Data Privacy Policy and Cookies

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as 'Data') within our online offering and the related websites, features and content. (Collectively referred to as 'web appearance' or 'online offer'). With regard to the terminology used, e.g. 'Processing' or 'Controller', we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Person responsible / Controller

InstaVouch UG (haftungsbeschränkt)
Dietrich-Bonhoeffer-Str. 16
10407 Berlin
Geschäftsführer: Marvin Lindtke

Nature of processed data

Purpose of data processing

Used terminology

'Personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

'Processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

'Pseudonymisation' means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

'Profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

'Controller' means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

'Processor' means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data privacy policy is mentioned, the following applies: The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) (b) GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) (c) GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Art. 6 (1) (f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR as legal basis.

Safety measures

We take appropriate safety measures in accordance with Art. 32 GDPR, considering the state of the art, the implementation costs and the nature, scope, context and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk. Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. In addition, we have established procedures that ensure the enjoyment of data subject rights, data erasure and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection by technology design and by privacy-friendly default settings taken into account (Art. 25 GDPR).

Collaboration with processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR, is needed to fulfill the contract), you have consented to a legal obligation or based on our legitimate interests (e.g. the use of agents, webhosters, etc.).

If we engage third parties to process data on the basis of a contract, this is done in accordance to Art. 28 GDPR.

Data transfers to third countries

If we process data in a third country (i.e. outside the European Union or the European Economic Area) or in the context of the use of third party services or disclosure, or transmission of data to third parties, this will only be done if it is necessary to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called 'standard contractual clauses').

Rights of data subjects

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

You have, in accordance with Art. 16 GDPR, the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.

In accordance with Art. 77 GDPR, you have the right to file a complaint with the competent supervisory authority.

Right of Withdrawal

You have the right to revoke the granted consent pursuant to Art. 7 (3) GDPR with effect for the future.

Right of Objection

You can contradict to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right of Objection in direct mail

'Cookies' are small files that are stored on the user's computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, also known as 'session cookies' or 'transient cookies' are cookies that are deleted after the user leaves the online shop and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or the login status can be saved. The term 'permanent' or 'persistent' refers to cookies that remain stored even after the browser has been closed. Within these cookies the login status can be saved for several days until the user visits the online service again. The interests of the users can be stored as well in such a cookie. These information may be used for range measurement or marketing purposes. A 'third-party cookie' refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if they are only the controller's cookies, these are called 'first-party cookies').

We can use temporary and permanent cookies and are clarifying the usage in the context of our privacy policy.

If users do not want cookies stored on their computer, they will be asked to disable the option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be explained for a variety of services, especially in the case of tracking, over the US website or the european page Furthermore the storage of cookies can be discontinued by switching it off in the settings of the browser. Please note that not all features of this online offer may be used after this.

Deletion of data

The data processed by us are deleted or limited in their processing in accordance with Art. 17 and Art. 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. So the data is blocked and not processed for any other purposes. This applies for example for data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 10 years according to section 147 (1) German Commercial Code and section 257 (1) No. 1 and 4 German Commercial Code (books, records, management reports, accounting documents, trading books, relevant documents for taxation, etc.) and 6 years in accordance with section 257 (1) no. 2 and 3 and (4) German Commercial Code (commercial letters).

Business-related data processing

In addition we process the following data

from our customers, prospects and business partners for the purpose of providing contractual services, support and customer care, marketing, advertising and market research.


The hosting services we use are for the purpose of providing the following services we need to operate this online service: infrastructure and platform services, computing capacity, storage and database services, security and technical maintenance services.

We respectively our hosting provider are processing inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR.

Collection of access data and log files

We, respectively our hosting provider, are collecting on the basis of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information are stored for security purposes (e.g. to investigate abusive or fraudulent activities) for a maximum of 7 days until deletion. Data whose further retention is required for evidential purposes shall be exempted from the deletion until final clarification of the incident.

Order processing in the online shop and customer account

We process the data of our customers as part of the ordering process in our online shop to allow them to select and order the selected products and services, as well as to complete their payment and delivery or execution of the order.

The processed data includes inventory data, communication data, contract data, payment data and persons affected by the processing belong to our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery and customer service. Here we use session cookies for the storage of the shopping cart contents and permanent cookies for the storage of the login status.

Processing is based on Art. 6 (1) (b) (execution of order transactions) and (c) (legally required archiving) GDPR. The information marked as required for the justification and fulfillment of the contract is required. We disclose the data to third parties only in the context of extradition, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if necessary for the fulfillment of the contract (e.g. on customer's request upon delivery or payment).

In order to execute orders the user has to create a customer account. As part of the registration, the required mandatory information will be communicated to the users during registration and during the order. The user accounts are not public and can not be indexed by search engines. If users delete their user account, their data belonging to the account will be deleted, if not necessary for commercial or tax reasons in accordance with Art. 6 (1) (c) GDPR. Information in the customer account remains until its deletion with subsequent archiving in case of a legal obligation. It is the responsibility of the users to secure their data upon termination before the end of the contract.

As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 (1) (c) GDPR.

The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years. In the case of legal archiving obligations, the deletion takes place after its expiration [end of commercial law (6 years) and tax law (10 years) retention obligation].

Third-party payment service providers

We use external payment service providers through whose platforms users and we can make payment transactions.

As part of the fulfillment of contracts, we set the payment service providers on the basis of Art. 6 (1) (b) GDPR. Otherwise, we use external payment service providers on the basis of our legitimate interests in accordance with Art. 6 (1) (b) GDPR to provide our users with effective and secure payment.

Amongst the data processed by the payment service providers are inventory data, e.g. the name and the address, bank data, such as Account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, summary and recipient-related information. The information is required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. We do not receive any account or credit card information but only the confirmation or negative disclosure of the payment. The data may be transmitted by the payment service providers to credit reporting agencies. This transmission aims at the identity and credit check. For this we refer to the terms and conditions and privacy policy of the payment service providers.

For the payments, the terms and conditions and the privacy policies of the respective payment service providers, which are available within the respective websites or transaction applications, apply. We also refer to these for further information about the rights of withdrawal, information rights and other data subjects.

Business analysis and market research

In order to operate our business, to be able to recognize market trends, customer and user requirements, we analyze the data we have on business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 (1) (f) GDPR, whereby the persons affected include customers, prospects, business partners, visitors and users of the online offer.

The analyzes are carried out for the purpose of business analysis, marketing and market research. In doing so, we can display the profiles of the registered users with indications e.g. to consider their purchase transactions. The analyzes serve us to increase the user-friendliness, the optimization of our offer and the business economics. The analyzes are for us alone and will not be disclosed externally unless they are anonymous aggregated data analysis.

If these analyzes or profiles can be assigned to a consumer, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally the overall business analyzes and general trend provisions are created anonymously if possible.


Visiting our website is possible without registration. In this case there are not all usage options available, in particular it is not possible to order vouchers and/or goods. It is required to registrate with a personal user account to order vouchers and/or goods from As part of the registration, the required mandatory information will be communicated to the users. Usually only an email address is needed to sign up. The address entered has to be confirmed after the double opt-in principle. The data entered during registration will be used for the purpose of using the online offer. Users may be informed by email about our web appearance or registration-related information, such as changes in the scope of the online offer or technical circumstances. It is possible that other mandatory information will be needed later using our online service (e.g. name and delivery address for deliveries, Identity verification information on a legal basis). If users have terminated their user account, their data belonging to the user account will be deleted if their retention is not necessary for commercial or tax law reasons according to Art. 6 (1) (c) GDPR. It is the responsibility of the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

In the context of the use of our registration and registration functions as well as the use of user accounts, the IP address and the time of the respective user action will be saved. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 (1) (c) GDPR. The IP addresses will be anonymized or deleted after 7 days at the latest.


For the full use of our website and our service the verification of the user account can be assumed according to the regulations of the TOS. To verify an account, the identification of the user is carried out. The legal basis for this is section 25i (2) No. 1 German Banking Act. The identification of the user is carried out by submitting pictures of a valid official ID card, with which the identification requirement in Germany is fulfilled. For this purpose the user can use e.g. his identity card or passport.

In accordance with the Money Laundering Act (section 11), the following information to be provided by the user will be required during the identification process according to the 'Know Your Customer' principle and will be compared with the submitted identification document.

If the residential address cannot be verified by means of the identification document, it must be proven by an official confirmation of registration. Data not required can be blackened on the identification document. The data entered during verification will not be passed on to third parties. The submitted images will be deleted after the identification process is completed.By applying for the verification you are agreeing to the processing and storage of the data entered in accordance to our legal obligations and permissions.

To ensure that users identify themselves with their own ID, a photo of the ID holder with the ID next to their face is also required. If additional documents are required to complete the user's identification, the verification request will be temporarily denied until the user has submitted the required documents. The user has 14 days to submit the requested documents. Upon expiration of this period, the specified data and submitted documents will be deleted.


When contacting us via email the information provided by the user to process the contact request and its processing according to Art. 6 (1) (b) GDPR processed. User information can be stored in a Customer Relationship Management System ('CRM System') or comparable request organization systems. We delete the requests if they are no longer required. We check the necessity every two years. Furthermore the legal archiving obligations apply.

Integration of services and contents of third parties

Based on our legitimate interests (e.g. interest in the analysis, optimization and economic operation of our online offer according to Art. 6 (1) (f) GDPR, we make use of content or services offered by third-party providers in order to provide their content and services Services, such as include videos or fonts (collectively referred to as 'content').

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as 'web beacons') for statistical or marketing purposes. The 'pixel tags' can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.

(Data Privacy Policy updated May 2020)