Privacy Policy
This privacy policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") in the context of providing our services and within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).Controller
sa den EMEA (limited liability)Rilkestrasse 7 | 77776 Bad Rippoldsau - Schapbach | Germany
Managing Director: André Kochmann
Types of data processed
- Inventory data (e.g., personal master data, names or addresses).- Contact data (e.g., email, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter we also collectively refer to the data subjects as "users").Purpose of processing
- Providing the online offer, its functions and content.- Answering contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing
Terms used
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "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 (e.g., a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person."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. The term is broad and encompasses virtually any handling of data.
"Pseudonymisation" means 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
The "controller" 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.
A "processor" is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Article 13 GDPR, we inform you of the legal bases of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the privacy policy:The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR;
The legal basis for processing to fulfil our services and implement contractual measures and answer inquiries is Article 6(1)(b) GDPR;
The legal basis for processing to fulfil our legal obligations is Article 6(1)(c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.
The legal basis for the necessary processing for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6(1)(e) GDPR.
The legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Article 6(4) GDPR.
The processing of special categories of data (in accordance with Article 9(1) GDPR) is governed by the provisions of Article 9(2) GDPR.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of security appropriate to the risk.These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to data and access to, input, disclosure, availability and separation of data. We have also established procedures to ensure the exercise of data subject rights, data deletion and response to data breaches. Furthermore, we already take into account the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If we disclose data to other persons and companies (processors, joint controllers or third parties) within the framework of our processing, transmit them to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is necessary for the fulfilment of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).If we disclose data to other companies in our group of companies, transmit it to them or otherwise grant them access to it, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this happens in the context of using third-party services or disclosing or transferring data to other persons or companies, this is only done if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have data processed in a third country if the legal requirements are met. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognised special contractual obligations.Rights of data subjects
You have the right to request confirmation as to whether the data concerning you are being processed, and to request access to such data and further information and a copy of the data in accordance with the legal requirements.In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
In accordance with the legal requirements, you have the right to request that the data concerning you be deleted without undue delay or, alternatively, to request a restriction on the processing of the data in accordance with the legal requirements.
You have the right to request that the data concerning you which you have provided to us be received in accordance with the legal requirements and to request the transmission of such data to other controllers.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with the legal requirements.
Right of revocation
You have the right to revoke any consent given with effect for the future.Right of objection
You can object to the future processing of data concerning you in accordance with the legal requirements at any time. The objection can in particular be made against processing for direct marketing purposes.Cookies and right of objection in the case of direct advertising
"Cookies" are small files that are stored on the users' computers. Different information can be stored within the cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or even after his visit to an online offer. Cookies that are deleted after a user leaves an online offer and closes his browser are referred to as temporary cookies, or "session cookies" or "transient cookies". For example, the content of a shopping cart in an online shop or a login status can be stored in such a cookie. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users visit it after several days. The users' interests can also be stored in such a cookie, which are used for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offer (otherwise, if they are only the controller's cookies, they are referred to as "first-party cookies").We may use temporary and permanent cookies and clarify this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offer.
A general objection to the use of cookies for online marketing purposes can be declared for many services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case, not all functions of this online offer may be usable.
Deletion of data
The data processed by us are deleted or their processing is restricted in accordance with the legal requirements. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their intended purpose and there are no legal storage obligations to the contrary.If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data are blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax law reasons.
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.Business-related processing
In addition, we process- Contract data (e.g., subject matter of the contract, term, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing in the online shop and customer account
We process the data of our customers within the framework of order processes in our online shop in order to enable them to select and order the chosen products and services, as well as their payment and delivery or execution.The processed data include inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, prospects and other business partners. The processing is carried out for the purpose of providing contractual services within the framework of operating an online shop, billing, delivery and customer services. In this context, we use session cookies to store the shopping cart content and permanent cookies to store the login status.
The processing is carried out to fulfil our services and implement contractual measures (e.g. execution of order processes) and insofar as it is legally prescribed (e.g. legally required archiving of business transactions for commercial and tax purposes). The information marked as required is necessary for the establishment and fulfilment of the contract. We only disclose the data to third parties within the framework of delivery, payment or within the framework of legal permissions and obligations, as well as if this is done on the basis of our legitimate interests, about which we inform you within the framework of this privacy policy (e.g. to legal and tax advisors, financial institutions, freight forwarders and authorities).
Users can optionally create a user account, where they can view their orders in particular. During registration, the required mandatory information is communicated to the users. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account are deleted, subject to their retention being necessary for commercial or tax law reasons. Information in the customer account remains until its deletion with subsequent archiving in the case of a legal obligation or our legitimate interests (e.g. in the case of legal disputes). It is the responsibility of the users to secure their data before the end of the contract if they terminate their contract.
When registering and re-registering and using our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the users' interest in protection against misuse and other unauthorised use. This data is generally not passed on to third parties, unless this is necessary for the pursuit of our legal claims as a legitimate interest or there is a legal obligation to do so.
Deletion takes place after the expiry of legal warranty and other contractual rights or obligations (e.g. payment claims or performance obligations from contracts with customers), whereby the necessity of storing the data is checked every three years; in the case of storage due to legal archiving obligations, deletion takes place after their expiry.
External payment service providers
We use external payment service providers via whose platforms users and we can make payment transactions (e.g., each with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)Within the framework of fulfilling contracts, we use the payment service providers on the basis of Article 6(1)(b) GDPR. Otherwise, we use external payment service providers on the basis of our legitimate interests in accordance with Article 6(1)(f) GDPR in order to offer our users an effective and secure payment option.
The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is necessary to carry out the transactions. However, the entered data are only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative confirmation of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit rating agencies. This transmission is intended for identity and creditworthiness checks. We refer you to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers, which can be accessed on the respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and the assertion of rights of revocation, information and other data subject rights.
Business analyses and market research
In order to operate our business economically and to be able to recognise market trends and the wishes of our contractual partners and users, we analyse the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data and metadata on the basis of Article 6(1)(f) GDPR, whereby the persons concerned include contractual partners, prospects, customers, visitors and users of our online offer.The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve to improve user-friendliness, optimise our offer and improve business efficiency. The analyses serve only us and are not disclosed externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal data, they are deleted or anonymised upon termination of the user's account, otherwise after two years from the conclusion of the contract. Otherwise, overall business analyses and general trend determinations are prepared anonymously as far as possible.
Registration function
Users can create a user account. Within the framework of registration, the required mandatory information is communicated to the users and processed on the basis of Article 6(1)(b) GDPR for the purpose of providing the user account. The processed data include in particular the login information (name, password and an email address). The data entered during registration are used for the purposes of using the user account and its purpose.Users can be informed about information relevant to their user account, such as technical changes, by email. If users have terminated their user account, their data with regard to the user account are deleted, subject to a legal retention obligation. It is the responsibility of the users to secure their data before the end of the contract if they terminate their contract. We are entitled to irretrievably delete all data of the user stored during the contract period.
When using our registration and login functions and using the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the users' interest in protection against misuse and other unauthorised use. This data is generally not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Article 6(1)(c) GDPR. The IP addresses are anonymised or deleted after 7 days at the latest.
Contacting us
When contacting us (e.g. via contact form, email, telephone or via social media), the user's details are processed to process the contact request and its handling in accordance with Article 6(1)(b) (within the framework of contractual/pre-contractual relationships), Article 6(1)(f) (other inquiries) GDPR. The user's details may be stored in a Customer Relationship Management System ("CRM system") or comparable inquiry organisation.We delete the inquiries if they are no longer necessary. We check the necessity every two years; furthermore, the legal archiving obligations apply.
Newsletter
The following information provides details on the content of our newsletter, the registration, dispatch and statistical evaluation procedures, and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter "newsletter") with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described within the framework of registration for the newsletter, it is decisive for the consent of the users. Otherwise, our newsletters contain information about our services and ourselves.
Double-Opt-In and logging: Registration for our newsletter takes place in a so-called double-opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with foreign email addresses. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.
Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for personal address in the newsletter.
The dispatch of the newsletter and the associated success measurement are carried out on the basis of the consent of the recipients in accordance with Article 6(1)(a), Article 7 GDPR in conjunction with Section 7(2)(3) UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Article 6(1)(f) GDPR in conjunction with Section 7(3) UWG.
The logging of the registration process is carried out on the basis of our legitimate interests in accordance with Article 6(1)(f) GDPR. Our interest is in the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to prove consent.
Termination/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of possibly defending claims. An individual deletion request is possible at any time, provided that the former existence of consent is simultaneously confirmed.
Newsletter
The following information provides details on the content of our newsletter, the registration, dispatch and statistical evaluation procedures, and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter "newsletter") with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described within the framework of registration for the newsletter, it is decisive for the consent of the users. Otherwise, our newsletters contain information about our products and accompanying information (e.g. safety instructions), offers, promotions and our company.
Double-Opt-In and logging: Registration for our newsletter takes place in a so-called double-opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with foreign email addresses. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.
Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for personal address in the newsletter.
The dispatch of the newsletter and the associated success measurement are carried out on the basis of the consent of the recipients in accordance with Article 6(1)(a), Article 7 GDPR in conjunction with Section 107(2) TKG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Article 6(1)(f) GDPR in conjunction with Section 107(2) and (3) TKG.
The logging of the registration process is carried out on the basis of our legitimate interests in accordance with Article 6(1)(f) GDPR. Our interest is in the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to prove consent.
Termination/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of possibly defending claims. An individual deletion request is possible at any time, provided that the former existence of consent is simultaneously confirmed.
Hosting and email dispatch
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offer.In this context, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Article 6(1)(f) GDPR in conjunction with Article 28 GDPR (conclusion of a contract processing agreement).
Collection of access data and log files
We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Article 6(1)(f) GDPR on each access to the server on which this service is located (so-called server log files). Access data include the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.Log file information is stored for security reasons (e.g. to investigate misuse or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes are excluded from deletion until the final clarification of the respective incident.
Online presences in social media
We maintain online presences within social networks and platforms in order to communicate with active customers, prospects and users there and to inform them about our services.We would like to point out that user data may be processed outside the European Union. This can lead to risks for users, as, for example, the enforcement of users' rights could be made more difficult. With regard to US providers who are certified under the Privacy Shield, we would like to point out that they undertake to comply with EU data protection standards.
Furthermore, user data are usually processed for market research and advertising purposes. For example, usage profiles can be created from user behaviour and the resulting interests of users. Usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of users. For these purposes, cookies are usually stored on the users' computers, in which user behaviour and the interests of users are stored. Furthermore, data may also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in there).
The processing of users' personal data is carried out on the basis of our legitimate interests in effectively informing users and communicating with users in accordance with Article 6(1)(f) GDPR. If users are asked by the respective providers for consent to data processing (i.e. they declare their consent, for example, by ticking a checkbox or confirming a button), the legal basis for processing is Article 6(1)(a), Article 7 GDPR.
For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the following linked information from the providers.
Also in the case of requests for information and the assertion of user rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can directly take appropriate measures and provide information. If you still need help, you can contact us.
- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) - Privacy policy: https://www.facebook.com/about/privacy/, Opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
- Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy policy: https://policies.google.com/privacy, Opt-out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy policy/ Opt-out: http://instagram.com/about/legal/privacy/.
- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy policy/ Opt-out: https://about.pinterest.com/de/privacy-policy.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy policy https://www.linkedin.com/legal/privacy-policy , Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
- Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) - Privacy policy/ Opt-out: https://privacy.xing.com/de/datenschutzerklaerung.
Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Article 6(1)(f) GDPR), we use content or service offers from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").This always presupposes that the third-party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore necessary for the presentation of this content. We endeavour only to use content whose respective providers only use the IP address for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Using "pixel tags", information such as visitor traffic on the pages of this website can be evaluated. The pseudonymised information can also be stored in cookies on the user's device and may contain, among other things, technical information on the browser and operating system, referring websites, visit time and other details on the use of our online offer, and may also be linked with such information from other sources.