Data Privacy Policy

We as operators of the PaulCamper platform on the websites "https://paulcamper.de, https://paulcamper.com, https://paulcamper.at and https://paulcamper.nl", https://paulcamper.co.uk and the mobile app ("Platform") are responsible in the sense of the applicable data protection law, in particular the General Data Protection Regulation ("GDPR"), for the personal data of the user ("you") of this website.

In the following, we inform you clearly within the scope of our information obligations (Art. 13 et seq. GDPR) about which data is processed when you visit our platform and on which legal basis this is done. You will also receive information about how we protect your data in technical and organizational terms and what rights you have against us and against the competent supervisory authority.

Due to your registration or a legal requirement, you may be obliged to provide personal data, especially if this is necessary to fulfill your own contractual or legal obligations. In this respect, you may be liable for fines or damages if you fail to provide this information. As far as the disclosure of your data is necessary for the fulfillment of our obligations, there is an obligation on your part. A refusal can result in the loss of your entitlement to benefits as well as claims for damages on our part.

You are not subject to automated decision-making in the sense of Art. 22 GDPR.

1. Information about the responsible person

Name and contact details: Represented by the managing director Dirk Fehse. Landsberger Allee 117, D-10407 Berlin, Germany Phone: +49 (0) 30 609 849 722

Fax: +49 (0) 30 37 71 94 21 E-Mail: hello[at]paulcamper[dot]co[dot]uk

2. Data protection officer

We have appointed a company data protection officer: Michael Nachtigall c/o DS Compliance GmbH Carlsplatz 24 40213 Düsseldorf Tel: +49 (0) 211 942 588 - 24 E-mail: m.nachtigall[at]wecomply[dot]de

3. Processing of your personal data

3.1 Informative use of our website

If you call up our website merely to visit it, so-called log files are processed by being automatically recorded by our system. The following log files are processed automatically:

• IP address of the requesting computer
• Type of Internet browser used
• Language of the Internet browser used
• Version of the Internet browser used
• Operating system and its version
• Interface of the operating system
• Pages visited
• Date and time of the visit
• Time zone difference from Greenwich Mean Time (GMT)
• Access status/http status code
• Amount of data transferred
• Referrer
• Websites accessed by the visitor's system via our website
• Internet service provider of the user

The log files contain your IP address and possibly other personal data. Therefore, an assignment to you is generally possible. However, we only store your data temporarily and, in particular, not together with other personal data.

The processing of the above-mentioned data is necessary for the provision of our website. We also store the data for the purpose of the security of our information technology systems. In these purposes is also our legitimate interest to process the data on the legal basis Art. 6 (1) lit. f GDPR. The log files, which also contain your IP address, are deleted or anonymized immediately after they are no longer required to achieve the aforementioned purposes, but at the latest after one month.

3.2 Contact by e-mail

You have the possibility to contact us by e-mail. Your personal data transmitted in the e-mail will be stored by us. The data will not be passed on to third parties. The data will be processed exclusively to handle your contact. The legal basis for processing your data depends on the content of your inquiry. Basically, the legal basis is our legitimate interest according to Art. 6 (1) f GDPR to offer you a simple and convenient way to contact us. The data will be stored until they are no longer required to achieve the purpose of the conversation with you and the concern of your contact has been comprehensively clarified.

If your e-mail is aimed at concluding a contract with us, the additional legal basis for the processing of your personal data is Art. 6 (1) lit. b GDPR. This data will be stored as long as it is necessary for the execution of the contract. Beyond that, we only store your data in order to comply with contractual or legal obligations (e.g. tax obligations).

You can object to the processing of your personal data at any time by sending an e-mail to "hello[at]paulcamper[dot]co[dot]uk". In this case, all personal data of the conversation will be deleted and a continuation of the conversation is not possible.

3.3 Support

You can contact us directly by mail. For this purpose, we use the tool Zendesk of Zendesk, Inc. 1019 Market St., San Francisco, CA 94103, USA ("Zendesk"). In doing so, Zendesk receives the data that you provide as part of the request.

For each support request, this is at least the following information: First and Last Name, User-Id, Phone Number, Email Address, Camper Name(s), Booking ID, and the history of your previous support requests.

In addition, Zendesk may receive other personally identifiable information that you voluntarily submit as part of your support request.

As part of a general support request, Zendesk receives the following information: Email address (to contact you), first and last name, phone number, time (date and time) your information was submitted to us, your IP address, and any other personally identifiable information you voluntarily submit as part of your support request.

Zendesk may analyze and categorize your requests for faster processing and to improve support. For example, frequently used keywords are assigned to your request. The legal basis for processing your data depends on the content of your request. Basically, the legal basis is our legitimate interest according to Art. 6 (1) f GDPR to offer you a simple and convenient way to contact us. Your IP address is recorded to ensure the security of our systems and to prevent misuse. The data will be stored until they are no longer necessary to achieve the purpose of the conversation with you and the concern of your contact has been fully clarified. The data will be stored until they are no longer necessary to achieve the purpose of the conversation with you and the request for your contact has been fully clarified.

You can object to the processing of your personal data at any time by sending an e-mail to "hello[at]paulcamper[dot]co[dot]uk". In this case, all personal data of the conversation will be deleted and a continuation of the conversation is not possible.

3.4 Newsletter

On our platform, we offer you the opportunity to subscribe to our newsletter free of charge. In addition to your declaration of consent, we need your e-mail address. By sending the newsletter registration, you agree to the processing of your data by us. Further details, e.g. your name, are voluntary and serve to address you personally. The legal basis for sending the newsletter is Art. 6 (1) lit. a GDPR.

For sending the newsletter, we use the email provider MailChimp, The Rocket Science Group LLC, 675 Ponce de Leon Avenue NE, Suite 5000, Atlanta, GA 30308, USA ("MailChimp"). Your data is transmitted to MailChimp in the USA and stored there. In addition to the simple e-mail dispatch, MailChimp offers various analysis options in order to find out for us whether, when and where the sent newsletters are opened, used or rejected. Among other things, MailChimp uses cookies and similar technologies for this purpose.

You can find more information about MailChimp's privacy policy at the following web addresses:

https://mailchimp.com/legal/privacy/
https://mailchimp.com/legal/cookies/

We will only send you the newsletter if you first confirm your registration via a confirmation e-mail sent to you for this purpose by clicking on the link provided. This is to ensure that only you can subscribe to the newsletter. Your confirmation must be made promptly after receipt of the confirmation e-mail, otherwise your newsletter registration will be automatically deleted from our database.

In addition, we store the time (date and time) of transmission of your data to us, as well as your IP address. The processing of this data is in accordance with our legitimate interest pursuant to Art. 6 (1) lit. f GDPR to document your consent, to ensure the security of our systems and to prevent misuse.

Your data will not be passed on to third parties and will only be processed in connection with the sending of newsletters. The purpose of processing your e-mail address is to enable us to send you the newsletter. Further data within the scope of the registration process serve either to address you personally or to ensure the security of our services and to prevent misuse of the e-mail address used.

Your data will only be stored as long as it is necessary to achieve the purpose. Your e-mail address will therefore be stored for the duration of your active newsletter subscription if you have given your consent for this. The additional data that we automatically collect during your subscription (IP address, date and time) will be deleted at the latest when you end your newsletter subscription.

If you make use of our services, for example a booking via our platform, we may use your email address to send you direct advertising for our own or similar goods or services, such as new vehicle categories, new functionalities or similar. The legal basis for sending newsletters in connection with the sale of goods or services is Article 6 (1) f GDPR. Our legitimate interest is to inform you about our new services and to present you with useful additions to the services you have already booked.

Option to object / unsubscribe from our newsletter
You can unsubscribe or cancel our newsletter at any time. You will find the link at the end of each newsletter. By doing so, you revoke your consent or object to further use of your data for the purpose of sending the newsletter.

3.5 Cookies

Please note the following: You can ensure yourself that no cookies are stored on your computer at all, or that the storage of only certain cookies is allowed. You can select this in your Internet browser settings. You can also view and delete the stored cookies there. If you block all cookies, it is possible that not all functions of our website will be available to you. We use cookies on our website. Cookies are text files that are sent from our web server to your browser when you visit our website and are stored on your computer for later retrieval. A cookie can therefore identify your Internet browser when you call up the website again.

Third-party cookies (third-party cookies)
We use cookies from so-called "third-party providers" on our website. This means that during your visit to our website, data is transferred from your web browser to the third party's web server and stored there.

Google Conversion Tracking
This website uses the online advertising program "Google AdWords" and as part of this, conversion tracking to measure on which web pages Interhyp AG's advertisements work best. The conversion tracking cookie is set when a user clicks on an ad placed by Google or its partners. The cookies set as a result lose their validity after 30 days and are not used for personal identification. This cookie allows us and Google to recognize through which ad you came to our website. Each visitor who came to our site via Google AdWords receives a different cookie. The information collected using the conversion cookie is used to determine which visitors triggered a specific action on our website via ads. We learn the total number of users who clicked on our ads and which clicks resulted in an action. We do not receive any information that personally identifies a user. Users who do not wish to participate in the tracking can easily delete the Google conversion tracking cookie via their internet browser under the user settings or deactivate it in principle. These users will then not be included in the conversion tracking statistics. Learn more about Google's privacy policy (https://policies.google.com/privacy?gl=en).

Google Remarketing
In addition, this website uses Google's program for interest-based advertising, known as Google Remarketing. Third-party vendors, including Google, serve ads on websites across the Internet using stored cookies based on a user's previous visits to that website. You can also disable Google's use of cookies for these purposes by visiting the Google advertising opt-out page (http://www.google.com/privacy_ads.html). Alternatively, you can disable the use of third-party cookies by visiting the Network Advertising Initiative disable page (http://www.networkadvertising.org/managing/opt_out.asp). By using Interhyp.de, you consent to the processing of data about you by Google in the manner and for the purposes set out above. We would like to point out that Google has its own data protection guidelines, which are independent of those of Interhyp AG. We assume no responsibility or liability for these policies and procedures. Please inform yourself about Google's privacy policy (https://policies.google.com/privacy?hl=en&gl=en) before using our website.

Google Analytics
On our website, the analysis service Google Analytics of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (hereinafter: "Google Analytics") is implemented.

• Google Analytics sets cookies that store the following information:
• Type of Internet browser used
• version of the internet browser
• the operating system you are using
• Referrer (previously visited website)
• Your shortened IP address
• Time of the server request

We use the Google Analytics feature to anonymize your IP address before storing or processing it. As a rule, your IP address is still shortened within the European Union/EEA and only then transferred to Google servers in the USA. The processing of your information is done as a pseudonym and we will not merge it with other personal data from you.

We use the data collected in this way for statistical purposes in order to optimize our website and offers. The legal basis for this is Art. 6 (1) lit. f GDPR.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link (http://tools.google.com/dlpage/gaoptout?hl=de).

You can either prevent the storage of Google cookies directly in your browser settings yourself, or prevent the processing of your data by clicking on the following link and "opting out": https://tools.google.com/dlpage/gaoptout. This will set an "opt-out cookie" that prevents the collection of your user data on this website.

You can find Google's privacy policy at the following link:https://policies.google.com/privacy?gl=en.

Social plugins
Social plugins (e.g. Facebook, Twitter) can collect data about your website visit and use it for networking. PaulCamper embeds social plugins from the following platforms.

Facebook
This website uses social plugins from the social network facebook.com ("Facebook"). Facebook is operated by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA. Detailed information about the functions of the individual plugins and their appearance can be found on the following website: https://developers.facebook.com/docs/plugins/. Those web pages of our Internet presence that contain Facebook social plugins establish a direct connection with Facebook's servers via your browser when you open them. Information is thereby transmitted to Facebook that the page of our Internet presence containing the social plugin has been accessed by you. Insofar as you are logged into Facebook at this time, the visit to our pages as well as all of your interactions in connection with the social plugins (e.g. clicking the "Like" button, creating a comment, etc.) can be assigned to your Facebook profile and stored by Facebook. Even if you do not have a Facebook profile, it cannot be ruled out that Facebook will store your IP address. Regarding the purpose and scope of the data collection as well as the processing and use of the data by Facebook, we refer to the Facebook privacy policy: https://www.facebook.com/about/privacy/. There you will also find an overview of the settings options in your personal Facebook profile to protect your privacy and your associated rights. To prevent Facebook from collecting data through your visit to our website, log out of Facebook before visiting our site. One way to prevent Facebook from generally accessing your data on our and other websites is to disable the Facebook social plugins by using an add-on for your browser.

3.6 Icon links to social networks

On our website, we use small icons that refer to our website on third-party platforms (Facebook, Twitter, YouTube and Google+). These are hyperlinks in each case, so no data is transferred from you automatically, but only when you click on the icons and a new tab opens in your browser with the website of the third-party provider.

4 Recipients of the data

As a matter of principle, we do not share your data with third parties. If you use our services as a landlord or tenant, we share your personal data to the extent necessary with the other party to carry out the booking. We use a web hoster for the technical provision of our platform and Google to perform usage analysis. They receive your personal data under a contract processing agreement and process your data only strictly according to our instructions. To a certain extent, your data is also processed outside the European Union or the European Economic Area. When using the services of Google, YouTube, Zendesk and MailChimp, your data will be transferred to the extent described above to the USA and thus to a third country within the meaning of Art. 44 GDPR and processed there. All providers are certified under the EU-US Privacy Shield. This ensures an appropriate level of data protection. We also work with developers located in Russia, Belarus and Ukraine. These developers are not directly contracted to process your data, but they have access to our systems as part of their job. We have entered into a processing agreement and EU standard contractual clauses with all developers to ensure an adequate level of data protection.

5. Your rights under GDPR

If we process your data, you are a "data subject" within the meaning of the GDPR. You have the following rights: right to information, right to rectification, right to restriction of processing, right to erasure, right to information and right to data portability. In addition, you have a right of objection and a right of withdrawal. Below you will find details on the individual rights:

Right to information
You have the right to request confirmation from us as to whether we are processing your personal data.

• If we process your personal data, you have the right to obtain information about the following:
• the purposes of processing
• the categories of personal data that are processed;
• the recipients or categories of recipients to whom your personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations;
• if possible, the planned duration for which your personal data will be stored or, if this is not possible, the criteria for determining this duration;
• the existence of a right to rectification or erasure of the personal data concerning you or to restriction of processing by us or a right to object to such processing;
• The existence of a right of appeal to a supervisory authority;
• if the personal data has not been collected directly from you, any available information about the origin of the data;
• the existence of automated decision-making, including profiling, pursuant to Article 22 (1) and (4) of the GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for you.

If we transfer your data to an international organization or to a third country, you also have the right to request information about whether appropriate safeguards exist in accordance with Art. 46 GDPR in connection with the transfer.

Right to rectification
You have the right to correct and/or complete the data we have stored about you if this data is incorrect or incomplete. We will carry out the correction or completion without delay.

Right to restriction of processing
Under certain circumstances, you have the right to request that we restrict the processing of your personal data. For this, at least one of the following conditions must be met:

• You dispute the accuracy of the personal data for a period of time that allows us to verify the accuracy of the personal data,
• The processing is unlawful and you object to the erasure of the personal data and instead request the restriction of the use of the personal data;
• We no longer need the personal data for the purposes of processing, but you need it to assert, exercise or defend legal claims; or
• You have objected to the processing pursuant to Art. 21 (1) GDPR, as long as it has not yet been determined whether our legitimate reasons outweigh your interests.

Right to erasure (“right to be forgotten”)
You have the right to demand that we delete your personal data immediately if we are obliged to do so. This is the case if one of the following conditions is met:

• Your personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
• You revoke your consent on which the processing was based pursuant to Art. 6 (1) lit. a or Art. 9 (2) lit. a GDPR and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
• Your personal data has been processed unlawfully.
• The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which we are subject.
• Your personal data has been collected in relation to information society services offered in accordance with Art. 8 (1) GDPR.

If we have made your personal data public, and we are obliged to erase it in accordance with the aforementioned conditions, we shall take reasonable measures, including technical measures, to inform other data controllers processing the personal data that you have requested that we erase all links to or copies or replications of that personal data, taking into account the technologies and implementation costs available to us.

However, your right to erasure does not exist if the processing is necessary for the following reasons (exceptions):

• To exercise the right to freedom of expression and information;
• For compliance with a legal obligation which requires processing under Union or Member State law to which we are subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
• for reasons of public interest in the area of public health pursuant to Art. 9 (2) lit. h and i and Art. 9 (3) GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the right referred to in (1) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
• for the assertion, exercise or defense of legal claims.

Right of Notification
If you have exercised your right to rectify, erase or restrict the processing of your data to us, we are obliged to notify all recipients to whom we have disclosed your personal data of the rectification, erasure or restriction of the processing of your data, unless this proves impossible or involves a disproportionate effort.

Right to data portability
You have the right, subject to the following condition, to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and the right to have this data transferred to another controller:

The processing is based on consent pursuant to Art. 6 (1) lit. a or Art. 9 (2) lit. a GDPR or on a contract pursuant to Art. 6 (1) lit. b and the processing is carried out with the help of automated procedures.

You have the right to request that we transfer your personal data directly to another controller, insofar as this is technically feasible and does not affect the freedoms and rights of other persons.

This right to data portability does not apply if the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6 (1) lit. e or lit. f GDPR. This also applies to profiling based on these provisions. We will no longer process your personal data after an objection, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If we process your personal data for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing. This also applies to profiling, insofar as it is related to direct advertising.

If you object to the processing of your personal data for direct marketing purposes, we will no longer process it for these purposes.

You have the option, in connection with the use of information society services - notwithstanding Directive 2002/58/EC (Directive on privacy and electronic communications) - to exercise your objection by means of automated procedures using technical specifications.

Right of withdrawal
According to Art. 7 (3) GDPR, you have the right to revoke your consent at any time. The revocation of consent does not retroactively invalidate the lawfulness of the processing.

Right of complaint to a supervisory authority
You have the right to lodge a complaint with a supervisory authority, without prejudice to any other administrative or judicial remedy. In particular, you can assert your right to complain in the member state of your place of residence, your place of work or the place of the alleged infringement if you believe that the processing of your personal data violates the GDPR.

You can find an overview of the respective data protection commissioners of the federal states as well as their contact details under the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

6. Date and change of this privacy policy

Status: last changed 3rd of March 2021.