Privacy Policy

up2parts GmbH takes the protection of your personal data very seriously and adheres strictly to all applicable legislation and regulations concerning data protection, in particular the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and the German Telemedia Act (TMG).

Please find below information on how we collect and use your personal data, e.g. if you visit our website or contact us otherwise (e.g. as a customer). You may access this policy at any time on our website.

1. Data controller

The service provider and data controller within the meaning of the Data Protection Act is up2parts GmbH, Dr.-Müller-Str. 26, 92637 Weiden i. d. OPf., Germany. Telephone: ++49 (0)961 6000-0 Fax: [+49] 961 60 00-7900, info(at)up2parts.com. Our data protection officer, Ms. Marina Stich, can be contacted at up2parts GmbH, Dr.- Müller-Str. 26, 92637 Weiden i. d. OPf., Germany. Telephone: +49 (0)961 6000-7309, Fax: [+49] 961 60 00-7900, info(at)up2parts.com .

2. Your rights

2.1 You have the right to demand information from us at any time about the data we have stored about you and about their origin, the recipients or categories of recipients to whom those data are transferred and the purpose of storage.

2.2 You have the right to demand of us prompt rectification of incorrect personal data about you or restriction of processing. Taking account of the purposes of processing, you also have the right to demand completion of incomplete personal data – including by means of an additional declaration.

2.3 You have the right to demand of us prompt erasure of personal data about you. Among other things, we are obliged to delete them if the purposes for which they were collected or otherwise processed are no longer necessary or you have withdrawn your consent.

2.4 You have the right to receive the personal data about you that you have provided to us in a structured, standard and machine-readable format and you have the right to transfer those data to another data controller without hindrance if processing is based on your consent or processing is carried out with the aid of automated procedures.

2.5 If you have given your consent to the use of your data, you may withdraw it at any time.

2.6 If we process your personal data on the basis of legitimate interests, you may object to that processing.

2.7 Please submit all requests for information, inquiries and objections regarding data processing by email to info(at)up2parts or to the address specified under section 1.

2.8 In the case of breaches of data protection law, you have a right to lodge a complaint with the relevant supervisory authority. The relevant supervisory authority for issues of data protection is the Bavarian State Office for Data Protection Supervision (address and contact: https://www.lda.bayern.de/de/impressum.html)

3. Data security

We use technical and organizational measures to protect your data managed by us against accidental or intentional manipulation, loss, destruction and access by unauthorized persons. Your data are transferred in encrypted form; the encryption protocol used is TLS 1.2.

4. Collection of personal data for information purposes, cookies

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4.1 If the website is used purely for information purposes, i.e. if you do not go beyond simply using the website and do not make contact with us or otherwise transfer information to us, we collect the user data that your browser sends to us automatically to facilitate your visit to the website. Storage is for exclusively system-related and statistical purposes (on the basis of Art. 6(1) section (b) GDPR) and, in exceptional cases, for reporting of criminal acts (on the basis of Art. 6(1) section (e) GDPR).

4.2 The data collected in accordance with section 4.1 are
- IP address
- Date and time of request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Data volume transferred
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software

4.3 In addition, cookies are stored on your computer when you use the website. Cookies are small text files that are associated with the browser you are using and are stored on your hard drive, and which provide certain information to the body that sets the cookie (in this case, us). Cookies do not do any damage to your computer and do not contain any viruses. Cookies are used to make our website more user friendly, more effective and more secure. Most of the cookies we use are what are known as “session cookies”. They are erased automatically at the end of your visit. Other cookies remain on your end device until you delete them. These cookies make it possible to recognize your browser on your next visit.


4.4 Cookies that are required to carry out the electronic communication process or to provide certain functions for you (e.g. the shopping cart function) are stored on the basis of Art. 6(1) section (f) GDPR. We have a legitimate interest in storing cookies in order to ensure the optimized provision of our services in a way that is free of technical faults. If other cookies (e.g. cookies for analysis of your surfing behavior) are used, they are covered separately in this Privacy Policy.

4.5 You can configure your browser settings to meet your needs and (for example) to reject acceptance of cookies. Please note, however, that you may not be able to use all the functions of this website.

4.6 This stored information is held separately from any other data provided to us. In particular, the cookie data are not linked to your other data.

5. Collection and processing of personal data when making contact and for marketing purposes

5.1 Collection and processing of personal data (this includes, for example, your name, telephone number and email address) is carried out if you expressly communicate these data to us via our contact form for the purpose of making contact with us. These personal data are used exclusively for the purposes of processing your inquiries and on the basis of Art. 6(1) section (f) GDPR.

5.2 Use for marketing purposes is carried out only on condition of consent given by you and on the basis of Art. 6(1) section (a) GDPR. Your data held by us for the purposes of providing the newsletter are stored by us until you cancel your subscription and they are deleted on cancellation of the newsletter.

6. Collection and processing of personal data for orders, opening a customer account, customer support, use for direct marketing

6.1 Personal data are collected on the basis of Art. 6(1) section (b) GDPR when you provide them voluntarily to execute a contract or open a customer account. These data are used – without your express consent – only to process a contract and answer your inquiries. On completion of processing of the contract and full payment of the purchase price, your data are stored in accordance with the retention periods stipulated by tax and commercial law and erased on expiry of those periods.

6.2 Your personal data will also be processed based on Art. 6 para. 1 lit. f GDPR in order to create a contact in our ERP and CRM system for you and/or the company you are working for. Your personal data will be processed for the purpose of customer support, acquisition and handling of orders, e.g. sending documents by email (e.g. written documentation of our business relationship, offers, complaints).

6.3 The email address you provide to us on conclusion of contract is also used for our own marketing purposes to advertise similar goods or services to those ordered by you in the form of our newsletter. You can object to the use of your email address at any time without incurring any costs other than the basic communication costs. Your objection (and thus your cancellation of our newsletter) can be provided to us using the link provided in the newsletter or by sending us a corresponding message. When you submit your objection, your email address is deleted immediately. The basis for processing is our legitimate interests, Art. 6(1) section (f) GDPR.

7. Credit checks, data processing by Klarna

7.1 If we have to provide advance payment, i.e. in the case of purchase on account, we reserve the right to obtain identity and credit information from specialist service providers (credit agencies) in order to protect our legitimate interests (Art. 6(1) section (f) GDPR). In this connection, we shall provide your personal data required for a credit check to the following company/companies: Creditreform Boniversum GmbH, Hellersbergstraße 11, 41460 Neuss, Germany The credit information may include probabilities (score values) that are calculated on the basis of scientifically accepted mathematical/statistical procedures; address data (among other types of data) are used in the calculation of these procedures. We use the information received about the statistical probability of a payment default to make a balanced decision about the establishment, execution or termination of the contractual relationship. Your legitimate interests are taken into account in accordance with the statutory provisions.

7.2 If you opt for Klarna’s payment services Klarna Account and Klarna Hire Purchase as your payment option, you give your consent to our collection and transfer to Klarna of the following personal data required for processing of the purchase on account and completion of an identity and credit check: first name, surname, address, date of birth, gender, email address, IP address, telephone number, and the data required for processing the purchase on account that are connected with the order, such as the number of items, item numbers, invoice amount and tax as a percentage. These data are transferred so that Klarna can issue an invoice to process your purchase with the account option you require and so that it can carry out an identity and credit check. In accordance with the Federal Data Protection Act, Klarna has a legitimate interest in this connection in the transfer of personal data of the purchaser and requires them to obtain information from credit agencies for the purposes of the identity and credit check. In Germany, the credit agencies concerned may be the following:

- Bürgel Wirtschaftsinformationen GmbH & Co. KG, Postfach 5001 66, 22701 Hamburg
- Creditreform Boniversum GmbH, Hellersbergstraße 11, 41460 Neuss
- Deltavista GmbH, Freisinger Landstr. 74, 80939 Munich
- Arvato Infoscore Consumer Data GmbH und Infoscore Consumer Data GmbH, Rheinstraße 99, 76532 Baden-Baden
- SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden

In the context of the decision on the establishment, execution or termination of the contractual relationship, in addition to an address check, Klarna collects and uses information about the previous payment behavior of the purchaser and probability values for that behavior in future. These score values are calculated by Klarna on the basis of a scientifically accepted mathematical/statistical procedure. Among other things, Klarna uses your address details for this. If, after this calculation, it emerges that your credit rating is inadequate, Klarna will notify you of this immediately.

Withdrawal of consent to use personal data in respect of Klarna: You may withdraw your consent to the use of your personal data in respect of Klarna at any time. Klarna may, however, still be entitled to process, use and transfer the personal data if this is necessary for contractual payment processing by Klarna’s services, if it is a legal requirement or it has been demanded by a court or public authority.

Of course, you can obtain information about the personal data stored by Klarna about you at any time. If, as a purchaser, you wish to do so or if you wish to notify Klarna of changes regarding the data stored, you can contact Datenschutz@klarna.de.

8. Collection and processing of personal data in relation to applications

8.1 We also collect personal data if you make an employment application to us. Processing of personal data is necessary for us to carry out the application process, including creation of an electronic applicant file, administration of your application and organization of interviews – in short, processing is a prerequisite for conclusion of an employment contract with you. Processing is carried out on the basis of Art. 6(1) section (b) GDPR.

8.2 We also use your data on the basis of Art. 6(1) section (f) GDPR to consider you for possible future vacancies, and we store your data for this purpose for a limited period of one year following an unsuccessful application. You may object to this use of your personal data at any time.

8.3 If you register for our job subscription service, we will notify you on the basis of Art.6(1) section (a) GDPR of any vacancies at up2parts by email. Cancellation of your subscription is possible at any time.

9. Recipients/categories of recipients of personal data,“thirdcountry” (i.e. non-EU) data transfers, legitimate interests pursued by us in this context

9.1 Your data will not be passed on to third parties. Exceptions to this are service providers whom we have commissioned to carry out data processing in accordance with this Privacy Policy, e.g. in the context of order processing.

9.2 For fulfillment of contract, we forward your data to the shipping company commissioned to provide delivery, insofar as this is necessary to deliver the ordered goods. For processing of payments, we give the payment data required to the financial institution appointed to carry out payment and to any payment service provider appointed by us or to the payment service selected by you in the order process.

9.3 These are:

9.3.1 Profihost AG, Expo Plaza 1, 30539 Hanover, Germany

9.3.2 Net-Build GmbH, Alfred-Nobel-Allee 38, 66793 Saarwellingen, Germany

10. Period for which the personal data are stored

If your data are no longer required, they are erased on expiry of the retention obligations under tax and commercial law (these can be up to 10 years for invoices).

11. Use of Google Analytics

This website uses Google Analytics, a web analysis service of Google LLC ("Google"). Google Analytics uses what are known as “cookies”: text files that are stored on your computer and that facilitate analysis of your use of the website. The information generated by the cookie about your use of this website is transferred to a Google server in the USA and stored there. If IP anonymization is activated on the website, however, your IP address will first be truncated within Member States of the European Union or in other states that are signatories to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. On behalf of the operator of this website, Google uses this information to evaluate your use of the website, to compile reports on website activities and to provide other services associated with website and Internet use to the website operator. The IP address sent by your browser in the context of Google Analytics will not be linked to other Google data. You can prevent storage of the cookies by means of a corresponding setting in your browser software; please note, however, that in this case you may not be able to use all of the functions of this website to their full extent. In addition, you can prevent recording of the data generated by the cookie and related to your use of the website (including your IP address) by Google and processing of those data by Google by downloading and installing the browser plugin available under the following link (http://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on or within browsers on mobile devices, you
can prevent Google Analytics from collecting your information by clicking on the following link. An opt-out cookie is set to prevent the collection of your information on future visits to this site:

Deactivate Google Analytics

An opt-out cookie is placed on your device. If you delete your cookies, you will have to click this link again. More detailed information about the terms of use and data protection can be found at http://www.google.com/analytics/terms/us and at https://policies.google.com/privacy?hl=en-US. Please note that Google Analytics on this website has been extended to include the code “gat._anonymizeIp();” to ensure anonymized recording of IP addresses (referred to as “IP masking”).

Data processing is carried out on the basis of Art. 6(1) section (f) GDPR. We have a legitimate interest in analyzing use of our website for optimization purposes.

12. Use of Google Tag Manager

This website uses Google Tag Manager, a tag management system of Google LLC ("Google"). Google Tag Manager does not record any personal data. Tag Manager makes it easier to integrate and manage certain tags. Tags are small elements of code which, among other things, are used to measure traffic and user behavior, record the effect of online advertising and social media channels, to set up remarketing and alignment with target groups and to test and optimize websites. If you have set up deactivation, that deactivation will be observed by Google Tag Manager. For further information about Google Tag Manager, see: https://www.google.com/analytics/terms/tag-manager.

13. Use of Google Recaptcha

On our website we use the reCAPTCHA service of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). The check is used to verify that the input has been made by a person and not by means of automated, machine processing. The check includes sending of the IP address and possibly of other data required by Google for the reCAPTCHA service to Google. For this purpose, your input is sent to Google and reused there. However, your IP address will first be truncated within Member States of the European Union or in other states that are signatories to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. On behalf of the operator of this website, Google uses this information to evaluate your use of this service. The IP address sent by your browser in the context of reCaptcha will not be linked to other Google data. Your data may be sent to the USA in this context. An adequacy decision of the European Commission, the “Privacy Shield,” is in place for data transmissions to the USA. Google participates in the “Privacy Shield” and has agreed to its terms. By activating the check, you give your consent to processing of your data. Processing is carried out with your consent on the basis of Art. 6(1) section (a) GDPR. You may withdraw your consent at any time without affecting the lawfulness of the processing carried out on the basis of your consent up to the point of its withdrawal. More detailed information about Google reCAPTCHA and the associated privacy policy can be found at: https://policies.google.com/privacy

14. Use of Google Ads

Based on your consent (Art. 6(1) section (a) GDPR), we use the marketing and remarketing service Google Ads on our website, which is also operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. You can withdraw your consent to this at any time with effect from that point forward. Simply use one of the listed opt-out options. Google is directly responsible for some of the data processing.

With the help of Google Ads, we can target advertisements for our website in Google Search. Google Ads allows us to set specific keywords. An ad in Google's search engine results will only be displayed if you use the search engine to retrieve a keyword-related search result. In the Google AdWords network, the ads are distributed to topic-relevant web pages using an automated algorithm and according to previously defined keywords. If you click on a Google Ads ad and are thereby redirected to our website, Google will set a remarketing tag and a conversion cookie on your device. This may be a cookie or similar technology. If you then visit another website from the AdWords network, this remarketing tag will be read and you will receive an appropriate advertising message. The conversion cookie allows us to see how many people are interacting with one of our ads.

This data is processed in connection with Google AdWords in an anonymized manner. That is, Google does not store or process your name or e-mail address, for example, but processes the relevant cookie data within anonymized user profiles. These are not directly attributable to you. Neither we nor Google know who you are. The ads will be shown to the owner of a specific cookie ID. The information collected through Google AdWords is sent to Google and stored on Google's servers in the United States. Google is certified under the Privacy Shield Agreement. This ensures that a data protection level comparable with the GDPR is observed (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Additional information and Google's Privacy Policy can be found at https://policies.google.com/privacy.

You can always prevent cookies from being set by our website through your browser settings. This also prevents the cookies associated with Google AdWords from being stored on your device. You can delete existing cookies already on your device.

You also have the ability to block interestbased advertising by Google. To do this, go to https://adssettings.google.com/authenticated and change the settings as you see fit. Finally, you can also set a corresponding opt-out cookie at http://optout.networkadvertising.org/?c=1#!/.

15. Use of Facebook Pixel

On our website, we use “Facebook Pixel” from the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). We also use this tool based on your consent (Art. 6(1), sentence 1, section (a) GDPR). We use Facebook Pixel to provide you with personalized advertising on Facebook and to analyze your usage behavior on our website. You can withdraw your consent to this at any time with effect from that point forward. Simply use one of the listed opt-out options.

When you visit our website, Facebook Pixel is activated and a cookie is set by us on your device (what is known as a “first-party cookie”) through which data is collected. In addition, cookies are integrated directly by Facebook and other companies (“third-party cookies”). Web beacons and other storage technology may also be used. As a result, a “cookie” is stored on your device.

Facebook Pixel allows us to monitor the effectiveness of Facebook ads (“Facebook Ads”) and to analyze your interaction with our website for statistical and market research purposes. With the help of Facebook Pixel, we can recognize, for example, whether you have been redirected to our website after clicking on a Facebook Ad and how you have interacted with our website (this is referred to as “conversion”). With the help of Facebook Pixel, we can also assess you and other visitors to our website with regard to your placement in a target group for Facebook Ads. We therefore use Facebook Pixel to improve our contact with customers on Facebook, as Facebook Ads that are switched on by us are only displayed to those Facebook users who have also shown an interest in our offers or who have certain characteristics (e.g. interests in certain topics or products that are determined from the websites visited, what is referred to as “custom audiences via websites”). We also want to make sure that our Facebook Ads are of interest to you and not annoying.

Various event and conversion data are collected on our website, e.g. which subpages you visit or how you interact with our website. Thus, we evaluate your activity on our website and use this analysis for personalized advertising. If you log in to Facebook or if you are logged in to Facebook when visiting our website, the visit to our website is noted in your Facebook profile. The data are, however, converted (“hashed”) directly into chains of numbers when collected. These data therefore do not allow us to draw any conclusions about you. We would like to point out, however, that the data are also stored and processed by Facebook. Facebook may use this information for its own market research and advertising purposes. We have no control over that.

Facebook is certified under the EU-US Privacy Shield. This ensures that a level of protection comparable to European data protection law is observed (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active). The Facebook Data Policy applies to data processing by Facebook. It contains general information concerning the placement of Facebook Ads: https://www.facebook.com/policy.php. For more information about Facebook Pixel and how it works, visit the help section of Facebook: https://www.facebook.com/business/help/651294705016616.

To set which types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions for usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platformindependent, i.e. they are applied to all devices, such as desktop computers and mobile devices. You can find general information from Facebook on how to use cookies here: https://www.facebook.com/policies/cookies/

You can also prevent collection of data by Facebook Pixel and the use of your data for Facebook Ads. Furthermore, you may revoke your consent to this. Please click here: Disable Facebook Pixel If you disable Facebook Pixel, an “opt-out” cookie will be saved on your device. If you delete the cookies in this browser, you must click the link again. In addition, this opt-out only works within the browser you are currently using and only for our website. To decline these and other interest-based advertising, you can also visit the following websites: http://www.networkadvertising.org/choices/; http://www.youronlinechoices.com/

16. Use of Outbrain

We use Outbrain Pixel on our website. We asked you for your consent to do so during your first visit to our website, so that the legal basis for the associated data processing is your consent (Art. 6(1) section (a) GDPR). To help you understand what data processing is associated with Outbrain Pixel, here's how Outbrain generates personalized advertising.

16.1 Personalized advertising in the Outbrain
Widget Outbrain provides the Outbrain Widget, through which personalized ads are shown to you, to “Partner Websites”. The use of an Outbrain widget can be recognized by the text referring to Outbrain (e.g. “Recommended by Outbrain” or “from Outbrain” next to the recommendations). For example, if you visit the website of an online newspaper, you may see an ad in the Outbrain widget.

Outbrain Inc., 39 West 13th Street, 3rd floor, New York, NY 10011, USA is responsible for data protection matters related to this widget. In other words, Outbrain decides which data is processed and for what purpose, and therefore is your direct contact. The companies whose ads appear in the Outbrain widget do not have access to this data and do not decide how and what data is collected.

Outbrain uses the Outbrain widget to collect some information to show you personalized online advertising. If you visit a website that incorporates this Outbrain widget, your device will be assigned a unique user ID (Unique User Identifier; UUID). In addition, Outbrain will catalog and analyze the content you consume on the particular website. The recommendations are based on: (i) browsing history; (ii) similar web surfing patterns of other users; (iii) recommendations that are popular with Outbrain's target audience; (iv) a degree of randomness; and (v) target requirements provided or required by us or other Outbrain customers. Each of your devices receives its own UUID. Several devices therefore have multiple UUIDs. By assigning a UUID, Outbrain can combine the visited pages and the clicks on Outbrain's recommendations from that UUID. All this serves the purpose of providing interesting recommendations.

Outbrain also collects the following information: (i) IP address (anonymized to industry standards); (ii) User Agent Data: device type (e.g. iPhone), browser type (e.g. Chrome), operating system (e.g. iOS); (iii) the pages visited; (iv) the time of the visit; and (v) the referring URLs and other information typically transmitted during HTTP requests. Through this statistical information, Outbrain obtains information about how many users have visited a particular page on partner websites on which the Outbrain widget is installed, how long each user stayed on the page, the type of content on the page that the user clicked on, and how the user behaved on the page in general. This information is personal information only when connected to a user ID. You can find
additional information on data processing by Outbrain here: https://www.outbrain.com/de/legal/privacy. You can also opt out and prevent data processing there. As with any widget, you can also access your profile and opt out: https://my.outbrain.com/recommendations-settings/profile

16.2 Outbrain Pixel
We only use Outbrain Pixel on our website. This means that you will not see personalized advertisements from Outbrain on our website and the data processing that was just described does not occur. However, Outbrain Pixel does collect some information about you. We are responsible for this data processing and Outbrain acts on our behalf.

Therefore, we would like to inform you about this in detail: When we pay for an Outbrain ad and you click on that ad, you are redirected to our website. Outbrain Pixel then determines if your device has an Outbrain unique user ID. If there is a unique user ID associated with this device, we may re-address your unique user ID or find out the total number of unique user IDs that have reached our website. Furthermore, we use Outbrain Pixel to see which areas of the website were visited with the unique user ID. No identifiable personal information is collected, transmitted or stored.

If you do not have an Outbrain unique user ID, Outbrain Pixel will not capture any data at all. This data processing helps us to understand how our website is used and whether our ads contribute to our appeal to our customers. All data points, such as page views and clicks associated with a unique user ID, are stored for 13 months and then deleted. For example, if unique user ID 123 read an article on December 31, 2017, that article will no longer be part of the unique user ID 123 profile on February 1, 2018. You can find additional information on data processing by Outbrain here: https://www.outbrain.com/de/legal/privacy

If you have disabled processing of data by the Outbrain widget, Outbrain Pixel will not automatically collect data because your device has no unique user ID. Finally, you have the option of preventing the setting of cookies by the use of corresponding settings in your browser. You can also disable preference-based advertising using the preference manager that is available here: http://www.youronlinechoices.com/de/praferenzmanagement/

17. Use of Hotjar

We use Hotjar to better understand the needs of our users and to optimize the offer on this website. Hotjar's technology helps us gain a better understanding of our users' experiences (e.g. how much time users spend on which pages, which links they click, what they like and what they don't like, etc.) and this helps us to tailor our offering to our users' feedback. Hotjar uses cookies and other technologies collect information about our users' behavior and their end devices (including, but not limited to, IP address of the device (only collected and stored in anonymous form), screen size, device type (Unique Device Identifiers), information about the browser used, location (country only), language preferred to view our website). Hotjar stores this information in a pseudonymous user profile. The information is not used by Hotjar or by us to identify individual users, nor is it merged with other data about individual users. The legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO. You can find further information in Hotjar's privacy policy: https://www.hotjar.com/legal/policies/privacy\n\nYou can object to the storage of a user profile and information about your visit to our website by Hotjar and to the setting of Hotjar tracking cookies on other websites via this link: https://www.hotjar.com/legal/compliance/opt-out