Privacy Notice

data protection

We appreciate your interest in our website. The security of your data is important for us. Therefore, we would like to inform you below which data of your visit we use for which purposes.

Data protection:

As of: December 15, 2018

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "Data") within our online offering and the related websites, features and content, as well as external online presence, e.g. our social media profiles on. (collectively referred to as "online offer"). With regard to the terminology used, e.g. "Personal data" or their "processing", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible:

Professor h.c. lamp

3001 Rocky Point Drive East

33607 Florida

[email protected]

 

Types of processed data:

Inventory data (e.g., names, addresses)

Contact details (e.g., e-mail, phone numbers)

Content data (e.g., text input, photographs, videos)

Contract data (e.g., subject, term, customer category)

Payment data (e.g., bank details, payment history)

Usage data (e.g., visited web pages, interest in content, access times)

Meta / communication data (e.g., device information, IP addresses)

Hereinafter, if not further described, referred to as "data".

Processing of special categories of data (Article 9 (1) GDPR):

In principle, no special categories of data are processed unless these are sent by the users to the processing, e.g. entered in online forms.

Categories of data subjects:

Customers / prospects / suppliers.

Visitors and users of the online offer.

In the following, we also refer to the affected persons as users.

Purpose of processing:

Provision of the online offer, its contents and functions.

Provision of contractual services, service and customer care.

Answering contact requests and communicating with users.

Marketing, advertising and market research.

 

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adjust the privacy policy as soon as the changes to the data processing we make require it. We will notify you as soon as the changes require your participation (eg consent) or other individual notification.

Safety measures

We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection commensurate with the risk; Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and disconnection. We have also set up procedures to ensure data subject awareness, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection by technology design and privacy-friendly default settings taken into account (Article 25 GDPR).

The security measures include in particular the encrypted transmission of data between your browser and our server.

Collaboration with processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant access to the data, this is done only on the basis of a legal permission (eg if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) DSGVO), you have consented to a legal obligation or on the basis of our legitimate interests (eg the use of agents, webhosters, etc.).

Insofar as we commission third parties to process data on the basis of a so-called "contract processing contract", this is done on the basis of Art. 28 GDPR.

 

Transfers to third countries

If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special requirements of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

Rights of data subjects

You have the right to request a confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted without delay, or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other responsible persons.

You have gem. Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.

Withdrawal

You have the right to consent according to. Art. 7 para. 3 DSGVO with effect for the future.

right to

You may at any time object to the future processing of your data in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right to object to direct mail

We set temporary and persistent cookies, i. small files that are stored on users' devices a (explanation of the term and function, see last section of this Privacy Policy). In part, the cookies are used for security or to operate our online offer (e.g., for the presentation of the website) or to save the user's decision in the confirmation of the cookie banner. In addition, we or our technology partners use cookies for measuring reach and marketing purposes, which users are informed about in the course of the privacy policy.

A general objection to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.

Deletion of data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legally permitted purposes, its processing will be restricted. That the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.

According to legal requirements, the storage takes place in particular for 6 years in accordance with § 257 paragraph 1 HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and for 10 years in accordance with § 147 Abs. 1 AO (books, records, management reports , Accounting documents, commercial and business letters, tax documents, etc.).

 

Provision of contractual services

We process inventory data (e.g., names and addresses and contact details of users), contract data (e.g., services used, names of contacts, payment information) to fulfill our contractual obligations and services in accordance with Art. Art. 6 para. 1 lit b. DSGVO. The entries marked as obligatory in online forms are required for the conclusion of the contract.

Users can optionally create a user account, in particular by being able to view their orders. As part of the registration, the required mandatory information will be communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. It is the responsibility of the users to secure their data upon termination prior to the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO.

We process usage data (e.g., the visited web pages of our online offering, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile to inform the user e.g. To display product information based on their previously used services.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the storage of the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after their expiration (end of commercial law (6 years) and tax law (10 years) retention obligation); Information in the customer account remains until it is deleted.

contact

When contacting us (via contact form or e-mail), the information provided by the user to process the contact request and its processing acc. Art. 6 para. 1 lit. b) DSGVO processed.

We delete the requests, if they are no longer required. We check the requirement every two years; Inquiries from customers who have a customer account, we store permanently and refer to the deletion on the details of the customer account. In the case of legal archiving obligations, the deletion takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation).

 

Comments, posts and ratings

If users leave comments or other contributions, their IP addresses are based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO saved.

This is for our own safety, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we may be sued for the comment or post and are therefore interested in the identity of the author.

 

Collection of access data and log files

Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider ,

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of seven days and then deleted. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.

 

Online presence in social media

Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Online presence within social networks and platforms in order to communicate with the active customers, prospects and users and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.

Unless otherwise stated in our Privacy Policy, we process users' data as long as they communicate with us within social networks and platforms, e.g. Write posts on our online presence or send us messages.

 

Cookies & reach measurement

Cookies are information transmitted by our web server or third-party web servers to users' web browsers and stored there for later retrieval. Cookies can be small files or other forms of information storage.

We use "session cookies" that are only stored for the duration of the current visit to our online presence (for example, to enable the storage of your login status or the shopping cart function and thus the use of our online offer). In a session cookie a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the retention period. These cookies can not save other data. Session cookies will be deleted when you have finished using our online offer and you are e.g. log out or close the browser. We also use "Persistent Cookies". They are automatically deleted after a specified period, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

The use of cookies in the context of pseudonymous range measurement informs users in the context of this privacy policy.

If users do not want cookies stored on their machine, they will be asked to disable the option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

You may opt for the use of cookies for distance measurement and promotional purposes through the Network Advertising Initiative's opt-out page (http://optout.networkadvertising.org/) and in addition to the US website (http://www.aboutads.info/choices ) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

 

Google Analytics

We use Google Analytics, a web analytics service of Google LLC ("Google"), based on our legitimate interests (that is, interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offering and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.

We use Google Analytics to display the advertisements displayed within Google and its affiliate advertising services, only those users who have shown an interest in our online offering or who have certain characteristics (eg, interest in specific topics or products that they use) Web pages) that we submit to Google (so-called "remarketing" or "Google Analytics audiences"). With Remarketing Audiences, we also want to make sure that our ads are in line with the potential interest of users and are not annoying.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users 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 sent to a Google server in the US and shortened there.

The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https: // tools .google.com / dlpage / gaoptout? hl = en.

For more information about Google's data usage, hiring and opt-out options, please visit Google's websites: https://www.google.com/intl/en/policies/privacy/partners ("Google's use of your data when you use websites or apps our partners "), https://policies.google.com/technologies/ads (" Use of data for promotional purposes "), https://adssettings.google.com/authenticated (" Manage information that Google uses to show you advertising ").

Google Re / marketing services

On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we use the marketing and remarketing services ("Google Marketing Services "), LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (" Google ").

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. If a user e.g. Showing ads for products he's been interested in on other websites is called remarketing. For these purposes, when Google and our other websites access Google Marketing Services, Google immediately codes Google and becomes so-called (re) marketing tags (invisible graphics or code, also known as Web Beacons ") incorporated into the website. With their help, the user is provided with an individual cookie on the device. a small file is saved (instead of cookies, comparable technologies can be used). Cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file is noted which websites the user visited, for what content he is interested and what offers he has clicked, as well as technical information about the browser and operating system, referring websites, visit time and other information on the use of the online offer. The IP address of the users is also recorded, whereby in the context of Google Analytics we announce that the IP address is shortened within member states of the European Union or other parties to the Agreement on the European Economic Area and only in exceptional cases to one Google server in the United States transferred and shortened there. The IP address will not be merged with data of the user within other offers from Google. The above information may also be linked by Google with such information from other sources. If the user subsequently visits other websites, they may be shown according to his interests, the ads tailored to him.

The data of the users are pseudonym processed in the context of the Google marketing services. That Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google's servers in the United States.

Among the Google marketing services we use is u.a. the online advertising program "Google AdWords". In the case of Google AdWords, each advertiser receives a different "conversion cookie". Cookies can not be tracked through the websites of advertisers. The information gathered through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive any information that personally identifies users.

We can incorporate third-party ads based on the Google Double-Click marketing service. Double-Click uses cookies that allow Google and its affiliate websites to serve ads based on users' visits to this site or other sites on the Internet.

Also we can use the service "Google Optimizer". Google Optimizer allows us to "A / B-Testings" to understand how various changes to a website affect (for example, changes in the input fields, the design, etc.). Cookies are stored on users' devices for these purposes. Only pseudonymous data of the users are processed.

In addition, we may use the "Google Tag Manager" to integrate and manage the Google Analytics and Marketing Services on our website.

For more information about Google's data usage for marketing purposes, visit the overview page: https://policies.google.com/technologies/ads, Google's Privacy Policy is available at https://policies.google.com/privacy.

If you wish to opt-out of interest-based advertising through Google Marketing Services, you can use the recruitment and opt-out options provided by Google: https://adssettings.google.com/authenticated.

Google Recaptcha

In order to ensure sufficient data security when submitting forms and to ward off spam, bots and viruses, we sometimes use the re-CAPTCHA service provided by Google Inc. on our website. This serves primarily to distinguish whether the input is done by a human or abusive by automated, machine processing. The query includes the sending of the IP address and, if necessary, other data required by Google for the re-CAPTCHA service to Google. For this purpose, your input will be transmitted to Google and used there.

However, if IP anonymisation is activated on this website, your IP address will be truncated by Google beforehand 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 sent to a Google server in the US and shortened there.

Google will use this information on behalf of the operator of this website to evaluate your use of this service. The IP address provided by re-Captcha from your browser will not be merged with other data provided by Google. This data is subject to Google's different privacy policy: https://policies.google.com/privacy

Newsletter

With the following information we inform you about the content of our newsletter as well as the registration, shipping and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Insofar as the content of a newsletter is concretely described in the context of an application for the newsletter, it is decisive for the consent of the user. Incidentally, our newsletters contain information about our products, offers, promotions and our company.

Double opt-in and logging: Registration for our newsletter is done in a so-called double opt-in procedure. That After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the logon and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.

Furthermore, the shipping service provider may, according to its own information, transmit these data in pseudonymous form, i. without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletters or for statistical purposes to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write them down or to pass them on to third parties.

Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.

Measuring success: The newsletters contain a so-called "web beacon", i. a pixel-sized file, which is retrieved from the server of the shipping service provider when the newsletter is opened. As part of this call, technical information, such as information about the browser and your system, as well as your IP address and time of the call are collected. This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the 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 endeavor nor that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The dispatch of the newsletter and the measurement of success are based on the consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 DSGVO in connection with § 7 Abs. 2 Nr. 3 UWG or on the basis of the legal permission acc. § 7 Abs. 3 UWG.

The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to the receipt of the newsletter.

Termination / Revocation - Newsletter recipients may terminate the receipt of our newsletter at any time, ie. Revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. At the same time, their consent to success measurement expires. A separate revocation of the performance measurement is unfortunately not possible, in this case, the entire newsletter subscription must be terminated. With the deregistration of newsletter, the personal data will be deleted, unless their retention is legally required or justified, in which case their processing is limited to these exceptions. In particular, we may save the e-mail addresses for up to three years on the basis of our legitimate interests before we delete them for purposes of newsletter delivery, in order to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Integration of services and contents of third parties

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Services, such as Include videos or fonts (collectively referred to as "content"). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to 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 include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.

The following presentation provides an overview of third-party providers as well as their contents, as well as links to their data protection statements, which further notes on the processing of data and, for already mentioned here, contradictory possibilities (so-called opt-out) contain:

If our customers use the payment services of third parties (such as Transferwise or similar), the terms and conditions and the privacy notices of the respective third party providers, which are retrievable within the respective websites, or transactional applications apply.

For payment in advance and purchase on account, the payment is processed by comfort cash. In this case, we pass on required personal data to LTC Information Services GmbH. The privacy policy of Komfortkasse can be found here: https://komfortkasse.eu/datenschutz. The transfer of data is solely for the purpose of payment.