This privacy policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profiles. (hereinafter collectively referred to as "Online Offer"). With regard to the terms used, such as "personal data" or their "processing", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Person responsible
Manfred Platz
Utzschneiderstr.10
80469 München
Germany
Phone: 0157-72948549
E-mail: manfred.platz@radlguide.de
Types of data processed
Inventory data (e.g., names, addresses)
Contact data (e.g., e-mail, telephone numbers)
Content data (e.g., text entries, photographs, videos)
Contract data (e.g., subject matter of the contract, term, customer category)
Payment data (e.g., bank details, payment history)
Usage data (e.g., websites visited, interest in content, access times)
Meta/communication data (e.g., device information, IP addresses)
Processing of special categories of data (Art. 9 para. 1 GDPR)
In principle, no special categories of data are processed unless they are provided by the user for processing, e.g. entered in online forms.
Categories of data subjects affected by the processing
Customers, interested parties, suppliers, visitors and users of the online offer
In the following, we also refer to the data subjects collectively as "users".
Purpose of the processing
Provision of the online offering, its content and functions
Provision of contractual services, service and customer care
Responding to contact requests and communicating with users
Marketing, advertising and market research
Security measures
1. Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
2. Changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as 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.
3. Security measures
We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk; the measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and their separation. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
The security measures include, in particular, the encrypted transmission of data between your browser and our server.
4. Cooperation with processors and third parties
If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission, if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.
5. Transfers 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 occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done 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 if the special requirements of Art. 44 et seq. GDPR are met.
This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
6. Rights of the data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
Accordingly Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.
You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other controllers.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.
You have the right to withdraw your consent in accordance with Art. 7 para. 3 GDPR with effect for the future.
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for direct marketing purposes.
7. Cookies and right to object to direct advertising
We use temporary and permanent cookies, i.e. small files that are stored on users' devices (for an explanation of the term and function, see the last section of this privacy policy). Some of the cookies are used for security purposes or are necessary for the operation of our online services (e.g. to display the website) or to save the user's decision when confirming the cookie banner. We or our technology partners also use cookies to measure reach and for marketing purposes.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, processing for marketing and analysis purposes can be deactivated for external services when you first enter the website. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that you may then not be able to use all the functions of this website.
You can change your data protection settings here: Data protection settings.
8. Deletion of data
The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, 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. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
In accordance with legal requirements, storage is carried out in particular for 6 years in accordance with Section 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).
9. Provision of contractual services
We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.
In the context of registration and renewed logins as well as the use of our online services, we store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests and those of the user to protect against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c GDPR.
The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
According to legal requirements, data is stored for 6 years in accordance with Section 257 (1) HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
10. Contacting us
When contacting us (via booking form, contact form or e-mail), the user's details are processed to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.
The user's details may be stored in our customer relationship management system (“CRM system”) or a comparable inquiry organization.
We delete the inquiries if they are no longer required. We review the necessity every two years; we store inquiries from customers who have a customer account permanently and refer to the information on the customer account for deletion. 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).
11. Comments and contributions
If users leave comments or other contributions, their IP addresses are stored on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR for 4 weeks. GDPR for 4 weeks.
This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
12. Collection of access data and log files
We collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we collect data about every 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.
Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum period of 4 weeks and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
13. Online presences in social media
We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of the respective operators apply.
Unless otherwise stated in our privacy policy, we process users' data if they communicate with us within social networks and platforms, e.g. write posts on our online presences or send us messages.
14. Cookies & reach measurement
Cookies are pieces of information that are transferred from our web server or third-party web servers to the user's web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.
We use “session cookies”, which are only stored for the duration of the current visit to our online presence (e.g. to enable the storage of your login status or the shopping cart function and thus the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and, for example, log out or close the browser.
Users are informed about the use of cookies in the context of pseudonymous reach measurement in this privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored 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 can object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the network advertising initiative (https://optout.networkadvertising.org) and additionally the US website (https://www.aboutads.info/choices) or the European website (https://www.youronlinechoices.com/uk/your-ad-choices/).
15. Google Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analytics service provided by Google. GDPR) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (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 offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics to display the ads placed by Google and its partners within advertising services only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users and are not annoying.
The IP address transmitted by the user's browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
Further information on the use of data by Google, setting and objection options can be found on Google's websites:
https://www.google.com/intl/de/policies/privacy/partners ("Data use by Google 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 information that Google uses to show you advertising”).
16. Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR) content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor 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. Pixel tags can be used to analyze 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, among other things, 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 being linked to such information from other sources.
The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):
PayPal: The PayPal service is provided by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. When paying with PayPal, you will be redirected to the PayPal website via a link. To use this service, PayPal collects, stores and processes your personal data such as your name, address, telephone number and e-mail address as well as your credit card or bank account details. PayPal is solely responsible for the protection and handling of the data collected by PayPal. In this respect, the PayPal terms of use apply, which you can access at http://www.PayPal.com. Further information on the handling of your data and the possible commissioning of third parties can be found in PayPal's privacy policy, which is available at the following link: https://www.paypal.com/de/webapps/mpp/ua/privacy-full