Privacy Policy – Cello Platform

1. Introduction

In the following, we provide information about the collection of personal data when using the Cello Online Platform available at or (the Cello Online Platform is hereinafter referred to as “website” for reasons of simplicity).

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is PowerPlay GmbH, Philipp-Loewenfeld-Straße 19, 80339 Munich, Germany, email: We are legally represented by ‍Stefan Bader, Robert Coletti.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin,, E-Mail:

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

We send newsletters with the tool HubSpot of the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: The provider processes content, usage, meta/communication data and contact data in the process in the EU.

3. Data processing on our website

3.1. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2. Web hosting and provision of the website

Our website is hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sarl, 38 avenue John F. Kennedy, L-1855, Luxemburg. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider’s privacy policy at

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

We use the content delivery network Cloudfront (Amazon AWS) for our website. The provider is Amazon Web Services, Inc., P.O. Box 81226 Seattle, WA 98108-1226 USA. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider’s privacy policy at

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

3.3. Use of our product

To the extent that customers use our product, we process personal data as a processor of our customers and our order processing agreement applies.

3.4. Single sign-on procedure Google

Site visitors can log in to our website using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using a single sign-on procedure, we receive information from the provider that the site visitor is logged in with the provider and the provider receives information that the site visitor is using the single sign-on procedure on our website. Depending on the settings of the site visitor in his account on the provider’s site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the site visitor who logs in to our site with the account (Art. 6 para. 1 s. 1 lit. a GDPR). The provider of the procedure is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (privacy policy:

3.5. Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

  • PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxemburg
  • Stripe Payments Europe, Ltd., Ireland

3.6. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter “Technically Necessary Cookies”), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website. Specifically, we set technically necessary cookies for the following purpose or purposes:

  • Cookies that apply language settings
  • Cookies that store log-in data

3.7. Third parties

3.7.1. HubSpot

We use HubSpot for customer relationship management. The provider is HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), content data (e.g. entries in online forms), and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in managing data in a simple and inexpensive way.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at

4. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

5. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

Version: August 15, 2022