Privacy Policy for the Website "Aumio Kids"

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Version: 04.08.2026
Scope: Website "Aumio Kids" (kids.aumio.com)

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1. Controller

Aumio GmbH
Mühlenstraße 8a
14167 Berlin
Germany

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2. Data Protection Officer

External Data Protection Officer (DPO): Graham Reilly (Workstreet)
E-Mail: graham.reilly@workstreet.com

Internal Data Protection Coordinator: Steffen Scherf (Aumio GmbH)
E-Mail: datenschutz@aumio.de

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3. General Information on Data Processing

We process personal data to provide and optimize the website "Aumio Kids". Processing is based on the following legal bases, depending on the function:

• Art. 6(1)(f) GDPR (legitimate interest; e.g. operation, security, stability)
• Art. 6(1)(a) GDPR (consent; e.g. analytics/tracking/communication)
• Art. 6(1)(b) GDPR (contract/pre-contractual measures; e.g. signing up for information/updates)

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4. Consent

We use a consent management tool (Cookiebot) to obtain and document consent for the use of non-essential cookies and services (e.g. analytics/tracking/communication services).

Services (analytics/tracking/third-party) are only started after consent has been given.

Consent can be withdrawn at any time with effect for the future (via the cookie settings on the website).

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5. Target Audience / Age Restriction

The website "Aumio Kids" is primarily aimed at parents and legal guardians who wish to learn about the Aumio Kids app. The advertised app itself is used by children (aged approx. 0–14 years).

The website itself does not collect personal data from children directly (e.g. no registration or account creation on the website). Where children visit the website, the same protective measures apply (consent requirement, no data processing without consent of the legal guardian). Consent to non-essential cookies/services (e.g. analytics) should only be given by a legal guardian.

Note: A separate privacy policy (app privacy policy) applies to data processing within the Aumio Kids app itself.

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6. What Data We Process

6.1 Access Data / Server Logs (Hosting)

Each time the website is accessed, the following data is technically processed:

• IP address
• Date and time of the request
• Accessed content / URL
• Referrer URL
• Browser type/version, operating system
• Other technical log data (e.g. request ID)

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Purposes: Operation of the website, security, error analysis, abuse prevention.

Legal basis: Art. 6(1)(f) GDPR.

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6.2 Consent Data (Cookiebot)

To store your cookie/consent settings, consent data is processed (e.g. status/preferences).

Purposes: Collection, documentation, management of consent.

Legal basis: Art. 6(1)(c) GDPR and/or Art. 6(1)(f) GDPR; for non-essential cookies additionally § 25(1) TTDSG.

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6.3 Usage and Analytics Data (Website Analytics)

Depending on integration, we process events and usage data to evaluate website usage, e.g.:

• Page views / sessions
• Interactions (clicks, scrolls)
• Technical information (device, browser, language)
• Approximate location information (derived from IP)

Purposes: Product/website improvement, stability, bug fixing, usage evaluation.

Legal basis: Art. 6(1)(a) GDPR (consent), where tracking/analytics is used.

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6.4 Newsletter / Communication (CleverTap)

Newsletter sign-ups and possible email registrations (e.g. for updates or the first free story) are currently managed via CleverTap. We use CleverTap as a communication and engagement tool.

Depending on the specific flow, the following data may be processed:

• Contact and identification data (e.g. email address; name if applicable)
• Communication and interaction data (e.g. sign-up time, delivery/open/click events, opt-in/opt-out)
• Technical data/online IDs (e.g. device and browser information, cookie/SDK IDs), where required

Purposes: Newsletter delivery, communication, engagement (e.g. reminders, content notifications).

Legal basis:

• For newsletter/marketing communication: Art. 6(1)(a) GDPR (consent) in conjunction with § 25(1) TTDSG
• For purely transactional/offer-related communication: Art. 6(1)(b) GDPR

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7. Services Used (Hosting / Analytics / Communication)

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7.1 Hosting (Webflow)

Hosting/website delivery is provided by Webflow.

Purposes: Delivery of the website, operation, security, stability.

Legal basis: Art. 6(1)(f) GDPR.

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7.2 Analytics / Tracking (only after consent)

The following service is currently integrated and only started after consent:

• Google Analytics (GA4)

Purposes: Reach measurement, usage analysis, optimization of website and content.

Legal basis: Art. 6(1)(a) GDPR (consent) in conjunction with § 25(1) TTDSG.

Note: Google Ads/Conversion tracking is not used on the website.

Depending on the provider, data may be transferred to third countries (in particular the USA) (see section 9).

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7.3 Newsletter / Communication (CleverTap)

CleverTap may be used for email communication (e.g. newsletter/updates, first free story).

Purposes: Communication, newsletter management, segmentation, delivery of information.

Legal basis: See section 6.4.

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8. Recipients / Data Processors

We use service providers as data processors. Relevant recipients (website):

• Webflow (hosting)
• Cookiebot (consent management)
• Google Analytics (website analytics)
• CleverTap (communication/engagement; newsletter)

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9. Third Country Transfers

For transfers to third countries, appropriate safeguards pursuant to Art. 46 GDPR are used, in particular EU Standard Contractual Clauses (SCC).

Where providers are certified under the EU-US Data Privacy Framework, the transfer is based on this framework.

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10. Storage & Retention Periods

• Access data/server logs are only stored as long as required for operation, security and error analysis.
• Analytics/tracking data is stored according to the respective tool settings and retention policies.
• Communication/newsletter data (CleverTap) is stored as long as required for communication/management or until withdrawal of consent, unless legal retention obligations apply.

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11. Rights of Data Subjects

Data subjects have – where applicable – the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent (Art. 7(3) GDPR) with effect for the future
• Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

Requests can be directed to datenschutz@aumio.de.

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11a. Automated Decisions

No automated decision-making with legal or similarly significant effect within the meaning of Art. 22 GDPR takes place.

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12. Changes

The current version is always available on the website.

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