1. General Information
The safety and the secrecy of your own personal information are of the utmost importance to us. In this document, we shall explain how your personal data is handled and processed by our company, as well as which measures are taken in order to ensure the maximum level of user privacy on this website. All of the data which is submitted through this website is handled with the highest confidentiality, pursuant to the directives listed in the General Data Protection Regulation (GDPR) and in accordance with the specific national data protection regulations, such as the Bundesdatenschutzgesetz neu (BDSG neu) or the Telemediengesetz (TMG). The processing of the abovementioned data may occur either due to your own personal consent in compliance with GDPR Art. 6, 1a, due to performance or initiation of a contract in compliance with GDPR Art. 6, 1b, due to legal obligations we may undergo in compliance with GDPR-Art. 6, 1c, or due to the defence of any legitimate interests on our part in compliance with GDPR-Art. 6, 1f.
2. Responsible Data Processing Body
German eTrade GmbH
Phone: +49 351 89 570 300
For any questions, suggestions, or comments please contact:
External Data Protection Officer
PRODATIS CONSULTING AG
Phone: +49 351 266 23 30
3. Submission and Processing of Personal Data
‘Personal data’ means any information related 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.
‘Processing’ means 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
The personal data you submit via our website is only processed in order to communicate with you and to accomplish the purposes for which you made the information available to us in the first place.
With each access to our website, our system automatically stores information transmitted by your internet browser during your activity on our website. Such information is only stored temporarily and, should certain content be downloaded from our website, it leaves a trace in a specific log file. More specifically, the following information is stored with every access / download:
- IP address
- Date and time of access
- Accessed page / name of the downloaded file
- Internet browser and requesting domain
- Volume of the transferred data
- Report about the successfulness of the access
The data is processed in compliance with GDPR Art. 6, 1f complying with our legitimate interest in improving and stabilising our website’s functionality. The transfer and disclosure of personal data or its use in any other context is absolutely excluded. We reserve ourselves the right, though, to refer to our server log files in case they may contain evidence leading to the exposing of illegal activity.
4. Newsletter Policy
If you consent to receiving our newsletter, your e-mail address will be used for our marketing purposes until you express your will to revoke that permission. In order to customise newsletters, it is possible to voluntarily enter title, first and / or last name upon registration. Such newsletter registration is completely reversible and can be cancelled at any moment via the ‘unsubscribe’ link provided in every newsletter issue. Alternatively, you can unsubscribe from all future issues of our newsletter without any additional costs other than those linked to the forwarding of your request (phone call, mobile data traffic, etc.):
Phone: +49 351 89 570 300
5. Use and Transfer of Personal Information
The personal data (i.e. first name, last name, phone number, address, e-mail address) provided by you via the contact form is used in order to communicate with you, for the processing of your requests, or for any other purpose you made the information available to us for in the first place.
Any other use of your personal data is excluded, except in utterly anonymous form for statistical analysis only.
As we may employ external providers for the fulfilment of our services, the resulting contractual relationship is established in compliance with the already mentioned European General Data Protection Regulation (GDPR) and Bundesdatenschutzgesetz neu (BDSG neu). This applies for the following categories of recipients:
- IT contractors in their function of ensuring safety and secrecy
- Financial service providers for the processing of transactions and ensuring adherence to the related legal regulations
- Logistics service providers
- External suppliers in case of direct shipment
We may share anonymous data with our partners, for the performance of statistical analysis. Our partners are not allowed to make any use of your data which is not strictly relevant to our offers and services.
6. User Registration and Placing Orders in our Online Shop
We collect and process your personal data in order to allow transactions on our Online Shop, so that you may be able to purchase our products and services as well as in order for payment and delivery to be completed successfully. The personal data we collect contains information such as first and last name, date of birth, billing and shipping addresses, phone number, e-mail address and chosen method of payment. Said data is thus transferred to our system after being encrypted and, if necessary, is securely forwarded to our commercial partners, such as financial and logistics service providers.
On our website, it is possible to create an account with personal information. The resulting registration has the only purpose of offering a better user experience to our customers, allowing improved pre-purchase support, as well as an easy fulfilment and billing of the contract. Should you request the termination of your customer account, the whole data present in it will be deleted, unless legal obligations pertaining business, taxation and or management issues have to be considered.
Our Online Shop uses session cookies for the correct listing of the products in the shopping basket, as well as permanent cookies for the monitoring of the log-in status. We only transfer your data to third parties to allow shipping and billing processes, or in case of legal obligations towards legal representatives and institutions. Data transfer to third countries is only admissible when necessary in compliance with the fulfilment of the contract.
7. Storage Period of your Personal Data
The personal information submitted via our website is stored for no longer than the time needed for the purpose it was submitted for in the first place. In case legal obligations in regard to business, taxation and or management issues have to be considered, retention periods range from 6 up to 10 years.
8. Your Data Protection Rights
As ‘subject’ whose data we process, you are granted a number of rights by the European General Data Protection Regulation. You have the right to be informed about which data is being processed and for which purpose, as well as about the categories of the processed data, about the recipients and / or recipient categories who were allowed access to your information, about the planned storage period of your data and the criteria used to determine said period. Should you decide to withdraw your consent regarding the processing and / or the storage of your personal data, or should your data be incorrect, you have the right to its deletion, processing limitation, or rectification. Upon your request, we will delete your personal data, reduce the extent of its processing, or perform the necessary corrections, provided that it all complies with the norms in force at that given moment. Moreover, you have the right to withdraw your consent for any future processing of your data, as well as the right to its transferability and the right of complaint at the pertaining supervisory authority.
9. Data Encryption
We use state-of-the-art encryption methods (e.g. SSL) on HTTPS, in order to protect the privacy of your personal data during its transfer.
11. Use of Script Libraries – Google Webfonts
In order for our website content to be displayed in a correct and appealing fashion on the wide variety of internet browsers, we use script and font libraries such as Google Webfonts (https://www.google.com/webfonts/). Google Webfonts are used to avoid multiple loading instances in the cache of your internet browser. In case Google Webfonts are not supported or accessible by your internet browser, the written content of our website will be shown using a standard font.
With every access to script and font libraries, a connection to the provider of these services is established automatically and it is thus possible that the provider might collect data. Whether this actually happens and for which purposes are matters of pure speculation, though.
At the following link you will find the Data Protection Policy of the library provider (Google): https://www.google.com/policies/privacy/
12. Use of Google Analytics
Our website uses Google Analytics, a web analysis service by Google Inc. (Google). Google Analytics uses ‘cookies’, text files which are stored locally in the visitor’s internet browser, thus allowing the analysis of the website to take place throughout your visit. The information about your visit on the website is collected through a dedicated cookie and is generally transferred and stored into a Google Server located in the USA. The IP address resulting from your internet browser is not associated to any other data by Google. On our website, we implemented the code ‘anonymizeIP’ for Google Analytics, thus ensuring the secrecy of your IP address. This way, only anonymous data can be collected. Only in exceptional cases the whole IP address is transferred to the Google Servers in the USA, where it is in any case abridged.
On behalf of our website provider, Google will analyse your experience on the website via the collected information, as well as creating reports about the general website activity and providing other services related to the use of the website and / or the Internet, which may be possibly requested by the operator of the website.
It is possible to deactivate cookies via an option provided by your internet browser, we have to inform you, though, that in this case the use of our website may be subject to some limitations. It is possible to deactivate the acquisition of the data stored in the cookie during your activity on the website (including your IP address), thus preventing it from being gathered and analysed by Google. To do so, you need to download and install the following plug-in available at this address: https://tools.google.com/dlpage/gaoptout?hl=en . As an alternative, especially for internet browsers operating on smartphones and tablets, it is possible to disable the data acquisition process by Google Analytics simply by clicking on the same link. An ‘opt-out cookie’ will be created, which will prevent any further gathering of your data on every future access to this website. The opt-out cookie will only be valid for the current internet browser and solely for our website. It will be stored in your device, so if you delete cookies from your internet browser, the opt-out cookie will have to be created again.
We use Google Analytics to analyse data from Double Click cookies and AdWords, for statistical purposes. If you do not wish to consent to this use, you can deactivate this option in the ad-preferences menu (http://www.google.com/settings/ads/onweb/?hl=en)
13. Google AdWords Conversion Tracking
Our websites use the online marketing programme Google AdWords for the analysis of user activity, here mentioned as ‘Google AdWords Conversion Tracking’ as well. This service is provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; ‘Google’).
If you click on a Google generated ad, a conversion tracking cookie will be stored in your computer. These particular cookies have a limited validity and do not contain any personal data, nor can they be used to identify users in any way.
If you are forwarded to one of our websites by one of those ads and the cookie in your browser has not expired, Google and we will be informed that you have clicked on the ad and have thus been redirected to our website.
The use of all information gathered via Google AdWords conversion cookies is limited to statistical purposes only.
You can deactivate targeted advertising by modifying the related settings for Google. If you are unsure about how to do this, you can find a quick guide at the following link: https://support.google.com/ads/answer/2662922?hl=en
14. Bing Ads Conversion Tracking
Our websites use conversion tracking by Microsoft (Microsoft Corporation, 1 Microsoft Way, Redmond WA 98052-6399, USA). A cookie by Microsoft Bing Ads will be stored on your computer for this purpose, provided that you were redirected to our website via a Microsoft Bing ad. In this way, Microsoft Bing and we will be notified that a user clicked on the ad, was redirected to our website, and visited a certain webpage. We only receive information about the total number of users who click on the ad and are afterwards redirected to the conversion website. No personal information about the identity of the user is transmitted.
If you do not consent to Microsoft using said information in the way mentioned above, you can disable the storage of the related cookie –you can deactivate the option for the automatic storage of cookies in your internet browser settings. Furthermore, it is possible to deactivate the acquisition of the data stored in the cookie during your activity on the website, thus preventing it from being gathered and analysed by Microsoft. You can do so by following the instructions available at this link: http://choice.microsoft.com/en-us/opt-out. More information about data protection, as well as about Microsoft and Bing Ads cookies, can be found on Microsoft’s website at: https://privacy.microsoft.com/en-us/privacystatement.
15. Embedded YouTube Videos
We embed YouTube videos on our website. The plug-in related to the visualization of such videos is provided by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
Whenever you access a website containing a YouTube plug-in, your internet browser establishes a direct connection with the YouTube servers, thus notifying YouTube about the website you are currently visiting. YouTube can associate your website activity to your personal profile, if you are currently logged in your YouTube account (Google account). This can be avoided by simply logging off of your YouTube account (Google account).
If you play a YouTube video on our website, Google automatically stores cookies to gather information about online user behaviour. Should you have already disabled the acceptance of cookies for the Google Ad software, no such cookies will obviously be stored, although YouTube might collect usage information in anonymous form via other additional cookies. If you wish to disable the storage of cookies altogether, you can do so by changing your internet browser settings.
16. Tailored Advertising
Our website uses the remarketing feature in Google AdWords with cross-device functions, such as Google DoubleClick. This way, users of our website may be shown ads relevant to their interests on websites which are part of the Google network, such as Google Ads in the Google search engine or on other third-party websites. For this purpose, your activity on our website (e.g. the products you clicked on) is analysed, in order to display tailored ads on other websites after you have visited ours. In order to provide this service, Google stores cookies which gather the necessary data for the identification of the specific internet browser running on the specific computer accessing the website; the collection of said data is completely unrelated to the hypothetical purpose of revealing the user’s personal identity.
The gathered data might be transmitted to servers in USA territory, however, a valid Adequacy Decision by the European Commission is available for data transfers to the USA.
You can deactivate the cross-device remarketing function via Google, by downloading and installing the related plug-in provided by Google at: www.google.com/settings/ads/plugin, or by changing the respective settings at: https://www.google.com/settings/ads/onweb/.
17. Use of Social Media Plug-ins
We use plug-ins from different social networks on our websites. With every access to one of our websites, those plug-ins allow the transmission of data to the servers of the respective provider, such as your IP address, the pages of our website you visited or are currently visiting, etc. As we have no influence whatsoever about the collecting, storing and processing of the data gathered through these plug-ins, we forward you to the data protection policies of the single providers, available at the following links :
- Google https://policies.google.com/privacy?hl=en
- Instagram https://help.instagram.com/
- Twitter https://twitter.com/en/privacy
- Facebook https://en-us.facebook.com/policy.php
In order to avoid that the plug-in providers directly associate your social media accounts to said collected data, we suggest you log out from their websites before you access ours.
18. Use of Facebook Plug-ins and Components
This website uses Social Plug-ins (plug-ins) from the social network ‘Facebook’, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (Facebook). Those plug-ins are marked with the Facebook logo or with the label ‘Facebook Social Plug-in’. At the following link, you can find an overview of the different Facebook plug-ins and their appearance: http://developers.facebook.com/plugins.
Each time you access one of our websites containing such a plug-in, your internet browser establishes a direct connection with the Facebook servers. The content of the plug-in is transmitted to your internet browser and then integrated in the website. Through the integration of the plug-in, Facebook receives a notification related to your access to the specific page of our website you visited, even if you have no Facebook account or are currently logged off. This information (including your IP address) is transmitted directly by your internet browser to a Facebook server in the USA, where it is also stored. If you are currently logged in on Facebook, this can associate your visit to our website to your Facebook account. If you interact with those plug-ins, e.g. by clicking on the ‘Like’ button or by writing a comment, the related information will directly be transmitted to a Facebook server, where it will also be stored. The resulting information will be published on Facebook and shown to your Facebook friends. Facebook may use this information for advertisement, market research and for the tailoring of your Facebook feed. Use, interest and correlation profiles are then created, in order to analyse the peculiarities of your access to our website on the background of the ads integrated by Facebook in your personal feed, as well as to inform other Facebook users about your activity on our website and to provide other Facebook-related services.
If you do not want Facebook to associate the data gathered on our website to your Facebook account, we recommend you log out of Facebook before accessing our website. More detailed information about the purpose and extent of data collection, data processing and their use by Facebook, as well as about the related rights and options for the protection of your privacy can be found in the data protection policy for Facebook, available at the following link: http://www.facebook.com/policy.php.
19. Rating Sites
For our website, we use shopauskunft.de, a rating service by Shopauskunft.de GmbH & Co.KG , Habichthorst 38a, 22459 Hamburg, Germany.
Shopauskunft.de provides you with a feedback form to rate your overall user experience on our website and our product quality. Of course, all of the rating-related details are to be given voluntarily. Your feedback will then be published on https://www.shopauskunft.de and may possibly appear on our website and in Google’s search results.
Together with the abovementioned platform, we use an additional rating service for our website, called Trustpilot, by Trustpilot Inc., 245 5th Avenue, 5th floor, New York, NY 10016, USA.
Trustpilot provides you with a feedback form to rate your overall user experience on our website and our product quality. Of course, all of the rating-related details are to be given voluntarily. Your feedback will then be published on https://www.trustpilot.com and may possibly appear on our website and in Google’s search results.
20. Use of Zopim - Chat Programme by Zendesk
In order to improve communication with users and customers, those browsing our website may contact us via Zopim, a chat programme by Zendesk, Inc., (‘Zendesk’).
The information about the user’s activity on the website (including the anonymised IP address) is gathered via the respective cookie and transmitted to the Zendesk servers in the USA and stored therein. We store the individual ID number and the time of registration in an encrypted cookie on your computer for the usage period only. This cookie allows you to freely browse our website from page to page, without having to register every single time. As soon as you log off, the related cookies are deleted from your computer, whereas the chat content is logged and stored. You can disable the acceptance of cookies via the related settings in your internet browser, although in that case we cannot guarantee the full and correct functioning of our website.
21. Information on Data Protection according to the European General Data Protection Regulation
In addition to the information on data protection specific for this website, the following directives from the European General Data Protection Regulation apply as well:
Occasionally, we redirect visitors to third-party websites. Even though we choose our partners and select their web-sites most carefully, we can neither improve nor guarantee the accuracy and completeness of their content, as well as we cannot take any responsibility concerning the security of customer data on these third-party websites. This data protection policy does not apply to linked third-party websites. All of the information contained in this website has been checked with the utmost care and attention, nevertheless, we cannot guarantee that all of the information available on or through our website be always correct, complete and up-to-date. Any important changes to this data protection policy will be made available on this webpage.
23. Legal Effectiveness of this Data Protection Policy
This data protection policy is to be considered as part of the commercial offer on our website. Should any particular formulations or passages in this text not entirely or partly comply with the actual legal norms, the validity and content of the remaining articles in this text will not thereby be affected.
© 07/2018 German eTrade