Privacy Policy

We are very pleased that you are interested in our company. Data protection is a top priority for the management of Keys Distribution GmbH. In general, you can use the Keys Distribution GmbH website without providing any personal data. However, if a data subject wishes to use specific services offered by our company via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data—such as a data subject’s name, address, email address, or phone number—is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to Keys Distribution GmbH. Through this Privacy Policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this Privacy Policy informs data subjects of their rights.

As the data controller, Keys Distribution GmbH has implemented numerous technical and organizational measures to ensure the most comprehensive possible protection of the personal data processed via this website. Nevertheless, internet-based data transmissions may generally involve security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, any data subject is free to provide personal data to us through alternative means, such as by telephone.

1. Definitions

The privacy policy of Keys Distribution GmbH is based on the terminology used by European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this Privacy Policy, we use the following terms, among others:

• a) Personal Data

  Personal data refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier, or one or more specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

• b) Data Subject

  A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

• c) Processing

  Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution, or any other form of disclosure, the comparison or linking, the restriction, erasure, or destruction.

• d) Restriction of processing

  Restriction of processing means the marking of stored personal data with the aim of limiting its future processing.

• e) Profiling

  Profiling is any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.

• f) Pseudonymization

  Pseudonymization is the processing of personal data in such a way 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 that ensure the personal data is not attributed to an identified or identifiable natural person.

• g) Data Controller

  The controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. If the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for by Union law or the law of the Member States.

• h) Data processor

  A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

• i) Recipient

  A recipient is a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, regardless of whether or not that body is a third party. However, public authorities that may receive personal data in the course of a specific investigative mandate under Union law or the law of the Member States are not considered recipients.

• j) Third Party

  A third party is a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

• k) Consent

  Consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, expressed in the form of a statement or other unambiguous affirmative action, by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

2. Name and Address of the Data Controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions of a data protection nature is:

Keys Distribution GmbH

Birkenweg 6

9490 Vaduz

Liechtenstein

Tel.: +41775221371

Email: willkommen@keys.express

Website: www.keys.express

3. Cookies

The Keys Distribution GmbH website uses cookies. Cookies are text files that are placed and stored on a computer system via a web browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that allows websites and servers to associate the cookie with the specific web browser in which it was stored. This enables the visited websites and servers to distinguish the data subject’s individual browser from other web browsers that contain different cookies. A specific web browser can be recognized and identified via the unique cookie ID.

By using cookies, Keys Distribution GmbH can provide users of this website with more user-friendly services that would not be possible without setting cookies.

Cookies allow us to optimize the information and offerings on our website to better serve the user’s needs. As mentioned earlier, cookies enable us to recognize users of our website. The purpose of this recognition is to make it easier for users to navigate our website. For example, a user of a website that uses cookies does not have to re-enter their login credentials every time they visit the website, because this information is handled by the website and the cookie stored on the user’s computer system. Another example is the shopping cart cookie in an online store. The online store uses a cookie to remember the items a customer has placed in the virtual shopping cart.

The data subject can prevent our website from setting cookies at any time by adjusting the settings of the web browser they are using, thereby permanently objecting to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via a web browser or other software programs. This is possible in all common web browsers. If the data subject disables cookies in the web browser they are using, not all features of our website may be fully accessible under certain circumstances.

4. Collection of General Data and Information

The Keys Distribution GmbH website collects a range of general data and information each time a data subject or an automated system accesses the website. This general data and information is stored in the server’s log files. The following may be collected: (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 (known as the referrer), (4) the subpages on our website accessed via the accessing system, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

Keys Distribution GmbH does not use this general data and information to draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the content of our website, (2) to optimize the content of our website as well as the advertising on it, (3) to ensure the ongoing functionality of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. Keys Distribution GmbH therefore evaluates this anonymously collected data and information both for statistical purposes and with the aim of enhancing data protection and data security within our company, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

5. Registration on Our Website

The data subject has the option to register on the data controller’s website by providing personal data. The specific personal data transmitted to the data controller in this process is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the data controller and for its own purposes. The data controller may arrange for the transfer of this data to one or more processors, such as a package delivery service, which will also use the personal data exclusively for internal purposes attributable to the data controller.

Furthermore, when registering on the data controller’s website, the IP address assigned by the data subject’s Internet service provider (ISP), as well as the date and time of registration, are stored. This data is stored because it is the only way to prevent misuse of our services, and this data enables us to investigate criminal offenses if necessary. In this respect, the storage of this data is necessary to protect the data controller. This data is generally not disclosed to third parties, unless there is a legal obligation to do so or the disclosure serves the purposes of criminal prosecution.

The data subject’s registration, which involves the voluntary provision of personal data, enables the data controller to offer the data subject content or services that, by their very nature, can only be made available to registered users. Registered users are free to modify the personal data provided during registration at any time or to have it completely deleted from the data controller’s database.

Upon request, the data controller will provide any data subject with information at any time regarding which personal data has been stored about them. Furthermore, the data controller will correct or delete personal data at the request or upon notification by the data subject, provided that no statutory retention obligations prevent this. All employees of the data controller are available to the data subject as points of contact in this regard.

6. Subscription to Our Newsletter

On the Keys Distribution GmbH website, users are given the opportunity to subscribe to our company’s newsletter. The personal data transmitted to the data controller when subscribing to the newsletter is determined by the input form used for this purpose.

Keys Distribution GmbH informs its customers and business partners at regular intervals via a newsletter about the company’s offers. In general, the data subject can only receive our company’s newsletter if (1) the data subject has a valid email address and (2) the data subject registers to receive the newsletter. For legal reasons, a confirmation email is sent via the double-opt-in procedure to the email address provided by a data subject when first registering for the newsletter. This confirmation email serves to verify that the owner of the email address, as the data subject, has authorized receipt of the newsletter.

When subscribing to the newsletter, we also store the IP address assigned by the Internet service provider (ISP) to the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to be able to trace any (potential) misuse of a data subject’s email address at a later date and therefore serves to provide legal protection for the data controller.

The personal data collected as part of a newsletter subscription is used exclusively for sending our newsletter. Furthermore, newsletter subscribers may be notified by email if this is necessary for the operation of the newsletter service or for registration purposes, such as in the event of changes to the newsletter content or alterations to the technical conditions. Personal data collected as part of the newsletter service is not disclosed to third parties. The data subject may cancel their subscription to our newsletter at any time. Consent to the storage of personal data that the data subject has provided to us for the purpose of sending the newsletter may be revoked at any time. A link for revoking consent is included in every newsletter. Furthermore, you may unsubscribe from the newsletter at any time directly on the data controller’s website or notify the data controller of your wish to unsubscribe by other means.

7. Data Protection When Using the Electronic Withdrawal Function

If you use our electronic withdrawal function, we will process the data you enter, in particular your name, email address, order number, customer number, order details, and the content of your withdrawal notice.

This processing is carried out for the purpose of receiving, reviewing, processing, and documenting your cancellation, as well as to fulfill legal obligations related to consumer rights and contract fulfillment.

The legal basis is Article 6(1)(c) of the GDPR, insofar as the processing is necessary to fulfill legal obligations, and Article 6(1)(b) of the GDPR, insofar as the processing is necessary for the performance of the contractual relationship. To the extent that further documentation is required for the defense of legal claims, processing is based on Article 6(1)(f) of the GDPR.

The data will be stored only as long as necessary to process the revocation, to comply with statutory retention obligations, or to assert, exercise, or defend legal claims.

8. Contact Options via the Website

In accordance with legal requirements, the Keys Distribution GmbH website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general electronic mail address (email address). If a data subject contacts the data controller via email or a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data, transmitted voluntarily by a data subject to the data controller, is stored for the purposes of processing the request or contacting the data subject. This personal data is not disclosed to third parties.

9. Subscribing to Comments on the Website’s Blog

Comments posted on the Keys Distribution GmbH blog may generally be subscribed to by third parties. In particular, a commenter has the option to subscribe to comments posted in response to their own comment on a specific blog post.

If a data subject chooses to subscribe to comments, the data controller sends an automatic confirmation email to verify, via a double opt-in process, that the owner of the provided email address has indeed opted for this feature. The option to subscribe to comments can be canceled at any time.

10. Routine Deletion and Blocking of Personal Data

The data controller processes and stores the data subject’s personal data only for the period necessary to achieve the purpose of storage or to the extent provided for by the European legislative and regulatory authorities or another legislator in laws or regulations to which the data controller is subject.

If the purpose of storage no longer applies or if a retention period prescribed by European legislative bodies or other competent legislative bodies expires, the personal data will be routinely blocked or deleted in accordance with legal requirements.

11. Rights of the Data Subject

• a) Right to Confirmation

  Every data subject has the right, granted by the European legislative authorities, to request confirmation from the data controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact a representative of the data controller at any time.

• b) Right of access

  Every data subject affected by the processing of personal data has the right, granted by European legislation, to receive from the controller, at any time and free of charge, information regarding the personal data stored about them and a copy of such information. Furthermore, the European legislative and regulatory authorities have granted the data subject the right to receive the following information:

  • the purposes of the processing
  • the categories of personal data being processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • if possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this duration
  • the existence of a right to have personal data concerning them rectified or erased, or to have processing restricted by the controller, or a right to object to such processing
  • the existence of a right to lodge a complaint with a supervisory authority
  • if the personal data are not collected from the data subject: all available information regarding the origin of the data
  • the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR, and—at least in such cases—meaningful information regarding the logic involved, as well as the scope and intended effects of such processing on the data subject

  Furthermore, the data subject has the right to be informed whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to receive information about the appropriate safeguards in connection with the transfer.

  If a data subject wishes to exercise this right of access, they may contact a representative of the controller at any time.

• c) Right to Rectification

  Every data subject affected by the processing of personal data has the right, granted by European legislation, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to request that incomplete personal data be completed—including by means of a supplementary statement.

  If a data subject wishes to exercise this right to rectification, they may contact a representative of the data controller at any time.

• d) Right to Erasure (Right to be Forgotten)

  Every data subject affected by the processing of personal data has the right, granted by European legislation (directives and regulations), to request that the controller erase personal data concerning them without delay, provided that one of the following grounds applies and insofar as the processing is not necessary:

  • The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
  • The data subject withdraws their consent on which the processing was based pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data has been processed unlawfully.
  • The erasure of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • The personal data was collected in connection with information society services offered pursuant to Article 8(1) of the GDPR.

  If any of the above reasons apply and a data subject wishes to request the erasure of personal data stored by Keys Distribution GmbH, they may contact a representative of the data controller at any time. The employee of Keys Distribution GmbH will ensure that the request for erasure is complied with without delay.

  If the personal data has been made public by Keys Distribution GmbH and our company, as the controller, is obligated to erase the personal data pursuant to Article 17(1) of the GDPR, Keys Distribution GmbH shall take appropriate measures, including technical measures, taking into account available technology and the costs of implementation, to inform other data controllers processing the published personal data that the data subject has requested that these other data controllers delete all links to such personal data or copies or replicas of such personal data, provided that the processing is not necessary. The employee of Keys Distribution GmbH will take the necessary steps on a case-by-case basis.

• e) Right to Restriction of Processing

  Every data subject affected by the processing of personal data has the right, granted by European legislation (directives and regulations), to request that the controller restrict processing if one of the following conditions is met:

  • The data subject disputes the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, the data subject objects to the erasure of the personal data, and instead requests the restriction of the use of the personal data.
  • The controller no longer needs the personal data for the purposes of processing, but the data subject needs it to assert, exercise, or defend legal claims.
  • The data subject has objected to the processing pursuant to Art. 21(1) of the GDPR, and it has not yet been determined whether the controller’s legitimate grounds override those of the data subject.

  If any of the above conditions are met and a data subject wishes to request the restriction of personal data stored by Keys Distribution GmbH, they may contact an employee of the data controller at any time. The Keys Distribution GmbH employee will arrange for the restriction of processing.

• f) Right to Data Portability

  Every data subject affected by the processing of personal data has the right, granted by European legislation, to receive the personal data concerning them—which the data subject has provided to a controller—in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) of the GDPR or Art. 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, provided that 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, when exercising their right to data portability pursuant to Art. 20(1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another controller, provided this is technically feasible and does not adversely affect the rights and freedoms of others.

  To exercise the right to data portability, the data subject may contact a representative of Keys Distribution GmbH at any time.

• g) Right to Object

  Any data subject affected by the processing of personal data has the right, granted by the European legislative and regulatory authorities, to object, on grounds relating to their particular situation, to object at any time to the processing of personal data concerning them that is carried out on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

  In the event of an objection, Keys Distribution GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing is necessary for the establishment, exercise, or defense of legal claims.

  If Keys Distribution GmbH processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for such marketing purposes. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Keys Distribution GmbH regarding processing for direct marketing purposes, Keys Distribution GmbH will no longer process the personal data for these purposes.

  In addition, the data subject has the right, for reasons arising from their particular situation, to object to the processing of personal data concerning them that is carried out by Keys Distribution GmbH for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

  To exercise the right to object, the data subject may contact any employee of Keys Distribution GmbH or another employee directly. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise their right to object by means of automated procedures that use technical specifications.

• h) Automated Individual Decision-Making, Including Profiling

  Every data subject affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing—including profiling — that produces legal effects concerning the data subject or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject, and such law provides for appropriate measures to safeguard the data subject’s rights and freedoms as well as legitimate interests, or (3) is based on the data subject’s explicit consent.

  If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is made with the data subject’s explicit consent, Keys Distribution GmbH shall take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, including at a minimum the right to obtain human intervention on the part of the controller, to express the data subject’s point of view, and to contest the decision.

  If the data subject wishes to exercise rights relating to automated decisions, he or she may contact an employee of the data controller at any time.

• i) Right to Withdraw Consent Under Data Protection Law

  Every data subject affected by the processing of personal data has the right, granted by European legislation, to withdraw consent to the processing of personal data at any time.

  If the data subject wishes to exercise their right to withdraw consent, they may contact a representative of the data controller at any time.

12. Data Protection in Connection with Job Applications and the Application Process

The data controller collects and processes the personal data of job applicants for the purpose of conducting the application process. Processing may also take place electronically. This is particularly the case when an applicant submits the relevant application documents to the data controller electronically, for example via email or through a web form on the website. If the data controller enters into an employment contract with an applicant, the data submitted will be stored for the purpose of managing the employment relationship in accordance with legal requirements. If the data controller does not enter into an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the data controller preclude such deletion. Other legitimate interests in this context include, for example, the burden of proof in proceedings under the General Equal Treatment Act (AGG).

13. Privacy Policy Regarding the Use of Facebook

The data controller has integrated components of the company Facebook into this website. Facebook is a social network.

A social network is a social gathering place operated on the Internet—an online community that generally enables users to communicate with one another and interact in a virtual space. A social network can serve as a platform for exchanging opinions and experiences or enable the online community to share personal or business-related information. Among other things, Facebook allows users of the social network to create private profiles, upload photos, and connect with others through friend requests.

Facebook is operated by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject resides outside the United States or Canada, the controller responsible for the processing of personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which a Facebook component (Facebook plug-in) has been integrated, the web browser on the data subject’s computer system is automatically prompted by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins is available at https://developers.facebook.com/docs/plugins/?locale=de_DE. As part of this technical process, Facebook learns which specific subpage of our website the data subject is visiting.

If the data subject is logged into Facebook at the same time, Facebook recognizes which specific subpage of our website the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website. This information is collected by the Facebook component and assigned by Facebook to the data subject’s respective Facebook account. If the data subject clicks on one of the Facebook buttons integrated into our website—for example, the “Like” button—or posts a comment, Facebook associates this information with the data subject’s personal Facebook user account and stores this personal data.

Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is logged into Facebook at the same time as accessing our website; this occurs regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not wish for this information to be transmitted to Facebook, they can prevent the transmission by logging out of their Facebook account before visiting our website.

Facebook’s Privacy Policy, available at https://de-de.facebook.com/about/privacy/, provides information about Facebook’s collection, processing, and use of personal data. It also explains the settings options Facebook offers to protect the data subject’s privacy. In addition, various applications are available that allow users to prevent data from being transmitted to Facebook. The data subject may use such applications to prevent data from being transmitted to Facebook.

14. Privacy Policy Regarding the Use of Google Analytics (with Anonymization Function)

The data controller has integrated the Google Analytics component (with anonymization feature) into this website. Google Analytics is a web analytics service. Web analytics refers to the collection, gathering, and evaluation of data regarding the behavior of website visitors. Among other things, a web analytics service collects data on which website a data subject came from (known as a “referrer”), which subpages of the website were accessed, and how often and for how long a subpage was viewed. Web analytics is primarily used to optimize a website and to perform cost-benefit analyses of online advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The data controller uses the "_gat._anonymizeIp" add-on for web analytics via Google Analytics. This parameter causes Google to truncate and anonymize the IP address of the data subject’s Internet connection when accessing our website from a member state of the European Union or from another signatory state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor traffic on our website. Google uses the data and information collected, among other things, to evaluate the use of our website, to compile online reports for us that illustrate activity on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s computer system. What cookies are has already been explained above. By placing the cookie, Google is enabled to analyze the use of our website. Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which a Google Analytics component has been integrated—the web browser on the data subject’s computer is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains personal data, such as the data subject’s IP address, which Google uses, among other things, to track the origin of visitors and clicks and, consequently, to facilitate commission settlements.

The cookie is used to store personal information, such as the time of access, the location from which access originated, and the frequency of the data subject’s visits to our website. Each time our website is visited, this 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. This personal data is stored by Google in the United States of America. Google may, under certain circumstances, disclose this personal data—collected through technical means—to third parties.

The data subject may prevent our website from setting cookies at any time, as described above, by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the user’s web browser would also prevent Google from setting a cookie on the data subject’s computer system. In addition, a cookie already set by Google Analytics can be deleted at any time via the web browser or other software programs.

Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics regarding the use of this website, as well as to the processing of this data by Google, and to prevent such collection and processing. To do so, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on uses JavaScript to inform Google Analytics that no data or information regarding website visits may be transmitted to Google Analytics. Google considers the installation of the browser add-on to be an objection. If the data subject’s computer system is subsequently deleted, formatted, or reinstalled, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

15. Privacy Policy Regarding the Use of Instagram

The data controller has integrated components of the Instagram service into this website. Instagram is a service that qualifies as an audiovisual platform and enables users to share photos and videos, as well as to redistribute such content on other social networks.

The operator of Instagram’s services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which an Instagram component (Insta button) has been integrated, the web browser on the data subject’s computer system is automatically prompted by the respective Instagram component to download a display of the corresponding Instagram component. As part of this technical process, Instagram learns which specific subpage of our website the data subject is visiting.

If the data subject is logged into Instagram at the same time, Instagram recognizes which specific subpage the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website. This information is collected by the Instagram component and assigned by Instagram to the data subject’s respective Instagram account. If the data subject clicks on one of the Instagram buttons integrated into our website, the data and information transmitted thereby are associated with the data subject’s personal Instagram user account and are stored and processed by Instagram.

Instagram always receives information via the Instagram component that the data subject has visited our website whenever the data subject is logged into Instagram at the same time as accessing our website; this occurs regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not wish for this information to be transmitted to Instagram, they can prevent the transmission by logging out of their Instagram account before visiting our website.

Further information and Instagram’s applicable privacy policy can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

16. Privacy Policy Regarding the Use of Twitter

The data controller has integrated Twitter components into this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and share so-called tweets—short messages limited to 280 characters. These short messages are accessible to everyone, including people who are not registered with Twitter. However, the tweets are also displayed to the respective user’s so-called followers. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter enables users to reach a broad audience through hashtags, links, or retweets.

Twitter is operated by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which a Twitter component (Twitter button) has been integrated, the web browser on the data subject’s IT system is automatically prompted by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information about the Twitter buttons is available at https://about.twitter.com/de/resources/buttons. As part of this technical process, Twitter learns which specific subpage of our website the data subject is visiting. The purpose of integrating the Twitter component is to enable our users to share the content of this website, to promote this website in the digital world, and to increase our visitor numbers.

If the data subject is logged into Twitter at the same time, Twitter recognizes which specific subpage of our website the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website. This information is collected by the Twitter component and assigned by Twitter to the data subject’s respective Twitter account. If the data subject clicks one of the Twitter buttons integrated into our website, the data and information transmitted thereby are associated with the data subject’s personal Twitter user account and are stored and processed by Twitter.

Twitter receives information via the Twitter component that the data subject has visited our website whenever the data subject is logged into Twitter at the time of accessing our website; this occurs regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not wish for this information to be transmitted to Twitter, they can prevent the transmission by logging out of their Twitter account before visiting our website.

Twitter’s current privacy policy is available at https://twitter.com/privacy?lang=de.

17. Privacy Policy Regarding the Use of YouTube

The data controller has integrated YouTube components into this website. YouTube is an online video portal that allows video publishers to upload video clips free of charge and enables other users to view, rate, and comment on them, also free of charge. YouTube allows the publication of all types of videos, which is why complete movies and TV shows, as well as music videos, trailers, and user-generated videos, are available via the website.

YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

Each time a user accesses one of the individual pages of this website—which is operated by the data controller and on which a YouTube component (YouTube video) has been integrated, the web browser on the data subject’s computer system is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information about YouTube is available at https://www.youtube.com/yt/about/de/. As part of this technical process, YouTube and Google learn which specific subpage of our website the data subject is visiting.

If the data subject is logged into YouTube at the same time, YouTube recognizes which specific subpage of our website the data subject is visiting when a subpage containing a YouTube video is accessed. This information is collected by YouTube and Google and associated with the data subject’s respective YouTube account.

YouTube and Google always receive information via the YouTube component that the data subject has visited our website whenever the data subject is logged into YouTube at the same time as accessing our website; this occurs regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not wish for this information to be transmitted to YouTube and Google, they can prevent the transmission by logging out of their YouTube account before visiting our website.

The privacy policy published by YouTube, available at https://www.google.de/intl/de/policies/privacy/, provides information about the collection, processing, and use of personal data by YouTube and Google.

18. Payment Method: Privacy Policy Regarding PayPal as a Payment Method

The data controller has integrated PayPal components into this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which are virtual personal or business accounts. PayPal also allows users to make virtual payments via credit cards if they do not have a PayPal account. A PayPal account is managed via an email address, which is why there is no traditional account number. PayPal enables users to initiate online payments to third parties or to receive payments. PayPal also acts as an escrow agent and offers buyer protection services.

PayPal’s European operating company is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449, Luxembourg.

If the data subject selects “PayPal” as the payment method during the ordering process in our online store, the data subject’s information is automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transfer of personal data necessary for payment processing.

The personal data transmitted to PayPal generally includes first name, last name, address, email address, IP address, phone number, cell phone number, or other data necessary for payment processing. Personal data related to the respective order is also necessary for the fulfillment of the purchase contract.

The purpose of the data transfer is payment processing and fraud prevention. The data controller will transfer personal data to PayPal, in particular, when there is a legitimate interest in doing so. The personal data exchanged between PayPal and the data controller may be transferred by PayPal to credit bureaus. The purpose of this transfer is to verify identity and creditworthiness.

PayPal may disclose personal data to affiliated companies, service providers, or subcontractors to the extent necessary to fulfill contractual obligations or where the data is to be processed on its behalf.

The data subject has the option to revoke their consent to the processing of personal data at any time by notifying PayPal. Such revocation does not affect personal data that must be processed, used, or transferred for the mandatory (contractual) processing of payments. 

PayPal’s current privacy policy can be accessed at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

18b - reCAPTCHA

Google reCAPTCHA

To protect our forms from misuse, spam, and automated access, we use Google reCAPTCHA. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA checks whether entries on our website are made by a human or by an automated program. In particular, IP addresses, browser and device information, session duration, mouse movements, interactions with the website, and other technical usage data may be transmitted to Google and processed there.

This is done to protect our website and our forms from misuse. Depending on the technical implementation, the legal basis is either Article 6(1)(f) of the GDPR or consent pursuant to Article 6(1)(a) of the GDPR in conjunction with the applicable regulations governing access to end-device information.

For more information on data processing by Google, please see Google’s Privacy Policy.

19. Legal Basis for Processing

Article 6(1)(a) of the 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 delivery of goods or the provision of other services or consideration— the processing is based on Article 6(1)(b) of the GDPR. The same applies to processing operations necessary for the implementation of pre-contractual measures, such as in cases of inquiries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data—such as to fulfill tax obligations—the processing is based on Article 6(1)(c) of the 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 on our premises and their name, age, health insurance information, or other vital information had to be disclosed to a doctor, a hospital, or other third parties. In such cases, the processing would be based on Article 6(1)(d) of the GDPR. Finally, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases, provided that the processing is necessary to safeguard a legitimate interest of our company or a third party, so long as the interests, fundamental rights, and fundamental freedoms of the data subject do not take precedence. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this regard, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, Sentence 2 of the GDPR).

20. Legitimate Interests in Processing Pursued by the Controller or a Third Party

If the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.

21. Duration for which personal data is stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. Upon expiration of this period, the relevant data is routinely deleted, provided it is no longer necessary for the performance of a contract or for entering into a contract.

22. Legal or contractual requirements for the provision of personal data; necessity for the conclusion of a contract; obligation of the data subject to provide personal data; possible consequences of failure to provide data

We hereby inform you that the provision of personal data is in some cases required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information about the contracting party). In some cases, the conclusion of a contract may require that a data subject provide us with personal data, which we must subsequently process. For example, the data subject is obligated to provide us with personal data when our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, 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 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 what the consequences of failing to provide the personal data would be.

23. Use of Automated Decision-Making

As a responsible company, we do not engage in automated decision-making or profiling.

Developed by the legal tech specialists at Willing & Able, who also developed the system for the digital record of processing activities. The texts of the Privacy Policy Generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.