We are very pleased about your interest in our company. Data protection is one of the highest priorities of the management of BIENTER S.A. The use of the websites of BIENTER S.A. is possible without any indication of personal data. However, if a data subject wishes to use special services of the company via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for it, we seek the consent of the data subject.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject, must always be in accordance with the General Data Protection Regulation (GDPR), as well as with the specific national data protection regulations applicable to BIENTER S.A. Through this data protection declaration, our company would like to inform the general public about the nature, scope, and purpose of the personal data we collect, use, and process. In addition, through this data protection declaration, data subjects are informed about their rights.
As the controller, BIENTER S.A. has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through the website. However, data transmissions via the Internet may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, for example by telephone.
1. Definitions
The data protection declaration of BIENTER S.A. is based on the terms used by the European legislator for the adoption of the GDPR. Our data protection declaration should be legible and understandable for the general public, as well as for our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, among others, the following terms:
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a) Personal Data – Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
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b) Data Subject – A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
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c) Processing – Processing is any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
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d) Restriction of Processing – Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
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e) Profiling – Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
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f) Pseudonymisation – Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
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g) Controller – Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
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h) Processor – Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
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i) Recipient – Recipient means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
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j) Third Party – Third party means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
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k) Consent – Consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the Controller
Controller for the purposes of the GDPR and other data protection laws applicable in the Member States of the European Union and other provisions related to data protection is:
BIENTER S.A.
IFAISTOU 1 & KYKLADON
GLYKA NERA
GREECE
Telephone: +30 210 6619590
Email:
Website: bienter.gr
3. Cookies
The websites of BIENTER S.A. use cookies. Cookies are text files stored on a computer system via an Internet browser.
Many websites and servers use cookies. Many cookies contain what is called a cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows the visited websites and servers to distinguish the data subject’s browser from other Internet browsers that contain other cookies. A specific browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, BIENTER S.A. can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. As mentioned before, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. For example, a user of a website that uses cookies does not have to enter access data each time he or she accesses the website, because this is taken over by the website, and the cookie is therefore stored on the user’s computer system. Another example is the shopping cart in an online store: the online store remembers the items a customer placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
4. Collection of general data and information
The website of BIENTER S.A. collects a series of general data and information when a data subject or an automated system calls up the website. These general data and information are stored in the server log files. The following data may be collected:
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the browser types and versions used,
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the operating system used by the accessing system,
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the website from which an accessing system reaches our website (the so-called referrer),
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the sub-websites,
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the date and time of access to the Internet site,
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an Internet protocol address (IP address),
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the Internet service provider of the accessing system, and
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any other similar data and information that may be used in the event of attacks on our IT systems.
When using these general data and information, BIENTER S.A. does not draw any conclusions about the data subject. Rather, this information is needed to:
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deliver the content of our website correctly,
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optimize the content of our website as well as its advertising,
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ensure the long-term viability of our IT systems and website technology, and
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provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
Therefore, BIENTER S.A. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for his own purposes. The controller may request the transfer to one or more processors (for example, a parcel service) that also uses personal data for an internal purpose attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of these data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. In this respect, the storage of this data is necessary to secure the controller. These data are not passed on to third parties unless there is a statutory obligation to pass them on, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject content or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.
6. Subscription to our newsletters
On the website of BIENTER S.A., users are given the opportunity to subscribe to the newsletter of our enterprise. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
BIENTER S.A. informs its customers and business partners regularly by means of a newsletter about enterprise offers. The company’s newsletter may only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter delivery. A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter delivery, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove whether the owner of the email address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of a data subject’s email address at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for newsletter delivery, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
7. Newsletter Tracking
The newsletter of BIENTER S.A. contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails that are sent in HTML format to enable log file recording and analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, BIENTER S.A. may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the newsletter delivery, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double opt-in procedure. After a revocation, these personal data will be deleted by the controller. BIENTER S.A. automatically regards a withdrawal from the receipt of the newsletter as a revocation.
8. Contact possibility via the website
The website of BIENTER S.A. contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
9. Comment function in the blog on the website
BIENTER S.A. offers users the possibility to leave individual comments on individual blog posts on a blog which is on the website of the controller. A blog is a web-based, publicly accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blog posts. Blog posts may usually be commented on by third parties.
If a data subject leaves a comment on the blog published on this website, the comments made by the data subject are also stored and published, as well as information on the date of the comment and on the user’s chosen pseudonym. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged.
The storage of the IP address takes place for security reasons, and in case the data subject violates the rights of third parties, or posts illegal content through a given comment. The storage of these personal data is, therefore, in the own interest of the controller, so that he can exculpate himself in the event of an infringement. These collected personal data will not be passed to third parties unless such a transfer is required by law, or serves the aim of the defense of the controller.
10. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
11. Rights of the Data Subject
a) Right to Confirmation
Every data subject has the right, granted by the European legislator, to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If the data subject wishes to exercise the right to confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of Access
Every data subject has the right, granted by the European legislator, to obtain free information at any time from the controller regarding personal data stored about them and to receive a copy of that information. Furthermore, European Directives and Regulations grant the data subject the right of access to the following information:
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the purposes of processing,
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the categories of personal data concerned,
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the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations,
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where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period,
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the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing,
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the right to lodge a complaint with a supervisory authority,
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where the personal data are not collected from the data subject, any available information as to their source,
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the existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4), and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
In addition, the data subject has the right to be informed whether personal data are transferred to a third country or international organization. In such cases, the data subject has the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise the right of access, he or she may, at any time, contact an employee of the controller.
c) Right to Rectification
Every data subject has the right, granted by the European legislator, to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. If the data subject wishes to exercise this right, he or she may, at any time, contact an employee of the controller.
d) Right to Erasure (“Right to be Forgotten”)
Every data subject has the right, granted by the European legislator, to request from the controller the erasure of personal data concerning them without undue delay, and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies, as long as processing is not necessary:
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The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
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The data subject withdraws consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and where there is no other legal ground for the processing.
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The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
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The personal data have been unlawfully processed.
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The personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject.
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The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
If one of the above applies and the data subject wishes to have personal data erased that is stored by BIENTER SA, he or she may contact an employee of the controller at any time. Every employee of BIENTER SA shall ensure that the request for erasure is complied with immediately.
Where the controller has made the personal data public and is obliged under Article 17(1) GDPR to erase the personal data, the controller, taking account of available technology and implementation cost, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, to the extent that processing is not required. An employee of BIENTER SA will ensure that appropriate measures are taken in each individual case.
e) Right to Restriction of Processing
Every data subject has the right, granted by the European legislator, to obtain restriction of processing from the controller where one of the following applies:
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The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
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The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
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The controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
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The data subject has objected to processing pursuant to Article 21(1) GDPR pending verification of whether the legitimate grounds of the controller override those of the data subject.
If one of these conditions applies and the data subject wishes to request restriction of processing of personal data stored by BIENTER SA, he or she may, at any time, contact an employee of the controller. Every employee of BIENTER SA shall ensure that the request for restriction is complied with immediately.
f) Right to Data Portability
Every data subject has the right, granted by the European legislator, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, insofar as processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising the right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where it does not adversely affect the rights and freedoms of others. In order to exercise the right to data portability, the data subject may contact an employee of BIENTER SA at any time.
g) Right to Object
Every data subject has the right, granted by the European legislator, to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. BIENTER SA shall no longer process the personal data in the event of an objection, unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.
Where BIENTER SA processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent related to such direct marketing. If the data subject objects to BIENTER SA to the processing for direct marketing purposes, BIENTER SA will no longer process the personal data for these purposes.
Additionally, for reasons relating to their particular situation, the data subject has the right to object to the processing of personal data concerning them by BIENTER SA for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact employees of BIENTER SA at any time. Moreover, the data subject is free, in the context of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.
h) Automated Individual Decision-Making, Including Profiling
Every data subject has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller; or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the rights, freedoms, and legitimate interests of the data subject; or (3) is based on the data subject’s explicit consent.
If the decision (1) is necessary for a contract, or (2) is based on explicit consent, BIENTER SA shall implement suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.
If the data subject wishes to exercise the rights concerning automated decision-making, they may contact an employee of BIENTER SA at any time.
i) Right to Withdraw Consent
Every data subject has the right, granted by the European legislator, to withdraw consent to processing of their personal data at any time. If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact an employee of BIENTER SA.
The following sections (12, 13) describe data protection provisions related to the use of Facebook and Google Analytics. They essentially explain:
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what Facebook and Google Analytics do,
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what kind of data is collected,
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how cookies work,
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how users can prevent or object to tracking,
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and links to official privacy policies for further information.
12. Data Protection Provisions Concerning the Application and Use of Facebook
On this website, the controller has integrated components of the company Facebook. Facebook is a social network.
A social network is an online meeting place, a virtual community, that typically allows users to communicate and interact with each other in a digital environment. A social network can serve as a platform for sharing opinions and experiences, or it may allow the online community to provide personal or business-related information. Facebook enables users of the social network to create private profiles, upload photos, and establish connections through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
When accessing any page of this website operated by the controller into which a Facebook component (Facebook plug-in) has been integrated, the internet browser of the data subject’s IT system is automatically prompted to download a display of the corresponding Facebook component from Facebook itself. A list of all Facebook plug-ins can be found at: https://developers.facebook.com/docs/plugins/. During this technical process, Facebook is informed of which specific subpage of our website was visited by the data subject.
If the data subject is logged in to Facebook at the same time, Facebook detects with each visit to our website by the data subject – and for the entire duration of their stay on our website – which specific subpage was visited. This information is collected by the Facebook component and is associated by Facebook with the data subject’s respective Facebook account. If the data subject clicks on one of the Facebook buttons integrated into our website, such as the “Like” button, or submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores this personal data.
Facebook always receives information, via the Facebook component, that the data subject has visited our website whenever the data subject is logged in to Facebook during the visit to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desired by the data subject, he or she can prevent this by logging off from their Facebook account before accessing our website.
The data protection guidelines published by Facebook, available at https://facebook.com/about/privacy/, provide information on the collection, processing, and use of personal data by Facebook. They also explain the options Facebook offers to protect the privacy of the data subject. Additionally, different configuration settings are made available to allow the termination of data transmission to Facebook. These applications can be used by the data subject to stop the transfer of data to Facebook.
13. Data Protection Provisions Concerning the Application and Use of Google Analytics (with Anonymization Function)
On this website, the controller has integrated the component Google Analytics (with anonymization function). Google Analytics is a web analytics service. Web analytics involves the collection, gathering, and evaluation of data on the behavior of visitors to websites. A web analytics service collects, among other things, data on the website from which a person arrived at another website (the so-called referrer), which subpages were accessed, how often, and for what duration a subpage was viewed. Web analytics is mainly used to optimize a website and to carry out a cost-benefit analysis of internet advertising.
The company operating Google Analytics is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
For web analytics through Google Analytics, the controller uses the application “_gat._anonymizeIp”. By means of this application, the IP address of the internet connection of the data subject is shortened and anonymized by Google when accessing our website from a Member State of the European Union or another contracting state to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is the analysis of visitor traffic on our website. Google uses the data and information collected, among other things, to evaluate the use of our website, to compile online reports showing activities on our websites, and to provide other services relating to the use of our website.
Google Analytics places a cookie on the data subject’s IT system. (The definition of cookies is provided earlier in this document.) By setting the cookie, Google is enabled to analyze the use of our website. With each call-up of one of the individual pages of this website that is operated by the controller and on which a Google Analytics component is integrated, the internet browser on the data subject’s IT system is automatically prompted to transmit data to Google for the purpose of online analysis. During the course of this technical procedure, Google gains knowledge of personal data, such as the IP address of the data subject, which serves, among other things, to help Google understand the origin of visitors and clicks, and subsequently to calculate commissions.
Cookies are used to store personal information, such as the time of access, the location from which access was made, and the frequency of visits to our website by the data subject. With each visit to our website, such personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through this technical process to third parties.
The data subject may, as mentioned above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the internet browser used, thereby permanently denying the setting of cookies. Such an adjustment to the internet browser would also prevent Google Analytics from setting a cookie on the data subject’s IT system. In addition, cookies already set by Google Analytics may be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the possibility of objecting to a collection of data generated by Google Analytics related to the use of this website, as well as to the processing of this data by Google, and the possibility of preventing such. For this purpose, the data subject must download and install a browser add-on via the link: https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics, via JavaScript, that data and information about website visits may not be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the IT system of the data subject is later deleted, formatted, or reinstalled, the data subject must reinstall the browser add-on to disable Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or any other person with access to the system, it is possible to reinstall or reactivate it.
Further information and Google’s applicable data protection provisions can be found at:
Google Analytics is further explained at the following link: https://www.google.com/analytics/
14. Data protection provisions regarding the application and use of Google Remarketing
On this website, the controller has integrated Google Remarketing services.
Google Remarketing is a feature of Google AdWords that allows a business to display advertising to internet users who have previously visited the business’s website.
The integration of Google Remarketing therefore enables the business to create user-specific ads and to show relevant advertising to internet users.
The company managing Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Remarketing is the insertion of interest-based advertising. Google Remarketing allows us to display advertising within the Google network or on other websites, based on the individual’s preferences and the interests of internet users.
Google Remarketing places cookies on the data subject’s IT system. (The definition of cookies has been provided above.) Through the use of cookies, Google can recognize a visitor to our website whenever they visit consecutively different websites that are also members of Google’s advertising network.
Whenever a page with Google Remarketing services integrated is accessed, the data subject’s browser is automatically recognized by Google.
During this technical process, Google receives personal data such as the IP address or browsing behavior of the data subject, which Google uses, among other things, to deliver interest-based advertising.
Cookies are used to store personal data, such as the websites visited by the data subject. Each time our website is visited, personal data — including the IP address used by the data subject — is transmitted to Google in the United States of America. These personal data are stored by Google in the USA. Google may also transfer these personal data, collected through this technical process, to third parties.
The data subject may, as mentioned above, prevent the setting of cookies by our website at any time by adjusting the internet browser settings used, thereby permanently denying the setting of cookies. Such a browser adjustment would also prevent Google from placing a cookie on the IT system of the data subject. Furthermore, cookies already in use by Google may be deleted at any time via the internet browser or other software programs.
In addition, the data subject has the option to object to Google’s interest-based advertising. For this purpose, the data subject must use the link www.google.de/settings/ads and adjust the settings for each internet browser they use.
Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.com/intl/en/policies/privacy/.
15. Data protection provisions regarding the application and use of Google AdWords
On this website, the controller has integrated Google AdWords.
Google AdWords is an online advertising service that allows an advertiser to place ads in Google’s search engine results and in the Google advertising network.
Google AdWords allows an advertiser to predefine keywords, by means of which an ad will be displayed in Google’s search results only when the user uses the search engine to retrieve results relevant to the keyword. In the Google advertising network, the ads are distributed on relevant websites using an automatic algorithm, taking into account the predefined keywords.
The company operating Google AdWords is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google AdWords is the promotion of our website by including relevant advertising on third-party websites and in Google’s search engine results, and the placement of third-party advertising on our website.
If a data subject accesses our website via a Google ad, a conversion cookie is placed on the IT system of the data subject by Google. (The definition of cookies has been provided above.) A conversion cookie loses its validity after 30 days and is not used for the identification of the data subject.
If the cookie is still valid, it is used to check whether specific sub-pages, such as the shopping cart of an online shop system, were accessed on our website. Through the conversion cookie, both Google and the controller can determine whether a person who accessed an AdWords ad on our site completed or canceled a purchase.
The data and information collected through the use of conversion cookies are used by Google to compile visit statistics for our website. These visit statistics are then used to determine the total number of users who were served through AdWords ads, to verify the success or failure of each AdWords ad, and to optimize AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google by which the data subject could be identified.
The conversion cookie stores personal information, such as the websites visited by the data subject. Each time our website is visited, personal data — including the IP address used by the data subject to access the internet — is transmitted to Google in the USA. These personal data are stored by Google in the USA. Google may transfer these personal data collected through this technical process to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by adjusting the web browser used, and thus permanently deny the setting of cookies. Such an adjustment would also prevent Google from placing a conversion cookie on the data subject’s IT system. In addition, cookies already used by Google AdWords can be deleted at any time via the internet browser or other software programs.
The data subject has the possibility to object to Google’s interest-based advertising. For this purpose, the data subject must access www.google.de/settings/ads from each internet browser they use and set the preferences accordingly.
Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.com/intl/en/policies/privacy/.
16. Data protection provisions regarding the application and use of Instagram
On this website, the controller has integrated components of Instagram.
Instagram may be regarded as an audiovisual platform, which allows users to share photos and videos, as well as to disseminate such data on other social networks.
The operating company of Instagram’s services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each visit to one of the individual pages of this website, managed by the controller, and on which an Instagram component (the “Insta button”) has been integrated, the internet browser on the data subject’s IT system automatically downloads a representation of the Instagram component. During this technical process, Instagram becomes aware of which specific sub-page of our website was visited by the data subject.
If the data subject is logged into Instagram at the same time, Instagram detects with every visit to our website by the data subject — and throughout the duration of their stay on our site — which specific sub-page they visited. This information is collected through the Instagram component and is associated with the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated into our site, Instagram matches this information with the personal Instagram account of the data subject and stores the personal data.
Instagram receives information via the Instagram component about the visit of the data subject to our website, provided that the data subject is logged in to Instagram at the time of visiting our site. This occurs regardless of whether the person clicks on the Instagram icon or not.
If the data subject does not wish to transmit such information to Instagram, they can prevent this by logging out of their Instagram account before visiting our website.
Further information and Instagram’s applicable data protection provisions can be found at:
17. Data protection provisions regarding the application and use of LinkedIn
The controller has integrated components of LinkedIn Corporation into this website.
LinkedIn is an internet-based social network that enables users with existing business contacts to connect and to establish new business contacts. More than 400 million registered individuals in over 200 countries use LinkedIn, making it the largest business contact platform and one of the most visited websites in the world.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. For privacy matters outside the United States, responsibility lies with LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
With each visit to an individual page of this website that has a LinkedIn component (LinkedIn plugin) integrated, the internet browser on the data subject’s IT system automatically downloads a display of the LinkedIn component. Further information about LinkedIn plugins can be found at https://developer.linkedin.com/plugins. During this technical process, LinkedIn learns which specific sub-page of our website was visited by the data subject.
If the data subject is logged into LinkedIn at the same time, LinkedIn detects with each visit to our website by the data subject — and for the entire duration of their stay on our site — which specific sub-page was visited. This information is collected via the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated into our website, LinkedIn assigns this information to the personal LinkedIn account of the data subject and stores the personal data.
LinkedIn receives information via the LinkedIn component that the data subject visited our website, provided that the data subject is logged into LinkedIn at the time of visiting our site. This occurs regardless of whether the person clicks on the LinkedIn icon or not.
If the data subject does not wish this information to be transmitted to LinkedIn, they can prevent it by logging out of their LinkedIn account before accessing our site.
LinkedIn provides the possibility to unsubscribe from email messages, SMS messages, and targeted ads via https://www.linkedin.com/psettings/guest-controls, as well as the option to manage advertising preferences. LinkedIn also uses partners such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. Placement of such cookies can be denied via https://www.linkedin.com/legal/cookie-policy.
The applicable privacy policy of LinkedIn is available at https://www.linkedin.com/legal/privacy-policy.
LinkedIn’s Cookie Policy is available at https://www.linkedin.com/legal/cookie-policy.
18. Data protection provisions regarding the application and use of Pinterest
On this website, the data controller has integrated components of Pinterest Inc. Pinterest is a social network. A social network is an online social meeting place, a virtual community that allows users to communicate and interact with each other in a digital space. Such a network serves as a platform for exchanging opinions and experiences, or enables the online community to share personal and corporate information.
Pinterest allows users of its social network to publish, among other things, collections of pictures and individual images, as well as descriptions on digital notice boards (so-called pins), which can then be shared further (re-pins) or commented on by other users.
The company operating Pinterest is Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.
Whenever a user accesses an individual page of this website that is operated by the data controller and on which a Pinterest component (Pinterest plug-in) has been integrated, the internet browser on the user’s information system automatically downloads a display of the corresponding Pinterest component. More information on Pinterest is available at https://pinterest.com/. During this technical process, Pinterest learns which subpages of our website were visited by the user.
If the user is simultaneously logged in to Pinterest, then Pinterest recognizes – with each access to our website and for the entire duration of the user’s stay – which specific subpage of our website the user visits. This information is collected via the Pinterest component and is associated with the user’s Pinterest account. If the user clicks on the Pinterest icon integrated into our website, Pinterest links this information to the user’s personal Pinterest account and stores the personal data.
Pinterest receives information through the Pinterest component that the user has visited our website, provided the user is logged in to Pinterest at the time of visiting our site. This occurs regardless of whether the person clicks on the Pinterest icon or not. If the user does not wish this information to be transmitted to Pinterest, he or she can prevent this by logging out of their Pinterest account before accessing our website.
Pinterest’s privacy policy, available at https://about.pinterest.com/privacy-policy, provides information about the collection, processing, and use of personal data by Pinterest.
19. Data protection provisions regarding the application and use of Twitter
On this website, the data controller has integrated components of Twitter. Twitter is a multilingual, publicly available microblogging service where users may publish and disseminate so-called “tweets,” i.e., short messages limited to 280 characters. These short messages are available to anyone, including those not logged in to Twitter. Tweets are also displayed to the so-called followers of the respective user. Followers are Twitter users who follow the tweets of other users. In addition, Twitter allows users to address a wider audience through hashtags, links, or retweets.
The company operating Twitter is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.
Whenever a user accesses a subpage of this website operated by the data controller on which a Twitter component (Twitter icon) has been integrated, the internet browser on the user’s information system automatically downloads a presentation of the corresponding Twitter component. Learn more about available Twitter buttons at https://about.twitter.com/de/resources/buttons. During this technical process, Twitter learns which subpages of our website the user visited. The purpose of integrating the Twitter component is to enable the redistribution of our website’s content, so that our users can recommend our website in the digital world and thereby increase visitor numbers.
If the user is logged in to Twitter, Twitter detects – with each access to our website and throughout their stay – which specific subpages of our website the user visits. This information is collected via the Twitter component and associated with the user’s Twitter account. If the user clicks on the Twitter icon integrated into our website, Twitter links this information with the user’s personal Twitter account and stores the personal data.
Twitter receives information through the Twitter component that the user has visited our website, provided the user is logged in to Twitter at the time of visiting. This occurs regardless of whether the person clicks on the Twitter icon or not. If the user does not wish this transmission of information to Twitter, he or she can prevent it by logging out of their Twitter account before visiting our website.
Twitter’s applicable privacy provisions are available at https://twitter.com/privacy?lang=en.
20. Data protection provisions regarding the application and use of YouTube
On this website, the data controller has integrated components of YouTube. YouTube is an online video portal that allows video publishers to set up video clips free of charge and enables other users to view, evaluate, and comment on them free of charge. YouTube allows the publication of all types of videos, so users can view full movies, TV broadcasts, music videos, trailers, and user-produced videos via the portal.
The company operating YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
Whenever a user accesses a subpage of this website operated by the data controller and on which a YouTube component (a YouTube video) has been integrated, the internet browser on the user’s information system is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube can be found at https://www.youtube.com/yt/about/en/. During this technical process, YouTube and Google gain knowledge of which specific subpages of our website were visited by the user.
If the user is simultaneously logged in to YouTube, then with each access to a subpage containing a YouTube video, YouTube recognizes which specific subpage of our website the user has visited. This information is collected by YouTube and Google and associated with the user’s YouTube account.
YouTube and Google receive information through the YouTube component that the user has visited our website, provided the user is logged in to YouTube at the same time. This happens regardless of whether the person clicks on a YouTube video or not. If the user does not wish such transmission of information to YouTube and Google, the user can prevent this by logging out of their YouTube account before accessing our website.
The data protection provisions published by YouTube, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing, and use of personal data by YouTube and Google.
21. Method of payment: Data protection provisions for the use of PayPal in payment processing
On this website, the data controller has integrated components of PayPal. PayPal is an online payment service provider. Payments are made via so-called PayPal accounts, which represent digital private or business accounts. PayPal may also process online payments via credit card if the user does not have a PayPal account. A PayPal account is managed through an email address, which replaces the traditional account numbers you may be familiar with. PayPal makes it possible to accept payments or to make online payments to third parties. PayPal also functions as a trustee and provides buyer protection services.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg.
If the data subject chooses “PayPal” as a payment method in our online shop during the ordering process, their data are automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transmission of personal data required for the processing and execution of the payment.
The personal data transmitted to PayPal usually include first name, last name, address, date of birth, gender, email address, IP address, telephone number, and other data necessary for payment processing. In addition, data required for fulfilling the payment agreement, such as information about the order, are also transmitted.
The transmission of data serves the purpose of payment processing and the prevention of fraud. The data controller will transmit personal data to PayPal where there is a legitimate interest in doing so. Personal data exchanged between PayPal and the data controller may be transferred by PayPal to credit reporting agencies. The purpose of this transfer is identity and creditworthiness checks.
If necessary, PayPal may also transmit personal data to affiliated companies, service providers, or subcontractors to the extent this is required to fulfill contractual obligations or to process the order.
The data subject has the option to revoke their consent to the processing of personal data by PayPal at any time. Such a revocation does not affect personal data that must be processed, used, or transmitted for contractual payment processing.
PayPal’s applicable privacy provisions can be accessed at: https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
22. Legal basis for processing
Article 6(1)(a) of the General Data Protection Regulation (GDPR) serves as the legal basis for processing operations for which we obtain consent for a specific purpose.
If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, such as when processing is required for the supply of goods or the provision of a service, the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations necessary for carrying out pre-contractual measures, for example, in cases of inquiries concerning our products or services.
If our company is subject to a legal obligation requiring the processing of personal data, such as fulfilling tax obligations, the processing is based on Article 6(1)(c) GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third party. In that case, processing would be based on Article 6(1)(d) GDPR.
Finally, processing operations may be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations not covered by any of the above, where processing is necessary for the legitimate interests of our company or a third party, provided these interests are not overridden by the interests, fundamental rights, or freedoms of the data subject requiring the protection of personal data. Such processing operations are expressly permitted by the European legislator. A legitimate interest is deemed to exist where the data subject is a client of the controller (Recital 47, sentence 2 GDPR).
23. Legitimate interests pursued by the controller or a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the pursuit of our business activities for the benefit of the well-being of all our employees and shareholders.
24. Period for which personal data will be stored
The criteria used to determine the period of storage of personal data is the statutory retention period. After the expiry of this period, the corresponding data are routinely deleted, provided they are no longer necessary for the performance or initiation of a contract.
25. Provision of personal data as a legal or contractual requirement – Requirement necessary to enter into a contract – Obligation of the data subject to provide personal data – Possible consequences of failure to provide such data
We clarify that the provision of personal data may, in part, be required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information to the contractual partner). Sometimes it may be necessary, in order to conclude a contract, that the data subject provides us with personal data which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.
Before providing personal data, the data subject must contact one of our employees. The employee will clarify whether the provision of personal data is legally or contractually required, or necessary for the conclusion of the contract, whether there is an obligation to provide the data, and the consequences of failing to provide the data.
26. Automated decision-making processes
As a responsible company, we do not use automated decision-making or profiling.
