- Objectives and responsibilities
- Basic information on data processing and legal bases
- Security Measures
- Provision of contractual services
- Disclosure of data to third parties and third-party providers
- Comments and Contributions
- Registration and Termination
- Analysis, content and ads based on user profiles
- Collection of access data
- Cookies & Range Measurement
- Google Analytics
- Integration of third-party services and content
- User Rights
- Deletion of Data
- Right of Objection
1. Objectives and responsibilities
1.2 The provider of the Online Service and responsible for data protection is PINPOOLS GmbH, Ohligser Straße 82, 42781 Haan, Germany. Managing Directors: Alexander Lakemeyer and Heribert-Josef Lakemeyer: firstname.lastname@example.org (hereinafter referred to as ‚we‘ or ‚us‘). For further information about us and contact details, please refer to our imprint: https://de.pinpools.com/imprint
2. Basic information on data processing and legal bases
2.1 The personal user data processed within the scope of this online offer include inventory data (e.g., names and addresses of customers), contract data (e.g., services used, names of clerks, payment information), usage data (e.g., the websites visited on our online offer, interest in our products) and content data (e.g., entries in the contact form).
2.2 The term ‚user‘ covers all categories of persons affected by data processing. These include our business partners, customers, buyers, sellers, interested parties and other visitors to our online services. The terms used, such as ‚user‘, are to be understood gender-neutrally.
2.3 We process personal user data only in compliance with the relevant data protection regulations. That means, the data of the users are processed only with existence of a legal permission. I.e., in particular if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) and online services, or is required by law, a consent of the users, as well as due to our legitimate interests (i.e. interest in the analysis, optimisation and economic operation and security of our online services within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO, in particular for range measurement, the creation of profiles for advertising and marketing purposes as well as the collection of access data and the use of third-party services.
2.4 From 25.05.2018 (hereinafter referred to as ‚DSGVO deadline‘), the validity of our processing of personal data shall be determined solely in accordance with the DSGVO and then applicable data protection laws, including in particular the BDSG New. The terms and regulations of the DSGVO are already used within the scope of this data protection declaration, but their content basically corresponds to the regulations and terms of the laws valid up to the DSGVO deadline. If terms are not defined below, their meaning up to the DSGVO deadline is to be understood in the sense of the applicable data protection regulations. If, within the framework of the data protection declaration, legitimate interests within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act (DSGVO) have been taken into account, the following provisions shall apply DSGVO, § 28 (1) sentence 1 no. 2 and § 15 (3) TMG shall apply as the legal basis for our legitimate interests until the DSGVO becomes effective on 25 May 2018.
2.5 With regard to the processing of personal data on the basis of the Data Protection Ordinance (DSGVO), we would like to point out that the legal basis for the consents is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for the processing to fulfil our services and carry out contractual measures is Art. 6 para. 1 lit. b DSGVO, the legal basis for the processing to fulfil our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f DSGVO.
3. Security Measures
3.1 We shall take organisational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of the data protection laws are complied with and to protect the data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.
3.2 The security measures include in particular the encrypted transmission of personal data between your browser and our server.
4. 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 within the meaning of. Art. 6 para. 1 lit b. DSGVO.
5. Disclosure of data to third parties and third-party providers
5.1 Data shall only be passed on to third parties within the framework of the statutory provisions. We only pass on user data to third parties if, for example, this is necessary for billing purposes or for other purposes if these are necessary in order to fulfil our contractual obligations towards users.
5.2 If we use subcontractors to provide our services, we will take appropriate legal precautions and take appropriate technical and organisational measures to ensure the protection of personal data in accordance with the relevant statutory provisions.
6.1 When the user is contacting us (via contact form or e-mail), the user’s details are processed for processing the contact request and its processing.
6.2 The user data can be stored in our Customer Relationship Management System (‚CRM System‘) or comparable inquiry organisation and must be stored as business letters for 6 years due to legal requirements.
7. Comments and Contributions
7.1 If users leave reviews or comments, we will, on the basis of our legitimate interests as defined in Art. 6 Para. 1 lit. f. of the German Civil Code, make a reasonable assessment of the content of the website. DSGVO will store their IP addresses.
7.2 This is done for our safety if someone leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and contributions. In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
7.3 The authors agree to the storage of IP addresses and their use (which may include disclosure, where objectively justified) in the event that we are used by third parties.
8. Registration and Termination
8.1 Within the scope of registration by the users, the required mandatory information will be communicated to the users. This includes in particular:
E-mail address (non-public information);
Password (non-public information, stored in encrypted form);
First name and surname of the user (non-public information);
Company name (public information);
Company address (public information);
Telephone number (public information).
8.2 In addition to the above-mentioned data, each User shall decide for himself on further details which shall in principle constitute public information (except in the case of payment data);
8.3 The users‘ public profile information (which includes the company details) can be viewed and searched by other users. The User’s locations can be displayed on a map.
8.4 In the context of registration and renewed registrations as well as the 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 unauthorised 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 within the meaning of Art. 6 Para. 1 lit. c DSGVO.
8.5 The content of private messages exchanged between users is only stored for the purpose of transmission and is not otherwise processed by us.
8.6 Upon termination, we are entitled to delete the user profiles of the users. It is the responsibility of the users to secure their profile information.
8.7 With the termination of the user account, the user’s data will be deleted in accordance with the information on the termination in the GTC, provided that they concern the user account and are not stored for other legally permitted or necessary reasons (e.g. ordering processes on the basis of tax retention obligations).
8.8 It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
9. Analysis, content and ads based on user profiles
9.1 We process on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer as well as optimisation of the user experience of our online offer within the meaning of Art. 6 Para. 1 lit. f.). DSGVO the profile data of the users, as well as their contributions from offers, comments and other contributions (not however private messages), in order to indicate to them contents (e.g. news or advertisements) prepared for their potential interests.
9.2 We process usage data of our customers (e.g. the visited websites of our online offer, interest in our products as well as abandoned offer requests) in a user profile on the basis of our legitimate interests in advertising and market research purposes pursuant to Art. 6 Para. 1 lit. f DSGVO, in order to propose product information to the customer, e.g. based on the services they have used to date, by displaying it within our online offer or in order to analyse and optimise the development of our online offer.
9.3 In the context of the analysis of the submitted inquiries of buyers to sellers, we store only the information on the product and the buyer and seller. The content of the exchanged individual messages is only stored for the purpose of transmission and is not otherwise processed by us.
9.4 In order to be able to display interest-based content, so-called user profiles are created. I.e. we store e.g. the reference that the user’s company is located in Berlin and belongs to a certain branch, so that we can offer the user suitable offers for the place and branch.
10. Collection of access data
10.1 Based on our legitimate interests, we collect data about each access to the server on which this service is located (so-called server log files). Access data includes the name of the website accessed, the 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.
10.2 Log file information is stored for a maximum period of seven days for security reasons (e.g. to clarify misuse or fraud) and then deleted. Data, the further storage of which is necessary for evidence purposes, is excluded from deletion until the respective incident has been finally clarified.
11. Cookies & Range Measurement
11.1 Cookies are pieces of information that are transmitted from our web server or third-party web servers to the user’s web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. Unless expressly stated in this data protection declaration, we only use so-called ’session cookies‘, which are only stored for the duration of the current visit within our online service (e.g. to enable the storage of your login status and thus the use of our online service at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie 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 service and log out or close your browser, for example.
11.3 If the 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.
12. Google Analytics
12.2 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).
12.3 Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on activities within this website and to provide us with other services relating to the use of this website and the internet. Pseudonymous user profiles can be created from the processed data.
12.4 We use Google Analytics only with activated IP anonymization. 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.
12.6 Further information on the use of data by Google, setting and objection options can be found on the websites of Google: https://www.google.com/intl/de/policies/privacy/partners (‚Use of data by Google for your use of websites or apps of our partners‘), http://www.google.com/policies/technologies/ads (‚Use of data for advertising purposes‘), http://www.google.de/settings/ads (‚Manage information that Google uses to display advertising for you‘).
13.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the German Civil Code), we shall use the information contained in this website for our own purposes. DSGVO) the marketing and re-marketing services (short ‚Google Marketing Services‘) of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (‚Google‘).
13.2 Google is certified under the Privacy Shield Agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
13.3 Google’s marketing services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she is interested on other websites, this is referred to as ‚re-marketing‘. For these purposes, when you visit our and other websites on which Google marketing services are active, Google executes a code directly from Google and (re)marketing tags (invisible graphics or code, also known as ‚web beacons‘) are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file it is noted which websites the user visits, which contents he is interested in and which offers he has clicked, furthermore technical information about the browser and operating system, referring websites, visiting time as well as further information about the use of the online offer. The IP address of the user is also recorded, whereby we inform within the scope of Google Analytics that the IP address within member states of the European Union or in other contracting states of the Agreement on the European Economic Area is shortened and only in exceptional cases completely transferred to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google services. Google may also combine the above information with such information from other sources. If the user subsequently visits other websites, the ads tailored to the user’s interests may be displayed.
13.4 The user’s data will be processed pseudonymously within the framework of Google Marketing Services. This means, for example, that Google does not store and process the name or e-mail address of the user, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information Google Marketing Services collects about users is transmitted to Google and stored on Google’s servers in the United States.
13.5 The Google marketing services we use include the online advertising program ‚Google AdWords‘. In the case of Google AdWords, each AdWords customer receives a different ‚conversion cookie‘. Cookies cannot therefore be tracked through the websites of AdWords customers. The information collected through the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers know the total number of users who clicked on their ad and were directed to a page with a conversion tracking tag. However, you will not receive any information that personally identifies users.
13.8 We may also use the ‚Google Optimiser‘ service. Google Optimiser allows us to track how various changes to a web site affect your use of Google Optimiser through what is known as ‚A/B testing‘.
14.1 The following information will inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
14.2 Content of the newsletter: We send out newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as „newsletter“) only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information on chemical products, as well as on PINPOOLS and services offered within PINPOOLS.
14.3 Double opt-in and logging: Registration for our newsletter is carried out in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address.
14.4 Registration data: In order to subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to provide a name for the purpose of personal contact in the newsletter as well as your industry and website for the purpose of knowing our readers and adapting the newsletter content to their interests.
14.5 Statistical survey and analysis – The newsletters contain a so-called ‚web-beacon‘, i.e. a file the size of a pixel, which is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first 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. 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 nor the shipping service provider’s intention to monitor individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
14.6 The use of the shipping service provider, performance of statistical surveys and analyses as well as logging of the registration procedure shall be based on our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly and secure newsletter system which serves both our business interests and the expectations of the users.
14.7 Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consent to its dispatch will expire. You will find a link to cancel the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and cancelled their subscription, their personal data will be deleted.
15. Integration of third-party services and content
15.1 Within the scope of our online offer and 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. of the German Civil Code), we shall not be liable for any loss or damage incurred as a result of the use of, or in connection with, this online offer. DSGVO) content or service offers from third parties 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 perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. 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, among other things, technical information about the browser and operating system, referring web pages, visit times and other information about the use of our online offering, as well as may be linked to such information from other sources.
16. User Rights
16.1 Users have the right, upon request and free of charge, to obtain information about the personal data we have stored about them.
In addition, users have the right to correct inaccurate data, limit the processing and delete their personal data, if applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to lodge a complaint with the competent supervisory authority (the State Data Protection Commissioner).
16.2 Users may also revoke their consent, in principle with consequences for the future.
17. Deletion of Data
17.1 The data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the user’s data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to user data that must be stored for commercial or tax reasons.
17.2 In accordance with legal requirements, data shall be stored for 6 years in accordance with § 257 Para. 1 HGB (German Commercial Code) (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting records, etc.) and for 10 years in accordance with § 147 Para. 1 AO (German Tax Code) (books, records, management reports, accounting records, commercial and business letters, documents relevant for taxation, etc.).
18. Right of Objection
Users may at any time object to the future processing of their personal data in accordance with the statutory provisions. The objection can be made in particular against the processing for purposes of direct marketing.
19.2 Users are requested to inform themselves regularly about the content of the data protection declaration.
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