Privacy Policy
This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "personal data" or their "processing", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible:
cwhpro UG (hb)
Ringstrasse 20
96231 Bad Staffelstein, Deutschland
Registry Court: Amtsgericht Coburg, HRB:4563
Managing Director: Dirk Karl Traxler
Telephone number: +49 (0) 9573 2397 867
Telefax: +49 (0) 9573 2397 868
Email: dirk.traxler@cwhpro.de
Internet: www.cwhpro.de
Types of data processed:
· Inventory data (e.g., names, addresses).
· Contact information (e.g., email, phone numbers).
· Inhaltsdaten (z.B., Texteingaben, Fotografien, Videos).
· Content data (e.g., text input, photographs, videos).
· Payment data (e.g. payment history).
· Usage data (e.g. web pages visited, interest in content, access times).
· Meta/communication data (e.g., device information, IP addresses).
Processing of special categories of data (Art. 9 (1) GDPR):
No special categories of data are processed.
Categories of persons concerned by the processing:
· Customers / prospects / suppliers.
· Visitors and users of the online offer. In the following, we refer to the persons concerned collectively as
"users".
Purpose of processing:
· Provision of the online offer, its contents and functions.
· Provision of contractual services, service and customer care.
· Respond to contact requests and communicate with users.
· Marketing, Werbung und Marktforschung.
· Marketing, advertising and market research.
Status: 03.05.2018
1. Relevant legal bases
In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing to fulfill our services and carry out contractual measures and respond to inquiries is Art. 6(1)(b) DSGVO, the legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
2. Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
3. Security measures
3.1. We take appropriate technical and organizational measures in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk; the measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access concerning them, input, disclosure, ensuring availability and their separation. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 of the GDPR).
3.2. The security measures include, in particular, the encrypted transmission of data between your browser and our server.
4. Cooperation with processors and third parties
4.1. If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them or otherwise grant them 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, such as to payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
4.2. SIf we commission third parties with the processing of data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 DSGVO.
5. 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 if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
6. Rights of the data subjects
6.1. You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 DSGVO.
6.2. You have according to. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
6.3. In accordance with Article 17 of the GDPR, you have the right to demand that the data in question be deleted without delay or, alternatively, to demand restriction of the processing of the data in accordance with Article 18 of the GDPR.
6.4. Sie haben das Recht zu verlangen, dass die Sie betreffenden Daten, die Sie uns bereitgestellt haben nach Maßgabe des Art. 20 DSGVO zu erhalten und deren Übermittlung an andere Verantwortliche zu fordern.
6.5. You also have the right to file a complaint with the competent supervisory authority pursuant to Art. 77 DSGVO.
7. Right of revocation You have the right to revoke given consents according to Art. 7 para. 3 DSGVO with effect for the future.
8. Right of objection You may object to the future processing of data relating to you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against processing for direct marketing purposes.
9. Cookies and right to object to direct advertising We use temporary and permanent cookies, i.e. small files that are stored on users' devices (for an explanation of the term and its function, see the last section of this privacy policy). In part, the cookies serve security purposes or are necessary for the operation of our online offer (e.g., for the display of the website) or to store the user decision when confirming the cookie banner. In addition, we or our technology partners use cookies for range measurement and marketing purposes, about which users are informed in the course of the privacy policy. A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offer can be used.
10. Data deletion
10.1. The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
10.2. According to legal requirements, the storage takes place in particular for 6 years in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) as well as for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
11. Provision of contractual services
11.1. We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. DSGVO. The entries marked as mandatory in online forms are required for the conclusion of the contract.
11.2. Within the scope of registration and renewed logins as well as the 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. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c DSGVO.
11.3. We process usage data (e.g., the web pages visited on our website, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile, e.g., in order to display product information to the user based on the services they have used to date. 11.4 The deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation); information in the customer account remains until its deletion.
12. Contact
12.1. When contacting us (via contact form or e-mail), the user's details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) lit. b) DSGVO.
12.2. User information may be stored in our Customer Relationship Management System ("CRM System") or comparable inquiry organization.
13. Comments and contributions
13.1. When users leave comments or other contributions, their IP addresses are stored on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO are stored for 7 days.
13.2. This is done for our security, in case someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
14. Collection of access data and log files
14.1. We collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
14.2. Log file information is stored for security reasons (e.g. to clarify acts of misuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
15. Online presence in social media
15.1. We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing policies of their respective operators apply.
15.2. Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.
16. Cookies & Reach Measurement
16.1. Cookies are pieces of information that are transmitted from our web server or third-party web servers to users' web browsers, where they are stored for later retrieval. Cookies may be small files or other types of information storage.
16.2. We use "session cookies", which are only stored for the duration of the current visit to our online presence (e.g. to enable the storage of your login status or the shopping cart function and thus the use of our online offer at all). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close the browser, for example.
16.3. Users are informed about the use of cookies in the context of pseudonymous reach measurement as part of this privacy policy.
16.4. If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
16.5. You can object to the use of cookies used for reach measurement and advertising purposes via the Network Advertising Initiative opt-out page (http://optout.networkadvertising.org/) and, additionally, the U.S. website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
17. Google Analytics
17.1. We use Google Analytics, a web analytics service provided by Google LLC ("Google"), on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) lit. f. DSGVO) Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.
17.2. Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (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 other services related to the use of this online offer and the Internet. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
17.4. We use Google Analytics to display the ads placed within Google's advertising services and those of its partners only to users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called "Remarketing Audiences" or "Google Analytics Audiences"). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of users and do not have a harassing effect.
17.5. We only use Google Analytics with IP anonymization enabled. This means that the IP address of the user is 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 transferred to a Google server in the USA and shortened there.
17.6. The IP address transmitted by the user's browser is not merged with other data from Google. Users may prevent the storage of cookies by selecting the appropriate settings on their browser software; users may also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
17.7. For more information about Google's data use, settings and opt-out options, please visit Google's websites: https://www.google.com/intl/de/policies/privacy/partners ("Data use by Google when you use our partners' websites or apps"), https://policies.google.com/technologies/ads ("Data use for advertising purposes"), https://adssettings.google.com/authenticated ("Manage information Google uses to serve ads to you").
18. Google-Re/Marketing-Services
18.1. We use 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 para. 1 lit. f. DSGVO) the marketing and remarketing services (in short "Google Marketing Services") of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google").
18.2. Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
18.3. Google's marketing services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products he or she was interested in on other websites, this is referred to as "remarketing". For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and other information about the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The IP address is not merged with the user's data within other Google offerings. The aforementioned information may also be linked on the part of Google with such information from other sources. If the user subsequently visits other websites, he can be shown ads tailored to his interests.
18.4. User data is processed pseudonymously as part of Google's marketing services. I.e. Google does not store and process e.g. the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google's servers in the USA.
18.5. The Google marketing services we use include the online advertising program "Google AdWords". In the case of Google AdWords, each AdWords customer receives a different "conversion cookie". Cookies can therefore not be tracked across the websites of AdWords customers. The information obtained using the cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. The AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to identify users personally.
18.6. We can also use the "Google Optimizer" service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to the input fields, design, etc.) as part of so-called "A/B testing". Cookies are placed on users' devices for these testing purposes. Only pseudonymous user data is processed in the process.
18.7. Furthermore, we may use the "Google Tag Manager" to integrate and manage Google analytics and marketing services on our website.
18.8. For more information on the use of data for marketing purposes by Google, please visit the overview page: https://policies.google.com/technologies/ads, Google's privacy policy is available at https://policies.google.com/privacy.
18.9 If you wish to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google: https://adssettings.google.com/authenticated.
19. Newsletter
19.1. With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures.
19.2. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our products, offers, promotions and our company.
19.3. Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.
19.4. Dispatch service provider: The newsletter is dispatched using "MailChimp", a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active).
19.5. Furthermore, according to its own information, the shipping service provider may use this data in pseudonymous form, i.e. without assigning it to a user, to optimize or improve its own services, e.g. to technically optimize the shipping and display of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties.
19.6. Registration data: To register for the newsletter, it is sufficient to provide your e-mail address.
19.7. Performance measurement - The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the dispatch 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.
19.8. The newsletter is sent and its success is measured on the basis of the recipients' consent pursuant to Art. 6 Para. 1 lit. a, Art. 7 DSGVO in conjunction with Section 7 Para. 2 No. 3 UWG or on the basis of statutory permission pursuant to Section 7 Para. 3 UWG.
19.9. The logging of the registration process is based on our legitimate interests pursuant to Art. 6 (1) lit. f DSGVO and serves as proof of consent to receive the newsletter.
19.10. Cancellation/Revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consents. You will find a link to cancel the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and cancelled this subscription, their personal data will be deleted.
20. Integration of third-party services and content
20.1. Within our online offer, we use content or service offers of third-party providers 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 para. 1 lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as "content"). This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
20.2. The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):
- The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, in part already mentioned here, opt-out options:
- When paying by credit card, the payment is processed via Stripe by the payment service provider Stripe Payments Europe Ltd, Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland. You can find more information about Stripe's data protection at https://stripe.com/de/privacy#translation.
- External fonts from Google, LLC., https://www.google.com/fonts ("Google Fonts"). The integration of Google Fonts is done by a server call at Google (usually in the USA). Privacy policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
- Landkarten des Dienstes „Google Maps“ des Drittanbieters Google LLC, 1600 Amphitheatre Parkway, Mountain View,CA 94043, USA, gestellt. Datenschutzerklärung: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
- Maps of the service "Google Maps" of the third party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View,CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
- Videos from the "Vimeo" platform of the third-party provider Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA. Privacy policy: https://vimeo.com/privacy.
- External code of the JavaScript framework "jQuery" provided by the third party vendor jQuery Foundation, https://jquery.org.