Privacy Policy
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of
what will happen with your personal data when you visit this website. The term “personal data”
comprises all data that can be used to personally identify you. For detailed information about the subject matter of
data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this
website (i.e., the “controller”)?
The data on this website is processed by the operator of the
website, whose contact information is available under section “Information about the responsible party
(referred to as the “controller” in the GDPR)” in this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for
instance be information you enter into our contact form.
Other data shall be recorded by our IT systems
automatically or after you consent to its recording during your website visit. This data comprises primarily technical
information (e.g., web browser, operating system, or time the site was accessed). This information is recorded
automatically when you access this website.
What are the purposes we use your data for?
A
portion of the information is generated to guarantee the error free provision of the website. Other data may be used
to analyze your user patterns.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal
data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data
are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at
any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of
your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the
competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about
this or any other data protection related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns
will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer
to as analysis programs.
For detailed information about these analysis programs please consult our Data
Protection Declaration below.
2. Hosting
We are hosting the content of our website at the following provider:
External Hosting
This website is hosted externally. Personal data collected on this website are stored
on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and
communications, contract information, contact information, names, web page access, and other data generated
through a web site.
The external hosting serves the purpose of fulfilling the contract with our potential and
existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online
services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is
carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the
storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the
meaning of the TDDDG. This consent can be revoked at any time.
Our host(s) will only process your data to
the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such
data.
We are using the following host(s):
Host Europe GmbH
c/o WeWork
Friesenplatz 4
50672 Köln
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-
mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data
of our website visitors only based on our instructions and in compliance with the GDPR.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data
very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory
data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety
of personal information will be collected. Personal data comprises data that can be used to personally identify you.
This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also
explains how, and for which purpose the information is collected.
We herewith advise you that the
transmission of data via the Internet (i.e., through e‑mail communications) may be prone to security gaps. It is not
possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
ETHEN ROHRE GmbH
Grüner Weg 5
52070 Aachen
Phone: +49 241 900716–0
E‑mail: info@ethen-rohre.de
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as
to the purposes of and resources for the processing of personal data (e.g., names, e‑mail addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your
personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a
justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have
other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data processing on this website
If you have consented
to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special
categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of
personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to
the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data
processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is
required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your
data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation,
we process it on the basis of Art. 6(1)© GDPR. Furthermore, the data processing may be carried out on the basis of
our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case
is provided in the following paragraphs of this privacy policy.
Designation of a data protection officer
We have appointed a data protection officer.
Schadowski Consulting GmbH
Bahnhofstraße 9
52159 Roetgen
Phone: +49 2471 705 960 5
E‑mail: datenschutz@ethen-rohre.de
Information on the data transfer to third-party countries that are not secure under data protection law and the
transfer to US companies that are not DPF-certified
We use, among other technologies, tools from
companies located in third-party countries that are not safe under data protection law, as well as US tools whose
providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are enabled, your
personal data may be transferred to and processed in these countries. We would like you to note that no level of
data protection comparable to that in the EU can be guaranteed in third countries that are insecure in terms of data
protection law.
We would like to point out that the US, as a secure third-party country, generally has a level
of data protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is
certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances.
Information on transfers to third-party countries, including the data recipients, can be found in this Privacy
Policy.
Recipients of personal data
In the scope of our business activities, we cooperate with
various external parties. In some cases, this also requires the transfer of personal data to these external parties. We
only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are
legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure
pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors,
we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of
joint processing, a joint processing agreement is concluded.
Revocation of your consent to the processing of data
A wide range of data processing transactions
are possible only subject to your express consent. You can also revoke at any time any consent you have already
given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your
revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21
GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU
HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON
GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON
THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED,
PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO
LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT
COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH
YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING,
EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU
HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE
PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT
IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL
SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO
ART. 21(2) GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the
GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state
where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The
right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal
recourses.
Right to data portability
You have the right to have data that we process automatically on the basis of
your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable
format. If you should demand the direct transfer of the data to another controller, this will be done only if it is
technically feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory
provisions, you have the right to demand information about your archived personal data, their source and recipients
as well as the purpose of the processing of your data at any time. You may also have a right to have your data
rectified or eradicated. If you have questions about this subject matter or any other questions about personal data,
please do not hesitate to contact us at any time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions
as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to
demand restriction of processing applies in the following cases:
- In the event that you should dispute
the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that
this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand
the restriction of the processing of your data instead of demanding the eradication of this data.
- If we do not
need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right
to demand the restriction of the processing of your personal data instead of its eradication.
- If you have
raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each
other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of
the processing of your personal data.
If you have restricted the processing of your personal data,
these data – with the exception of their archiving – may be processed only subject to your consent or
to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for
important public interest reasons cited by the European Union or a member state of the EU.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential
content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an
SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line
of the browser switches from “http://” to “https://” and also by the appearance of the
lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be
read by third parties.
Rejection of unsolicited e‑mails
We herewith object to the use of contact information published in
conjunction with the mandatory information to be provided in our Site Notice to send us promotional and
information material that we have not expressly requested. The operators of this website and its pages reserve the
express right to take legal action in the event of the unsolicited sending of promotional information, for instance via
SPAM messages.
4. Recording of data on this website
Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies
are small data packages that do not cause any damage to your device. They are either stored temporarily for the
duration of a session (session cookies) or they are permanently archived on your device (permanent cookies).
Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on
your device until you actively delete them, or they are automatically eradicated by your web browser.
Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies).
Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies
for handling payment services).
Cookies have a variety of functions. Many cookies are technically essential
since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or
the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.
Cookies, which are required for the performance of electronic communication transactions, for the provision of
certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the
optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience),
shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has
a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision
of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies
has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and
§ 25 (1) TDDDG); this consent may be revoked at any time.
You have the option to set up your browser
in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in
specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-
function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions
of this website may be limited.
Which cookies and services are used on this website can be found in this
privacy policy.
Consent with Borlabs Cookie
Our website uses the Borlabs consent technology to obtain your
consent to the storage of certain cookies in your browser or for the use of certain technologies and for their data
privacy protection compliant documentation. The provider of this technology is Borlabs GmbH, Rübenkamp
32, 22305 Hamburg, Germany (hereinafter referred to as Borlabs).
Whenever you visit our website, a
Borlabs cookie will be stored in your browser, which archives any declarations or revocations of consent you have
entered. These data are not shared with the provider of the Borlabs technology.
The recorded data shall
remain archived until you ask us to eradicate them, delete the Borlabs cookie on your own or the purpose of storing
the data no longer exists. This shall be without prejudice to any retention obligations mandated by law. To review the
details of Borlabs’ data processing policies, please visit https://de.borlabs.io/kb/welche-daten-
speichert-borlabs-cookie/
We use the Borlabs cookie consent technology to obtain the declarations of
consent mandated by law for the use of cookies. The legal basis for the use of such cookies is Art. 6(1)© GDPR.
Contact form
If you submit inquiries to us via our contact form, the information provided in the
contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry
and in the event that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a
contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our
legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your
agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The
information you have entered into the contact form shall remain with us until you ask us to eradicate the data,
revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer
exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory
legal provisions, in particular retention periods.
Request by e‑mail, telephone, or fax
If you contact us by e‑mail, telephone or fax, your request,
including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing
your request. We do not pass these data on without your consent.
These data are processed on the basis of
Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-
contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective
handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has
been obtained; the consent can be revoked at any time.
The data sent by you to us via contact requests
remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage
lapses (e.g. after completion of your request). Mandatory statutory provisions — in particular statutory retention
periods — remain unaffected.
5. Social media
Facebook
We have integrated elements of the social network Facebook on this website. The
provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. According to
Facebook’s statement the collected data will be transferred to the USA and other third-party countries
too.
An overview of the Facebook social media elements is available under the following link: https://developers.facebook.com/docs/plugins/.
If the social media element has been
activated, a direct connection between your device and the Facebook server will be established. As a result,
Facebook will receive information confirming your visit to this website with your IP address. If you click on the
Facebook Like button while you are logged into your Facebook account, you can link content of this website to your
Facebook profile. Consequently, Facebook will be able to allocate your visit to this website to your user account. We
have to emphasize that we as the provider of the website do not receive any information on the content of the
transferred data and its use by Facebook. For more information, please consult the Data Privacy Policy of Facebook
at: https://de-de.facebook.com/privacy/explanation.
The use of this service is based on your
consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to
Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the
collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward
transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint
processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are
responsible for providing the privacy information when using the Facebook tool and for the privacy-secure
implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You
can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with
Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data
transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can
be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-
de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https:
//www.dataprivacyframework.gov/s/participant-search/participant-
detail?contact=true&id=a2zt0000000GnywAAC&status=Active.
LinkedIn
This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland
Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Any time you access a page of this
website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is
notified that you have visited this website with your IP address. If you click on LinkedIn’s
“Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a
position to allocate your visit to this website to your user account. We have to point out that we as the provider of
the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.
The
use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent
can be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses
(SCC) of the European Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-
und-der-schweiz?lang=de.
For further information on this subject, please consult LinkedIn’s
Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5448.
6. Analysis tools and advertising
Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited,
Gordon House, Barrow Street, Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to
integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not
create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages
and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also
be transferred to Google’s parent company in the United States.
The Google Tag Manager is used on
the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated
integration and administration of various tools on his website. If appropriate consent has been obtained, the
processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent
includes the storage of cookies or the access to information in the user’s end device (e.g., device
fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Google Analytics
This website uses functions of the web analysis service Google Analytics. The
provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4,
Ireland.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors.
To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the
utilized operating system and the user’s origin. This data is summarized in a user-ID and assigned to the
respective end device of the website visitor.
Furthermore, Google Analytics allows us to record your mouse
and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to
augment the collected data sets and uses machine learning technologies in data analysis.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user
behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a
rule transferred to a Google server in the United States, where it is stored.
The use of these services occurs
on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent
at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the
European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in
accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the
European Union and the US, which is intended to ensure compliance with European data protection standards for
data processing in the US. Every company certified under the DPF is obliged to comply with these data protection
standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
IP anonymization
Google Analytics IP anonymization is active. As a result, your IP address will be
abbreviated by Google within the member states of the European Union or in other states that have ratified the
Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be
transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases.
On behalf of the operator of this website, Google shall use this information to analyze your use of this website to
generate reports on website activities and to render other services to the operator of this website that are related to
the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your
browser shall not be merged with other data in Google’s possession.
Browser plug-in
You can prevent the recording and processing of your data by Google by
downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the
handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Google Signals
We use Google Signals. Whenever you visit our website, Google Analytics records, among other things, your
location, the progression of your search and YouTube progression as well as demographic data (site visitor data).
This data may be used for customized advertising with the assistance of Google Signal. If you have a Google account,
your site visitor information will be linked to your Google account by Google Signal and used to send you customized
promotional messages. The data is also used to compile anonymized statistics of our users’ online
patterns.
Contract data processing
We have executed a contract data processing agreement with Google and
are implementing the stringent provisions of the German data protection agencies to the fullest when using Google
Analytics.
Google Ads
The website operator uses Google Ads. Google Ads is an online promotional program of
Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google
Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search
terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in
its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze
these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how
many ads led to respective clicks.
The use of these services occurs on the basis of your consent pursuant to
Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.
Data transmission to
the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Google Ads Remarketing
This website uses the functions of Google Ads Remarketing. The provider
of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4,
Ireland.
With Google Ads Remarketing, we can assign people who interact with our online offering to
specific target groups in order to subsequently display interest-based advertising to them in the Google advertising
network (remarketing or retargeting).
Moreover, it is possible to link the advertising target groups
generated with Google Ads Remarketing to device encompassing functions of Google. This makes it possible to
display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a
device (e.g., cell phone) in a manner tailored to you as well as on any of your devices (e.g., tablet or PC).
If you
have a Google account, you have the option to object to personalized advertising under the following link: https://adssettings.google.com/anonymous?hl=de.
The use of these services occurs on the
basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any
time.
For further information and the pertinent data protection regulations, please consult the Data Privacy
Policies of Google at: https://policies.google.com/technologies/ads?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Formation of Target Groups with Customer Reconciliation
For the formation of target groups, we
use, among other things, the Google Ads Remarketing customer reconciliation feature. To achieve this, we transfer
certain customer data (e.g., email addresses) from our customer lists to Google. If the respective customers are
Google users and are logged into their Google accounts, matching advertising messages within the Google network
(e.g., YouTube, Gmail or in a search engine) are displayed for them to view.
7. Newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, we require an e-
mail address from you as well as information that allows us to verify that you are the owner of the e‑mail address
provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For
the handling of the newsletter, we use newsletter service providers, which are described below.
Mailchimp
This website uses the services of Mailchimp to send out its newsletters. The provider is
the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
Among
other things, Mailchimp is a service that can be deployed to organize and analyze the sending of newsletters.
Whenever you enter data for the purpose of subscribing to a newsletter (e.g. your e‑mail address), the information is
stored on Mailchimp servers in the United States.
With the assistance of the Mailchimp tool, we can analyze
the performance of our newsletter campaigns. If you open an e‑mail that has been sent through the Mailchimp tool, a
file that has been integrated into the e‑mail (a so-called web-beacon) connects to Mailchimp’s servers in the
United States. As a result, it can be determined whether a newsletter message has been opened and which links the
recipient possibly clicked on. Technical information is also recorded at that time (e.g. the time of access, the IP
address, type of browser and operating system). This information cannot be allocated to the respective newsletter
recipient. Their sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such
analyses can be used to tailor future newsletters to the interests of their recipients more effectively.
If you
do not want to permit an analysis by Mailchimp, you must unsubscribe from the newsletter. We provide a link for
you to do this in every newsletter message.
The data is processed based on your consent (Art. 6(1)(a)
GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be
without prejudice to the lawfulness of any data processing transactions that have taken place prior to your
revocation.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us
until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter
distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain
unaffected.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the
European Commission. Details can be found here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-
addendum/#Annex_C_-_Standard_Contractual_Clauses.
After you unsubscribe from the newsletter
distribution list, your e‑mail address may be stored by us or the newsletter service provider in a blacklist, if such
action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not
merged with other data. This serves both your interest and our interest in complying with the legal requirements
when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is
indefinite. You may object to the storage if your interests outweigh our legitimate interest.
For more details, please consult the Data Privacy Policies of Mailchimp at: https://mailchimp.com/legal/terms/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https:
//www.dataprivacyframework.gov/s/participant-search/participant-
detail?contact=true&id=a2zt0000000TXVKAA4&status=Active.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-
mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data
of our website visitors only based on our instructions and in compliance with the GDPR.
8. Plug-ins and Tools
YouTube with expanded data protection integration
This website integrates videos from the
YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House,
Barrow Street, Dublin 4, Ireland.
When you visit one of these websites on which YouTube is integrated, a
connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited.
If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your
personal profile. You can prevent this by logging out of your YouTube account.
We use YouTube in
extended data protection mode. According to YouTube, videos that are played in extended data protection mode are
not used to personalize browsing on YouTube. Ads that are played in extended data protection mode are also not
personalized. No cookies are set in extended data protection mode. Instead, so-called local storage elements are
stored in the user’s browser, which contain personal data similar to cookies and can be used for recognition. Details
on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780.
After activating a YouTube video,
further data processing operations may be triggered over which we have no influence.
The use of YouTube
is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this
is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the
basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the
access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG.
This consent can be revoked at any time.
For more information on how YouTube handles user data, please
consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter referred to as
“reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”),
Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to determine whether data
entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an
automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on a variety
of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis,
reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor
movements initiated by the user). The data tracked during such analyses are forwarded to Google.
reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is
underway.
Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a
legitimate interest in the protection of the operator’s websites against abusive automated spying and against
SPAM. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a)
GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in
the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be
revoked at any time.
For more information about Google reCAPTCHA please refer to the Google Data
Privacy Declaration and Terms Of Use under the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF
is an agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply
with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Wordfence
We have included Wordfence on this website. The provider is Defiant Inc, Defiant, Inc,
800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter “Wordfence”).
Wordfence is
designed to protect our website from unwanted access or malicious cyberattacks. To accomplish this, our website
establishes a permanent connection with Wordfence’s servers, which check and block their databases
against access to our website.
The use of Wordfence is based on Art. 6(1)(f) GDPR. The website operator
has a legitimate interest in the most effective protection of his website against cyberattacks. If appropriate consent
has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1)
TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end
device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Data transmission to the USA is based on the standard contractual clauses of the EU Commission. Details can be
found here: https://www.wordfence.com/help/general-data-protection-regulation/.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-
mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data
of our website visitors only based on our instructions and in compliance with the GDPR.
9. eCommerce and payment service providers
Processing of Customer and Contract Data
We collect, process, and use personal customer and
contract data for the establishment, content arrangement and modification of our contractual relationships. Data
with personal references to the use of this website (usage data) will be collected, processed, and used only if this is
necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes
is Art. 6(1)(b) GDPR.
The collected customer data shall be deleted upon completion of the order or
termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be
without prejudice to any statutory archiving periods.
Data transfer upon closing of contracts for online stores, retailers, and the shipment of merchandise
Whenever you order merchandise from us, we will share your personal data with the transportation company
entrusted with the delivery as well as the payment service commissioned to handle the payment transactions. Only
the data these respective service providers require to meet their obligations will be shared. The legal basis for this
sharing is Art. 6 (1)(b) GDPR, which permits the processing of data for the fulfillment of contractual or pre-
contractual obligations. If you give us your respective consent pursuant to Art. 6 (1)(a) GDPR, we will share your
email address with the transportation company entrusted with the delivery so that this company can notify you on
the shipping status for your order via email. You have the option to revoke your consent at any time.
10. Custom Services
Handling applicant data
We offer website visitors the opportunity to submit job applications to us
(e.g., via e‑mail, via postal services on by submitting the online job application form). Below, we will brief you on the
scope, purpose and use of the personal data collected from you in conjunction with the application process. We
assure you that the collection, processing, and use of your data will occur in compliance with the applicable data
privacy rights and all other statutory provisions and that your data will always be treated as strictly
confidential.
Scope and purpose of the collection of data
If you submit a job application to us, we
will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken
during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment
relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation
of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have
given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our
company, your personal data will only be shared with individuals who are involved in the processing of your job
application.
If your job application should result in your recruitment, the data you have submitted will be
archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment
relationship in our data processing system.
Data Archiving Period
If we are unable to make you a
job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have
submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the
application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the
physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal
dispute. If it is evident that the data will be required after the expiry of the 6‑month period (e.g., due to an impending
or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.
Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data
retention requirements preclude the deletion.
Admission to the applicant pool
If we do not make you a job offer, you may be able to join our
applicant pool. In case of admission, all documents and information from the application will be transferred to the
applicant pool in order to contact you in case of suitable vacancies.
Admission to the applicant pool is based
exclusively on your express agreement (Art. 6(1)(a) GDPR). The submission agreement is voluntary and has no
relation to the ongoing application procedure. The affected person can revoke his agreement at any
time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal
reasons for storage.
The data from the applicant pool will be irrevocably deleted no later than two years
after consent has been granted.