Privacy policy & Data protection concept
Privacy Policy
We are very pleased about your interest in our company. Data protection is of a particularly high priority for the management of ALP BRANDS – FZCO. The use of the internet pages of ALP BRANDS – FZCO is possible without any indication of personal data. However, if a person concerned wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain 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 shall always be in line with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to ALP BRANDS – FZCO. By means of this data protection declaration, our enterprise would like to inform the general public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of the rights to which they are entitled by means of this data protection declaration.
As the controller, ALP BRANDS – FZCO has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g., by telephone.
1) Definitions
The data protection declaration of ALP BRANDS – FZCO is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public as well as 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:
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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is 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.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
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.
f) Pseudonymization
Pseudonymization 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 is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is 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.
h) Processor
Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient is 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.
j) Third party
Third party is 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.
k) Consent
Consent of the data subject is 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 General Data Protection Regulation, other data protection laws applicable in Member states of the European Union, and other provisions related to data protection is:
ALP BRANDS – FZCO Digital Park Silicon Oasis, Building A1, Dubai, United Arab Emirates
Email: info@alp-brands.com
General Manager: Laurin Roider
Director & Secretary: Hannes Widmann
3) Cookies
The internet pages of ALP BRANDS – FZCO use cookies. Cookies are text files that are stored in a computer system via an internet browser. Many internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited internet sites and servers to differentiate the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, ALP BRANDS – FZCO 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. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the articles that a customer has 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 popular 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 ALP BRANDS – FZCO collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the internet site, (6) an Internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, ALP BRANDS – FZCO does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, ALP BRANDS – FZCO 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. Contact via Email or Contact Form
The website of ALP BRANDS – FZCO includes information, as required by law, that allows for quick electronic contact with our company as well as direct communication with us, which also includes a general address for 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 is automatically stored. Such personal data, voluntarily provided by a data subject to the data controller, is stored for the purpose of processing or contacting the data subject. This personal data is not shared with third parties.
6. Routine Deletion and Blocking of Personal Data
The data controller processes and stores 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 directives and regulations or any other legislator 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 directives and regulations or another applicable legislator expires, the personal data is routinely blocked or deleted in accordance with legal requirements.
7. 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 is being processed. If a data subject wishes to exercise this right of confirmation, they may, at any time, contact any employee of the controller.
b) Right to Access Each data subject has the right granted by the European legislator to obtain from the controller free information about their personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
Furthermore, the data subject has a right to obtain information as to whether personal data is transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, they may, at any time, contact any employee of the controller.
c) Right to Rectification Each 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 the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, they may, at any time, contact any employee of the controller.
d) Right to Erasure (Right to Be Forgotten) Each data subject has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by ALP BRANDS – FZCO they may, at any time, contact any employee of the controller. An employee of ALP BRANDS – FZCO shall promptly ensure that the erasure request is complied with immediately.
Where ALP BRANDS – FZCO has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, ALP BRANDS – FZCO taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other 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, as far as processing is not required. An employee of ALP BRANDS – FZCO will arrange the necessary measures in individual cases.
e) Right to Restriction of Processing Each data subject has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by ALP BRANDS – FZCO they may at any time contact any employee of the controller. The employee of ALP BRANDS – FZCO will arrange the restriction of processing.
f) Right to Data Portability Each data subject has the right granted by the European legislator to receive the personal data concerning them, which was provided to a controller, in a structured, commonly used, and machine-readable format. They have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, as long as the 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 their right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may at any time contact any employee of ALP BRANDS – FZCO.
g) Right to Object Each 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, which is based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.
ALP BRANDS – FZCO shall no longer process the personal data in the event of the objection unless we 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.
If ALP BRANDS – FZCO 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. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to ALP BRANDS – FZCO to the processing for direct marketing purposes, ALP BRANDS – FZCO will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by ALP BRANDS – FZCO for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the 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 any employee of ALP BRANDS – FZCO:
The data subject is also free to exercise their right to object to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
h) Automated Decisions in Individual Cases, 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, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, ALP BRANDS – FZCO shall implement suitable measures to safeguard the data subject’s rights and 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 rights concerning automated individual decision-making, they may, at any time, contact any employee of the controller.
i) Right to Withdraw Data Protection Consent
Every data subject has the right granted by the European legislator to withdraw their consent to the processing of their personal data at any time. If the data subject wishes to exercise the right to withdraw their consent, they may, at any time, contact any employee of the controller.
8. Data Protection Provisions About the Application and Use of Facebook
The controller has integrated components of the company Facebook on this website. Facebook is a social network. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a person lives outside the USA or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Facebook component (Facebook plug-in) is integrated, the web browser on the information technology system of the data subject is automatically prompted to download the display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook plug-ins may be accessed under https://developers.facebook.com/docs/plugins/?locale=en_US. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our website—which specific sub-site of our internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g., the „Like“ button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up 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 desirable for the data subject, they may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at https://www.facebook.com/about/privacy/, provides information about the collection, processing, and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
9. Data Protection Provisions About the Application and Use of Google Analytics (with Anonymization Function)
The controller has integrated the component of Google Analytics (with the anonymization function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data on which website a person has come from (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and to carry out a cost-benefit analysis of internet advertising.
The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The controller uses the application „_gat._anonymizeIp“ for web analytics through Google Analytics. By means of this application, the IP address of the internet connection of the data subject is shortened by Google and anonymized when accessing our websites 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 to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Google Analytics component was integrated, the web browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our website, such personal data, including the IP address of the internet access used by the data subject, will be 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 the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following link https://www.google.com/analytics/.
10. Data Protection Provisions on the Use and Application of Google Remarketing
The controller has integrated Google Remarketing services on this website. Google Remarketing is a feature of Google AdWords that allows a company to display advertisements to internet users who have previously visited the company’s website. The integration of Google Remarketing allows a company to create user-related advertising and consequently display interest-relevant advertisements to internet users.
The operating company of Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Remarketing is the display of interest-relevant advertising. Google Remarketing enables us to display ads within the Google advertising network or on other websites that are tailored to the individual needs and interests of internet users.
Google Remarketing sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. With the setting of the cookie, Google allows the recognition of the visitor of our website if they subsequently visit websites that are also part of the Google advertising network. With each visit to a website on which the Google Remarketing service has been integrated, the internet browser of the data subject automatically identifies itself to Google. During the course of this technical procedure, Google receives knowledge of personal data, such as the IP address or browsing behavior of the user, which Google uses, among other things, to display interest-relevant advertising.
By means of the cookie, personal information, such as the websites visited by the data subject, is stored. Each time our websites are visited, personal data, including the IP address of the internet connection used by the data subject, is 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 the technical procedure on to third parties.
The data subject may prevent the setting of cookies through our website, as already stated above, at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. Additionally, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Furthermore, the data subject has the possibility of objecting to interest-based advertising by Google. For this purpose, the data subject must access the link www.google.de/settings/ads from each of the internet browsers they use and set the desired settings there.
Further information and the applicable data protection provisions of Google can be retrieved under https://www.google.de/intl/en/policies/privacy/.
11. Data Protection Provisions on the Use and Application of Google AdWords
The controller has integrated Google AdWords on this website. Google AdWords is an internet advertising service that allows advertisers to place ads both in Google’s search engine results and within the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords by which an ad on Google’s search engine results will be displayed only when the user retrieves a keyword-relevant search result with the search engine. In the Google advertising network, the advertisements are distributed on relevant web pages using an automatic algorithm and in accordance with the previously defined keywords.
The operating company of Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google AdWords is the promotion of our website by the inclusion of interest-relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine, and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google advertisement, a conversion cookie is filed on the information technology system of the data subject by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, such as the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both we and Google can understand whether a data subject who reached our website via an AdWords ad generated revenue, i.e., completed or canceled a purchase.
The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are used by us to determine the total number of users who were referred to us through AdWords ads, thus determining the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
By means of the conversion cookie, personal information, such as the websites visited by the data subject, is stored. Each time our websites are visited, personal data, including the IP address of the internet connection used by the data subject, is 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 the technical procedure on to third parties.
The data subject may prevent the setting of cookies through our website, as already stated above, at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the internet browser used would also prevent Google from setting a conversion cookie on the information technology system of the data subject. Additionally, a cookie set by Google AdWords may be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the possibility of objecting to interest-based advertising by Google. For this purpose, the data subject must access the link www.google.de/settings/ads from each of the internet browsers they use and set the desired settings there.
Further information and the applicable data protection provisions of Google can be retrieved under https://www.google.de/intl/en/policies/privacy/.
12. Data Protection Provisions on the Use and Application of Instagram
The controller has integrated components of the Instagram service on this website. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos, as well as disseminate such data on other social networks.
The operating company of the Instagram services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this website, which is operated by the controller and into which an Instagram component (Insta button) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Instagram component from Instagram.
During the course of this technical procedure, Instagram becomes aware of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to our website by the data subject—and for the entire duration of their stay on our website—which specific sub-page of our internet page was visited by the data subject. This information is collected through the Instagram component and associated with the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated on our website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.
Instagram receives information via the Instagram component whenever the data subject is logged in at the same time on Instagram during the time of the call-up to our website, regardless of whether the data subject clicks on the Instagram component or not. If such a transmission of information to Instagram is not desirable for the data subject, then they may prevent this by logging off from their Instagram account before a call-up to our website is made.
Further information and the applicable data protection provisions of Instagram may be retrieved under https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.
13. Data Protection Provisions on the Use and Application of YouTube
The controller has integrated YouTube components on this website. YouTube is an internet video portal that allows video publishers to upload video clips free of charge and other users to view, rate, and comment on them free of charge as well. YouTube permits the publication of all types of videos, which is why complete films and television broadcasts, as well as music videos, trailers, and videos made by users themselves, are available via the internet portal.
The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
With each call to one of the individual pages of this website, operated by the controller and on which a YouTube component (YouTube video) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective YouTube component to download a display of the corresponding YouTube component from YouTube. More information about YouTube can be obtained at https://www.youtube.com/yt/about/en/.
During the course of this technical procedure, YouTube and Google receive knowledge of which specific sub-page of our website was visited by the data subject. If the data subject is logged in on YouTube at the same time, YouTube recognizes which specific sub-page of our website the data subject is visiting when a sub-page containing a YouTube video is called up. This information is collected by YouTube and Google and associated with the respective YouTube account of the data subject.
YouTube and Google receive information via the YouTube component whenever the data subject is logged in on YouTube at the same time as accessing our website, regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desired by the data subject, the data subject may prevent this by logging off from their YouTube account before accessing our website.
YouTube’s privacy policy, which is available at https://www.google.de/intl/en/policies/privacy/, provides information about the collection, processing, and use of personal data by YouTube and Google.
14. Legal Basis for Processing
Art. 6 I lit. a GDPR serves as the legal basis for our company’s processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations required for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are 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 by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. 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 would have to be passed on to a doctor, hospital, or other third party. In such a case, the processing would be based on Art. 6 I lit. d GDPR. Finally, processing operations could be based on Art. 6 I lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal grounds if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, provided that such interests are not overridden by the interests, rights, and freedoms of the data subject. Such processing operations are particularly permitted because they have been specifically mentioned by the European legislator. The legislator considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
15. Legitimate Interests in the Processing Pursued by the Controller or a Third Party
If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is to carry out our business for the well-being of all our employees and shareholders.
16. Period for Which the Personal Data Will Be Stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of this period, the corresponding data is routinely deleted, provided that it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
17. Legal or Contractual Requirements for the Provision of Personal Data; Necessity for the Conclusion of the Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide
We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a 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 signs a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before the provision of personal data by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract, or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of the non-provision of the personal data.
18. Newsletter
If you would like to receive the newsletter offered on the website, we need your email address and information that allows us to verify that you are the owner of the specified email address and agree to receive the newsletter. No further data will be collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The processing of the data entered into the newsletter registration form takes place exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the email address, and their use for sending the newsletter at any time, for example, via the „unsubscribe“ link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
The data stored by us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted after unsubscribing from the newsletter.
18.1 Use of Google reCAPTCHA
We use the Google reCAPTCHA service to determine whether a human or a computer is making a particular input in our contact or newsletter form. Google checks the following data to determine whether you are a human or a computer: IP address of the device used, the website you visit and on which the captcha is integrated, the date and duration of the visit, the recognition data of the browser and operating system used, Google account if you are logged in to Google, mouse movements on the reCAPTCHA areas as well as tasks where you need to identify images. The legal basis for the described data processing is Art. 6 para. 1 lit. f GDPR. There is a legitimate interest on our part in this data processing to ensure the security of our website and to protect us from automated inputs (attacks).
18.2 Consent Text in the Newsletter Form
Our free newsletter informs you regularly by email about product news and special offers. The data you enter here will only be used to personalize the newsletter and will not be passed on to third parties. You can unsubscribe from the newsletter at any time or revoke your consent at any time by email to info@broshield.de. Your data will be deleted after the newsletter is canceled, provided that the deletion does not conflict with any statutory retention requirements. By submitting the data you have entered, you consent to the data processing and confirm our privacy policy.
19. Hubspot
We use the HubSpot service for various purposes on this website. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500. HubSpot is an integrated software solution that we use to cover various aspects of our online marketing. These include, among others: email marketing, social media publishing & reporting, reporting, contact management (e.g., user segmentation & CRM), landing pages, and contact forms. Our registration service allows visitors to our website to learn more about our company, download content, and provide their contact information and other demographic information. This information, as well as the contents of our website, is stored on the servers of our software partner HubSpot. They may be used by us to contact visitors to our website and to determine which services of our company are of interest to them.
All information we collect is subject to this data protection policy. We use all collected information exclusively to optimize our marketing measures.
More information about HubSpot’s privacy policy » More information about HubSpot’s compliance with EU data protection regulations » More information about the cookies used by HubSpot can be found here & here »
As part of the optimization of our marketing measures, the following data can be collected and processed via HubSpot: – Geographic location – Browser type – Navigation information – Referral URL – Performance data – Information on how often the application is used – Mobile apps data – Login information for the HubSpot subscription service – Files viewed on site – Domain names – Viewed pages – Aggregate usage – Operating system version – Internet service provider – IP address – Device ID – Duration of the visit – Source of the application download – Operating system – Events occurring within the application – Access times – Clickstream data – Device model and version
In addition, we use HubSpot to provide contact forms. For further information, please refer to section 7 of this privacy policy. The legal basis for the processing is your consent according to Art. 6 para. 1 lit. a GDPR. If you do not want the mentioned data to be collected and processed via HubSpot, you can refuse your consent or withdraw it at any time with effect for the future. Personal data will be kept for as long as it is necessary to fulfill the purpose of processing. The data will be deleted as soon as it is no longer required for the purpose.
In the context of processing via HubSpot, data may be transferred to the USA. The security of the transfer is ensured by so-called standard contractual clauses, which ensure that the processing of personal data is subject to a level of security equivalent to that of the GDPR. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent according to Art. 49 para. 1 lit. a GDPR may serve as a legal basis for the transfer to third countries. Please refer to section “7. Forms” for further information.
20. Existence of Automated Decision-Making
As a responsible company, we do not use automatic decision-making or profiling.
This privacy policy was created using the privacy policy generator of the DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an external data protection officer in Straubing, in cooperation with the lawyer for data protection law Christian Solmecke.
21. Inventory Management
Use of an external inventory management system We use an inventory management system for order processing as part of an order processing agreement. For this purpose, your personal data collected during the order process will be transmitted to:
Billbee Gesellschaft mit beschränkter Haftung Arolser Str. 10 34477 Twistetal
22. Payment Service Providers and Credit Information
Use of PayPal All PayPal transactions are subject to the PayPal Privacy Policy. You can find this at https://www.paypal.com/de/webapps/mpp/ua/privacy-full (https://www.paypal.com/de/webapps/mpp/ua/privacy-full).
Use of PayPal Express We use the PayPal Express payment service on our website, provided by PayPal (Europe) S.à.r.l. et Cie, S.C.A. (22-24 Boulevard Royal L-2449, Luxembourg; „PayPal“). The data processing serves the purpose of being able to offer you payment via the PayPal Express payment service. To integrate this payment service, it is necessary that PayPal collects, stores, and analyzes data (e.g., IP address, device type, operating system, browser type, location of your device) when you visit the website. Cookies may also be used for this purpose. The cookies enable the recognition of your browser.
The use of cookies or similar technologies is based on § 15 para. 3 sentence 1 TMG. The processing of your personal data is based on Art. 6 para. 1 lit. f GDPR, from our overriding legitimate interest in offering a customer-oriented range of different payment methods. You have the right to object to the processing of your personal data at any time for reasons arising from your particular situation.
By selecting and using PayPal Express, the necessary data for payment processing will be transmitted to PayPal to fulfill the contract with you using the chosen payment method. This processing is based on Art. 6 para. 1 lit. b GDPR. Further information on data processing when using the PayPal Express payment service can be found in the associated privacy policy at www.paypal.com/de/webapps/mpp/ua/privacy-full?locale.x=de_DE#Updated_PS (http://www.paypal.com/de/webapps/mpp/ua/privacy-full?locale.x=de_DE#Updated_PS).
Use of Amazon Payments We use the Amazon Payments payment service on our website, provided by Amazon Payments Europe s.c.a. (38 avenue John F. Kennedy, L-1855 Luxembourg; „Amazon Payments“). The data processing serves the purpose of being able to offer you payment via the Amazon Payments payment service. To integrate this payment service, it is necessary that Amazon Payments collects, stores, and analyzes data (e.g., IP address, device type, operating system, browser type, location of your device) when you visit the website. Cookies may also be used for this purpose. The cookies enable the recognition of your browser. The use of cookies or similar technologies is based on your consent in accordance with § 15 para. 3 sentence 1 TMG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is based on your consent in accordance with Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the lawfulness of the processing based on the consent before its withdrawal. By selecting and using „Amazon Payments,“ the necessary data for payment processing will be transmitted to Amazon Payments to fulfill the contract with you using the chosen payment method. This processing is based on Art. 6 para. 1 lit. b GDPR. Further information on data processing when using the Amazon Payments payment service can be found in the associated privacy policy at: https://pay.amazon.com/de/help/201212490 (https://pay.amazon.com/de/help/201212490).
Use of Personal Data When Selecting Klarna Payment Options To offer you Klarna’s payment options, we will transfer personal data, such as contact and order details, to Klarna. This allows Klarna to assess whether you can take advantage of the payment options offered through Klarna and to tailor the payment options to your needs. General information about Klarna can be found at: https://www.klarna.com/de/ (https://www.klarna.com/de/). Your personal data will be handled by Klarna in accordance with the applicable data protection regulations and as described in Klarna’s privacy policy at https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/privacy (https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/privacy).
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