Legal
Data Protection
1. Responsible
The responsible party for the processing of personal data described in this privacy policy is:
Stefan Kneisel, trading as PureVision Digital
6 Croftwell Drive
Dublin 24
D24 EY9D
Ireland
Business name registration number with the Companies Registration Office (CRO): 791088
Email: hello@purevisiondigital.com
Website: purevisiondigital.com
PureVision Digital is operated by Stefan Kneisel as a sole trader based in Ireland.
2. Scope of this privacy policy
This privacy policy explains how PureVision Digital processes personal data in connection with its website, inquiries, potential and existing business customers, suppliers, professional contacts, VisionService, VisionConnect, and other services.
This privacy policy primarily describes processing operations in which PureVision Digital acts as the controller.
Insofar as PureVision Digital processes personal data exclusively on behalf of a customer, including customer and order data processed via VisionConnect, or data accessed in the context of specific VisionService, Odoo, migration, integration, or support services, the customer generally acts as the controller and PureVision Digital as the processor.
This processing is governed by the respective customer contract and the data processing agreement of PureVision Digital.
3. Personal data that we can process
Depending on the respective interaction, PureVision Digital may process the following personal data in particular:
Names
Company names and employers
Job titles or business functions
Business addresses
Email addresses
Phone numbers
Contents of inquiries and correspondence
Meeting and appointment information
Project requirements
Offers and contracts
Customer and supplier data
Billing, payment, and accounting information
Odoo account and project information
Activity and time tracking data within the framework of VisionService
VisionConnect account and subscription information
Support information
System access information, as required for a project
IP addresses
Device and technical information
Server and security logs
documents and files provided in the context of a project
other voluntarily provided information
When PureVision Digital acts as a data processor for a client, PureVision Digital may also process personal data of employees, clients, marketplace customers, suppliers, recipients, or other contacts of the client, as described in the applicable data processing agreement.
Origin of personal data
PureVision Digital typically receives personal data directly from the data subject, from the company for which the person works, from a client when PureVision Digital acts as a data processor, or from systems and marketplaces that a client has connected.
Insofar as personal data originates from other sources, PureVision Digital provides the information required under Art. 14 GDPR, as far as legally required.
4. Purposes and legal bases
PureVision Digital processes personal data only when there is an appropriate legal basis for doing so.
Requests and information from potential clients are processed to respond to inquiries, create offers, discuss projects, and carry out pre-contractual measures.
The legal basis is generally Art. 6 para. 1 lit. b GDPR or, for business contacts, Art. 6 para. 1 lit. f GDPR based on PureVision Digital's legitimate interest in processing business inquiries and maintaining business relationships.
Customer, account, subscription, and project information is processed to provide services, manage VisionService and VisionConnect, provide support, communicate, generate invoices, and manage contractual relationships.
The legal basis is generally Article 6(1)(b) GDPR and for representatives of corporate customers Article 6(1)(f) GDPR.
Invoices, accounting documents, and transaction information are processed to fulfil tax, accounting, and other legal obligations in accordance with Article 6(1)(c) GDPR as well as for legitimate business management in accordance with Article 6(1)(f) GDPR.
Technical, usage, and security information is processed to operate, secure, troubleshoot, and improve our services.
The legal basis is generally Article 6(1)(f) GDPR.
Where processing is based on consent, the legal basis is Article 6(1)(a) GDPR. Consent can be revoked at any time with effect for the future.
Provision of personal data
The provision of certain contact, contractual, or technical information may be necessary to process a request, carry out pre-contractual measures, fulfil a contract, or comply with legal obligations.
If required information is not provided, PureVision Digital may not be able to create an offer, conclude a contract, or provide the relevant service.
Automated decisions
PureVision Digital currently does not use exclusively automated decision-making, including profiling, that has legal effects on a person or significantly affects them in a similar way.
5. Odoo
PureVision Digital uses Odoo as a self-hosted CRM, ERP, and business management platform for customer relationship management, project management, quotes, service management, invoicing, and related business processes.
The primary productive Odoo environment of PureVision Digital is hosted on Hetzner infrastructure in Falkenstein, Germany.
PureVision Digital uses CloudPepper to manage relevant Odoo environments, including deployment, monitoring, maintenance, troubleshooting, and backup management.
Information stored in Odoo may include in particular:
business contact details
Customer and supplier data
project data
quotes
orders
contract information
invoices and accounting-related information
Support information
project-related communication
The legal basis depends on the underlying processing operation and is generally Article 6(1)(b), Article 6(1)(c), or Article 6(1)(f) of the GDPR.
6. VisionService
PureVision Digital provides development and technical services under the name VisionService for agencies and other business clients.
For account management, project coordination, time tracking, support and invoicing, PureVision Digital can process the names and business contact details of the client's employees, project information, ticket and repository information, communication, as well as evidence of services rendered.
For this processing, PureVision Digital generally acts as the data controller within the framework of its own business administration.
Insofar as employees or contractors of VisionService access the client's systems or personal data solely at the client's instruction to provide development, migration, integration, testing, maintenance or support services, PureVision Digital generally acts as the data processor.
This processing is governed by the applicable data processing agreement and not solely by this privacy policy.
7. VisionConnect
PureVision Digital offers the Software-as-a-Service middleware platform VisionConnect for business customers.
VisionConnect is designed to connect Odoo with third-party marketplaces and platforms such as Amazon, eBay and other supported services.
For account management, subscription management, billing, security, support and the operation of the service, PureVision Digital can particularly process the following data:
Names of customer administrators
business contact details
Account identifiers
Subscription information
Support communication
IP addresses
Technical logs
Information on the use of the service
For these purposes, PureVision Digital generally acts as the data controller.
As far as VisionConnect transfers, synchronises, stores or otherwise processes personal data from a customer's connected Odoo or marketplace systems solely for the provision of the service at the customer's instruction, the customer essentially acts as the controller and PureVision Digital as the processor.
Depending on the customer's configuration, the following data may be processed as part of the processing agreement:
Customer names
Contact details
Marketplace identifiers
Order information
Delivery information
Transaction information
other business data required for the synchronisation of the connected systems
PureVision Digital does not use personal data processed on behalf of VisionConnect customers for its own independent marketing purposes.
Processing as a processor is governed by the processing agreement.
Amazon, eBay and other marketplaces selected by the customer are independent third-party platforms.
The customer is responsible for the legal basis and information obligations regarding its own use of these platforms as well as for its contractual relationship with the respective platforms.
8. Hetzner and CloudPepper
PureVision Digital uses Hetzner Online GmbH, Germany, to provide server infrastructure.
The primary productive Odoo server of PureVision Digital is located in Falkenstein, Germany.
Backups managed for this environment are stored on Hetzner infrastructure.
PureVision Digital uses Cloudpepper BV, Belgium, for the technical management of relevant Odoo environments.
CloudPepper can provide the following services in particular:
Deployment
Monitoring
Maintenance
Updates
Troubleshooting
technical support
Backup management
CloudPepper may have technical access to personal data as far as this is necessary for these services.
As far as Hetzner or CloudPepper process personal data on behalf of PureVision Digital, the agreements required under Art. 28 GDPR for data processing are in place.
9. Google Workspace
PureVision Digital uses Google Workspace for business communication and productivity, including services such as:
Gmail
Google Drive
Google Docs
Google Sheets
Google Calendar
Google Meet
Personal data processed through Google Workspace may include in particular:
Names
business contact details
Emails
Email attachments
Appointments
Meeting information
Documents and files
Project information
business correspondence
Google processes customer data in accordance with the applicable contractual and data processing terms of Google Workspace.
International processing may take place, provided that this is permissible under applicable data protection law and appropriate safeguards for data transfer are in place.
10. Website and technical information
When visiting purevisiondigital.com, technical information necessary for the provision and security of the website may be processed automatically.
This includes, in particular:
IP address
Date and time of the request
Requested page or resource
Browser and device information
Operating system information
Referring website or referrer
HTTP status information
Security-related technical information
This processing serves to provide the website, maintain security, diagnose errors, prevent attacks and abuse, and ensure reliable operation.
The legal basis is generally Article 6(1)(f) GDPR.
To the extent that a third party hosts or technically operates purevisiondigital.com, that provider may process technical website data on behalf of PureVision Digital and is subject, where necessary, to appropriate contractual and data protection obligations.
11. Cookies and similar technologies
The website may use cookies or similar technologies that are strictly necessary for the operation, security, or a service explicitly requested by the user.
To the extent that analysis, advertising, conversion tracking, or other non-essential technologies are used, these will only be activated after the necessary consent has been granted.
Visitors must be able to refuse or withdraw such consent as easily as they can give it.
Where cookies or similar technologies are used, the cookie notices and consent mechanism of the website inform about the technologies used on purevisiondigital.com and the available options.
Further information on the cookies used, their purpose and storage duration can be found in our Cookie Policy.
12. Business Communication and Marketing
PureVision Digital may use business contact details to communicate about inquiries, projects, service information and relevant business relationships.
Where electronic direct marketing requires consent or another specific condition under applicable law regarding electronic communication, PureVision Digital will comply with these requirements.
Recipients can object to direct marketing at any time by hello@purevisiondigital.com contacting or using an available unsubscribe mechanism.
13. Recipients of Personal Data
PureVision Digital does not sell personal data.
Personal data may be shared, where necessary, particularly with the following recipients:
Hosting and IT providers
Hetzner
CloudPepper
Google Workspace
professional advisors such as tax consultants, accountants, lawyers or insurers
banking and payment service providers
contractors involved in the provision of an agreed service
Authorities, as far as there is a legal obligation to disclose
other service providers that are necessary for the operation of PureVision Digital
As far as PureVision Digital acts as a data processor for a customer, the subcontractors used are governed by the applicable data processing agreement.
Marketplaces selected by the customer, such as Amazon or eBay, are not solely data processors of PureVision Digital because data is exchanged with them at the customer's instruction.
14. International Data Transfers
The primary self-hosted Odoo environment of PureVision Digital is located in Falkenstein, Germany.
The backup storage for this managed environment is carried out on Hetzner infrastructure.
Some global service providers, particularly Google, may process personal data outside the European Economic Area.
If personal data is transferred to a country for which there is no applicable adequacy decision, appropriate safeguards will be implemented as necessary.
These may include, in particular, the standard contractual clauses of the European Commission as well as any supplementary protective measures.
15. Retention Period
PureVision Digital retains personal data only as long as is necessary for the purpose for which it was collected, as well as to meet legal, contractual, accounting, security-related, and evidential requirements.
Information from inquiries that do not lead to a customer relationship will only be stored for a reasonable period for tracking and securing legal risks.
Customer, project, VisionService, and subscription management data may be stored for the duration of the business relationship and for a reasonable period thereafter.
Invoices and accounting documents will be retained for the statutory period applicable to Irish business documents.
Irish tax-relevant business documents are generally retained for six years.
Technical and security-related logs will only be stored as long as necessary for security, troubleshooting, and system administration, unless a longer retention is required in connection with a security incident or due to a legal obligation.
Insofar as PureVision Digital acts as a data processor, personal customer data will be stored in accordance with the documented instructions of the customer and the data processing agreement.
Upon termination of the contract, they will be returned or deleted, as applicable, subject to legal obligations and usual backup cycles.
16. Security
PureVision Digital takes appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access.
The measures include, in particular:
restricted administrative access rights
confidentiality obligations
secure transmission protocols, where supported
Security monitoring
Patch and update procedures
managed backups
procedures for responding to security incidents appropriate to the respective risk
No internet-based system can be fully protected against all security risks.
17. Your rights
Subject to the applicable legal requirements and restrictions, data subjects have in particular the right to:
request information about their personal data
request the correction of inaccurate personal data
request the deletion of personal data
request the restriction of processing
object to processing based on legitimate interests
object to processing for direct marketing purposes at any time
receive certain personal data in a structured, commonly used and machine-readable format
withdraw consent given at any time with effect for the future
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Requests can be sent to hello@purevisiondigital.com .
PureVision Digital may request appropriate information to verify identity.
Insofar as PureVision Digital processes personal data solely on behalf of a customer, relevant requests should generally be directed to that customer as the data controller.
PureVision Digital supports the customer in accordance with the data processing agreement and applicable law.
18. Complaints
If you have concerns regarding the processing of personal data by PureVision Digital, you can contact us at the following email address:
You also have the right to lodge a complaint with a competent data protection supervisory authority, particularly in the member state of your habitual residence, your place of work, or the location of the alleged data protection infringement.
The lead supervisory authority for PureVision Digital is:
Data Protection Commission
Ireland
Further information can be found at dataprotection.ie.
19. Changes to this Privacy Policy
PureVision Digital may update this Privacy Policy when our services, systems, providers, or legal obligations change.
The current version will be published on purevisiondigital.com.
This Privacy Policy should be reviewed regularly and whenever significant changes to processing are introduced.
PureVision Digital
Stefan Kneisel
6 Croftwell Drive
Dublin 24
D24 EY9D
Ireland
CRO Business Name Registration Number: 791088
Email: hello@purevisiondigital.com
Website: purevisiondigital.com