1. General
www.turbopass.com is provided by Turbopass GmbH, Niederwall 53, 33602 Bielefeld, +49 (0) 40 87 88 098 50, referred to below as "Turbopass".The security of your data is of particular importance to us. Therefore we provide information about the collection and use of your personal data here and, if necessary, will obtain consent for its use. Please read the following provisions carefully. You can view these at any time at www.turbopass.com/data-protection and print and save them using your browser. If you have any questions please contact us at
We have, of course, taken technical and organizational measures to ensure compliance with statutory data protection provisions. We have also taken precautions against unauthorized access by third parties. However for clarity we point out that the transmission of data - particularly through the internet via email – can be subject to holes in security. Unfortunately, it is never possible to completely protect data against access by third parties. In addition, we cannot monitor the use by third parties of data published on the website.

2. Collection and use of data
Our webpages can be visited anonymously without providing personal information.
Frequent appearance on many other websites – it is technically necessary that data are transmitted to our server via your internet browser. The following data are recorded during an on-going connection for communication purposes between your internet browser and our web server: the visited domain, the operating system used by you, the browser you use, the date and time of your visit to our website and the URL of the page previously visited (referrer address), the access status (file transfer, file not found, etc), the IP address of the requesting computer, the amount of data transferred.. This is merely for statistical purposes and the improvement of our service. We ensure that these data cannot be associated with any particular person. In addition, the log file serves the evaluation of system security and stability as well as administrative purposes. The legal basis for the temporary storage of data or log files is Art. 6 para. 1 lit. f DSGVO.
However, we can only provide you with some of our services if we obtain personal data from you. This data is collected on a voluntary basis. For example, we generate personal data if you use our services and book tickets or other services through our website. In this case, you will be requested to carefully read this data protection policy and then declare your consent to the use of your data prior to the conclusion of the booking process.
If you transmit data to us - even without being registered – e.g. booking requests, form data etc. this data can be made anonymous and used for statistical purposes. This is also the case if no booking is made.

Due to reasons of technical security, in particular, to ward off attacks on our web server, this data may be temporarily stored by us. Tracking back individuals based on this data is not possible. After seven days at the latest, the data is anonymised by shortening the IP address to the domain level, so that it is no longer possible to relate to the individual user. There is no evaluation of this data except for statistical purposes in anonymous form. A merge of this data with data from other data sources is not performed.

3. Collection and use of personal data
a. Registration and booking
Information about our customers helps us to personalize your shopping experience with Turbopass and further improve it. It is not our business to sell this information. We save the data provided by you primarily for order processing. This applies to your name and address, date of birth, user name and password, email address and telephone number as well as the date and time of your registration. When you first make an order or use functions that require registration, your data are saved to set up a customer account to make it quicker and easier for you to purchase our services in the future. You gain the opportunity with your user account to use other parts of our website and to log in to the offers you have purchased. Legal basis of the data processing is with consent Art. 6 Abs. 1 lit. a DSGVO or Art. 6 para. 1 lit. b DSGVO, if processing is required to provide the requested services. Your data will be deleted as soon as the user account on our website is deleted and there are no statutory storage requirements. A change and of your user account, including the data you have provided, can usually be done directly in your user account after logging in. A deletion of your account can be done by sending a message to the afore-mentioned person in charge.
Your personal data may upon consent be used for our own advertising initiatives (emails, newsletters, etc.). You can object to these advertising initiatives at any time by revoking your consent by email to dataprotection [at] turbopass.com or by writing to the above address. In no event will we pass on your details to third parties for commercial purposes.
In order to exclude misuse by external parties, we reserve the right to save your IP-address during the registration or booking process.

b. Payment process (credit cards, PayPal, bank transfer, Klarna/SOFORT banking)
When you pay for the services you have booked, the payment is processed by different payment service providers. Turbopass does not save any payment information during this process. During the payment process, the payment service provider will inform you of its own data protection provisions and request you to agree to them.

In regard to card payments (direct debit/girocard/credit cards) we work together with Concardis GmbH (Concardis), Helfmann Park 7, D-65760 Eschborn, represented by its managing directors ark Freese, Jens Mahlke and Luca Zanotti. In addition to the purchase amount and date, card data are also transmitted to the above-mentioned company. All payment data and data on any chargeback that may occur are only stored as long as they are needed for the processing of payments (including the processing of possible chargeback and collection of receivables) and for the fight against misuse; generally, the data will be deleted no later than 13 months after it has been collected. Beyond that, further storage may be undertaken if and as long as this is necessary to comply with a statutory retention period or to prosecute a specific case of misuse. The legal basis for data processing is according to Art. 6 para. 1 f) General Data Protection Regulation. You may request information and, if necessary, rectification or deletion, as well as the limitation of the processing of your data and/or possibly object to the processing of your data. If you have any questions about data processing by Concardis or to assert your rights, you can contact the Data Protection Officer, either through the given address or by email at Datenschutzbeauftragter@concardis.com. Furthermore, you have the right to complain to a supervisory authority (in Germany at the State Data Protection Commissioner). Please note that the provision of payment data is neither legally nor contractually required. If you do not want to provide your payment details, you can use a different payment method (e.g. cash payment).

In addition, we offer the payment via PayPal. The provider of the payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). If you pay via PayPal, the payment details you enter will be sent to PayPal. The basis for the transmission are Art. 6 Art. 6 para. 1 lit. a DSGVO (consent) and Art. 6 para. 1 lit. b DSGVO (processing to fulfil a contract). You have the right to revoke your consent to data processing at any time. Revocation does not affect the effectiveness of historical data processing operations.

We ,moreover, offer payments via Klarna, a payment service of Klarna AB, Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter “Klarna”). When paying via Klarna (Klarna check-out solution) Klarna collects various personal data from you. Further information is available at: https://www.klarna.com/de/datenschutz/. Klarna uses cookies for the optimization of the Klarna checkout solution, which represents a legitimate interest according to Art. 6 para. 1 lit. F DSGVO. For more information on the use of cookies by Klarna see: https://cdn.klarna.com/1.0/shared/content/policy/cookie/de_de/checkout.pdf. The basis for the transmission of your data to Klarna is Art. 6 Art. 6 para. 1 lit. a DSGVO (consent) and Art. 6 para. 1 lit. b DSGVO (processing to fulfill a contract). You have the right to revoke your consent to data processing at any time. Revocation does not affect the effectiveness of historical data processing operations.

In addition, we offer the payment via "Sofortüberweisung", a payment service of Sofort GmbH, Theresienhöhe 12, 80339 Munich (hereinafter "Sofort GmbH"). Upon payment via “Sofortüberweisung”, among others, for identity verification and to prevent attempts at fraud, the following personal data is transmitted to the Sofort GmbH: First and last name, address, telephone number (s), email address, IP address and possibly other data required for payment processing. The basis for the transmission of your data to Sofort GmbH are Art. 6 Art. 6 para. 1 lit. a DSGVO (consent) and Art. 6 para. 1 lit. b DSGVO (processing to fulfill a contract). You have the right to revoke your consent to data processing at any time. Revocation does not affect the effectiveness of historical data processing operations.

4. Data collection using cookies
Similarly to other webpages, we use so-called cookies on some of our webpages in order to make visits to our website attractive and to enable certain functions to be used. Small text files are placed on your computer, which allow your use of this website to be analyzed anonymously. Most of the cookies used by us are deleted from your hard drive at the end of the browser session (so-called session cookies). Other cookies remain on your computer, enabling us to recognize your computer on your next visit (so-called permanent cookies). Our partner companies are not permitted to use cookies to collect, process or use personal data through our website.
If you do not want cookies to be used, you can prevent this: the help function in the menu list of most web browsers explains how you can configure your browser so that it will not accept new cookies, will notify you of new cookies, or will delete all cookies already received. However, cookies permit you to use some of the functions on our website, so we recommend you to leave the cookie function switched on.

5. Server log files
The page provider automatically collects and saves information in so-called server log files that your browser transmits to us automatically. This includes:
- Browser type / browser version
- Operating system
- Referrer URL
- Host name of the device accessing the page
- Date/time of the server request
This data cannot be associated with specific persons. A combination of this data with other data sources will not occur. We reserve the right to examine this data later if we discover concrete evidence of unlawful use.

6. Contact form
If you send us inquiries using the contact form, the information entered into the form, including the indicated contact information, is used to process the inquiry, and is saved for possible follow-up questions. The information will not be passed on to anyone without your permission. The legal basis for processing the data is our legitimate interest in answering your request in accordance with Art. 6 para. 1 lit. f DSGVO and Art. 6 para. 1 lit. b DSGVO, if your request sets toward the completion of the contract. Your data will be deleted after final processing of your request, as long as no legal storage requirements are in conflict.

7. Newsletter data
If you would like to receive the newsletter offered on the website, we need your e-mail address as well as information which allow us to verify that you are the owner of the e-mail address and want to receive the newsletter. Further data is not collected. This data is used only to send the requested information and will not be passed on to third parties. Upon registration for the newsletter, we store, in additon to the email-address required for shipment, the IP address, which you have used to subscribe to the newsletter as well as the date and time of registration and confirmation in order to prevent possible misuse and retrace it in a later stage. We make use of the application MailChimp for the newsletter dispatch. Upon confirming the registration, you acknowledge that the information you provide to MailChimp will be shared and processed in accordance with its Privacy Policy and Terms.We make use of MailChimp, a platform of the US-provider Rocket Science Group, to distribute our newsletter. Upon confirming the registration, you acknowledge that the information you have shared to MailChimp is used, in accordance with its data protection guidelines and terms, for processing purposes and may be transferred. The Rocket Science Group LLC d/b/a MailChimp is certified according to the Privacy Shield Agreement and thus guranteeing compliance with European data protection standards. The service provider is applied on the basis of a service processing contract and our legitimate interests; Recipient data may be used to optimize the own website without the assignemnt to a user whilst no data will be passed on to third parties.
 

You can unsubscribe from the newsletter at any time via the link inserted in each newsletter or an e-mail to the person mentioned above. After cancellation, your e-mail address will be deleted immediately from our newsletter distribution, as far as you have not expressly consented to a continued use of the collected data or the continued processing is otherwise permitted by law.

8. Web Analytics and Web Tracking
8.1 Google Analytics
This website uses Google Analytics, a web analysis service by Google Ireland Limited („Google"), Gordon House, Barrow Street, Dublin 4, Ierland. Google Analytics uses so-called "cookies", which are text files that are stored on your computer and enable your use of the website to be anlayzed. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymization is activated on this website, your IP address will, however, be abbreviated by Google prior to this within the member states of the European Union or other European Economic Area member states, whereby a direct reference to a person will be impossible. Only in exceptional cases will your full IP address be transmitted to a Google server in the USA and abbreviated there. Google Inc., based in the United States, is certified to the European Privacy Convention "Privacy Shield", which ensures compliance with the level of data protection in the EU. The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO or § 15 Abs. 3 TMG based on our legitimate interest in the statistical analysis of user behaviour for optimization and marketing purposes.

Google will use this information on behalf of this website's operator to evaluate your use of the website, assemble reports about website activity and provide other services for the website operator in connection with website and internet use. The IP address transmitted by your browser in the course of Google Analytics will not be combined with other Google data. You can prevent cookies from being stored by configuring your browser accordingly; we would, however, point out that in this event you may not be able to fully use all functions of this website. In addition, you can also prevent the gathering of data generated by the cookie and relating to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

8.2 Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link: https://www.hotjar.com/legal/policies/privacy

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link: https://www.hotjar.com/legal/compliance/opt-out

8.3 Google AdSense
Our website uses Google AdSense, an online advertising service by Google Ireland Limited ("Google"). Google AdSense uses so-called "cookies", which are text files that are stored on your computer and enable your use of the website to be analyzed. Google AdSense also uses so-called web beacons (invisible graphics). Through these web beacons, information such as the user traffic on the offer pages can be analyzed. The information produced by cookies and web beacons (including the IP address of the user) about the use of this website and delivery of advertising formats are transmitted to a server in the USA and stored there. This information can be passed on to Google's contract partners by Google. However, Google will not combine your IP address with other stored personal data.
 

Users can prevent the installation of cookies by Google AdSense in various ways:
a) through the appropriate settings in their web browser;
b) by deactivating personalized ads from Google at https://www.google.com/settings/u/0/ads/authenticated;
c) by deactivating the personalized ads from providers that are part of the self-regulation campaign "About Ads" at http://www.aboutads.info/choices/#completed;
d) through permanent deactivation by a browser plug-in.
The settings under b) and c) are deleted when cookies are deleted in the browser settings.

More information about data privacy and cookies for advertising with Google AdSense can be found in Google's privacy policy, which is available under the following link: http://www.google.de/policies/privacy/

8.4 Google Analytics remarketing
This website uses the remarketing or "similar target groups" function by Google Ireland Limited ("Google"). With this function, the provider of the website can address the visitors of the website with target-oriented advertising, in which the visitors to the provider's website are shown personalized advertisements when they visit other websites in Google's advertising network. For analyzing the website usage, which is the foundation of the creation of personalized advertisements, Google uses so-called cookies. For this purpose, Google saves a small file with a sequence of numbers in the browsers of the website visitors. With this number, the visits to the website as well as anonymized information about the use of the website is collected. Personal data of the website visitors is not stored. Google uses this information to provide functions for display advertising, such as remarketing, reports about impressions in the Google advertising network, or Google Analytics reports about the performance in various demographics or interest areas. Google may also pass this information on to third parties if required by law or if the third parties process the data on behalf of Google.

This website uses the following Google AdWords functions:
- remarketing,
- interest categories and categorization according to demographic characteristics (e.g. age, gender),
- similar target groups,
- other types of personalized advertising.

We use these Google AdWords functions to readdress visitors of this website on websites of third party providers or address internet users with specific interest profiles based on their internet use. With our cookies, remarketing lists, or other anonymous IDs, we do not collect any personal data.

You can permanently deactivate the use of cookies by Google by opening the following link, and downloading and installing the provided plug-in: https://www.google.com/settings/ads/plugin. Alternatively, you can deactivate the use of cookies by third parties by visiting the deactivation page of the Network Advertising Initiative under http://www.networkadvertising.org/choices/ and following the opt-out information provided there. More information about Google Remarketing as well as Google's privacy policy can be viewed at: http://www.google.com/privacy/ads/. 

9. Transmission of data
We may provide your data to third parties if this is permitted by statute (for example, the German Data Protection Act), and is also necessary, such as the provision of your data to criminal prosecution and regulatory authorities to defend state and public security, as well as for the prosecution of crime. The use of stored data for the performance of the contract also includes passing on your data to third parties and their use of the data where this is necessary to find, perform and conclude your user relationship and any purchase contracts that have been entered.

10. Duration of storage of personal data
The duration of the storage of personal data is determined by the relevant statutory retention periods (e.g. from commercial law and tax law). After expiry of the respective deadline, the corresponding data will be routinely deleted. If data is required to fulfil the contract or to initiate an agreement or if we have a legitimate interest in the re-storage, the data will only be deleted if you are no longer required for these purposes or if you exercise your right of revocation or objection.

11. Data protection by third parties
The website contains links to and (if applicable) from the websites of third parties. If you follow a link to one of these websites, please be aware that these websites are subject to their own data protection provisions and that we cannot accept responsibility for data protection by other parties. Before transmitting your data to third parties you should read their data protection policy.

12. Right to information
Under the German Data Protection Act you have a right to be given information related to the data we have stored about you free of charge. You are entitled to the correction, restriction of processing or deletion of such data. In addition, you have the right to transfer your personal data to other persons responsible (data transferability according to Art. 20 GDPR) as well as the right of complaint and the revocation of granted consent. Requests can be sent at any time and in no special form, to dataprotection [at] turbopass.com or Turbopass GmbH, Niederwall 53, 33602 Bielefeld.

13. Right of withdrawal
You can also object to anonymized data collection and storage. You also have the option to revoke an existing consent at any time. The specification of reasons is not required for this purpose. Please direct contradictions of this kind to dataprotection [at] turbopass.com (please replace the [at] in your email with the @ sign) or send it via post to the address mentioned above.

14. Changes
We will notify you of any changes to our Data Protection Policy here. We therefore request that you visit this page regularly.

15. Cookies
We use cookies when you visit our website. Cookies are small text files that your internet browser places and stores on your computer. When you visit our website again, these cookies provide information to automatically recognize you. Cookies also include the "user IDs", where user information is stored using hidden profiles. When you visit our website, we inform you about the use of cookies for the aforementioned purposes and how you can object to or prevent their storage by referring to our data protection declaration.The following types of cookies are distinguished:

• Necessary, essential cookies: Essential cookies are cookies that are absolutely necessary for the operation of the website in order to store certain website functions such as logins, shopping cart or user entries, e.g. regarding the language of the website.

• Session-Cookies: Session-Cookies are needed to recognize multiple use of anoffer by the same user (e.g. if you have logged in to determine your login status). When you visit our Website again, these cookies provide information toautomatically recognize you. The information obtained in this way serves to optimize our offers and make it easier for you to access our site. When you close the browser or log out, the session cookies are deleted.

• Persistent cookies: These cookies remain stored even after closing the browser. They are used to store the login, the range measurement and for marketing purposes. They are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete the cookies at any time in the security settings of your browser.

• Third-party cookies (third party cookies, especially from advertisers): You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. However, we would like to inform you at this point that you may not be able to use all functions on our website. Read more about the cookie topic with the respectivedata protection declarations of the third party providers.

15.1 Data categories:
User data, cookie, user ID (especially the pages which have been visited, device information, access times and IP addresses).

15.2 Purpose of the processing:
The information which have been obtained in this way, serves the purpose of optimizing our web offers technically and economically and to enable you to access our website more easily and securely.

15.3 Legal basis:
The information which have been obtained in this way, serves the purpose of optimizing our web offers technically and economically and to enable you to access our website more easily and securely.

15.4 Storage period/ cancelation:
The data will be deleted as soon as they are not longer necessary for the purposeof their collection. In case of the collected data for the provision of the website, this is the case when the respective session is ended.Cookies are otherwise stored on your computer and transmitted from there to oursite. Therefore, you, as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies which are already stored can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it is possible that not all functions of the website can be used to their full extent.

15.5. Objection
The storage of cookies on your hard drive can be generally prevent regardless of consent or legal permission, by selecting in your browser settings "do not accept cookies". However, this can result in a functional restriction of our offers and Website. You can reject the use of third-party cookies for advertising purposes viathis American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de/praferenzmanagement/)

15.6. Cookies

Your settings for cookies on our website are obtained in advance consent from you. You can view and edit the cookie settings directly via the following link:

Manage Cookie-Settings

Data Protection Provisions, 25th May 2018