ ONE LLC
3343 Peachtree Rd NE # 1600, Atlanta, GA 30326
- Contact Person:
Name: Yahya Hilali
Email: yahya@stoltzone.com
Further Information
Disclosure of Data to third parties.
As a general principle, we do not transfer any Personal Data to third parties other than for the purposes explained in this Policy. However, if we are obliged to do so by law or court order, we will transfer the applicable Personal Data to the authorities entitled to receive information.
Links to other websites.
Our Website may contain links to other websites. These links are usually marked as such. We have no influence over the extent to which the applicable data protection regulations are observed on the linked websites.
Changes to this Policy.
The status of this Policy is indicated by the date shown (below). We reserve the right to amend this Policy at any time. The latest version can be accessed directly via our Website. Please visit our Website regularly to check the status of the Policy and any changes made thereto.
To exercise these rights, please contact:
The Company at the following address/contact details.