OVERVIEW
Data protection is of highest priority for us. The use of 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 of 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 in 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 most complete protection of personal data processed through this website.
However, Internet-based data transmissions may in principle have security gaps, so
absolute protection may not be guaranteed.
NAME AND ADDRESS OF THE
CONTROLLER
Controller for the purposes of 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.
DEFINITIONS
This data protection declaration is based on the terms used by the European legislator for
the adoption of the General Data Protection Regulation (GDPR). Our data protection
declaration should be legible and understandable to the general public, as well as to our
customers and business partners. To ensure this, we would like to first explain the
terminology used.
In this data protection declaration, we use the following terms:
A.) PERSONAL DATA
Personal data means any information relating to an identified or identifiable natural person
(“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 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
Data subject is any identified or identifiable natural person, whose personal data is
processed by the controller responsible for the processing.
C.) PROCESSING
Processing is any operation or set of operations which is performed on personal data or on
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 with the aim of limiting 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, behaviour, location or
movements.
F.) PSEUDONYMISATION
Pseudonymisation 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
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
Processor is a natural or legal person, public authority, agency or other body which
processes personal data on behalf of the controller.
I.) RECIPIENT
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 which
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 be in compliance with the applicable data protection rules
according to the purposes of the processing.
J.) THIRD PARTY
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 a 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 that are 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 Internet browsers that contain other cookies. A specific Internet
browser can be recognized and identified using the unique cookie ID.
Through the use of 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 this is taken over by the website, 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 that a customer has placed in the
virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by
means of a corresponding setting of the Internet browser used, and may thus permanently
deny the setting of cookies. Furthermore, already set cookies may be deleted at any time
via an Internet browser or other software programs. 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 a series of 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, with the aim of increasing the data protection and data security of
our enterprise, 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 from the
controller the confirmation as to whether or not 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 personal 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 lodge a complaint 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 means of 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 in relation to 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 pursuant to 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 have been collected in relation to the offer of information
society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the
erasure of personal data stored by us, he or she may, at any time, contact any employee of
the controller. 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 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 instead the restriction of their use instead.
● The controller no longer needs the personal data for the purposes of the
processing, but they are required by the data subject for the establishment,
exercise or defence of legal claims.
● The data subject has objected to processing pursuant to Article 21(1) of the
GDPR pending the verification whether the legitimate grounds of the controller
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 us, he or she
may at any time contact any employee of the controller. 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, which was 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.
In order 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 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 which override the interests,
rights and freedoms of the data subject, or for the establishment, exercise or defence of
legal claims.
If we process personal data for direct marketing purposes, the data subject shall have the
right to object at any time to processing of 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 processing of personal data concerning him or her for scientific or
historical research purposes, or for 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.
In order to exercise the right to object, the data subject may contact any employee. In
addition, the data subject is free in the context of the use of information society services,
and 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 authorised 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 processing of his or her personal 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. If the processing of personal data is necessary
for the performance of a contract to which the data subject is party, as is the case, for
example, when processing operations are necessary for the supply of goods or to provide
any other service, 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 in the case of inquiries concerning our products or services. Is our company
subject to a legal obligation by which processing of personal data is required, such as for
the fulfillment of 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 of another natural person. This would be the case, for example, 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 which
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 they have been specifically mentioned by the European
legislator. 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 personal data of the data subject 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 to.
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 in accordance with 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 favour of the well-being of all our employees and the
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 expiration of that period, the corresponding data is routinely
deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation
of a contract.
Provision of personal data as 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 must subsequently be processed by us. 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 have the consequence that the
contract with the data subject could not be concluded. Before personal data is provided by
the data subject, 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 a quick electronic contact to our enterprise,
as well as 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 on a voluntary basis by a data
subject to the data controller are stored for the purpose of processing or contacting the data
subject. There is no transfer of this personal data to third parties
NEWSLETTER SUBSCRIPTION
On our website, users are given the opportunity to subscribe to our enterprise's newsletter.
The input mask used for this purpose determines what personal data are transmitted, as
well as when the newsletter is ordered from the controller.
We inform our customers and business partners regularly by means of 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 in order 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 in
the event of a change in technical circumstances. There will be no transfer of personal data
collected by 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 the purpose of 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 website of the
controller, or to communicate this to the controller in a different way.
NEWSLETTER TRACKING
Our newsletters contain tracking pixels. A tracking pixel is a miniature graphic embedded in
such emails, which are 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 an email was opened by a data
subject, 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 in order 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 has the possibility to register on the website of the controller with the
indication of personal data. Which personal data are transmitted to the controller is
determined by the respective input mask used for the registration. The personal data
entered by the data subject are collected and stored exclusively for internal use by the
controller, and for his own 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 which
is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet
service provider (ISP) and used by the data subject—date, and time of the registration 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 in question. Registered
persons are free to change the personal data specified during the registration at any time, or
to have them completely deleted from the data stock of the controller.
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 is also able to 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.à.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 of the data subject to PayPal. By
selecting this payment option, the data subject agrees to the transfer of 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 such personal
data, which are in connection 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, in particular, if a legitimate interest in the
transmission is given. The personal data exchanged between PayPal and the controller for
the processing of 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 has the possibility to revoke consent for the handling of personal data at
any time from PayPal. A revocation shall not have any effect on personal data which must
be processed, used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved under
https://www.paypal.com/us/webapps/mpp/ua/privacy-full.