Data protection
This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the “Online Offering”). With regard to the terminology used, e.g. “Processing” or “Responsible”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible
Westensee & Partner Rohstoff GmbH
Benzstraße 9
21423 Winsen (Luhe) Germany
E-mail address: info@awp-rohstoffe.de
Managing Director / Owner: Ms. Wiebke Westensee
Link to the imprint: http://www.awp-rohstoffe.de/en/impressum
Types of processed data:
– Inventory data (e.g., names, addresses).
– contact information (e.g., e-mail, phone numbers).
– content data (e.g., text input, photographs, videos).
– usage data (e.g., websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach Measurement / Marketing
Used terms
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
“Responsible person” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as legal basis.
Safety measures
We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).
Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (eg if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to a legal obligation or based on our legitimate interests (eg the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 GDPR the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.
You have gem. Art. 77 GDPR the right to file a complaint with the competent supervisory authority.
Withdrawal
You have the right to grant consent in accordance with. Art. 7 para. 3 GDPR with effect for the future
Contradictory legal
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object in direct mail
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called “first-party cookies”).
We can use temporary and permanent cookies and clarify this in the context of our privacy policy.
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general contradiction to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.
Deletion of data
The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That The data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, relevant for taxation Documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage takes place especially for 7 years according to § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
Contractual services
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (eg, names and addresses), contact data (eg e-mail addresses and telephone numbers) as well as contract data (eg, services used, contract contents, contractual communication, names of contact persons) and payment data (eg, Bank details, payment history).
In principle, we do not process special categories of personal data, unless they are part of a contracted or contractual processing.
We process data which are necessary for the establishment and fulfillment of the contractual services and point out the necessity of their indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as the legal requirements.
As part of the use of our online services, we can save the IP address and the time of each user action. The storage is based on our legitimate interests, as well as the interests of the user in the protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is to pursue our claims acc. Art. 6 para. 1 lit. f. GDPR required or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c. GDPR.
The data will be deleted if the data is no longer required for the fulfillment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this majority of company-related data permanently.
Business analysis and market research
In order to operate our business economically, to recognize market trends, wishes of the contractors and users, we analyze the data available to us for business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata based on the nature 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyzes are carried out for the purpose of business analysis, marketing and market research. In doing so, we can provide the profiles of registered users with information, e.g. take into account their services. The analyzes serve us to increase the user-friendliness, the optimization of our offer and the business economics. The analyzes are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analyzes.
If these analyzes or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analyzes and general trend provisions are created anonymously if possible.
Privacy policy in the application process
We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if the data processing e.g. is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).
The application process requires applicants to provide us with the applicant data. The necessary applicant data are, as far as we offer an online form marked, otherwise result from the job descriptions and basically include the information on the person, postal and contact addresses and the application documents, such as cover letter, CV and the certificates. In addition, applicants can voluntarily provide us with additional information.
By submitting the application to us, the applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set forth in this Privacy Policy.
Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b GDPR (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).
If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us according to the state of the art.
Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by post.
The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to at any time.
The cancellation is subject to a legitimate cancellation of the candidate, after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.
contact
When contacting us (for example, by contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its processing in accordance with. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR processed .. User information can be stored in a Customer Relationship Management System (“CRM System”) or similar request organization.
We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.
Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us.
Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.
Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.
The dispatch of the newsletter and the associated performance measurement are based on a consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 GDPR i.V.m § 7 Abs. 2 No. 3 UWG or if consent is not required, based on our legitimate interests in the direct marketing acc. Art. 6 para. 1 lt. F. GDPR i.V.m. § 7 Abs. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f GDPR. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent.
Termination / Revocation – You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter – Success Measurement
The newsletters contain a so-called “web-beacon”, i. a pixel-sized file that is retrieved from the server when opening the newsletter from our server, or if we use a shipping service provider. This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval.
This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters will be opened, when they will be opened and which links will be clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
A separate revocation of the performance measurement is unfortunately not possible, in this case, the entire newsletter subscription must be terminated.
Hosting and e-mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services we use to operate this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f GDPR i.V.m. Art. 28 GDPR (conclusion of contract processing contract).
Collection of access data and log files
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider ,
Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
Google AdWords and conversion measurement
We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online service within the meaning of Art. 6 (1) lit. GDPR) , USA, (“Google”).
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use Google’s online AdWords marketing tool “AdWords” to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a suspected interest in the ads. This allows us to more specifically display ads for and within our online offering so that we only present ads to users that potentially match their interests. If a user e.g. Showing ads for products he’s been looking for on other online offers is called remarketing. For these purposes, upon access to our and other websites where the Google Advertising Network is active, Google will immediately execute a Google code and become so-called (re) marketing tags (invisible graphics or code, also known as “).” Web beacons “) incorporated into the website. With their help, the user is provided with an individual cookie, i. a small file is saved (instead of cookies, comparable technologies can also be used). In this file is noted which websites the user visited, for what content he is interested and what offers the user has clicked, as well as technical information about the browser and operating system, referring websites, visit time and other information on the use of the online offer.
Furthermore, we receive an individual “conversion cookie”. The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only hear the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive any information that personally identifies users.
The data of the users are pseudonym processed within the Google advertising network. That Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.
Further information on the use of data by Google, options for setting and contradicting, can be found in the privacy policy of Google.
Google ReCaptcha
We bind the function to detect bots, e.g. when entering into online forms (“ReCaptcha”) of the provider Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
Content delivery network from Cloudflare
We use a so-called “Content Delivery Network” (CDN) offered by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare is certified under the Privacy Shield Agreement, providing a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active).
A CDN is a service that helps deliver content from our online offering, especially large media files, such as graphics or scripts, using regionally distributed and Internet-connected servers. The processing of the data of the users takes place solely for the aforementioned purposes and the maintenance of the security and functionality of the CDN.
Use is made on the basis of our legitimate interests, i. Interest in a safe and efficient provision, analysis and optimization of our online offer acc. Art. 6 para. 1 lit. f. GDPR.
For more information, see the Cloudflare Privacy Policy: https://www.cloudflare.com/security-policy
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