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PRIVACY POLICY

FRANCOTYP-POSTALIA LIMITED

 

Introduction

Welcome to Francotyp-Postalia Limited’s privacy notice.

Francotyp-Postalia Limited (We) respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and any other data protection laws and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

The use of our website is basically possible without providing personal data. However, if you use our company’s services via our website, it may be necessary to process your personal data. As the company responsible for data processing, we have defined technical and organizational measures to ensure the highest possible level of protection of your personal data

 

 

  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights
  10. Disclaimer for Google Analytics
  11. Glossary

 

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of our websites

 

Including any data you may provide through the Websites when you sign up to our newsletter, request a call back, request a quote or purchase a product or service.

The Websites are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Francotyp-Postalia Limited is the controller and responsible for your personal data (collectively referred to as Francotyp-Postalia Limited, “we”, “us” or “our” in this privacy notice).

We hope that we can resolve any query or concern you raise about our use of your information. However, under the General Data Protection Regulation you have the right to make a complaint at any time with a supervisory authority, in particular in the European Union (or European Economic Area or the United Kingdom) where any alleged infringement of data protection laws occurred.

The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 0303 123 1113.

Francotyp-Postalia Vertrieb und Service GmbHPrenzlauer Promenade 2813089 BerlinPhone: +49 30 220 660-0E-Mail: info@franctoyp.com

When you visit us on our websites, service providers who are also subject to data protection store the name of your Internet service provider, the website from which you visit us, the websites you visit on our website, as well as the date and duration of your visit. So-called “cookies” are used by us to track the preferences of visitors and to make their use of our website as pleasant as possible. We use analysis tools for this. If you do not want your data to be tracked when you visit our website, you can opt out here. In addition, personal data will only be stored if you provide it yourself, such as in the case of a contact request.

We process and store your personal data only for the period necessary to achieve the respective storage purpose or as provided for by the various retention periods provided for by law.

After discontinuation of a storage purpose or after expiry of the retention period provided for by law, the personal data will be routinely blocked or deleted for further processing in accordance with the statutory provisions.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Websites.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Websites, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • create an account on our Websites;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • request a quote for services via our Websites;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions.

As you interact with our Websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies.

We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at https://www.fpmailing.co.uk/wp- content/uploads/2020/08/Cookies-Policy-Aug-2020.pdf for further details.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • analytics providers such as Google based outside the EU;
  • advertising networks Amazon SES, Survey Monkey, Facebook, Twitter, Instagram based inside and outside the EU;
  • search information providers such as Bing based inside the EU; and
  • comparison websites and providers of business information and insight.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Worldpay and Jotform based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we will call you to confirm your details and requirements.
  • Where we need to perform the contract we are about to enter into or have entered into with you and to provide you with the information, products and services that you request from us.
  • Where we provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
  • Where we need to notify you about changes to our services.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

 

Purpose/Activity: To register you as a new customer.

Type of data: (a)  Identity, (b)  Contact

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you


Purpose/Activity: To process and deliver your order including:

  • Manage payments, fees and charges
  • Collect and recover money owed to us

Type of data: (a)  Identity, (b)  Contact, (c)  Financial, (d)  Transaction, (e)  Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

  • Performance of a contract with you
  • Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity: To manage our relationship with you which will include:

  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey

Type of data: (a)  Identity, (b)  Contact, (c)  Profile, (d)  Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity: To enable you to partake in a prize draw or competition.

Type of data: (a)  Identity, (b)  Contact, (c)  Profile, (d)  Usage, (e)  Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)


Purpose/Activity: To administer and protect our business and the Websites  (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: (a)  Identity, (b)  Contact, (c)  Technical

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation

Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data: (a)  Identity, (b)  Contact, (c)  Profile, (d)  Usage, (e)  Marketing and Communications, (f)  Technical

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)


Purpose/Activity: To use data analytics to improve our Websites, products/services, marketing, customer relationships and experiences

Type of data: (a)  Technical, (b)  Usage

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Websites updated and relevant, to develop our business and to inform our marketing strategy)


Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data: (a)  Identity, (b)  Contact, (c)  Technical, (d)  Usage, (e) Profile

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, including requesting a quote for goods or services, or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Francotyp-Postalia Limited group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us by telephone on 0344 225 2233 or emailing us at admin@fpmailing.co.uk at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Websites may become inaccessible or not function properly. For more information

About the  cookies we use, please see our Cookie Policy available at https://www.fpmailing.co.uk/wp-content/uploads/2020/08/Cookies-Policy-Aug-2020.pdf

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Any member of our group, which means our franchisees, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. If you require further details of our company group and its subsidiaries, please contact us.
  • Selected Internal and External third parties including;
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our Websites.
  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you and you have agreed to such a search being undertaken.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may also disclose your personal information where we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use of any of our Websites and online portal and other agreements; or to protect the rights, property or safety of our customers or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction.

6. International Transfers

We share your personal data within the Francotyp-Postalia Limited Group. This will involve transferring your data outside the European Economic Area (EEA).

Your personal data may also be processed by staff operating outside the EEA who work for us or one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data and providing your consent by expressly opting in (where you have ticked the relevant box situated on forms used to collect personal data) you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you require details of the retention periods for different aspects of your personal data, please contact us.

In some circumstances we will review list of customers and prospects every 12 months. Personal information of customers or prospects may be deleted if, for example, they have withdrawn their consent, are no longer in business or such personal data is incorrect or incomplete.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or you have chosen) a password which enables you to access certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share this password with anyone.

9. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of the personal data that we hold about you
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing of your personal data
  • Request the transfer of your personal data
  • Withdraw consent at any time

If you wish to exercise any of the rights set out above, please contact us by telephone on 0344 225 2233 or email us admin@fpmailing.co.uk.

Our Websites may, from time to time, contain links to and from the website of our partner networks, franchisees, advertisers and affiliates.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This

is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

11. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to 74 Powdermill Lane, Dartford, Kent, DA1 1EF or by email to admin@fpmailing.co.uk.

12. Disclaimer for Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website.

Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.

You can refuse the use of Google Analytics by clicking on the following link. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting this website: <a href=“javascript:gaOptout()“>Disable Google Analytics</a>

Further information concerning the terms and conditions of use and data privacy can be found    at http://www.google.com/analytics/terms/gb.html or at https://www.google.de/intl/en_uk/policies/. Please note that on this website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking).

Privacy Policy for the use of Google Analytics:

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. Data sent by us and linked to cookies, user IDs or advertising IDs will be kept for 14 months, after which the data will be automatically deleted. The automatic deletion of data with an expired retention period takes place once a month.

You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can view Google’s privacy policy on http://www.google.de/intl/de/policies/privacy/. Further information on terms of use and data protection can be found under http://www.google.com/analytics/terms/de.html or under http://www.google.com/intl/de/analytics/privacyoverview.html.

Privacy Policy for the use of Google Conversion Tracking:

This website also uses Google Conversion Tracking. Google Adwords places a cookie on your computer if you have reached our website via a Google ad. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the AdWords customer’s website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page. Each AdWords customer receives a different cookie. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected using the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information with which users can be personally identified. If you do not wish to participate in the tracking process, you can also refuse the setting of a cookie required for this – for example by means of a browser setting that generally deactivates the automatic setting of cookies. You can also disable cookies for conversion tracking by setting your browser to block cookies from the “googleadservices.com” domain.

Privacy statement for the use of Microsoft Bing:

Our online offers also use conversion tracking from Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). Microsoft Bing Ads places a cookie on your computer if you have reached our website via a Microsoft Bing ad. In this way, Microsoft Bing and we can recognize that someone has clicked on an ad, has been redirected to our website and has reached a previously determined landing page (conversion page). We only learn the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No personal information about the identity of the user is communicated. If you do not wish to participate in the tracking process, you can also refuse the setting of a cookie required for this – for example by means of a browser setting that generally deactivates the automatic setting of cookies. Further information on data protection and the cookies used by Microsoft Bing can be found on the Microsoft http://privacy.microsoft.com/DE-DE/fullnotice.mspx website.

13. Glossary LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract with you or your business or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Francotyp-Postalia Limited Group acting as joint controllers or processors and who are based in the UK, EU and countries outside of the EEA and provide IT and system administration services.

External Third Parties

  • Service providers acting as processors based in the UK, EU and countries outside of the EEA who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, EU and countries outside of the EEA who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • External marketing correspondence providers such as Webpost based inside the EU.
  • Our websites may contain links to other websites outside our area of responsibility to which this data protection declaration does not extend and for whose content we assume no responsibility.

YOUR LEGAL RIGHTS

If you have any questions about your personal data, you can always contact us in writing. You have the following rights under the GDPR:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You have the right to request the immediate deletion of your data (“right to be forgotten”), in particular if the storage of the data is no longer necessary, you revoke your consent to data processing, your data has been unlawfully processed or has been unlawfully collected and there is a legal obligation to delete under EU or national law.

However, the right to be forgotten does not apply if there is an overriding right to freedom of expression or freedom of information, if data storage is necessary to fulfil a legal obligation (e.g. retention obligations), if archiving purposes preclude deletion or if the storage serves to assert, exercise or defend legal claims.

The right to data portability You have the right to portability of your personal data, which you have provided to our company in the form of a common format, so that you can have your personal data forwarded to another person responsible without hindrance, provided that, for example, you have given your consent and the processing is carried out by means of an automated procedure.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You have the right to object at any time to the collection, processing or use of your personal data for the purposes of direct marketing or market and opinion research as well as general commercial data processing, unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms.

In addition, you cannot exercise your right to object if a legal provision provides for the collection, processing or use of the data or obliges it to collect, process or use it.

Right to lodge a complaint with the data protection supervisory authority You have the right to complain to the competent supervisory authority if you believe that there has been a breach in the processing of your personal data.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

The right to rectification You have the right to request the immediate rectification of your inaccurate personal data and, taking into account the purposes of the processing, to request the completion of incomplete personal data also by means of a supplementary statement. If you wish to exercise the right to rectification, you can contact our data protection officer or the controller at any time.

Right to revoke consent under data protection law You can revoke your consent to the processing of your personal data at any time and without giving reasons. This also applies to the revocation of declarations of consent that were issued to us before the EU General Data Protection Regulation came into force.

The right to information You have the right at any time to obtain information about which categories and information about your personal data are processed by us for what purpose and for how long and according to which criteria this data is stored and whether automated decision-making, including profiling, is used in this context. You also have the right to know to which recipients or categories of recipients your data have been or will be disclosed; in particular for recipients in third countries or international organisations. In this case, you also have the right to be informed of appropriate safeguards in connection with the transfer of your personal data.

In addition to the right to lodge a complaint with the supervisory authority and the right to information about the origin of your data, you have the right to deletion, correction and the right to restriction or objection to the processing of your personal data.

In all the above cases, you have the right to request from the data processor a copy of your personal data processed by us free of charge. For any further copies that you request or that go beyond the data subject’s right to information, we are entitled to charge a reasonable administrative fee.

Legal or contractual provisions for the provision of personal data and possible consequences of non-provision

We hereby point out that the provision of personal data is required by law in certain cases (e.g. tax regulations) or may result from contractual provisions (e.g. information on the contractual partner). For example, it may be necessary for the conclusion of a contract that the data subject/contractual partner must provide his personal data so that his request (e.g. order) can be processed by us at all. An obligation to provide personal data arises above all when concluding contracts. If no personal data is provided in this case, the contract with the data subject cannot be concluded. Before personal data is provided by the data subject, the data subject may contact our data protection officer or the controller. The data protection officer or the controller then clarifies to the data subject whether the provision of the required personal data is required by law or contract or is necessary for the conclusion of the contract and whether the concerns of the data subject result in an obligation to provide the personal data or the consequences of non-provision of the desired data for the data subject.

Legal basis of processing

When processing personal data for which we obtain the consent of the data subject, Article 6 (1) sentence 1 a) of the GDPR serves as the legal basis.

In the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1, sentence 1 b) GDPR serves as the legal basis. This regulation also includes processing operations necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1, sentence 1 c) GDPR serves as the legal basis.

If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Article 6 (1) sentence 1 f) (GDPR) serves as the legal basis for the processing. The legitimate interest of our company lies in the execution of our business activities as well as in the analysis, optimization and maintenance of the security of our online offer.

 

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