Data Protection Declaration of STULZ GmbH concerning the use of e-STULZ

     

    -       Information according to Articles 13, 14 and 21 of the General Data Protection Regulation (“GDPR”) –

     

    1. Introduction

    This Data Protection Declaration will inform you about which personal data, in the course of the use of e-STULZ, are collected from you, processed, and/or used by us, STULZ GmbH, (the “Processing). We process personal data in order to offer you our services. Personal data are any information relating to an identified or identifiable natural person.

     

    2. Controller

    STULZ GmbH (“we” or “us”) is the controller for the processing of personal data in the course of the use of e-STULZ. Our contact details are: STULZ GmbH, Holsteiner Chaussee 283, 22457 Hamburg, Germany, phone: +49 40 5585 0, fax +49 40 5585 352, info(at)stulz.de. You can find further details about us in the imprint.

     

    3. Data protection officer

    You can reach our data protection officer via email at: datenschutz(at)stulz.de or under our address with the addition “The data protection officer”.

     

    4. Purpose and legal basis of the data processing

    To the extent that personal data are processed in the course of the use of e-STULZ, such processing takes place for the purpose of preparation and execution of a contract, for provision and execution of all services of e-STULZ, including e-STULZ itself, as well as for customer support.

    To the extent not further specified in this Data Protection Declaration, the legal basis for the processing of your personal data in the course of the use of e-STULZ and the functions deployed there is Article 6(1)(f) GDPR. This standard of permission allows the processing of personal data as part of the “legitimate interest” of the controller. Our legitimate interest consists of providing our partners access to information on products and services, training videos and planning tools as well as the online shop to enable the best possible use of our products. To the extent your use of e-STULZ aims at the conclusion or execution of a contract, the legal basis for processing of personal data is Article 6(1)8f) GDPR. To the extent that you consent to our processing of personal data for specific purposes, your consent shall be the legal basis for such processing, Article 6(1)(a) GDPR.

    5. Data processing

     

    5.1 Technical use data

    During the use, e-STULZ automatically transfers general information to our server. This information is stored exclusively for purposes of technical administration of e-STULZ. As an example, the webserver and statistical programs used routinely store: date and time of accessing, operating system, IP address, Browser.

     

    5.2 User data

    In order to ensure that only you have access to e-STULZ, it shall be necessary for you to register with e-STULZ. For this purpose, the following data are stored: title, your first and last name, password to be set by you, your e-mail address (user name) and company name and address. In case we provided you with respective access, these data are partly used (first name, last name, user name, password, e-mail address) to log in to the Digital Asset Management (“DAM”) as well.

     

    5.3 Optional user data

    You can also enter the following optional data through your user account and update these data as needed: academic title, customer number and up to three additional address lines.

     

    5.4 Online shop

    In our online shop you may order brochures, advertising materials, STULZ-branded clothing and roll-up banner and flags. To do this you have to state your first and last name, email-address, telephone number, company, nature of the business relationship, address and different delivery address, if necessary. Your data will not be stored in our shop system, you will have to enter you data again for every new order. Depending on the agreement, you will receive an invoice for the order or we will charge you cost center.

     

    6. Analysis Tools

    6.1 Cookies

    In order to make the visit to e-STULZ attractive and to facilitate the use of certain functions, on various sites we use so-called cookies. These are small text data files that are deposited on your end device. Some of the cookies used by us are erased immediately after the end of the browser session, i.e., after closing your browser, (so-called session cookies). Other cookies remain on your end device and enable us to recognize your browser again at the next visit (so-called persistent cookies).

    You can adjust your browser so that you are informed about the placement of cookies and can decide on an individual basis whether to accept them or to preclude their acceptances in certain cases or generally. Also, you can adjust your browser so that it automatically erases cookies once the browser is closed. In the event cookies are not accepted, the functionality of e-STULZ may be reduced. The legal basis for use of technically necessary cookies by e-STULZ is our legitimate interest in maintenance of the proper operation of e-STULZ, Article 6(1)(f) GDPR.

    6.2 Google Analytics

    Apart from this, we use cookies that permit the analysis of the users’ surfing behavior. For this purpose, e-STULZ uses Google Analytics, a web-analysis service of Google, Inc. (“Google”). Google Analytics uses so-called “cookies,” text data files that are stored on your mobile end device and enable an analysis of your use of Website.

    The information generated by the cookie about your use of this site (including you IP address) is generally transferred to a Google server in the United States of America and stored there. You can find additional information about the handling of user data recorded by Google Analytics in the data privacy and security principles of Google Analytics at https://support.google.com/analytics/answer/6004245?hl=de.

    Google will use this information to evaluate your use of the Website, in order to compile reports on the Website activities and to provide further services connected to Website use and internet use for the Website operators. Google will also transfer this information to third parties if this is required by law or to the extent that third parties process these data on behalf of Google. In no case will Google combine your IP address with any other data of Google. You may prevent installation of the cookies by making the corresponding settings in your browser software; however, please note that you may be unable to fully use all functions of the Website in such a case. By using this Website, you agree to processing of the data collected concerning you by Google in the manner described above and for the purpose set forth above.

    In the event the IP anonymization on this Website is activated, your IP address will, however, first be abbreviated by Google within the member states of the European Union or in other states parties to the Agreement on the European Economic Area. Only in cases of exception will the full IP address be transferred to a Google server in the United States and abbreviated there. IP anonymization is active in e-STULZ. On behalf of the operator of e-STULZ, Google will use this information to evaluate your use of the App, in order to compile reports about the App activities and to render to the App operator services associated with the use of the App and of the internet.

    The IP address transferred by your mobile end device through Google Analytics will not be merged with other data from Google. You can prevent the storage of cookies by adjusting your mobile end device accordingly; however, we would like to point out to you that in this event, it is possible that you may not be able to use all of the functions of e-STULZ to their fullest extent. Moreover, you can prevent the recording of the data generated by the cookie and relating to your use of the Website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

    You may object to recording by Google Analytics by clicking the following link. An opt-out cookie is set that will prevent the future recording of your data when visiting this Website:

    We would like to point out to you that in e-STULZ, Google Analytics has been expanded using the code “anonymizelp” in order to guarantee an anonymized recording of IP addresses (so-called IP masking). The legal basis for this processing of your data is Article 6(1)(f) GDPR. This standard of permission allows the processing of personal data as part of our “legitimate interest” , to the extent that your fundamental rights, freedoms, or interests are not overriding. Our legitimate interest consists of the analysis of the use of e-STULZ.

     

    7. Circulation of data

    We employ service providers in the course of processing when rendering performances, particularly for providing, servicing and maintenance of IT systems. Moreover, personal data are transferred to third persons or locations only if you provided your consent or we are obligated to do so by law.

     

    8. Duration of storage

    Your personal data will be stored in our system’s log files by us to the extent that and as long as such is necessary for the processing purposes pursued by us. If you use, for example, the functions provided by us in e-STULZ, then we will store the data recorded in connection therewith until the respective use relationship has been resolved or terminated. To the extent there exist any statutory or contractual retention periods extending beyond this date, which periods provide for further storage of your data, your personal data shall be erased after expiration of the respective retention periods, insofar as you have not expressly consented to the further use of your data or unless any other legal basis entitles us to further use. The legal basis for temporary storage of the data and the log files is our legitimate interest in the proper operation and improvement of e-STULZ and in securing the safety of our information technology systems, Article 6(1)(f) GDPR. These data will not be stored together with any other personal data. A log rotating mechanism ensures that only fourteen (14) logs are stored from time to time and the respective oldest ones are overwritten.

    9. Rights of the data subject

     

    9.1 Right of access, right to rectification, erasure, restriction, and transfer

    If your personal data are processed, then you are the data subject within the meaning of the GDPR, and you are entitled to the following rights vis-à-vis the controller:

    If the statutory prerequisites are present, then you have the right to obtain from us (i) access to personal data or the processing of personal data concerning you (Article 15 GDPR); (ii) the rectification, erasure, and restriction of personal data or data processing concerning you (Articles 16 through 18 GDPR), and (iii) the transfer of personal data concerning you (Article 20 GDPR). Upon request, you would receive your personal data in a structured, commonly used, and machine-readable format. Should the erasure be contradicted by any retention duties pursuant to statute, contracts, tax law, or commercial law, or any other statutorily grounded reasons, then in lieu of the erasure, only the blocking of your data can take place.

     

    9.2 Right to lodge a complaint

    If you believe that the processing of your personal data set forth in this Data Protection Declaration infringes any statutory provision you may lodge a complaint against this, without prejudice to any other administrative or judicial remedy, with a supervisory authority, in particular in the member state of your habitual residence, place of work, or place of the alleged infringement.

    Under the following link, you can find the addresses and links of all German data protection supervisory authorities and German, European, and international data protection officers: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

     

    Information on your right to object under Article 21 GDPR

    You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(f) GDPR (data processing on the basis of our legitimate interest).

    If you object, then we shall no longer process your personal data unless (i) we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights, and freedoms, or (ii) the processing serves the establishment, exercise, or defense of legal claims. The objection can be made without using any particular form.

    To assert the aforementioned rights and/or to receive more specific information concerning them, please contact our data protection officer or contact us directly at the addresses set forth in items 2 and 3.