This data protection declaration explains the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content connected to it as well as external online presences, e.g. our social media profiles (hereinafter jointly referred to as “online offer”). With regard to the terms used here, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (DSGVO).
ABRO Team GmbH
CEO: Adriaan van der Werf
Types of data processed:
– Inventory data
– contact data
– content data
– contract data
– payment data
– Usage data
– Meta/communication data
Processing of special categories of data (Art. 9 (1) DSGVO):
No special categories of data are processed.
Categories of data subjects:
– Customers, interested parties, visitors and users of the online offer, business partners.
– Visitors and users of the online offer.
In the following, we also refer to the data subjects collectively as “users”.
Purpose of processing:
– Provision of the online offer, its contents and shop functions;
– Provision of contractual services, service and customer care;
– Answering contact requests and communication with users;
– Marketing, advertising and market research;
– Security measures.
1.1 “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.2 “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
1.3 “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
2. Relevant legal basis
In accordance with Art. 13 DSGVO, we inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is Art. 6(1)(b) DSGVO, the legal basis for processing in order to fulfil our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing in order to protect our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO serves as the legal basis.
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
4. Safety measures
4.1 In accordance with Article 32 of the GDPR, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons. The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, transfer, ensuring availability and separation of the data. In addition, we have established procedures to ensure the exercise of data subject rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 of the GDPR).
4.2 The security measures include in particular the encrypted transmission of data between your browser and our server.
5. Disclosure and transmission of data
5.1 If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is required pursuant to Art. 6 para. 1 lit. b DSGVO is necessary for the performance of a contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfil our contractual obligations, administrative tasks and duties).
5.2 If we commission third parties with the processing of data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 DSGVO.
6. Transmissions to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the processing of data in a third country if the special requirements of Art. 44 ff. DSGVO are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
7. Rights of the data subjects
7.1 You have the right to obtain confirmation as to whether data in question are being processed and to obtain information about these data, as well as further information and a copy of the data in accordance with Article 15 of the GDPR.
7.2 You have the right according to Art. You have the right to request the completion of data concerning you or the correction of inaccurate data concerning you in accordance with Article 16 of the GDPR.
7.3 In accordance with Article 17 of the GDPR, you have the right to demand that the data in question be deleted without delay or, alternatively, to demand that the processing of the data be restricted in accordance with Article 18 of the GDPR.
7.4 You have the right to request that the data relating to you that you have provided to us be received in accordance with Article 20 of the GDPR and to request that it be transferred to other data controllers.
7.5 You also have the right to lodge a complaint with the competent supervisory authority in accordance with Article 77 of the GDPR.
8. Right of withdrawal
You have the right to revoke consent granted in accordance with Art. 7 (3) DSGVO with effect for the future.
9. Right of objection
You may object to the future processing of data concerning you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against processing for direct marketing purposes.
10. Cookies and right to object to direct advertising
10.1 “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 information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his or her browser. In such a cookie, for example, the contents of a shopping basket in an online shop or a login status can be stored. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies” are cookies from providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
11. Deletion of data
11.1 The data processed by us will be deleted or its processing restricted in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
11.2 In accordance with legal requirements, data is stored for 6 years in particular pursuant to § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years pursuant to § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
12. Order processing in the online shop
12.1 We process data of our customers in the context of the order processes in our online shop in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.
12.2 The processed data includes inventory data, communication data, contract data, payment data and the data subjects are our customers, interested parties and other business partners. The processing is carried out for the purpose of providing contractual services within the framework of the operation of an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.
12.3 The processing is based on Art. 6 Para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. In this context, the information marked as required is necessary for the justification and fulfilment of the contract. We only disclose the data to third parties within the scope of delivery, payment or within the scope of legal permissions and obligations towards legal advisors and authorities. The data is only processed in third countries if this is necessary for the fulfilment of the contract (e.g. at the customer’s request for delivery or payment).
12.4 The deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation.
13. Business analyses and market research
13.1 For the purposes of business analyses and market research, we analyse the data we have on business transactions, contracts, enquiries, etc.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of business management evaluations, marketing and market research. The analyses serve us to increase user-friendliness, optimise our offer and improve business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised values.
13.2 If these analyses or profiles are personal, they will be deleted or anonymised upon termination of the user, otherwise after two years from the conclusion of the contract. In all other respects, the overall business analyses and general trend analyses shall be prepared anonymously wherever possible.
14. Contact and customer service
14.1 When contacting us (via contact form or e-mail), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO.
14.2 The user’s details may be stored in our customer relationship management system (“CRM system”) or comparable enquiry organisation.
14.3 We delete the enquiries if they are no longer necessary. We review the necessity every two years; we store enquiries from customers who have a customer account permanently and refer to the information on the customer account for deletion. Furthermore, the statutory archiving obligations apply.
15.1 We collect data about every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. DSGVO, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
15.2 Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
16. Online presences on social media
16.1 We maintain online presences within social networks and platforms on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. DSGVO, we maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
17. Google Analytics
17.2 Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
17.3 Google will use this information on our behalf to evaluate the use of our online offer by the users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
17.4 We only use Google Analytics with IP anonymisation activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
17.5 The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
17.6 You can find out more information about Google’s use of data, settings and opt-out options on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Google’s use of data when you use our partners’ websites or apps”), https://policies.google.com/technologies/ads (“Use of data for advertising purposes”), https://adssettings.google.com/authenticated (“Manage the information Google uses to serve ads to you”).
18. Citrix Podio
18.1 We use the services of Podio for data collection and storage of requests within our intranet. The provider is Citrix Systems, Inc, 851 West Cypress Road, Ft. Lauderdale, FL 33309 (USA), Tel.:+1 954 267 3000; Fax: + 1 805 690 6471; E-Mail: email@example.com.
18.3 We have concluded a so-called “Data Processing Agreement” with Podio, in which we oblige Podio to protect our customers’ data and not to pass it on to third parties.
19. Facebook Social Plugins
19.1 We use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd. DSGVO) social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognisable by one of the Facebook logos (white “f” on a blue tile, the terms “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
19.2 Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
19.3 When a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with Facebook’s servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the latter. In the process, user profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.
19.4 By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from their device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and store his or her IP address. According to Facebook, only an anonymised IP address is stored in Germany.
19.6 If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it to his/her membership data stored on Facebook, he/she must log out of Facebook and delete his/her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
20. Communication via post, e-mail or telephone
20.1 We use remote means of communication, such as post, telephone or e-mail, for business processing and marketing purposes. In doing so, we process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
20.2 The processing is carried out on the basis of Art. 6 para. 1 lit. a, Art. 7 DSGVO, Art. 6 para. 1 lit. f DSGVO in conjunction with legal requirements for promotional communications. Contact is only made with the consent of the contact partners or within the scope of legal permissions and the processed data is deleted as soon as it is no longer required and otherwise with objection/ revocation or discontinuation of the authorisation bases or legal archiving obligations.
21.1 With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
21.2 Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Apart from that, our newsletters contain information about our products, offers, promotions and our company.
21.3 Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
21.5 Insofar as we use a dispatch service provider, the dispatch service provider may, according to its own information, use this data in pseudonymous form, i.e. without attribution to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.
21.6 Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name for the purpose of a personal address in the newsletter.
21.7 Performance measurement – The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file which is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The analyses serve us much more to recognise 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.
21.8 The dispatch of the newsletter and the measurement of success are based on the consent of the recipients pursuant to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 no. 3 UWG or on the basis of the legal permission pursuant to § 7 para. 3 UWG.
21.9 The logging of the registration process is based on our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to receive the newsletter.
21.10. Newsletter recipients can cancel receipt of our newsletter at any time, i.e. revoke their consent. You will find a link to cancel the newsletter at the end of each newsletter. At the same time, their consent to the performance measurement expires. Unfortunately, it is not possible to cancel the performance measurement separately; in this case, the entire newsletter subscription must be cancelled. When you unsubscribe from the newsletter, your personal data will be deleted, unless their retention is legally required or justified, in which case their processing will be limited to these exceptional purposes only. In particular, we may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them for the purposes of sending newsletters in order to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
22. Integration of third-party services and content
22.1 We use content or service offers of third party providers within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO). DSGVO) to integrate content or services offered by third-party providers (hereinafter uniformly referred to as “content”). This requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain a. technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
22.2 The following presentation provides an overview of third-party providers and their content, as well as links to their data protection declarations, which contain further information on the processing of data and opt-out options:
– If our customers use the payment services of third parties (e.g. PayPal or Sofortüberweisung), the terms and conditions and the data protection notices of the respective third party providers apply, which can be accessed within the respective websites or transaction applications.