1. Privacy Policy

Your privacy is important to me at Freecard-Winni. So I have created this privacy policy to explain my information collection and use practices in connection with the Service. You’re bound to the Privacy Policy, too: it’s part of the Agreement, and by using the Service you agree that you have read it, that you understand it, and that you will comply with it.

If you see any capitalized terms that aren’t defined in this Privacy Policy, they’ll have the meaning I give them elsewhere in the Agreement.

“Data 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;

2. “GDPR” means the General Data Protection Regulation (EU) 2016/679;

“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; 

“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

“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;

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

“Special categories of personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

3. Access to Personal Data

Only me at who need access to the Personal Data to perform my work tasks is processing the Personal Data. 

3.1 Right to Access Personal Data

You have the right to obtain from confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to the Personal Data and the following information:

  • the purposes of the processing; 
  • the categories of Personal Data concerned; 
  • the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries, i.e. a country outside of the EU/EEA; 
  • where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; 
  • the existence of the right to request from me rectification or erasure of Personal Data or restriction of processing of Personal Data concerning you or to object to such processing; 
  • the right to lodge a complaint with a supervisory authority; 
  • where the Personal Data are not collected from you, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you. Where Personal Data are transferred to a third country, i.e. a country outside of the EU/EEA, or to an international organisation, you shall have the right to be informed of the appropriate safeguards 
  • pursuant to Article 46 of the GDPR relating to the transfer.

4. Right to Rectification etc.

I´m aiming at processing only Personal Data which is correct and that it is 


5. Rectification

You have the right to obtain from me without undue delay the rectification of inaccurate Personal Data concerning you. 

5.1 The right to be forgotten

You have the right to obtain from me the erasure of Personal Data concerning you without undue delay and I have the obligation to erase Personal Data without undue delay inter alia when the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed or you have withdrawn consent on which the processing is based. 

5.2 Restriction of processing

You have the right to obtain from me restriction of processing if you have a particular reason for wanting the restriction. This may be if you have issues with the content of the information I hold or how I have processed your personal data. It can also be the case when I no longer needs the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.

5.3 Data portability

You have the right to receive the Personal Data concerning you, which you have provided to me, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller without hindrance from me where the processing is based on consent or on a contract or the processing is carried out by automated means.

5.4 Profiling

You have the right to object to processing of Personal Data concerning you based on automated decisions and/or profiling. This shall not apply if the decision is necessary for entering into, or performance of, a contract between you and me or follows from a legal obligation.

5.5 Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authority.

Postcards & more - Winfried Jung - Zabel-Krüger-Damm 50 - 13469 Berlin - Allemagne

Phone: +49 30 403 99 106

Fax: +49 30 402 33 29


6. The Personal Data We Collect and/or Receive

When you sign up to become a User or when you purchase a Product, you may be required to provide me with Personal Data about yourself, including, without limitation, your name, phone number, e-mail address, and profile picture. The legal basis for such processing is the performance of the contract with you. And, if you contact me via the Contact Us page, you’ll need to provide your name and other contact information. I don’t collect any Personal Data from Visitors or Users when they use the Service, unless they provide such information voluntarily. Some of this Personal Data (User name/name, products and/or shops which you have chosen to save to your profile, the Users that you follow and the Users that follow you), will be publically accessible through the Service, and I may display this publically accessible Personal Data to other Users or elsewhere on the Service, by itself or in connection with other Information relating to your activities on the Service or with any User Content you provide. 

In addition I may collect or receive additional information. Such other information may be collected:

  1. From Your Activity. In an ongoing effort to improve the Service and the user experience, I automatically collect certain information when Visitors and Users access and use the Service. Such information includes, without limitation, IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, Stores followed or reviewed, Products bought, what sections of the Website are accessed, what features of the Service are used, log files, and similar information and data. The legal basis for the processing of personal data is legitimate interest.
  2. From Cookies. I collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. I may use session cookies (which expire once you close your web browser), persistent cookies (which stay on your computer until you delete them) or equivalent technologies (including but not limited to “Local Storage”) to help me collect information and to enhance your experience using the Service. If you do not want me to place a cookie on your hard drive, you may be able to turn that feature off on your computer. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from me, the Website or the Service may not function properly.
  3. From You. You may voluntarily provide me additional information about yourself that does not identify you personally, including, without limitation, your gender, country, product and service preferences, and other information.

In order to process any transactions through the Service, such as for a Product or Application, you may be required to provide certain billing information, such as information related to your PayPal account, debit card number, credit card number, expiration date, bank account information, billing address, activation code, and similar information (collectively, the “Billing Information”). This Billing Information may be collected and processed by our third-party payment vendors (“Payment Platform”) pursuant to the terms and conditions of their privacy policies and terms of use. If I obtain access to your Billing Information in connection with those transactions, I promise not to share it with any third parties unless it is necessary to process your transaction or administer the Service.

7. The Personal Data Collected by or through Third-Party Advertising Companies

I may share information mentioned under 1, 2 and 3 in section 6 above about your activity on the Website with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Website and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such information for such purposes. Pixel tags enable me, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

08. How I use and share the Personal Data

I may use the Personal Data to provide and improve our Website, Service, and other products and services; to process transactions you request; to inform you about my products and services and those of my promotional partners; and to bring you customized content (such as newsletters) based on your activity in connection with the Service.

I may use and/or share Personal Data as described below.

  • I may share the Personal Data concerning our users with my resellers, distributors, and sales representatives, which may use the Information to help inform Users about my products and services.
  • I may, from time to time, share Personal Data with other companies, which may provide you information about the products and services they or their partners offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.
  • I will access, use, and share the Personal Data as required to fulfill my contractual obligations to you (legal basis according to the GDPR: performance of a contract) and to address your questions or requests regarding my products, services, and/or support. I have legitimate interests to process Personal Data in connection with customer service and support (legal basis according to the GDPR: legitimate interest). 
  • I may employ other companies and individuals to perform functions on my behalf, i.e. data processors. Examples may include providing technical assistance, recruiting services, order fulfillment, customer service, and marketing assistance. These other companies will have access to the Personal Data only as necessary to perform their functions and to the extent permitted by law.
  • In an ongoing effort to better understand my Visitors, Users, Website, Service, and other products and services and those of our promotional partners, I may analyze certain information in anonymized and aggregate form. This aggregate information does not identify you personally. I may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. I may also disclose aggregated user statistics in order to describe the Website and these products and services to current and prospective business partners and to other third parties for other lawful purposes.
  • I may share some or all of your Personal Data with any of my parent companies, subsidiaries, joint ventures, or other companies under common control with me.
  • As I develop our businesses, I might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Personal Data may be part of the transferred assets.
  • To the extent permitted by law, I may also disclose the Personal Data: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever I believe that disclosing the information is necessary or advisable, for example, to protect the rights, property, or safety of freecard-winni or others. 

09. Accessing and Modifying Personal Data and Communication Preferences

Users may access, remove, review, and/or make changes to their Personal Data by following the instructions found on the Website. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any freecard-winni marketing e-mail. I will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. Users and job applicants cannot opt out of receiving transactional e-mails related to their account with freecard-winni.

10. How I protect the Personal Data

I take reasonable steps to protect the Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. I can not guarantee the security of my databases, nor can I guarantee, that the Personal Data that you supply will not be intercepted while being transmitted to and from me over the Internet. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to me via e-mail.

11. Transfer of Personal Data to other countries

The Service, the Website and its servers may be operated in the European Union (EU), the United States, and elsewhere. Please be aware that your Personal Data, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.. When Information is transferred from the EU/EEA to a third country, i.e. a country outside of the EU/EEA, I take all appropriate legal, technical and organisational measures to secure that the level of protection is the same as within the EU/EEA. In case Personal Data is processed outside of the EU/EEA the level of protection is guaranteed either via a decision of the European Commission that the country in question has an adequate level of protection for Personal Data or by using appropriate safety measures such as binding corporate rules or Privacy Shield. 

12. External Websites

The Website may contain links to External Sites. Freecard-winni has no control over the privacy practices of External Sites, and I am not responsible for the content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any External Sites.

13. Children

We do not knowingly collect Personal Data from children under the age of 13 through the Website. If you are under 13, please do not give me any Personal Data. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to me, please contact us at and I will endeavor to delete that information from my databases.

14. Storage of Personal Data

I only store your Personal Data as long as it is necessary for the purposes for which the Personal Data are processed. 

15. Privacy Policy Changes

Freecard-winni may change its Privacy Policy from time to time in freecard-winni´s sole discretion. Any such changes will be posted on the Website, and Freecard-Winni encourages Visitors to frequently check this page. If you have a Store, you should also check your Store’s dashboard for alerts to these changes. By accessing the Website or using the Service after I make any changes to this Privacy Policy, you accept those changes. Please be aware that, to the extent permitted by applicable law, my use of the Information is governed by the Privacy Policy in effect at the time we collect the Information.

DATE: 29-01-2019