Name / Company: Voleatech GmbH
Street: Grathwohlstr. 5
Postcode, City, Country: 72762, Reutlingen, DE
Commercial Register / No.: B 754643
Managing Directors / Owners: Sven Auhagen and Marianne Dunker
Telephone number: +49 (0) 7121 530 55 0
E-Mail address: email@example.com
Types of processed data:
– Inventory data (e.g., names, addresses).
– contact information (e.g., e-mail, phone numbers).
– content data (e.g., text input, photographs, videos).
– contract data (e.g., subject, term, customer category).
– Payment data (e.g., bank details, payment history).
– Meta / communication data (e.g., device information, IP addresses).
Processing of special categories of data (Article 9 (1) GDPR)
No special categories of data are processed.
Categories of data subjects:
– Customers, prospects, visitors and users of the online offer, business partners.
Following, we also refer to the concerned persons as “users”.
Purpose of processing:
– Provision of contractual services, service and customer care.
– Marketing, advertising and market research.
– Safety measures.
Version: May / 2018
1. Terms used
1.1. “Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
1.2. “Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
1.3. “Responsible person” means the natural or legal person, public authority, body or body that decides, alone or in together with others, on the purposes and means of processing personal data.
2. Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the fulfillment of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO is the legal basis.
4. Security measures
4.1. We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk; Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the execution of affected rights, data deletion and data vulnerability. Furthermore, we already consider the protection of personal data during development, or selection of hardware, software and procedures, according to the principle of data protection taken into account technology design and privacy-friendly default settings (Article 25 GDPR).
4.2. One of the security measures is the encrypted transfer of data between your browser and our server.
5. Disclosure and Submission of Data
5.1. If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) DSGVO), you have consented to a legal obligation or on the basis of our legitimate interests (e.g. the use of agents, hosting providers, tax, business, etc.) and legal advisers, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual, administrative and other duties).
5.2. If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
6. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. This means the processing is based on e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
7. Rights of affected persons
7.1. You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
7.2. You have according to Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
7.3. In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
7.4. You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.
7.5. You have according to Art. 77 DSGVO the right to file a complaint with the responsible supervisory authority.
8. Revocation Right
You have the right to revoke your given approval in accordance with. Art. 7 para. 3 DSGVO with effect for the future.
9. Right of Objection
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
10. Cookies and Right to object direct marketing
10.1. “Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. As a third-party cookie, cookies are referred to by providers other than the person responsible for the online offer (otherwise, if only their cookies are called first-party cookies).
11. Deletion of data
11.2. Germany: According to legal requirements, the storage takes place in particular for 6 years according to § 257 paragraph 1 HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and for 10 years in accordance with § 147 Abs. 1 AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.)
12. Order processing in the online shop and customer account
12.1. We process the data of our customers as part of the ordering process in our online shop to allow them to select and order the selected products and services, as well as their payment and delivery, or execution.
12.2. The processed data include inventory data, communication data, contract data, payment data and as the affected persons our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery and customer service. Here we use session cookies for the storage of the shopping cart contents and permanent cookies for the storage of the login status.
12.3. Processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The information marked as required for the establishment and fulfillment of the contract is required. We disclose the data to third parties only in the context of extradition, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if necessary for the fulfillment of the contract (for example, on customer’s request upon delivery or payment).
12.4. Users can optionally create a user account, in particular to be able to view their orders. As part of the registration, the necessary mandatory information will be communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. Information in the customer account remains until its deletion with subsequent archiving in case of a legal obligation. It is the responsibility of the users to secure their data upon termination before the end of the contract.
12.5. As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO.
12.6. The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); Information in the customer account remains until its deletion.
13. Business analysis and market research
13.1. In order to operate our business economically, to be able to recognize market trends, customer and user requirements, we analyze the data we have on business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons affected include customers, prospects, business partners, visitors and users of the online offer. The analyzes are carried out for the purpose of business analysis, marketing and market research. In doing so, we can display the profiles of the registered users with indications e.g. to consider their purchase transactions. The analyzes serve us to increase the user-friendliness, the optimization of our offer and the business economics. The analyzes are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analyzes.
13.2. If these analyzes or profiles are personal, they will be deleted or anonymized upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analyzes and general trend provisions are created anonymously if possible.
14. Credit information
14.1. If we make an advance payment (for example, when purchasing on invoice), we reserve the right to obtain identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service providers (credit reporting agencies).
14.2. As part of the credit report, we provide the following personal data of the customer (name, postal address, date of birth, details of the type of contract, bank details) to the following credit reporting agencies:
14.3. We process the information obtained by the credit reference agencies on the statistical probability of a default in the context of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right, in the case of a negative result of the credit check, to refuse payment on invoice or any other advance payment.
14.4 If we obtain an explicit consent from you, the legal basis for the credit information and the transmission of the customer’s data to the credit bureaus is the consent acc. Art. 6 para. 1 lit. a, 7 DSGVO. If no consent is obtained, our legitimate interests in the reliability of their claim for payment are the legal basis. Art. 6 para. 1 lit. f. DSGVO.
15. Collection of access data and logfiles
15.1. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
15.2. Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 14 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
16. Online presence in social media
16.1. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO we maintain online presence within social networks and platforms in order to communicate with the active customers, prospects and users and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
16.3. We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services, only those users who have shown an interest in our online offering or who have certain characteristics (e.g. interests in specific topics or products visited by them) Web pages) that we submit to Google (so-called “remarketing” or “Google Analytics audiences”). With Remarketing Audiences, we also want to make sure that our ads are in line with the potential interest of users and are not annoying.
17. Google Analytics
17.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
17.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
17.4. We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened 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 sent to a Google server in the US and shortened there.
17.5. The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as 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=en.
17.6. For more information about Google’s data usage, settings and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Google’s use of your data when you use websites or apps Our Partners “), https://policies.google.com/technologies/ads (” Advertising Use of Data “), https://adssettings.google.com/authenticated (” Managing information Google uses to show you advertising “).
18.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO) we use the marketing and remarketing services (“Google Marketing Services “), LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (” Google “).
18.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
18.3. Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. If a user e.g. is shown ads for products he’s been interested in on other websites, this is called remarketing. For these purposes, when accessing our website and other websites, where Google Marketing Services are active, a code will be executed by Google and so-called (re) marketing tags (invisible graphics or code, also called “Web Beacons “) incorporated into the website. With their help, the user is provided with an individual cookie, i.e. a small file is saved (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file is noted which web pages the user visited, for what content he is interested and what offers he has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer. The IP address of the users is also recorded, whereby in the context of Google Analytics we announce that the IP address is shortened within member states of the European Union or other parties to the Agreement on the European Economic Area and only in exceptional cases is transmitted to a Google server in the US and shortened there. The IP address will not be merged with data of the user within other offers from Google. The above information may also be linked by Google with such information from other sources. If the user then visits other websites, the ads can be displayed according to his interests, tailored to him.
18.4. The data of the users are pseudonym processed in the context of the Google marketing services. That means Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That means from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google’s servers in the United States.
18.5. Among the Google marketing services we use among other things the online advertising program “Google AdWords”. In the case of Google AdWords, each advertiser receives a different “conversion cookie”. Cookies can not be tracked through AdWords advertisers’ websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
18.6. Also we can use the service “Google Optimizer”. Google Optimizer allows us to understand how various changes to a website (such as changes to the input fields, the design, etc.) can take place in so-called “A / B testings”. Cookies are stored on users’ devices for these purposes. Only pseudonymous data of the users are processed.
18.7. In addition, we may use the “Google Tag Manager” to integrate and manage the Google Analytics and Marketing Services on our website.
18.9. If you wish to opt-out of interest-based advertising through Google Marketing Services, you can take advantage of Google’s settings and opt-out options: https://adssettings.google.com/authenticated.
19. Jetpack (WordPress Stats)
19.1. Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO) we use the plugin Jetpack (here the subfunction “WordPress Stats”), which includes Automated Visitor Access Statistics Tool and is supplied by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, United States. Jetpack uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website by you.
19.2. Automattic is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
20. Communication via mail, e-mail, fax or telephone
20.1 We use means of remote communication, such as telecommunications, for business transactions and marketing purposes like Mail, telephone or e-mail. We process stock data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
20.2 Processing takes place on the basis of Art. 6 para. 1 lit. a, Art. 7 GDPR, Art. 6 para. 1 lit. f DSGVO in connection with legal requirements for advertising communications. The contact takes place only with the consent of the contact partners or within the scope of the legal permissions and the processed data are deleted as soon as they are not required and otherwise with opposition / revocation or elimination of the authorization basis or legal archiving obligations.
21.1. With the following information we inform you about the content of our newsletter as well as the registration, shipping and statistical evaluation process as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
21.2. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletters contain information about our products, offers, promotions and our company.
21.4. Insofar as we use a shipping service provider, the shipping service provider may, according to its own information, transmit these data in pseudonymous form, i.e. without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletters or for statistical purposes, to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write them down or to pass them on to third parties.
21.5. Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.
21.6. Measuring success – The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when opening the newsletter, or if we use a shipping service provider, their server. This retrieval will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval. This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters will be opened, when they will be opened and which links will be clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
21.7. Germany: The sending of the newsletter and the measurement of success are based on the consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 DSGVO in connection with § 7 Abs. 2 Nr. 3 UWG or on the basis of the legal permission according to Art. § 7 Abs. 3 UWG.
21.8. The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to the receipt of the newsletter.
21.9. Newsletter recipients may terminate the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. At the same time, their consent to success measurement expires. A separate revocation of the performance measurement is unfortunately not possible, in this case, the entire newsletter subscription must be terminated. By unsubscribing from the newsletter, the personal data will be deleted, unless their retention is legally required or justified, in which case their processing is limited only to these exceptional purposes. In particular, we may save the e-mail addresses sent for up to three years based on our legitimate interests before deleting them for purposes of sending out the newsletter in order to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
22. Integration of services and content of third parties
22.1. Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services, such as including videos or fonts (collectively referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web sites, visit time, and other information regarding the use of our online offer.
22.2. The following presentation provides an overview of third-party providers as well as their contents, as well as links to their data protection statements, which contain further information on the processing of data and, partially already mentioned here, revocation possibilities (so-called opt-out)
– If our customers use the payment services of third parties (for example, PayPal or Sofortüberweisung), the terms and conditions and the privacy notices of the respective third party, which are available within the respective websites, or transactional applications apply.