Privacy Policy

1. Introduction

This Privacy Policy explains how we collect and process personal data when you visit smarttrusthub.com (the “Website”).

The term “personal data” means any information relating to an identified or identifiable natural person (e.g. IP address, email address, etc.).

We take the protection of your personal data very seriously and process it in accordance with the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the German Telecommunications and Telemedia Data Protection Act (TTDSG), where applicable.

If you have any questions about this Privacy Policy or about data protection on this Website, you can contact us at any time using the details below.


2. Controller

The controller responsible for data processing on this Website (within the meaning of Art. 4(7) GDPR) is:

SmartTrust Hub
Emsdettener Str. 10
C/O Grosch Postflex #2290
48268 Greven
Germany

Phone: +49 6131 4896762
E-mail: contact(at)smarttrusthub.com


3. Hosting

This Website is hosted by an external provider:

HOSTINGER operations, UAB
Švitrigailos str. 34
LT-03230 Vilnius
Lithuania

Email: domains@hostinger.com

All data collected on this Website are stored on Hostinger’s servers. This may include, in particular, IP addresses, log files, and other technical data that are necessary for operating the Website.

The use of external hosting is based on our legitimate interest in a secure, fast and efficient provision of our Website (Art. 6(1)(f) GDPR) and, where applicable, on Art. 6(1)(b) GDPR (performance of contract).

We have concluded a data processing agreement (DPA) with Hostinger in accordance with Art. 28 GDPR.


4. General information on data processing

4.1 Scope of processing

We process personal data only to the extent necessary:

  • to provide this Website and its functions,

  • to analyze and optimize our content and reach,

  • to manage consents for cookies and similar technologies,

  • to operate affiliate marketing links.

We do not offer user registration, online payment, comments, or a contact form on this Website. If you contact us directly by email, the data you provide will be processed solely to handle your request (see section 7).

4.2 Legal bases

Depending on the specific processing, we rely on the following legal bases:

  • Art. 6(1)(a) GDPR – your consent (e.g. for non-essential cookies, analytics, and marketing tags such as Google Analytics or the Pinterest Tag, managed via our cookie banner / Complianz).

  • Art. 6(1)(b) GDPR – performance of a contract or pre-contractual measures (in rare cases where applicable).

  • Art. 6(1)(c) GDPR – compliance with legal obligations.

  • Art. 6(1)(f) GDPR – legitimate interests (e.g. secure website operation and basic server logs).

Where we rely on your consent, you can withdraw it at any time with effect for the future.

4.3 Storage period

Unless a more specific retention period is stated in this Privacy Policy, we store your personal data only for as long as necessary for the purposes described. After the purpose ceases to apply, data are deleted unless we are obliged by law to retain them longer (e.g. tax or commercial retention obligations).


5. Your rights under the GDPR

You have the following rights with respect to your personal data:

  • Right of access (Art. 15 GDPR): You can obtain information about which personal data we process.

  • Right to rectification (Art. 16 GDPR): You can request correction of inaccurate or incomplete data.

  • Right to erasure (Art. 17 GDPR): You can request deletion of your data under certain conditions.

  • Right to restriction of processing (Art. 18 GDPR).

  • Right to data portability (Art. 20 GDPR).

  • Right to object (Art. 21 GDPR):

    • You can object at any time to processing based on Art. 6(1)(e) or (f) GDPR for reasons arising from your particular situation.

    • You can object at any time to processing for direct marketing purposes.

  • Right to withdraw consent (Art. 7(3) GDPR): You can withdraw consent at any time with effect for the future.

  • Right to lodge a complaint with a supervisory authority (Art. 77 GDPR), in particular in the EU member state of your habitual residence, place of work or the place of the alleged infringement.

You can exercise your rights at any time by contacting us via the contact details provided above.


6. Data processing when visiting our Website

6.1 Server log files

When you visit our Website, our hosting provider automatically collects and stores information in so-called server log files, which your browser automatically transmits, for example:

  • Browser type and version

  • Operating system used

  • Referrer URL

  • Host name of the accessing computer

  • Date and time of the server request

  • IP address

This data is not merged with other data sources.

The processing is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the technically error-free presentation and optimization of our Website; for this purpose, server log files must be recorded.


6.2 Cookies and Consent Management (Complianz)

We use cookies and similar technologies on this Website. Some cookies are technically necessary; others are used for statistics and marketing.

Cookie consent on this Website is managed by the Complianz plugin (Complianz B.V., Kalmarweg 14-5, 9723 JG Groningen, Netherlands). WordPress.org

Complianz:

  • displays the cookie banner and records your consent choices,

  • stores a consent cookie in your browser so that your settings are remembered,

  • may perform website scans to identify cookies and services used (public data only).

The use of Complianz and storage of the consent cookie is based on Art. 6(1)(c) GDPR (legal obligation to document consent) and our legitimate interest in legally compliant cookie management (Art. 6(1)(f) GDPR).

You can change or withdraw your consent at any time via the cookie settings on our Website.


6.3 Cookies

Cookies are small text files that are stored on your device. We use:

  • Technically necessary cookies (e.g. to remember your cookie preferences). These are based on Art. 6(1)(f) GDPR and do not require consent.

  • Statistics and marketing cookies (e.g. for Google Analytics, Pinterest Tag). These are only set if you give your consent via the cookie banner (Art. 6(1)(a) GDPR, § 25(1) TTDSG).

You can configure your browser so that you are informed about the setting of cookies, only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this Website may be limited.

Details on individual cookies can be found in the cookie banner / cookie policy generated by Complianz.


6.4 Affiliate links and external websites (ClickBank & others)

Our Website contains affiliate links, especially to products offered via ClickBank and other third-party providers. When you click such a link:

  • you are redirected to the external provider’s website, and

  • this provider may collect and process personal data under its own responsibility (e.g. through cookies, tracking scripts, web analytics, or payment systems).

We do not have control over how these third-party websites process your data and are not responsible for their content or privacy practices. Please refer to the privacy policies of the respective providers (e.g. ClickBank) for more information about their data processing.

Affiliate marketing on our Website is based on our legitimate interest in financing our online offering (Art. 6(1)(f) GDPR). Any tracking by the affiliate network that relies on cookies or similar technologies is based on your consent given via the cookie banner, where applicable.


6.5 Contact by e-mail

If you contact us directly by e-mail, we will process the data you provide (e.g. name, e-mail address, content of your message) exclusively to handle your request.

Depending on the nature of the request, the legal basis is:

  • Art. 6(1)(b) GDPR (pre-contractual or contractual communication) or

  • Art. 6(1)(f) GDPR (our legitimate interest in responding to enquiries).

We store your enquiry for as long as necessary to process it and in accordance with statutory retention periods.


7. Analytics and tracking tools

7.1 Google Tag Manager

We use Google Tag Manager, a tag management system provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google

Google Tag Manager allows us to manage and load other tools (such as Google Analytics and the Pinterest Tag) via a single interface. Google Tag Manager itself does not create user profiles and does not store cookies. However, when Google Tag Manager is loaded, your IP address and certain technical information may be transmitted to Google servers (including servers in the United States).

Google Tag Manager is used on the basis of your consent (Art. 6(1)(a) GDPR, § 25(1) TTDSG) where it triggers tools that rely on cookies or other identifiers. You can withdraw your consent at any time via our cookie settings.


7.2 Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Hilfe+1

Google Analytics enables us to analyze how visitors use our Website (e.g. which pages are visited, how long they stay, which devices and browsers are used). Google Analytics 4 does not store IP addresses from EU users; IP addresses are dropped before logging. Nevertheless, Google processes technical and usage data, and data may be transferred to Google servers outside the EU (especially in the US).

We use Google Analytics exclusively on the basis of your prior consent via the cookie banner (Art. 6(1)(a) GDPR, § 25(1) TTDSG). You can withdraw your consent at any time with effect for the future.

You can also install a browser plug-in provided by Google to prevent data collection by Google Analytics:
https://tools.google.com/dlpage/gaoptout

Further information about Google’s data processing and privacy settings is available in Google’s privacy policy.


7.3 Pinterest Tag / Pinterest Conversion Tracking

We use the Pinterest Tag (conversion tracking) from Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland. Pinterest

The Pinterest Tag is a piece of JavaScript code that allows Pinterest to track conversions and interactions on our Website (e.g. page visits, sign-ups, or other events) and associate them with Pinterest campaigns. For this purpose, cookies and similar technologies may be used, and data such as:

  • pages visited,

  • actions taken (conversions),

  • device information,

  • and possibly hashed identifiers

may be transmitted to Pinterest servers, including servers in third countries (e.g. the USA).

We use the Pinterest Tag exclusively on the basis of your consent via the cookie banner (Art. 6(1)(a) GDPR, § 25(1) TTDSG). Without your consent, the Pinterest Tag is not activated.

You can find more information about data processing by Pinterest in Pinterest’s privacy policy.


8. Security / SSL encryption

For security reasons and to protect the transmission of confidential content (e.g. when you access the site or send us an email address), this Website uses SSL encryption (HTTPS). You can recognize an encrypted connection by the lock icon in your browser bar and the “https://” in the address line.

When SSL encryption is activated, data that you transmit to us cannot be read by third parties.


9. Children’s data

Our Website and our content are not directed at children under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe that a child under 16 has provided us with personal data, please contact us so that we can delete this data.


10. International data transfers

Some of the services we use (for example, Google and Pinterest) may transfer personal data to countries outside the European Union / European Economic Area, in particular to the United States. In such cases, we ensure that appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses approved by the European Commission.

Further details can be found in the privacy policies of the respective providers.


11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices or legal requirements. The current version is always available on this page.

If we make significant changes, we may inform you separately (e.g. via a notice on the Website).