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Privacy policy

 ID:  2751  ( 3676 ) -  convertible 

Information about the processing of your data

In accordance with Art. 12 of the General Data Protection Regulation (hereinafter referred to as the GDPR), we are obliged to inform you about the processing of your data when you use our website. We take the protection of your personal data very seriously and this privacy policy informs you about the details of the processing of your data and about your legal rights in this regard.

We reserve the right to adapt the privacy policy with future effect, in particular in the event of further development of the website, the use of new technologies or changes to the legal bases or the corresponding case law.

We recommend that you read this privacy policy from time to time and take a printout or a copy for your documents.

 

Definitions

 

Scope

This privacy policy applies to all pages of http://www.schliessfaecher.de/. It does not cover any linked websites of other providers.

Responsible provider/representative of the provider in the European Union (EU)

The following party is responsible for the processing of personal data within the scope of this privacy policy:

Mietra e.K.

Heinrich-Heine-Straße 4b

04651 Bad Lausick

Telephone: +49 (0) 34345 / 72 95 0; email: info@mietra.de

 

Questions about data protection

If you have any questions about data protection with regard to our company or our website, you can contact our data protection officer:

Spirit Legal LLP Rechtsanwälte

Attorney-at-law and data protection officer

Peter Hense

Postal address:

Data protection officer

c/o Mietra e.K., Heinrich-Heine-Straße 4b, 04651 Bad Lausick

Contact via encrypted online form:

Contact data protection officer

 

Security

We have taken comprehensive technical and organisational precautions to protect your personal data from unauthorised access, abuse, loss and other external disruption. To this end, we regularly review our security measures and adapt them to current standards.

 

Your rights

You have the following rights with regard to the personal data concerning you that you can assert against us:

You can assert your rights by informing us using the contact details specified above under ‘Responsible provider’ or by contacting the data protection officer designated by us.

You also have the right to lodge a complaint with a data protection supervisory authority about our processing of your personal data (Art. 77 GDPR).


Use of the website, access data

In principle, you can use our website for purely informational purposes without disclosing your identity. When you access the individual pages of the website in this sense, this only results in access data being transferred to our web hosting service so that the website can be displayed to you. This is the following data:

Temporary processing of the IP address by the system is necessary to make it technically possible to deliver the website to your device. This requires processing of your IP address for the duration of the session. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR.

The access data is not used to identify individual users and is not combined with other data sources. The access data is erased when it is no longer required for achieving the purpose of its processing. In the case of recording the data to provide the website, this is the case when you end your visit to the website.

IP addresses are stored in log files to ensure the functionality of the website. In addition, the data serves us to optimise the website and to ensure the security of our information technology systems. No evaluation of the data for marketing purposes takes place in this context either. In principle, data is erased after seven days at the latest; further processing is possible in individual cases. In this case, the IP address is erased or so transformed that an assignment of the retrieving client is no longer possible.

 

The recording of data for the provision of the website and the processing of data in log files is an absolute necessity for the operation of the website. You may object to the processing. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.


Cookies

In addition to the aforementioned access data, so-called cookies are stored in the internet browser of the device you use to access the website. These are small text files with a sequence of numbers that are stored locally in the cache of the browser used. Cookies do not become part of the device system and cannot execute programs. They serve to make our website user-friendly. The use of cookies may be technically necessary or may occur for other purposes (e.g. analysis/evaluation of website use).

a) Technically necessary cookies

Some elements of our website require that the retrieving browser can be identified even after a page change. This involves processing the following data in the cookies:

 The user data collected by technically necessary cookies is not processed to create user profiles. We also use session cookies, which store a session ID that can be used to assign various requests from your browser to the shared session. Session cookies are required for using the website. In particular, they enable us to recognise the device used when you return to the website. If you have an account with us, we use this cookie to recognise you on subsequent visits to the website; otherwise you would have to log in again each time you visited. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR. We use session cookies to make using our website more attractive and effective. Session cookies are erased as soon as you log out or close your browser.


Most browsers are preset to automatically accept cookies. You can object to the processing of your data by cookies. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

You can disable or restrict the transfer of cookies by changing the settings in your internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may no longer be possible to use the full functionality of the website.

 

 b) Technically non-essential cookies

In addition, we also use cookies on the website which enable an analysis of users’ surfing behaviour. For example, this involves processing the following data in the cookies:

 These cookies are used to make using the website more efficient and attractive. The legal basis of this processing is Art. 6(1) Sentence 1(f) GDPR. The technically non-essential cookies are automatically deleted after a specified period, which may vary depending on the cookie.



You can object to the processing of your data by cookies. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). If you do not wish to use cookies, you have the option of changing your browser settings in order to generally or selectively block the placement of cookies or remove stored cookies. You can also have the corresponding information displayed before a cookie is placed. If you change the browser settings for the use of cookies or disable cookies, the functionality of this website may be restricted.


Where we integrate cookies from third-party providers into our website, we point this out to you separately below.

c) Cookie banner notice

When you visit the website, an information banner notifies you about the use of cookies and refers you to this privacy policy. In this context, information is also provided about how the storage of cookies can be prevented by adjusting your browser settings.

 

Contacting our company

When contacting our company, e.g. by email or using the contact form on the website, we will process the personal data provided by you so that we can respond to your enquiry.

In order for us to process enquiries submitted via the contact form on the website, it is essential that you provide a name or pseudonym and a valid email address. At the moment when you submit the message to us, the following data will also be processed:

 

The legal basis of the processing is Art. 6(1) Sentence 1(f) GDPR and Art. 6(1) Sentence 1(b) GDPR, if the contact is made with the intention of concluding a contract.

Processing the personal data from the form allows us alone to process the contact you make with us. Where you contact us by email, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the submission process serves to prevent any misuse of the contact form and to ensure the security of our information technology systems.

The data will not be transmitted to third parties in this context. The data is only processed in order to process the conversation. As soon as processing is no longer necessary, we erase the data generated in this context or, if statutory retention obligations apply, restrict processing of the data.

 

You have the possibility to object to the processing of your personal data for contact requests at any time. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In particular, you have a right of objection if processing is not necessary to fulfil a contract with you, which is described by us in the previous description of the functions. In such a case, it may not be possible to continue processing the request. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.


Processing and transmission of personal data for contractual purposes

We process your personal data if and to the extent necessary for the initiation, creation, execution and/or termination of a legal transaction with our company. The legal basis of this results from Art. 6(1) Sentence 1(b) GDPR.

Once the purpose has been achieved (e.g. contract processing), the personal data will be blocked for further processing or erased, unless we are entitled to retain the data for a longer period and process it as required in the respective context on the basis of a consent granted by you (e.g. consent to the processing of your email address for sending promotional emails), a contractual agreement, a statutory authorisation (e.g. authorisation to send direct marketing) or on the basis of justified interests (e.g. retention for asserting claims).

Your personal data will be passed on if

  • we are aothorised or even obliged to pursure overriding legitimate interests (Art. 6 (1) Sentence 1 (f) GDPR

Your personal data will not be transmitted to other persons, companies or bodies unless you have effectively consented to such transmission. The legal basis of the processing is then Art. 6(1) Sentence 1(a) GDPR. 


Requests for information material

You have the possibility to request information material on the website, in which we inform you about the following content: products from our portfolio, further information about fire protection, sample lockers and consultations/customer feedback

In order to receive the information material, you need to give us your contact details. These include for example the name of the recipient, address, function, email address and number of pupils.

In addition to the data specified, the following data is processed at the time of the request: IP address and date/time of the request.

We process the mandatory data you provide us with for the purpose of preparing and, if necessary, performing the contract and sending you the information material. The legal basis for the processing is Art. 6(1) Sentence 1(b) GDPR. We will not pass your data on to third parties. Data processing is performed within the European Union. We erase the data as soon as storage is no longer necessary or, if statutory retention obligations apply, restrict processing of the data. Due to mandatory commercial and tax regulations, we are obliged to keep your address, payment and order data for a period of ten years. After two years after termination of the contract, we will restrict the processing and reduce the processing to compliance with our existing legal obligations.

As far as the information material contains advertising content that goes beyond pure information provided for the potential conclusion of a contract, the legal basis of this is Art. 6(1) Sentence 1(f) GDPR. We have a legitimate interest in processing for the purpose of direct marketing. We will not pass your data on to third parties. Processing is performed within the European Union. Unless you object to processing for advertising purposes, we will erase your data two years after you request the information material.

 

We would like to point out that you can object to receiving direct marketing at any time without incurring any costs other than the transmission costs according to the basic rates (Art. 21(2) GDPR). You can submit your objection to us using the contact details specified under ‘Responsible provider’.

 

 

Processing and transmission of personal data in the online ordering system

If you wish to submit an order or booking in our online shop, it is necessary for the initiation and conclusion of the contract that you provide personal data such as your name, your address and your email address. The mandatory data required for order and contract processing is marked as such; further information is provided voluntarily. We process your data for order processing; in particular, we will forward payment data to your chosen payment service provider or our main bank. The legal basis for the processing is Art. 6(1) Sentence 1(b) GDPR. To prevent unauthorised third parties from accessing your personal data, the order process on the website is encrypted using SSL/TLS technology.

As soon as storage is no longer necessary, we erase the data generated in this context or, if statutory retention obligations apply, restrict processing of the data. Due to mandatory commercial and tax regulations, we are obliged to keep your address, payment and order data for a period of ten years. After two years after termination of the contract, we will restrict the processing and reduce the processing to compliance with our existing legal obligations.

Registration/password-protected area on the website

If you wish to use the password-protected area of our website, you must register by providing the following information:

Furthermore, the following data is processed at the time of registration:

The data will be erased as soon as it is no longer required for achieving the purpose of its processing. This is the case for the data collected during the registration process if the registration on the website is cancelled or modified.

The following functions are available to you in the password-protected area:

If you use the password-protected area of the website, e.g. to edit your profile data or to view orders and bookings made, we also process the data about your person required for the initiation or performance of the contract, in particular address data and information about the payment method. The legal basis for the processing is Art. 6(1) Sentence 1(b) GDPR. The data will be erased as soon as it is no longer required for achieving the purpose of its processing or as soon as there are no legitimate interests preventing its erasure. Due to mandatory commercial and tax regulations, we are obliged to keep your address, payment and order data for a period of ten years. After two years after termination of the contract, we will restrict the processing and reduce the processing to compliance with our existing legal obligations.

If you provided further data voluntarily (e.g. about interests, gender, children, preferences, wish list), we will process your data which is not necessary for the initiation or performance of a contract for as long as you use the password-protected area and if you do not delete it yourself beforehand. Our aim in this respect is to optimise the use of the website for you as a user. The legal basis for this is Art. 6(1) Sentence 1(f) GDPR.


You can object to the processing of the information you provided voluntarily. Your right of objection exists when you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR).

You can manage, change or delete your voluntary information yourself at any time in the password-protected area. You are free to take measures in accordance with the ‘Your rights’ section, although if you do have any complaints we request that you first contact our company.

 

 

Email marketing

Advertising to existing customers

We reserve the right to process the email address provided by you when booking in accordance with the statutory provisions in order to send you, among other things, the following content by email whilst or after processing the contract, unless you have already objected to this processing of your email address:

The legal basis for the processing is Art. 6(1)(f) GDPR. We perform this processing for customer care and to enhance our services. We erase your data when you cancel your newsletter subscription, but no later than two years after termination of the contract.

 

We would like to point out that you can object to receiving direct marketing at any time without incurring any costs other than the transmission costs according to the basic rates. Here you have a general right of objection without giving reasons (Art. 21(2) GDPR). To do this, click on the unsubscribe link in the newsletter or send us your objection to the contact details provided under ‘Responsible provider’.


Payment service providers (PSPs)

Transmission of personal data for purposes of enforcing rights/ascertaining an address/debt collection

In the event of non-payment, we reserve the right to pass on the data provided at the time of booking to a lawyer and/or to external companies (e.g. Verband der Vereine Creditreform e.V., Hellersbergstraße 12, 41460 Neuss, Germany) if we have a legitimate interest pursuant to Art. 6(1) Sentence 1(f) GDPR in order to ascertain an address and/or enforce our rights.

In addition, we may pass on your information if this is necessary to protect our rights, as well as the rights of our affiliates, our cooperation partners, our employees and/or users of our website. Under no circumstances will we sell or rent your data to third parties. Such a transmission of your data would be based on Art. 6(1) Sentence 1(f) GDPR.

As soon as storage is no longer necessary, we erase the data generated in this context or, if statutory retention obligations apply, restrict processing of the data.

 

You have the possibility to object to the processing of your data at any time. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In particular, you have a right of objection if processing is not necessary to fulfil a contract with you, which is described by us in the previous description of the functions. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.


Hosting

We use external hosting services for the provision of the following services: infrastructure and platform services, computing capacity, storage resources and database services, security and technical maintenance services. This involves processing all data necessary for the operation and use of our website.

We use external hosting services to run this website. By using external hosting services, we aim to make the provision of our website efficient and secure. The legal basis for the processing is Art. 6(1)(f) GDPR.

 

The recording of data for the provision and use of the website and the processing of data using external web hosting services is an absolute necessity for the operation of the website. You may object to the processing. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

 

 

Integration of third-party content

The website integrates third-party content such as videos, maps, RSS feeds and graphics from other websites. This integration always requires that the providers of this content (‘third-party providers’) perceive the IP addresses of users. This is because without the IP address they would not be able to send the content to the browser of the respective user. As such, the IP address is required to display this content.

We endeavour to only use content from third-party providers who process the IP address solely for delivering the content. We do however have no influence over whether the third-party providers process the IP addresses, e.g. for statistical purposes. If we are aware of such activity, we inform you of this in the following.

Some of the third-party providers may process data outside the European Union.

 

You can object by installing a JavaScript blocker such as the browser plug-in NoScript (www.noscript.net) or disabling JavaScript in your browser. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). This may however result in functional restrictions on the website.

 

 

Google Fonts

We use web fonts provided by Google for the uniform display of fonts. When you retrieve a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google’s servers. By doing so, Google becomes aware that our website has been accessed via your IP address. Our use of Google Fonts is in the interest of a uniform and visually appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6(1) Sentence 1(f) GDPR. We have no knowledge of how long Google stores data and have no way of influencing this.

 

You can object to the processing by changing your browser settings in such a way that the browser does not support web fonts – although then your device will use a default font. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.

 

 

For more information about Google Fonts, please refer to https://developers.google.com/fonts/faq and Google’s privacy policy: https://www.google.com/policies/privacy/

 

Google Analytics

In order to tailor our website perfectly to your interests, we use Google Analytics, a web analytics service from Google. Google Analytics uses ‘cookies’ (see ‘Cookies’ above), which are stored on your device to enable the analysis of how you use the website. The information generated in this way about your use of this website is transferred to and stored by Google on a server in the USA.

However, if IP anonymisation is activated on this website, then within European Union Member States or in other member states of the European Economic Area Google will shorten your IP address before transferring it. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On our behalf, Google will use this information for the purpose of evaluating your use of this website, compiling reports for us on website activity, and providing us with other services relating to website usage and internet usage.

Google will not associate your browser’s IP address transmitted for Google Analytics purposes with any other data held by Google.

This website uses Google Analytics with the ‘_anonymizeIp()’ extension. As a result, IP addresses are further processed in abbreviated form, meaning that any association with individual persons can be ruled out. As far as the data collected about you relates to you personally, that relation is therefore excluded immediately and the personal data thus erased without delay.

We use Google Analytics to analyse and regularly improve the use of our website. The statistics help us to improve our website and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis of the processing by Google Analytics is Art. 6(1) Sentence 1(f) GDPR. The Analytics cookies are deleted after 14 months at the latest.


You have the right to object. You can prevent the storage of cookies using the corresponding settings in your browser software; however, we would like to point out that if you do this you may not be able to use the full functionality of this website. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). Furthermore, you can prevent the recording of data generated by the cookie about your use of the website (including your IP address) and its processing by Google by downloading and installing the browser plug-in available via the following link: http://tools.google.com/dlpage/gaoptout?hl=en


For more information about the third-party provider Google, please refer to:

http://www.google.com/analytics/terms/de.html, http://www.google.com/intl/de/analytics/learn/privacy.html, http://www.google.de/intl/en/policies/privacy

Usage-based online advertising

Social network plug-ins

Social network plug-ins are integrated into our website. These are provided by the following providers:

 

The plug-ins can be recognised on our website by the aforementioned lettering or by small stylised symbols.

We offer you the possibility to communicate directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it does the plug-in provider receive the information that you have accessed the corresponding page of our website. In addition, the data mentioned under ‘Access data’ is submitted.

In the case of Facebook, according to the respective providers’ own information, IP addresses in Germany are anonymised immediately after their collection. By activating the plug-in, personal data about you is therefore transferred to the respective plug-in provider and processed there (in the USA in the case of US providers). Since the plug-in provider collects data via cookies in particular, we recommend that before clicking on the greyed-out box you delete all cookies using your browser’s security settings.

We have no influence on the data collected and processing procedures, and nor are we aware of the full scope of data processing, the purposes of processing, or the storage periods. We also have no information about the erasure of the data collected by the plug-in provider.

The plug-in provider stores the data collected about you as usage profiles and processes this for purposes of advertising, market research and/or the demand-oriented design of its website. Such analysis takes place in particular (including for users who are not logged in) to display demand-oriented advertising and to inform other users of the social network about your activities on our website.

The legal basis of the use of the plug-ins is Art. 6(1) Sentence 1(f) GDPR. Through the plug-ins we offer you the possibility to interact with social networks and other users, so that we can improve our website and make it more interesting for you as a user.

 

You have the right to object to the creation of these user profiles, although you must contact the respective plug-in provider to exercise this right. Your right of objection exists if you have reasons arising from your particular situation, unless we can prove compelling legitimate reasons for the processing which outweigh your interests, rights and freedoms or, moreover, the processing serves to establish and exercise or defend against legal claims (Art. 21(1) GDPR). There are also various ways in which you can prevent the creation of user profiles and thus make use of your right to object:

 

The data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, the data about you collected by us will be directly assigned to your existing account with that plug-in provider. If you click or tap on the activated button and, for example, share a link to the page, the plug-in provider will also store this information in your user account and share it publicly with your contacts.

After using a social network, we recommend that you log out regularly, especially however before activating the button, as in this way you can avoid being assigned to your profile with the respective plug-in provider.

 

Copyright by Spirit Legal LLP


Last updated: August 2018

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