Data Protection Declaration
1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Erich Fritz, Fritz Prosolution, Ruta 6 KM 22, Picada Boca, 6860 Trinidad, Itapúa, Paraguay, Phone.: +595 994 855 356, e-mail: hello@postino.cards. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 The controller has appointed a representative in the European Union who can be contacted as follows:
"Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Wien, Österreich, Tel.: +43 1 9974124, E-Mail: office@prighter.com"
You can reach our data protection representative in the EU (Prighter Group) via the following contact point: https://app.prighter.com/portal/Postino.
2) Data Collection When You Visit Our Website
2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
3) Hosting & Content Delivery Network
3.1 Vercel
For the hosting of our website and the display of the page content, we use the system of the following provider: Vercel Inc, 340 S Lemon Ave #4133, Walnut, CA 91789, USA
All data collected on our website is processed on the provider's servers. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors' data and prohibiting unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
3.2 Cloudflare
We use a content delivery network offered by the following provider: Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA
This service enables us to deliver large media files such as graphics, page content or scripts faster via a network of regionally distributed servers. The processing is carried out to protect our legitimate interest in improving the stability and functionality of our website pursuant to Art. 6 (1) point f GDPR. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors' data and prohibiting unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
4) Cookies
In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called "session cookies"), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.
If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.
You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.
Please note that the functionality of our website may be limited if cookies are not accepted.
5) Contacting Us
When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.
The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.
6) Data Processing When Opening a Customer Account and for Contract Processing
Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed to the extent required in each case if you provide us with this data when opening a customer account. The data required for opening an account can be found in the input mask of the corresponding form on our website. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the person responsible. After deletion of your customer account, your data will be deleted, provided that all contracts concluded via it have been fully processed, no legal retention periods are opposed and no legitimate interest on our part in the continued storage exists.
Social features (contacts, family access, birthday calendar)
Within your customer account you can connect with other registered users (address book/contacts, family access) and keep a birthday calendar. If you connect with another user, they are added to your address book. A date of birth stored in your profile will be shown to your connected contacts in their birthday calendar, provided they use the calendar; conversely, a date of birth stored by your contacts may appear in your birthday calendar. This processing is carried out to provide the account and reminder features you use pursuant to Art. 6 (1) point b GDPR and on the basis of our legitimate interest in a user-friendly design of these features pursuant to Art. 6 (1) point f GDPR. You can delete individual entries in your birthday calendar yourself at any time; when you delete your customer account, the associated data is deleted.
7) Use of Client Data for Direct Advertising
Subscribe to our e-mail newsletter
If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link.
By activating the confirmation link, you give us your consent for the use of your personal data pursuant to Art. 6 (1) point a GPPR. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration for the purpose of tracing any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the promotional purposes by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data, or we reserve the right to a more extensive use your data which is permitted by law and about which we inform you in this declaration.
The newsletter is sent via the dispatch service provider Resend referred to in section 8.5 (see there for details on processing on our behalf and data transfers to the USA).
8) Processing of Data for the Purpose of Order Handling
8.1 Transmission of image files for order processing via upload function
On our website, we offer customers the opportunity to order the customization of products by sending image files via an upload function. The submitted image motif is used as a template for the customization of the selected product.
Using the upload function on the website, the customer can transmit one or more image files from the memory of the end device used directly to us via automated, encrypted data transmission. We then collect, store, and use files transmitted in this way exclusively to produce the customized product as defined in the respective service description on our website. If the transmitted image files are passed on to special service providers for the production and processing of the order, you will be explicitly informed in the following paragraphs. Any further disclosure will not take place. If the transmitted files or the digital motifs contain personal data (in particular images of identifiable persons), all the processing operations just mentioned will be carried out exclusively for the purpose of processing your online order in accordance with Art. 6 (1) point b GDPR.
The transmitted image files are stored in your user account for the creation and provision of your cards and are deleted as soon as you delete the respective card or your user account.
8.2 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Para. 1 lit. b GDPR.
If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by post or e-mail) about upcoming updates within the legally stipulated period of time within the framework of our statutory duty to inform pursuant to Art. 6 Para. 1 lit. c GDPR. Your contact details will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent that this is necessary for the respective information.
In order to process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.
8.3 Use of Payment Service Providers
- Paddle
A checkout system from the following provider is available on this website: Paddle.com Market Ltd, Judd House, 18-29 Mora Street, London, EC1V 8BT, United Kingdom
When you initiate the ordering process, you will be redirected to a web interface operated by the provider, where you can complete and pay for the order by entering your billing and delivery address and your payment details. The provider is originally responsible for collecting this data and processes the payment in its own name.
After placing and paying for the order, the provider transmits the order data and transaction details to us in accordance with Art. 6 para. 1 lit. b GDPR to the extent necessary for contract processing so that we can fulfil the order.
We have concluded a data processing agreement with the provider that protects the data of our website visitors and prohibits disclosure to third parties.
An adequate level of data protection is guaranteed at the provider's location by an adequacy decision of the European Commission.
8.4 Electronic termination option for continuing obligations with consumers
Consumers who have concluded contracts on this website for continuing obligations for which payment is required (e.g., subscription contracts) have the option of terminating these contracts via an electronic button in accordance with the applicable notice periods. Pressing the button leads to a confirmation page on which the consumer can provide more detailed information on the termination, clearly identify himself and subsequently declare his termination electronically. The collection of personal data and its transmission to us is carried out in accordance with Art. 6 (1) point b GDPR and only to the extent necessary for the proper processing of the termination. Pursuant to Art. 6 (1) point b GDPR, the provided personal data will also be used to confirm receipt of the termination declaration and the termination date by electronic means in text form. The additional legal basis for such processing is Art. 6 (1) point c GDPR. We are legally obliged to provide an electronic termination option for consumer contracts concluded by means of electronic commerce regarding continuing obligations for which payment is required.
8.5 Sending of service and transactional e-mails
To provide our services, we send service and transactional e-mails (e.g. account and sign-in confirmations via magic link, a one-time welcome e-mail after registration, family invitations, cancellation confirmations and notifications about shared cards). For this purpose, we use the dispatch service provider Resend (Plus Five Five, Inc., 2261 Market Street #5039, San Francisco, CA 94114, USA), which processes the data required for dispatch (in particular the e-mail address and message content) on our behalf. The processing is carried out pursuant to Art. 6 (1) points b and f GDPR. We have concluded a data processing agreement with the provider. For data transfers to the USA, the provider is certified under the EU-US Data Privacy Framework.
9) Tools and Miscellaneous
This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box.
Using the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.
The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point f GDPR based on our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.
Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.
Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.
10) Rights of the Data Subject
10.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:
- Right of access by the data subject pursuant to Art. 15 GDPR;
- Right to rectification pursuant to Art. 16 GDPR;
- Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
- Right to restriction of processing pursuant to Art. 18 GDPR;
- Right to be informed pursuant to Art. 19 GDPR;
- Right to data portability pursuant to Art. 20 GDPR;
- Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
- Right to lodge a complaint pursuant to Art. 77 GDPR.
10.2 RIGHT TO OBJECT
IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
11) Duration of Storage of Personal Data
The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).
If personal data is processed on the basis of express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.
If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.
When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If personal data is processed for the purpose of direct marketing based on Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.
Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.
12) Supplementary Information on Data Processing at Postino
12.1 Card creation & audit data
When you create a card, we store the card design (format, texts, image, colour and font choices), the uploaded image (in Supabase Storage) and a randomly generated share token. In addition, for the purpose of preserving evidence in cases of abuse and for law enforcement requests, we collect audit data (IP address of the creator, user agent, timestamp) pursuant to Art. 6 (1) point f GDPR. This audit data is deleted 12 months after the card was created, unless a statutory retention obligation applies.
If persons are identifiable in an uploaded image, the responsibility for obtaining the required consent lies with the person uploading it (see Terms); Postino does not carry out its own content review.
12.2 Birthdays & third-party recipient data
In the birthday calendar and in address or recipient fields you can enter personal data of other persons (typically name, date of birth, optionally relationship). This data is stored exclusively in your account and is not passed on to third parties. The legal basis for the technical storage is Art. 6 (1) point f GDPR; the legal basis vis-à-vis the third party entered (e.g. consent or personal/family context pursuant to Art. 2 (2) point c GDPR) must be ensured by you.
12.3 Opening a shared card
When a shared card is opened via its share link, we count the number of views and store the time of the last view (for the "has my card been seen yet?" feature). We do not store IP addresses or identifiers of the recipient.
12.4 Reporting cards
If you report a card, we store the reason, your optional comment, your IP address and your user agent in order to review the report and, where applicable, pass it on to the competent authorities. This data is deleted 24 months after the review has been completed.
12.5 Disclosure to authorities
In the event of a substantiated suspicion of criminal acts (in particular harassment, identity theft, hate crime, illegal content), we transmit stored audit data (e-mail, IP address, user agent, timestamp) to the competent law enforcement authorities. Legal basis: Art. 6 (1) point c GDPR (legal obligation) or point f GDPR (legitimate interest in protecting affected persons).
12.6 Analytics · PostHog (currently not active)
PostHog (EU region) is planned as a future analytics tool and is currently not active. Before activation, a consent mechanism will be introduced (Art. 6 (1) point a GDPR); this declaration will then be supplemented accordingly.
