Privacy Policy

OVERVIEW

Data protection is of the highest priority for us. Using our website is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, shall always be in line with the General Data Protection Regulation (GDPR) and accordance with the country-specific data protection regulations applicable to us. By means of this data protection policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, we have implemented numerous technical and organizational measures to ensure the complete protection of personal data processed through this website. However, Internet-based data transmissions may have security gaps, so absolute protection may not be guaranteed.

NAME AND ADDRESS OF THE CONTROLLER

Controller for the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union, and other provisions related to data protection is:

COMPLIANCE DEPT.


(Email)

DEFINITIONS

This data protection declaration is based on the terms used by the European legislator for adopting the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable to the general public and our customers and business partners. To ensure this, we would like first to explain the terminology used.

In this data protection declaration, we use the following terms:

A.) PERSONAL DATA

Personal data is any information about an identified or identifiable natural person (“data subject”). An identifiable natural person 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.

B.) DATA SUBJECT

The data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible.

C.) PROCESSING

Processing is any operation or set of operations that is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

D.) RESTRICTION OF PROCESSING

Restriction of processing is the marking of stored personal data to limit their processing in the future.

E.) PROFILING

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

F.) PSEUDONYMISATION

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

G.) CONTROLLER OR CONTROLLER RESPONSIBLE FOR THE PROCESSING

The controller or controller responsible for the processing is 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.

H.) PROCESSOR

A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

I.) RECIPIENT

The recipient is a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.

J.) THIRD-PARTY

The third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

K.) CONSENT

Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

COOKIES

Our website uses cookies. Cookies are text files stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other web browsers containing other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through cookies, we can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g., does not have to enter access data each time the website is accessed because the website takes this over, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles a customer places in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website using a corresponding Internet browser setting and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted anytime via an Internet browser or other software. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

COLLECTION OF GENERAL DATA AND INFORMATION

Our website collects general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, we analyze anonymously collected data and information statistically, intending to increase our enterprise's data protection and security and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

RIGHTS OF THE DATA SUBJECT

A.) RIGHT OF CONFIRMATION

Each data subject shall have the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

B.) RIGHT OF ACCESS

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  • 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 the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to complain with a supervisory authority;
  • where the personal data are not collected from the data subject, 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 envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

C.) RIGHT TO RECTIFICATION

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

D.) RIGHT TO ERASURE (RIGHT TO BE FORGOTTEN)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing under Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data about the offer of information society services referred to in Article 8(1) of the GDPR has been collected.

Suppose one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by us. In that case, he or she may, at any time, contact any controller employee. An employee shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee will arrange the necessary measures in individual cases.

E.) RIGHT OF RESTRICTION OF PROCESSING

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject for a period, enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
  • The controller no longer needs the personal data for the processing, but the data subject for establishing, exercising, or defense of legal claims requires them.
  • The data subject has objected to processing under Article 21(1) of the GDPR pending the verification of whether the controller's legitimate grounds override those of the data subject.
  • If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by us, he or she may contact any controller employee at any time. The employee will arrange the restriction of the processing.

F.) RIGHT TO DATA PORTABILITY

Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, provided to a controller, in a structured, commonly used, and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may at any time contact any employee.

G.) RIGHT TO OBJECT

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

We shall no longer process the personal data in the event of the objection unless we can demonstrate compelling, legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

Suppose we process personal data for direct marketing purposes. In that case, the data subject shall have the right to object at any time to processing personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee. In addition, the data subject is free in using information society services, notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

H.) AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject\s rights and freedoms and legitimate interests, or (3) is not based on the data subject\s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, we shall implement suitable measures to safeguard the data subject\s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee.

I.) RIGHT TO WITHDRAW DATA PROTECTION CONSENT

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee.

LEGAL BASIS FOR THE PROCESSING

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. Suppose the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary to supply goods or provide any other service. In that case, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations, which are necessary for carrying out pre-contractual measures, for example, concerning inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as to fulfill tax obligations? The processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. For example, this would be the case if a visitor were injured in our company, and his name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third party. Then, the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the abovementioned legal grounds if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because the European legislator specifically mentions them. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The data controller shall process and store the subject's personal data only for the period necessary to achieve the purpose of storage or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased by legal requirements.

THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY

Where the processing of personal data is based on Article 6(1) lit. f GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and shareholders.

PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted as long as it is no longer necessary to fulfill the contract or initiate a contract.

Provision of personal data as a statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes, it may be necessary to conclude a contract that the data subject provides us with personal data, which we must subsequently process. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact any employee.

The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.

CONTACT POSSIBILITY VIA THE WEBSITE

Our website contains information that enables quick electronic contact with our enterprise and direct communication with us via an email address. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted voluntarily by a data subject to the controller are stored for processing or contacting the subject. There is no transfer of this personal data to third parties.

NEWSLETTER SUBSCRIPTION

On our website, users are allowed to subscribe to our enterprise\s newsletter. The input mask used for this purpose determines what personal data are transmitted and when the newsletter is ordered from the controller.

We regularly inform our customers and business partners using a newsletter about enterprise offers. The enterprise\s newsletter may only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter shipping. A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove whether the owner of the email address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer or the event of a change in technical circumstances. There will be no transfer of personal data from the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the controller's website or to communicate this to the controller differently.

NEWSLETTER TRACKING

Our newsletters contain tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when a data subject opened an email and which links in the email were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke their declaration of consent to receive newsletters.

After a revocation, these personal data will be deleted by the controller. We automatically regard a withdrawal from the receipt of the newsletter as a revocation.

REGISTRATION ON OUR WEBSITE

The data subject can register on the controller's website by indicating personal data. The respective input mask used for the registration determines which personal data are transmitted to the controller. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for his purposes. The controller may request transfer to one or more processors (e.g., a parcel service) that also uses personal data for an internal purpose attributable to the controller.

By registering on the controller's website, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—the registration date and time are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate committed offenses. Insofar the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter. Registered persons are free to change the personal data specified during the registration at any time or to delete them completely from the controller's data stock.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

PAYMENT METHOD: DATA PROTECTION PROVISIONS ABOUT THE USE OF PAYPAL AS A PAYMENT PROCESSOR

On this website, the controller has integrated components of PayPal. PayPal is an online payment service provider. Payments are processed via PayPal accounts, which represent virtual private or business accounts. PayPal can also process virtual payments through credit cards when a user does not have a PayPal account. A PayPal account is managed via an email address, which is why there are no classic account numbers. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.Ă .r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

If the data subject chooses "PayPal" as the payment option in the online shop during the ordering process, we automatically transmit the data subject's data to PayPal. By selecting this payment option, the data subject agrees to transfer personal data required for payment processing.

The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires personal data connected with the respective order.

The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal, particularly if a legitimate interest in the transmission is given. The personal data exchanged between PayPal and the controller for processing the data will be transmitted by PayPal to economic credit agencies. This transmission is intended for identity and creditworthiness checks.

PayPal will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfill contractual obligations or for data to be processed in the order.

The data subject can revoke consent for handling personal data at any time from PayPal. A revocation shall not affect personal data, which must be processed, used, or transmitted by (contractual) payment processing.

The applicable data protection provisions of PayPal may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

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