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Data Policy

Privacy Statement of Basagan GmbH
I. Name and address of the person responsible
The person responsible within the meaning of the General Data Protection Regulation and other
national data protection laws of the member states as well as other data protection regulations is the:
Basagan GmbH
New Wall 10
20354 Hamburg
Germany
E-Mail: info@basagan.com
Website: www.basagan.com

II. Name and address of the data protection officer
The data protection officer of the responsible person is:
Dr. Sonja Asadi
Basagan GmbH
New Wall 10
20354 Hamburg
Germany
E-Mail: sonja.asadi@basagan.com
Website: www.basagan.com
III. General information on data processing
1. Scope of the processing of personal data
In principle, we process personal data of our users only to the extent necessary for providing a
functional website as well as our content and services. The processing of personal data of our users
takes place regularly only with the consent of the user. An exception applies to cases in which prior
consent is not possible for reasons of fact and the processing of the data is permitted by law.
2. The legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a
EU General Data Protection Regulation (GDPR) is the legal basis for processing.
If the processing of personal data is necessary for the performance of a contract to which the data
subject is a party, Art. 6 para. 1 lit. b GDPR forms the legal basis. This also applies to processing
operations required to carry out pre-contractual measures.
Insofar as the processing of personal data is required to fulfill a legal obligation that our company is
subject to, Art. 6 para. 1 lit. c GDPR as legal basis.
In the event that vital interests of the data subject or another natural person require the processing of
personal data, Art. 6 para. 1 lit. d GDPR forms the legal basis.
If processing is necessary to protect the legitimate interests of our company or a third party, and if the
interest, fundamental rights and fundamental freedoms of the data subject do not outweigh the former
interest, Art. 6 para. 1 lit. f GDPR is the legal basis for processing.
3. Data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage
is ceases to exist. After this purpose has ceased to exist, the data may be stored if provided for by the
European or national legislator in EU regulations, laws or other regulations to which the controller is
subject. A blocking or deletion of the data takes place even if a storage period prescribed by the
mentioned standards expires, unless there is a need for further storage of the data for a conclusion or
a fulfillment of the contract or other purposes.

IV. Use of the website, registration and posting advertisements
1. Description and scope of data processing
On our website, we offer users the opportunity to both inform themselves about the offer on Basagan
and to register by providing personal information in order to obtain more information about the offers
and to be able to contact sellers or to advertise their own offers. In the event that the user visits our
website without registering, we raise the following data in this context: time and date of access,
amount of data transferred, status of access (eg page viewed, page not found), operating system of
the web browser used, type of web browser used, user input or file name of the page, name of the
page from which a page or file is called, IP address including information about the name of the
internet provider. Finally, cookies are used to validate additional data (more information under the
Cookies section).
If the user registers as a buyer and / or seller to use extensive services from Basagan, the data will be
entered in an input mask and sent to us and stored. A transfer of data to third parties does not take
place. The following data is required as part of the registration process:
- name (first name, last name)
- Company name - Business type
- Address (street, house number, zip code, city, country)
- Contact information (phone number, mobile number or fax)
- E-mail
- Password
- Indication of occupational group (buy, sell or service)
Voluntary information requested is an indication of the company website and a description of the
company. This information helps us to improve our service to you. You are not required to provide this
information.
At the time of registration, the following data is also stored:
(1) The IP address of the user
(2) Date and time of registration
(3) Preference of language
(4) Preference of the currency
As part of the registration process, the consent of the user to process this information is obtained.
2. The legal basis for data processing
In the presence of the consent of the user the legal basis for the processing of the data is Art. 6 para.
1 lit. a GDPR.
If the registration serves the fulfillment of a contract of which the user is a party or the implementation
of pre-contractual measures, an additional legal basis for the processing of the data is Art. 6 para. 1 lit.
b GDPR. In addition, e.g. also § 15 Abs. 1 TMG forms a legal basis for the processing of this data.
Art. 6 para. 1 f of the GDPR is also to be mentioned as the legal basis for the processing of the data in
this context, because we have a predominant and legitimate interest in making the use of our website
as efficient as possible and as simple as possible. Where appropriate, your consent to the processing
of your personal data will also be obtained (Article 6 (1) (f) GDPR).
3. Purpose of data processing
User registration is required in order to be able to use our online offers in full and is also required to
fulfill a contract with the user or to implement pre-contractual measures.
Your data will be processed so that you can use our offer and our services as well as functions on our
website. When publishing an ad, we save and process your information. If applicable, we will send
your published ad to users who have set up a search job, if your ad matches the search request. Also,

we allow our users to rate the services and products received as well as the contact with business
partners. In this context, you may receive an email with a request for review.
We process data that we need to fulfill a contract with the user or to perform pre-contractual actions,
e.g. for sending invoices.
4. Storage Period
The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection.
This is the case during the registration process for the execution of a contract or for the performance
of pre-contractual measures, when the data is no longer necessary for the execution of the contract.
Even after the conclusion of the contract, there may be a need to store personal data of the
contracting party in order to comply with contractual or legal obligations.
If the user registers without entering into a contract with Basagan, then all data can be deleted insofar
as the purpose of the processing is omitted.
5. Opt-out and removal option
As a user, you have the option of canceling the registration at any time. You can always change or
change the data stored about you in your profile. You can request the deletion of your account by
sending an email to info@basagan.com.
If the data are necessary for the fulfillment of a contract or for the execution of pre-contractual
measures, a premature deletion of the data is only possible, as far as contractual or legal obligations
do not preclude a deletion.
V. Data Processing for the provision of the website and Collection of Log Files
1.Description and scope of data processing
Every time our website is accessed, our system automatically collects data and information from the
accessing computer’s computer system. The following data is collected here:
(1) Information on the browser type and version used
(2) The user’s operating system
(3) The user’s Internet service provider
(4) The user’s IP address
(5) Date and time of access
(6) Websites from which the user's system accesses our website
(7) Web sites accessed by the user's system via our website
(8) preference of language
(9) preference of the currency
The data is also stored in the log files of our system. A storage of this data together with other
personal data of the user does not take place.
2.The legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.
3. Purpose of data processing
The temporary storage of the IP address by the system is necessary to make the content contained on
our website available to the user. It is necessary to temporarily store the IP address for the duration of
the session.
Any processing and storage of the IP address in the log files is done to ensure the functionality of the
website. In addition, the data is used to optimize the website and to ensure the security of our
information technology systems. An evaluation of the data for marketing purposes does not take place
in this context.
For these purposes, Art. 6 para.1 lit. f GDPR forms the legal basis for processing of data.

4. Storage period
The data will be deleted as soon as it is no longer needed to achieve the purpose for which it was
collected. If the data was collected for the purpose of providing the website, this will be the case when
the respective session has ended. If data in the log files are stored, this is the case after no more than
seven days. An additional storage period is possible. In this case, the IP addresses of the users are
deleted or alienated, so that an assignment of the calling client is no longer possible.
5. Opt- out and removal option
The collection of the data for the provision of the website and the storage of the data in log files is
essential for the operation of the website. There is consequently no possibility for the user of opting
out.
VI. Use of cookies
a) Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the
Internet browser on the user's computer system. When a user visits a website, a cookie may be stored
on the user's operating system. This cookie contains a characteristic string of characters that allows
the browser to be uniquely identified when the website is reopened.
We use cookies to make our website more user-friendly. Some elements of our website require that
the calling browser can be identified even after a page break. The following data are stored and
transmitted in the cookies:
1. Language settings
2. Setting of the currency
3. Recently viewed articles
4. Log-in information (for example, IP address, username and user ID)
5. filename
6. Time of inquiry
We use cookies to give you a better experience on our website and to personalize content and online
advertising for you. By using our website, you agree to the use of these cookies. Further information
can be found in our privacy policy.
b) Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies forms Art. 6
para. 1 lit. f GDPR.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para.
1 lit. a GDPR, if the user has given its consent.
The legal basis for the processing of personal data using cookies for analysis purposes to create
pseudonymous evaluations is Article 6 paragraph 1 f GDPR or § 15 paragraph 3 TMG.
c) Purpose of the data processing
The purpose of using technically essential cookies is to simplify the use of websites for users. Some
features of our website cannot be offered without the use of cookies. For these, it is necessary that the
browser is recognized even after a site change.
For the following applications we need technically essential cookies:
(1) adoption of language settings
(2) Recently viewed items
(3) adoption of currency settings
(4) Log-in information (e.g., IP address, date and time). The user data collected by technically
necessary cookies will not be used to create user profiles.
The use of the analysis cookies is for the purpose of improving the quality of our website and its
contents.

Through the analysis cookies we learn how the website is used and so we can constantly optimize our
offer. For these purposes, our legitimate interest in the processing of personal data pursuant to Art. 6
para. 1 lit. f GDPR.
e) Data storage, opt-out and removal option
Cookies are stored on the computer or respective device of the user and transmitted to our website.
Therefore, as a user, you have full control over the use of cookies. By changing the settings in your
internet browser, you can disable or restrict the transmission of cookies. Already saved cookies can be
deleted at any time. This can also be done automatically. If cookies are disabled for our website, it
may not be possible to fully use all the functions of the website.
 
VII. Web analysis by Google Analytics
1.Extension of the processing of personal data
We use Google Analytics on our website to analyze the use of and to optimize our website. Google
Analytics is a web analytics service provided by Google. The software sets a cookie (text file) on the
user's computer (for further information on cookies see above). The cookie generates information
about the use of our website by the user. This information is usually transmitted to the United States to
a Google server and stored there. However, Google will generally shorten the IP address of the user
within the member states of the European Union or in other contracting states of the Agreement on the
European Economic Area prior to transmission to the company Google. With the help of the
information provided to Google, Google evaluates the use of this website on our behalf, compiles
reports on the activities and provides further services related to the use of the website and the Internet
to the operator of this website. In this context, there is no merge of your IP address with other data
from Google.
As shown in the section Cookies VIe, you have the option of preventing cookies from being saved by
making a change in the settings of your Internet browser. However, full use of our website may not be
possible as described.
This website uses the function provided by Google Analytics _anonymizelp or ga.js to anonymize all IP
addresses of their users within Google Analytics. For more information, please visit:
https://support.google.com/analytics/answer/2763052?hl=en&ref_topic=2919631
2.The legal basis for the processing of personal data
The legal basis for the processing of the users' personal data is Article 6 (1) lit. f GDPR. Website
analytics by Google Analytics helps us to increase the efficiency of our website and to optimize the
services. In order to safeguard the interests of the users in the protection of their personal data, the
use of Google Analytics only results in the anonymous collection of IP addresses.
3. Purpose of data processing
The processing of users' personal data enables us to analyze the surfing behavior of our users. By
analyzing the obtained data, we can compile information about the use of the individual components of
our website. This helps us to constantly improve our website and its user-friendliness. For these
purposes, our legitimate interest lies in the processing of data according to Art. 6 para. 1 lit. f GDPR.
The anonymisation of the IP address sufficiently takes into account the interest of users in their
protection of personal data.
4. Duration of storage
The data will be deleted as soon as it is no longer needed for our recording purposes.
In our case, this is the case after 14 months.
5.Contract and eliminate possibility
Cookies are stored on the computer of the user and transmitted izon our side. Therefore, as a user,
you have full control over the use of cookies. By changing the settings in your internet browser, you
can disable or restrict the transmission of cookies. Already saved cookies can be deleted at any time.
This can also be done automatically. If cookies are disabled for our website, it may not be possible to
use all the functions of the website to the full.

Google Analytics provides a browser add-on at http://tools.google.com/dlpage/gaoptout?hl=de with the
help of which deactivates Google Analytics and the collection of the website generated by the Google
Analytics cookie Information including your IP address is possible.
For more information on Google Analytics privacy and terms of use, please visit:
http://www.google.com/analytics/terms/en.html
VIII. Contact form, e-mail contact and telephone contact
1.Description and scope of data processing
On our website a contact form is available, which can be used for the electronic contact with us. If a
user realizes this possibility, the data entered in the input mask is transmitted to us and stored. These
data (mandatory) are:
- Surname
- Email
- Subject
- Theme
- Message
At the time of sending the message, the following data is also stored:
(1) the IP address of the user
(2) the date and time of sending
For the processing of the data, your consent is obtained during the sending process and reference is
made to this privacy policy.   
Alternatively, contact via the provided e-mail address is possible. In this case, the user's personal data
submitted by e-mail will be stored for processing.
There is no disclosure of data to third parties in this context. The data is used exclusively for
processing the conversation.
It is also possible to contact Basagan via the telephone number published on the website. In this case,
the following data is requested, stored and, if necessary, forwarded to the responsible specialist
department for further processing: salutation, name (first name / last name), e-mail address, telephone
number, reason for the call and possibly further relevant data for processing the request such as ad
number.
Users also have the opportunity to contact other users via the contact form. In this case, the following
data is stored:
- Surname
- User ID
- Email
- Subject
- Theme
- message
- Date and Time
2.The legal basis for data processing
Legal basis for the processing of the data is in the presence of the consent of the user Art. 6 para. 1 lit.
a GDPR. The legal basis for the processing of the data transmitted in the course of sending an e-mail
is Article 6 (1) lit. f GDPR. If the e-mail contact aims to conclude a contract, then additional legal basis
for the processing is Art. 6 para. 1 lit. b GDPR.
3. Purpose of data processing
The processing of the personal data from the input mask serves us only to process the contact. In the
case of contact via e-mail, this also includes the necessary legitimate interest in the processing of the

data. The other personal data processed during the sending process serve to prevent misuse of the
contact form and to ensure the security of our information technology systems.
.
4. Storage period
The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection.
For the personal data from the input form of the contact form and those sent by e-mail, this is the case
when the respective conversation with the user has ended. The conversation ends when it can be
inferred from the circumstances that the facts are finally clarified. The additional personal data
collected during the sending process will be deleted at the latest after a period of seven days.
5. Contract and eliminate possibility
The user has the possibility at any time to revoke his consent to the processing of personal data by
sending an email to info@basagan.com. If the user contacts us by e-mail, he may object to the
storage of his personal data at any time. In such a case, the conversation cannot be continued. All
personal data stored in the course of contacting will be deleted in this case.

IX. Newsletter
1. Description and scope of data processing
In the future, on our website there will be the possibility to subscribe to a free newsletter. When you
sign up for the newsletter, the data from the input mask (last name, first name, your email address) will
be sent to us. In addition, the following data are collected upon registration:
(1) IP address of the calling computer
(2) Date and time of registration
For the processing of the data, your consent is obtained during the registration process and reference
is made to this privacy policy.
2. The legal basis for data processing
The legal basis for the processing of the data after the user has registered for the newsletter is in case
of consent of the user Art. 6 para. 1 lit. a GDPR.
3. Purpose of data processing
The collection of the user's e-mail address serves to send and deliver the newsletter. The collection of
other personal data as part of the registration process is intended to prevent misuse of the services or
the e-mail address used.
4. Storage period
The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection.
The user's e-mail address will be saved as long as the subscription to the newsletter is active. The
other personal data collected during the registration process will normally be deleted after a period of
seven days.
5.Contract and eliminate possibility
Subscription to the newsletter may be terminated at any time by the user concerned. For this purpose,
there is a corresponding link in each newsletter. This also allows a revocation of the consent of the
storage of the personal data collected during the registration process.
X. Rights of the person concerned
If personal data is processed concerning you, you are a person concerned within the meaning of
GDPR and you have the following rights to the responsible person:
1. Right to information
You may ask the person in charge to confirm if personal data concerning you is processed by us. If
personal data concerning you are processed, you are entitled to information on
(1) the purposes for which the personal data is processed;

(2) the categories of personal data processed;
(3) the recipients or categories of recipients to whom your data has been disclosed or is yet to be
disclosed;
(4) the planned storage period of your personal data or, if specific information is not available, criteria
for determining the duration of storage;
(5) the right of correction or deletion of personal data concerning you, a right to restriction of
processing and/or a right the option of opting out;
(6) the existence of a right to complain to a supervisory authority;
(7) all available information on the source of the data if the personal data are not collected from the
data subject;
(8) the existence of automated decision-making including profiling under Article 22 (1) and (4) GDPR
and, at least in these cases, meaningful information about the logic involved, and the scope and
intended impact of such processing on the data subject.
You have the right to request information about whether your personal are transferred to a third
country or an international organization. In this regard, you can request information on the appropriate
guarantees in connection with the transfer according to Art. 46 GDPR.

2.Right to correction
You have a right to correction and / or completion, if your personal data is incorrect or incomplete. The
person in charge must make the correction without delay.

3. Right to restriction of processing
You may request the restriction of the processing of your personal data under the following conditions:
(1) if you have disputed the accuracy of your personal data for a period of time that enables the
controller to verify the accuracy of your personal information;
(2) if your personal data is unlawfully processed, you may request that instead of deleting your
personal data the use of it can be restricted.
(3) the controller no longer needs the personal data for the purposes of processing, but you need it to
assert, exercise or defend legal claims; or
(4) if you have objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet certain
whether the legitimate reasons of the person responsible outweigh your reasons.
If the processing of your personal data has been restricted, this data may only be used with your
consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of
another natural or legal person or for reasons of important public interest of the Union or a Member
State.
If the limitation of the processing according to the above-mentioned conditions are restricted, you will
be informed by the person in charge before the restriction is lifted.
4. Right to deletion
a) Obligation to delete
You have the right to demand that we delete your personal information without delay, and we are
required to delete that information immediately insofar as:

(1) your personal data is no longer needed for the purposes for which they were collected or
processed.
(2) You revoke your consent of processing in accordance with Art. 6 (1) lit. a or Art. 9 (2) lit. a GDPR
and there is no other legal basis for the processing.
(3) you have opted out of the data processing in accordance with Art. 21 GDPR and there are no prior
justifiable reasons for the processing, or According to Art. 21 para. 1 GDPR objection to the
processing and there are no prior justifiable reasons for the processing, or you have opted out of data
processing in accordance with Art. 21 para. 2 GDPR.
(4) Your personal data have been processed unlawfully.
(5) The deletion of personal data concerning you shall be required to fulfill a legal obligation under
Union law or the law of the Member States to which the controller is subject.
(6) The personal data concerning you were collected in relation to information society services offered
pursuant to Article 8 (1) of the GDPR.
b) Information to third parties
If the person responsible has made the personal data relating to you public and is in accordance with
Article 17 (1) of the GDPR obliged to delete it, it shall take appropriate measures, including technical
ones, to inform data controllers who process the personal data that you as affected person have
requested to delete all links to such personal data or to make copies or replicas of such personal data.
c) Exceptions
The right to deletion does not exist if the processing is necessary
(1) to exercise the right to freedom of expression and information;
(2) to fulfill a legal obligation which requires processing under Union or Member State law to which the
controller is subject to or for the performance of a task of public interest or in the exercise of public
authority delegated to the controller;
(3) for reasons of public interest in the field of public health pursuant to Art. 9 (2) lit. h and i and Art. 9
(3) GDPR;
(4) for archival purposes of public interest, for scientific or historical research purposes or for statistical
purposes according to Article 89 (1) GDPR, to the extent that the law referred to in subparagraph (a) is
likely to render impossible or seriously affect the achievement of the objectives of that processing, or
(5) to claim, exercise or defend legal claims.
c) Exceptions
The right to erasure does not exist if the processing is necessary
(1) to exercise the right to freedom of expression and information;
(2) to fulfill a legal obligation which requires processing under Union or Member State law to which the
controller is subject or for the performance of a task of public interest or in the exercise of official
authority conferring on the controller has been;
(3) for reasons of public interest in the field of public health pursuant to Art. 9 (2) lit. h and i and Art. 9
(3) GDPR;
(4) for archival purposes of public interest, for scientific or historical research purposes or for statistical
purposes acc. Article 89 (1) GDPR, to the extent that the law referred to in subparagraph (a) is likely to
render impossible or seriously affect the achievement of the objectives of that processing, or

(5) to assert, exercise or defend legal claims.
5. Right to information
If you have the right of correction, deletion or restriction of the processing to the controller, he / she is
obliged to notify all recipients to whom the personal data concerning you have been disclosed, of the
correction or deletion of the data or of the restriction of processing, unless this proves to be impossible
or involves a disproportionate effort.
You have the right to be informed about these recipients.
6. Right on data portability
You have the right to receive personally identifiable information about you that you have provided to
the controller in a structured, common and machine-readable format. You also have the right to
transfer this data to another person without hindrance by the person responsible for providing the
personal data, provided
(1) the processing on a consent according to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or
is based on a contract according to Art. 6 para. 1 lit. b GDPR and
(2) the processing is done by automated means.
In exercising this right, you also have the right to obtain that personal data relating to you be
transmitted directly from one controller to another controller, as far as technically feasible. Freedoms
and rights of other persons may not be affected.
The right to data portability does not apply to the processing of personal data necessary for the
performance of a task in the public interest or in the exercise of official authority delegated to the
controller.
7. Right on Contradiction
You have the right at any time, for reasons that arise from your particular situation, to prevent the
processing of your personal data pursuant to Art. 6 para. 1 lit. e or f GDPR; this also applies to
profiling based on these provisions.
The controller will no longer process the personal data concerning you unless he can demonstrate
compelling legitimate reasons for processing that outweigh your interests, rights and freedoms, or the
processing is for the purposes of asserting, exercising or defending legal claims. If the personal data
relating to you are processed for direct marketing purposes, you have the right to object at any time to
the processing of your personal data for the purpose of such advertising; this also applies to profiling
insofar as it is associated with such direct marketing. If you object to the processing for direct
marketing purposes, your personal data will no longer be processed for these purposes. Regardless of
Directive 2002/58 / EC, you have the option, in the context of the use of information society services,
of exercising your right to opt-out by means of automated procedures that use technical specifications.
8. Right to revoke the data protection consent declaration
You have the right to revoke your data protection consent declaration at any time. The revocation of
consent does not affect the legality of the processing carried out based on the consent until the
revocation.
9. Automated case-by-case decision, including profiling
You may be subjected to a decision based solely on automated processing - including profiling - that
will have legal effect or similarly affect you in a similar manner. This does not apply if the decision
(1) is required for the conclusion or fulfillment of a contract between you and the controller,

(2) is permitted by Union or Member State legislation to which the controller is subject, and where
such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate
interests, or
(3) with your explicit consent.
However, these decisions may not be based on special categories of personal data under Art. 9 (1)
GDPR, unless Art. 9 (2) lit. a or g GDPR applies and reasonable measures have been taken to protect
the rights and freedoms as well as your legitimate interests. With regard to the cases mentioned in (1)
and (3), the person responsible shall take appropriate measures to uphold the rights and freedoms
and your legitimate interests, including at least the right to obtain the intervention of a person by the
controller, to express his / her own position and contest the decision.
10.Right to appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to
a supervisory authority, in particular in the Member State of its place of residence, employment or the
place of the alleged infringement, if you believe that the processing of the personal data concerning
you has violated provisions of the GDPR.
The supervisory authority to which the complaint has been submitted shall inform the complainant of
the status and results of the complaint, including the possibility of a judicial remedy pursuant to Article
78 of the GDPR.
11. Miscellaneous
In communicating with other users of Basagan, you have also acknowledged that Basagan's Terms
and Conditions commit you to use other users' personal information only for the purpose set out by
Basagan.
Basagan continues to develop its offerings and its Internet platform with the aim of expanding services
and improving functionalities. The privacy policy will then also be adjusted in each case and can be
accessed under the Privacy section.
This is a translation of the German version of the Privacy Policy. The German version is legally valid.
As of: 09.01.2019