Last updated: December 1, 2020

Welcome to GABA-network.org (the “Site”), provided by German American Business Association of California ( “GABA,” “Us,” “Our,” and/or “We”), with offices at Two Embarcadero Center, Suite 1900, San Francisco, CA 94111. We value your security and privacy and provide this Privacy Policy (“Policy” or “Privacy Policy”) to describe the information we gather from you when you use the Site and related services (together, the “Services”), and when you otherwise contact us and how we use, process, and disclose that information. In addition, we may post additional privacy statements for some portions of the Services. By submitting personal information through our Services, you expressly consent to the transfer of your personal information to our servers in the U.S. for our collection, use, and disclosure in accordance with this Policy.

The term “personal information,” as used in this Privacy Policy, means information that relates to or is reasonably capable of being associated with a specific individual.

Information We Collect from You Through Your Use of the Site

Our Service: You may provide us with additional information by filling in forms on the Site or by corresponding with us by phone, text, email, live chat, or otherwise. When you create an account Service, we collect the following types of information from you:

• Name;
• Contact information such as your email address and phone number;
• Demographics information such as your gender, location (physical address);
• Any other information that you provide us, such as reviews, testimonials, content, and bio.

We automatically collect information about how you use our services, for example, pages you have viewed. We also collect certain technical information about your device including your Internet protocol address, geo-location information, your browser type, language and identifying information, your operating system, device types, device model and manufacturer, device identifiers, and your device operating system type and version.

Cookies and Tracking Technologies: We also use cookies, Web beacons, and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which usually stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. We also use cookies for data analytics purposes, including from Google Analytics. You can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners (or any successor URL). You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of our platform. Web beacons are digital images that are used to log information on the Services or in our emails. We use Web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use Web beacons to tell if you open or act on our emails.

 

Cookies used on our website:

 

 

Others, including third-party analytics service providers and advertising partners, may also collect personally identifiable information about your online activities over time and across different Web sites when you use our Services, including as described in this Privacy Policy. This Policy does not apply to and we are not responsible for those other parties. Third-party analytics services may use cookies and web beacons through our Site and platform device identifiers and software agents on and through our mobile Services to provide us with information about how you use and interact with our Site. We encourage you to review the privacy policies of these third parties to learn about your choices about information they collect from you.

Mobile Device Information: When you access and use the Site or Services from your mobile devices, we receive information from your mobile device. This may include your location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

Personal Information from Other Sources: We may receive personal information about you from third parties, such as GrowthZone. We may associate this information with the other personal information we have collected about you. The collection, use, and disclosure of information by third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you and may collect information and use it in a way that is inconsistent with this Privacy Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used, and disclosed by these third parties.

Third-Party Cookies: In addition to our use of Google Analytics as described above, we may engage third-party service providers, including Facebook and Instagram to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests. You can learn more about Facebook’s advertising cookies and opt-out options by visiting http://www.facebook.com/policy/cookies/ (or any successor URL). You can learn about Instagram’s advertising cookies and opt-out options by visiting http://help.instagram.com/1896641480634370?ref=ig (or any successor URL).

Pixel Tags: Pixel tags (a.k.a. clear gifs) are tiny graphics with a unique identifier, similar in function to cookies, which allow us to monitor the use of our Site and to deliver banner advertisements to you about our products and services as you browse the Internet. Pixel tags generally work in conjunction with cookies, registering when a particular computer visits a particular page. You cannot decline pixel tags; however, if you turn off cookies, the pixel tag will simply detect an anonymous visit. In addition, we use pixel tags in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Your Sharing of Your Information

The GABA Services may allow you to connect and share your actions, comments, content, profile, and information publicly or with other people. Please be mindful of your own privacy needs as you choose with whom to connect and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.

The Services may also provide you with the option to share certain information with social networking services like Facebook, Google, or Twitter. We are not responsible for the use or re-sharing by others of any of your information once it is made public. If you do not want your information to be made public, you should not use the GABA Services in this manner and/or you should adjust your privacy settings on the applicable social networking service accordingly. We are not responsible for and we do not control these social networking services privacy practices. Please review the applicable privacy policy for information about how they use your information.

How GABA Uses Your Information

GABA generally uses your information to:

• Identify you as a user in our system;
• Provide, personalize, and improve the Services;
• Communicate with you (including but not limited to by text messaging, telephone, and email) about your use of the Services and to market our products and services to you;
• Develop new products and services,
• Customize the advertising you view and recommend content;
• Fulfill your requests;
• Send newsletters, surveys, offers, and promotional materials related to the Services and for other marketing purposes of GABA;
• Protect, investigate, and prevent potentially fraudulent, unauthorized, or illegal activities;
• Protect our rights and the rights of other users; and
• As otherwise described in this Privacy Policy or in notices we provided to you.

We may also use your personal information as necessary to comply with legal requirements, to enforce our Terms, and to cooperate with law enforcement and regulatory authorities.

We may also use your information to verify your geographic location. We may use your geographic location data to personalize our Services, to recommend content and determine whether the information you have requested is available in your location. If personal information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, GABA may use it for any lawful business purpose.

How GABA Discloses Your Information

We may share your information as follows:

• We may share your personal information with your consent or at your direction.
• We may also share your personal information with others who perform services on our behalf.
• We may share your information with third-party service providers to fulfill your requests.
• We may disclose your information if we believe we are required to do so by law, or to comply with a court order, judicial or other government subpoena, or warrant.
• We also may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses or to protect GABA and our Services; or any rights, property, or personal safety of GABA or others.
• In the event that GABA is or may be merged with another organization or involved in any other business deal (or negotiation of a business deal) involving the sale or transfer of all or part of our business or assets, we may transfer or assign your information as part of or in connection with the transaction. Finally, in the event of insolvency, bankruptcy, or receivership, information may be transferred as a business asset.

We may also share aggregated and anonymized data with our partners, advertisers, and other third parties.

Third-Party Advertisers and Links

We permit advertisements to be delivered to you by third-party Internet advertising companies (also called ad networks or network advertisers). These companies may use cookies, Web beacons, platform device identifiers, software agents, and other technologies to collect non-personally identifiable information about your visits over time on our Service and across other websites to deliver advertisements to you targeted to your interests, measure their effectiveness and personalize advertising content, and to understand the usage and visitation of the Services and the other applications and websites tracked by these advertising companies. We do not have access to or control over cookies, Web beacons, platform device identifiers, software agents, or other technologies that they may use. We are not responsible for the privacy practices of third party advertisers. You should check the privacy policy of the third-party advertiser to determine how it handles information it separately collects from you.

Data Security and Transfer

No company can fully prevent security risks, however. While we strive to protect your personal information, we cannot guarantee its absolute security. To help protect yourself and your information, choose a unique password for our Services if prompted and do not use a password on our Services that you would use on any other website or online service.

Children’s Privacy

The Site and Services are for adult use only and are not directed towards children, minors, or anyone under the age of 18. If you are under the age of 18, you are not authorized to provide us with any personal information. If the parent or guardian of a child under 18 believes that the child has provided us with any personal information, the parent or guardian of that child should contact us at the email address below and ask to have this personal information deleted from our files. We appreciate your cooperation.

Using The Services From Outside The United States

The Services are not intended for visitors outside of the United States and we do not ship products internationally. If you are visiting the Services from outside the United States, please be aware that you are sending information to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have the data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage, and use of your information will at all times be governed by this Privacy Policy.

Your Privacy Rights

Depending on the state in which you reside, you may have certain privacy rights, such as to access, correct, update, port or delete your personal information or opt-out of certain disclosures. To exercise such rights, please contact us directly at info@abadiadetortoreos.com. If you have an account with us, you can also manage some of your personal information from within your account.

Information Choices

You may opt out of receiving marketing/promotional emails from GABA by following the instructions in those emails. You may opt-out of receiving marketing/promotional text messages from GABA at any time by replying STOP to a marketing/promotional text message. If you opt-out of receiving marketing/promotional emails and/or text messages, we may still send you non-promotional emails, such as emails about our ongoing business relations. You may also send requests about your personal information, including changes to your contact preferences, changes to or deletions of your information or content you post, and requests to opt-out of sharing your personal information with third parties by emailing info@abadiadetortoreos.com. Please note that deletion of your personal information or content does not ensure complete or comprehensive removal of the content or information posted on the Services.

You may contact us directly as provided below to be suppressed from our telemarketing lists. If you wish to decrease the amount of unsolicited telemarketing calls that you receive, you should register with the Federal Trade Commission’s National Do Not Call Registry. The federal government’s Do Not Call (DNC) Registry allows you to permanently restrict telemarketing calls by registering your phone number at donotcall.gov or by calling 1-888-382-1222.

When you visit the Site, we and others give you the following choices about use of mechanisms for tracking, including tracking of your online activities over time and across different websites and online services by third parties. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies from our Site or from third parties. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site. To opt-out of Google Analytics web tracking for certain browsers, you can download Google Analytics Opt-out Browser Add-on. You may opt out of other cookies that may be present on the Site by utilizing the option in your browser or mobile device. You can also choose to opt-out of use of cookies by some of our third party advertising partners to deliver ads tailored to your profile and preferences. However, while we and others give you choices as described in this Policy, there are many ways in which Web browser signals and other similar mechanisms can indicate your choice to disable tracking, and our Site may not be aware of or honor every mechanism.

You may decline to share certain personal information with GABA, in which case we may not be able to provide you with some of the features and functionality of the Site or Service. You may have the right to know what personal information GABA has about you and to correct any inaccuracies. Please direct any such requests by email to info@abadiadetortoreos.com.

Changes and Updates to this Privacy Policy

From time to time, we may revise the Policy. To help keep you up to date about any changes, we note the date the Privacy Policy was last updated above. You agree to review the Policy periodically so that you are aware of any modifications. Continued use of our Site or Services following notice of such changes shall indicate your acknowledgement of such changes.

GABA Contact Information

Please contact GABA at info@abadiadetortoreos.com with any questions or comments about this Policy, your information, our third-party disclosure practices, or your consent choices.

FOR CALIFORNIA RESIDENTS ONLY

This portion of our Privacy Policy advises California residents of rights provided in the California Consumer Privacy Act (the “CCPA”) and how to exercise those rights.

If you are a California resident, you may request certain information from us or certain actions by us, such as exercising the access and deletion rights below, or you may authorize an agent to make such a request on your behalf. We will seek to verify your identity and your agent’s authority when we receive an individual rights request from you or on your behalf to ensure the security of your personal information. To do so, we may need to collect additional pieces of personal information from you.

Please direct any such rights requests (as further described below) or additional questions that you may have regarding this Privacy Policy to: 775 Glenborough Drive, Suite 101 Mountain View, California 94041 or info@abadiadetortoreos.com.

We share your personal information, including your identifiers such as your name and address, commercial information such as your order history, and your demographic information with the following categories of third parties for our business purposes:

1. Payment processors
2. Analytics providers
3. Event partners
4. Consultants
5. Website hosting providers
6. Marketers
7. Common carriers

California residents have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

• Complete your transaction;
• Provide you a good or service;
• Perform a contract between us and you;
• Protect your security and prosecute those responsible for breaching it;
• Fix our Services in the case of a bug;
• Protect the free speech rights of you or other users;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

If you are a California resident, you may also request to receive details about how we collect, use, and share your personal information. You may also request to receive the specific pieces of personal information that we have collected about you.

If a business sells personal information, you have a right to opt-out of that sale. We do not, and do not intend to, sell personal information of California residents and, furthermore, do not have actual knowledge that we sell the personal information of consumers under 16 years old.

Businesses may not, and we do not, discriminate against you for exercising any CCPA rights, such as your access and deletion rights described above.

FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”) AND THE UNITED KINGDOM ONLY

In the sections below, all terms not otherwise defined shall have the meanings as defined under applicable data protection laws.

Consent

We will make it clear if we rely on your consent to process your personal data and you are free to withdraw your consent at any time. If you wish to do so, please contact us at info@abadiadetortoreos.com.

Legitimate Interest

Another reason we might use your personal data is because we have—or a third party has—a legitimate interest in doing so. We do so when responding to your inquires about our products and services; to provide services and technical support to you; to comply with laws that apply to us; and to enable internal administrative processes.

Retention Period

When we no longer need to process your personal data for the purposes described in this Policy, we will delete your personal data from our systems. We therefore generally retain information when we have an ongoing legitimate business need for the information and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Providing Your Data

One reason we might use your personal data is because you’ve inquired into entering into a contract with us or you’ve entered into a contract with us and we need to provide services under that contract. We may not be able to fulfill that contract if you choose not to provide us with your personal data.

Purpose of Processing

When we process your personal data, we determine the purpose of the processing and act as a controller. We will primarily process personal data from the EEA and the United Kingdom to offer our products services, process payments, and to provide prospective customers with information about our products, in addition to other purposes set out in this Policy.

Automated Profiling & Decision Making

We do not engage in any automated decision making or profiling as a part of our Services.

Your Right to Rectification

We want our records to be as accurate as possible, so please advise us of any errors and we will make corrections accordingly; although a difference of opinion or view does not necessarily mean that personal data is inaccurate. If you have a difference of opinion, we will do our best to add that opinion to our records.

Erasure and your “Right to be Forgotten”

Please contact us if you want us to delete your personal data. We will do our best to honor your request, but we may have an obligation to keep records for audit and legal purposes. We may also be able to “Restrict Processing” or delete specific information or a document, which we will do without undue delay, for example, where it has been sent to us in error.

Your Right to Object to Processing

In certain circumstances, you have the right to object to our use of your personal data, such as if we are using your personal data for direct marketing; for our or a third party’s legitimate interests or the public’s interest; or for scientific or historical research and statistics. Please contact us at info@abadiadetortoreos.com if you would like us to do so.

Right to Restrict Processing

Under some circumstances, you may request that we limit how we use your data or “Restrict Processing.” Simply a difference of opinion or view does not necessarily justify a restriction, but we will always consider your opinion. We will always inform you before we lift any restriction.

Your Right to Access Data

You have a right to receive a copy of your personal data from us. If you would like to do so, please contact us at info@abadiadetortoreos.com and we will advise you of the next steps as soon as possible, and in no more than one month.

Right to Data Portability

At your request, we are happy to provide your personal data in a machine-readable or “portable” format so you can move it or store it wherever you want, subject to certain limitations. We can also send it to another controller where technically feasible. If you would like to do so, please contact us at info@abadiadetortoreos.com and we will advise you of the next steps.

Right to Complain

If you have a complaint about how GABA uses your personal data, we hope that in the first instance you will contact us and we will promptly address your concern. However, you can always file a complaint with the supervisory authority in your Member State. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Charges/Fees

We do not charge you a fee for exercising any of your rights described above. The only exception to this will be if the request is excessive or repetitive, but we will always let you know that we plan to charge you before doing so.

Contact Information

Please direct any rights requests (as described above) or additional questions that you may have regarding this Privacy Policy to info@abadiadetortoreos.com or
German American Business Association,
Att. Siegmar Pohl, GABA Secretary of the Board of Directors
c/o Kilpatrick Townsend & Stockton LLP
Two Embarcadero Center, Suite 1900
San Francisco, CA 94111