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Privacy Policy

 

We attach great importance to the protection of your personal data. That’s why we respect your privacy and want you to be able to trust us as much when it comes to data protection. We always inform you transparently about what we need your data for and if and for how long we store it. This allows you to decide for yourself for which purposes we may use your data. To ensure the best possible security, the information is always transmitted to us in encrypted form. If you no longer wish us to use your data, please let us know informally, for example by email.

LIST OF CONTENT

  1. General Information

1.1.     Processing of Personal Data

1.2.     Controller

1.3.     Rights of the Data Subject

1.4.     Disclosure to Authority

  1. Collection and Processing of Personal Data when visiting our Website

2.1.     Cookies

2.2.     Web Analytics

2.3.     Social Plug-ins

2.4.     Social Login

2.5.     YouTube-Videos

2.8.     Captchas

2.9.     Google Maps

  1. Further services offered (on- and offline)

3.1.      Contacting/Communication/Collaboration

3.2.      Campaigns

3.3.      Postal mailings

3.4.      News letters

3.5.      Surveys

  1. Objection or Withdrawal of your consent to the Processing of Personal Data

GENERAL INFORMATION

The purpose of this privacy policy is to provide you with information concerning the processing of personal data when using our website and related services. This privacy policy applies to all websites or services that refer to this privacy policy.

1.1. Processing of Personal Data

Personal data within the meaning of Art. 4 of the EU General Data Protection Regulation (GDPR) are all information relating to an identified or identifiable natural person, e.g. name, address, email address, etc.

1.2. Controller

Responsible for the processing of personal data within the meaning of Art. 4 (7) GDPR is: The Director, Thrimana Publications (Pvt) Ltd, 09, Jayagath Rd, Nawinna, Maharagama.

Contact details:  admin[at]thrimana[dot]lk or under the postal address of the controller for the attention of the “data protection”.

1.3. Rights of the Data Subject

As data subject affected by the data processing activity, you have the following rights with regard to your personal data in accordance with the legal provisions:

Right of access;

Right to rectification and to erasure;

Right to restriction of processing;

Right to data portability; and

Right to object.

Furthermore, you have the right to lodge a complaint with a supervisory authority concerning the processing of your personal data.

When we work on your above-mentioned right, we may ask you for proof of your identity. For more information on how we process your data, see 3.1.

1.4. Disclosure to Authority

In the event of a legal obligation, we reserve the right to disclose information about you if we are required to surrender it to competent authorities or law enforcement bodies.

Legal basis:

Art. 6 (1) c) GDPR (legal obligation)

  1. COLLECTION AND PROCESSING OF PERSONAL DATA WHEN VISITING OUR WEBSITE

When visiting and using our website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server, which are technically necessary for us to display our website to you and to guarantee stability and security.

We transfer the collected data to the relevant internal departments for processing and/or to external service providers, contractors (e.g. hosting, content management system) in accordance with the purposes required (for displaying the website and setting up its content).

The deletion of the log files takes place after 7 days.

Legal basis:

Art. 6 (1) f GDPR (legitimate interest)

2.1. Cookies

In addition to the aforementioned data, cookies or other technologies like pixels (hereinafter referred to as “Cookies”) are used on your computer when visiting and using our website. Cookies are small text files that are stored by your browser on your device to save certain information or image files, such as pixels. The next time you visit our website on the same device, the information saved in the cookies will subsequently be transmitted either to our website (“First Party Cookie”) or to another website to which the cookie belongs (“Third Party Cookie”).

Through the information saved and returned, the respective website recognizes that you have already accessed and visited it with the browser you use on that device. We use this information to be able to design and display the website in an optimum way in line with your preferences. In that respect, only the cookie itself is identified on your device. Beyond this extent, your personal data will only be saved upon your express consent or if it is strictly necessary to be able to use the service offered to and accessed by you accordingly.

This website uses the following types of cookies, the scope and functionality of which are explained below:

  • Technical cookies (Type A)
  • Functional and Performance Cookies (Type B)
  • Consent based Cookies (e.g. Marketing) (Type C)

You can find more information on the cookie types set and used in the description of the tools implemented on our websites in this privacy policy.

2.1.1. Technical cookies (Type A)

Technical cookies guarantee functions without which you cannot use our web pages as intended. These cookies are used exclusively by us and are therefore first party cookies. This means that all information stored in the cookies will be returned to our website.

Technical cookies serve, for example, to ensure that you as a registered user always remain logged in when accessing various subpages of our website and thus do not have to re-enter your login data every time you access a new page.

The use of technical cookies on our website is possible without your consent. For this reason, technical cookies cannot be activated or deactivated individually. However, you can deactivate cookies in your browser at any time (see below).

Legal basis:

Art. 6 (1) b GDPR. (situation similar to a contract)

2.1.2. Functional and Performance Cookies (Type B)

Functional cookies enable our website to store information already provided (such as registered name or language selection) and to offer you improved and more personalized functions based on this information. These cookies collect and store only pseudonymized information so that they cannot track your movements on other websites.

Performance cookies collect information about how our websites are used in order to improve their attractiveness, content and functionality. These cookies help us, for example, to determine whether and which subpages of our website are visited and in which content users are particularly interested. In particular, we record the number of visits to a page, the number of subpages accessed, the time spent on our website, the order of the pages visited, which search terms led you to us, the country, region and, if applicable, the city from which access is made, and the proportion of mobile devices accessing our websites. We also capture movement, clicks and scrolling with the computer mouse to understand which areas of our website are of particular interest to users. As a result, we can tailor the content of our website more specifically to the needs of our users and optimize our offering. The IP address of your computer transmitted for technical reasons is automatically made anonymous and does not allow us to draw any conclusions about the individual user.

The functional and performance cookies are so-called “strictly necessary” cookies within the meaning of the ePrivacy Directive 2002/58 EC, which do not require consent.

Legal basis:

Art. 6 (1) f GDPR. (legitimate interest)

2.1.3. Consent based Cookies (Type C)

Cookies, which are neither technical Cookies (Type A) nor functional or performance cookies (Type B) will be used only upon your express consent, e.g. marketing cookies.

We also reserve the right to use information that we have obtained by means of cookies from an anonymous analysis of the usage behavior of visitors to our website in order to display specific advertising for certain of our products on our own websites. We believe that you as a user benefit from this because we display advertising or content that we think suits your interests based on your surfing behavior, so that you will see less randomly scattered advertising or certain content that might be of less interest to you.

Marketing cookies come from external advertising companies (third party cookies) and are used to collect information about the websites visited by the user in order to create target group-oriented advertising for the user.

Opt-out for cookies used for online advertising

You can also manage many companies’ cookies used for online advertising via the consumer choice tools created under self-regulation programs in many countries, such as the US-based https://www.aboutads.info/choices/ or the EU-based http://www.youronlinechoices.com/uk/your-ad-choices.

You can withdraw your consent to the use of consent-based cookies (Type C) individually at any time with effect for the future by adjusting your cookie settings accordingly.

Legal basis:

Art. 6 (1) a GDPR. (consent)

2.1.4. Administration and deletion of all cookies

You can set your web browser in such a way that cookies are generally prevented from being saved to your device and/or that you are asked each time whether you are in agreement with cookies being enabled. You can also at any time delete cookies that have been enabled again. You can find out how all this works in detail from your browser’s help function.

Please note that generally deactivating cookies may lead to functional restrictions of our website.

2.2. Web Analytics

2.2.1. Google Analytics

Purpose/Information

This website uses Google Analytics, a web analysis service of Google LLC. (“Google”). Google Analytics uses a specific form of cookie, which is stored on your computer and enables an analysis of your use of our website. The information about your use of this website generated by the cookie is generally transmitted to a Google server in the USA and stored there.

We would like to point out that Google Analytics has been expanded on this website to include the code “gat._anonymizeIp();” to ensure the anonymized recording of IP addresses (so-called IP masking). Due to the IP anonymization on this website, your IP address is shortened by Google within the territory of the EU and the Treaty States of the European Economic Area. Only in exceptional cases the full IP address is transmitted to a Google server in the USA and shortened there.

Google uses this information on our behalf to analyze your use of this website in order to compile reports on website activities and provide additional services related to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

We use Google Analytics to analyze and regularly improve the usage of our website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. In addition, we gain information about the functionality of our site (for example to detect navigation problems).

In the configuration of Google Analytics, we ensured that Google receives this data as a processor and is therefore not allowed to use this data for its own purposes. The “Google Analytics Advertising Features” configuration is independent from this and is described in the appropriate section below, provided it is also used on this website.

Used Cookies: Type B. For further information, see Cookie Section.

Recipients:

Third party information: Google LCC, 1600 Amphitheatre Parkway, Mountain View, CA phone (650) 253-0000.

Google Analytics Terms of Service: https://www.google.com/analytics/terms/gb.html, General overview on Google Analytics security and privacy principles: https://support.google.com/analytics/answer/6004245?hl=en, as well as Google’s privacy policy: https://policies.google.com/privacy?hl=en.

Transfer to third countries is possible. As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

Further recipients: We transfer the collected data to the relevant internal departments for processing and/or to external service providers, contract processors (e.g. platform, hosting, support and analysis service providers) in accordance with the required purposes (to perform analyses). Platform/hosting providers will have access to personal data from a third country (countries outside the European Economic Area). As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR with these providers. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

You can prevent the storage of cookies by making the proper setting using your browser software. In addition, you can prevent Google from recording the data related to your use of the website generated by the cookie (including your IP address) and from processing this data by downloading and installing the browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Cookie lifetime: up to 12 months (this applies only to cookies which have been set by this website)

Maximum storage period of data: up to 26 months.

Legal basis:

Art. 6 (1) f GDPR. (legitimate interest)

2.2.2. A/B Testing

Purpose/information:

This website also carries out analyses of user behavior via a so-called A/B testing. We can show you our websites with slightly varied content, depending on your profile assignment. This enables us to analyze and regularly improve our services and make them more interesting for you as a user.

Cookies are stored on your computer for these analyses. The information collected in this way is stored exclusively on a server in the EU. You can prevent the storage of cookies by making the proper setting using your browser software.

Before the analyses are carried out, the IP addresses are further processed in abbreviated form, so that direct personal contact can be ruled out. The IP address transmitted by your browser is not merged with other data collected by us.

Used Cookies: Type B. For further information, see Cookie Section.

Recipients:

The data is accessible by our analytical service providers based in the EU.

Deletion/objection:

Cookie lifetime: up to 2 years (this applies only for cookies which have been set by this website)

Maximum storage period of data: up to 25 months.

Legal basis:

Art. 6 (1) f GDPR. (legitimate interest)

2.3. Social Plug-ins

Social plug-ins (“plug-ins”) of social networks are used on our websites, in particular the “Share” or “Share with friends” button of Facebook, whose website facebook.com is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. The plug-ins are usually marked with a Facebook logo.

Besides Facebook, we use plug-ins from “Twitter” (Provider: Twitter, Inc., 1355 Market St, Suite 900, San Francisco, CA 94103), “Instagram” (Provider: Instagram, 1601 Willow Road, Menlo Park, CA 94025 ), “YouTube” (Provider: YouTube, LLC 901 Cherry Ave. San Bruno, CA 94066 USA),”WhatsApp” (Provider: WhatsApp LLC, Privacy Policy, 1601, Willow Road, Menlo Park, CA 94025 USA ) and “Pinterest” (Provider: Pinterest Inc., 808 Brannan Street San Francisco, CA 94103, USA).

By clicking on the respective button (e.g. “Pass on”, “Share” or “Share with friends”) you agree that your browser will produce a link to the respective social network’s servers and transmit usage data to the respective operator of the social network and vice versa. We have no influence upon the nature and extent of the data that is then gathered by the social networks.

The social network providers store the data collected about you as user profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation takes place in particular (also for not logged in users) for the representation of demand-fair advertisement and in order to inform other users of the social network about your activities on our website. You have a right of objection to the creation of these user profiles, whereby you must contact the respective plug-in providers to exercise this right.

The data is transferred regardless of whether you have an account with the plug-in providers and are logged in there. If you are logged in with the plug-in provider, your data collected with us will be directly assigned to your existing account with the plug-in provider. If you click the activated button and, for example, link the page, the plug-in providers also store this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button, as this way you can avoid being assigned to your profile with the plug-in provider.

For more information on the purpose and scope of data collection and its processing by the plug-in provider, please refer to the data protection declarations of these providers as notified below. They will also provide you with further information about your rights in this regard and setting options to protect your privacy.

  1. a) Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA;http://www.facebook.com/policy.php more information on the data collection: http://www.facebook.com/help/186325668085084http://www.facebook.com/about/privacy/your-info-on-other#applicationsas well as http://www.facebook.com/about/privacy/your-info#everyoneinfo
  2. b) Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA ; https://twitter.com/en/privacy
  3. c) Pinterest Inc., 808 Brannan Street San Francisco, CA 94103, USA); https://policy.pinterest.com/en/privacy-policy
  4. d) Facebook, Inc. ATTN: Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025 ; https://help.instagram.com/519522125107875
  5. e) YouTube, LLC 901 Cherry Ave. San Bruno, CA 94066 USA ; https://policies.google.com/privacy?hl=en-US
  6. f) WhatsApp LLC, Privacy Policy, 1601, Willow Road, Menlo Park, CA 94025 USA; https://www.whatsapp.com/legal/updates/privacy-policy/?lang=en

2.5. YouTube-Videos

We have integrated YouTube videos into our website, which are stored on http://www.youtube.com and can be played directly from our website. These are all integrated in the “extended data protection mode”, i.e. no data about you as a user will be transmitted to YouTube, if you do not click on the videos to start playing them. Only when you play the videos the data referred to in the next paragraph will be transferred to YouTube. We have no influence on this data transfer.

By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data specified in Section 2 of this privacy policy will be transmitted. This is independent of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. YouTube stores your data as user profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation takes place in particular (even for unlogged-in users) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

For more information on the purpose and scope of data collection and processing by YouTube, please refer to the privacy policy. There you will also find further information about your rights and setting options to protect your privacy:

https://www.google.com/intl/en/policies/privacy. Transfers to third countries are possible. As an appropriate safeguard standard contractual clause pursuant to Art. 46 GDPR apply. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

2.6.5. (Website) Facebook Custom Audiences / Conversion (“Facebook Pixel”)

Information/purpose:

This website uses the so-called “Facebook Pixel” of the social network “Facebook” for the following purposes:

  • Facebook (website) Custom Audiences

We use the Facebook pixel for remarketing purposes to be able to contact you again within 180 days. This allows us to display interest-based advertisements (“Facebook Ads”) to users of the website when they visit the social network “Facebook” or other websites also using this tool. In this way, we pursue the interest in displaying advertisements that are of interest to you in order to make our website or offers more interesting for you.

  • Facebook conversion

We also use the Facebook Pixel to ensure that our Facebook Ads match the potential interest of users and are not annoying. With the help of the Facebook Pixel, we can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

Due to the marketing tools used, your browser automatically establishes a direct connection with the Facebook server as soon as you have agreed to the use of cookies requiring your consent. Through the integration of the Facebook pixel, Facebook receives the information that you have called up the corresponding website of our internet presence or clicked on an advertisement from us. If you are registered with a Facebook service, Facebook can assign the visit to your account.

The processing of this data by Facebook takes place within the framework of Facebook’s data policy. Special information and details about the Facebook pixel and its functionality can also be found in the Facebook help area.

Used Cookies: Type C. For further information, see Cookie Section.

The process that takes place after the collection and transmission is within the sole responsibility of Facebook

The preparation of reports and analyses in aggregated and anonymized form is carried out as a Processor and is therefore within our responsibility.

The contact details of the Controller and the data protection officer of Facebook can be found here: https://www.facebook.com/about/privacy.

We have agreed with Facebook that Facebook can be used as a contact point for the exercise of data subject rights (see Section 1.3). Without prejudice to this, the jurisdiction of the Rights of Data Subjects is not limited.

Further information on how Facebook processes personal data, including its legal basis and further information on the rights of data subjects can be found here: https://www.facebook.com/about/privacy.

Information on the data security conditions can be found here. https://www.facebook.com/legal/terms/data_security_terms and on processing on the basis of standard contractual clauses can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum.

Further Recipients:

We transfer also the collected data to the relevant internal departments for processing and /or to external service providers, contract processors (e.g. platform-, hosting, support and analysis service providers) in accordance with the required purposes (for the execution of ad display and analysis). Platform/hosting providers will have access to personal data from a third country (countries outside the European Economic Area). As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR with these providers. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

Deletion/Withdrawal:

The “Facebook Custom Audiences” function can be deactivated in the Cookie Settings and for logged in users at https://www.facebook.com/settings/?tab=ads#.

Cookie lifetime: up to 180 days after last interaction (this applies only to cookies which have been set by this website)

Legal basis:

Art. 6 (1) a GDPR (consent)

2.8. Captchas

This website uses in specific cases the Google reCAPTCHA v2 to avoid the usage of text fields by automated programs/bots. It helps to support the security of our website and to avoid SPAM for the users. This is also our legitimate interest and fulfills our legal obligation.

The collected data are hardware and software information, such as device and application data and the result of integrity checks. These data will be sent to Google. The data will not be used by Google for personalized ads.

Further information can be found in their privacy policy: https://policies.google.com/privacy. Further documentation can be found here: https://developers.google.com/recaptcha/, https://www.google.com/recaptcha/admin/create

Legal basis:

Art. 6 (1) c GDPR (when processing is necessary for compliance with a legal obligation)

Art. 6 (1) f GDPR (when processing according to the legitimate interest described above)

2.9. Google Maps

Information/Purpose:

This website uses the mapping service Google Maps. When using the feature information is transferred to Google and analyzed for their purposes. As a rule, this information includes your IP address and the possibility that it will be transferred to one of Google’s servers in the USA. We use Google Maps to make the locations disclosed on our website easy to find. This constitutes our legitimate interest pursuant to Art. 6 (1) f GDPR.

More information on the processing of your data by Google can be found here: https://www.google.com/intl/en/policies/privacy

Legal basis:

Art. 6 (1) f GDPR (legitimate interest)

 

  1. FURTHER SERVICES OFFERED (ON- AND OFFLINE)

In addition to the purely informational use of our website, we offer various other services, for which we process your personal data.

If we use contracted service providers for individual functions of our offer or would like to use your data for advertising purposes, we will inform you in detail about the respective processes below.

External service providers have been carefully selected and commissioned by us, are bound by our instructions and are regularly checked.

We may also disclose your personal data to third parties when we offer promotions, contracts or similar services in conjunction with partners. Further information can be obtained at the time when you provide the data or in the description of the services below.

Contrary to 1.2, in some cases Thrimana Books is Controller for the services offered below, which has already been named to you as part of the communication. If reference is therefore made to sections of this privacy policy, e.g. by link, and a Controller has already been named, e.g. in the footer/signature of an e-mail or campaign card, this person is the Controller in accordance with. Art. 4 No. 7 GDPR.

If our service providers are based in the country outside, international data transfers can occur. We will inform you of the consequences of this circumstance in the description of the service below.

3.1. Contacting/Communication/Collaboration

Purpose / Information:

When communicating and/or collaboration with us, e.g. by email or via contact form on our website, data exchange platform, be it e.g. as a consumer, test person, business partner or customer, the data you provide (your email address, if applicable your name and your telephone number, or personal data submitted during the conversation) will be stored and processed by us in order to e.g. answer your questions, requests or for the purpose of business related correspondence.

When processing data arising in the course of communication, we have a legitimate interest in processing the data in accordance with legal requirements, for internal verification or in accordance with the respective communication request.

Recipients:

In order to combat terrorism, we are obliged by law to carry out a comparison with sanctions lists. Therefore, we also process your data to meet legal requirements for comparison with these lists. Furthermore, we process your data in the Thrimana Books for the prevention and investigation of criminal offences and other misconduct, the assessment and control of risks, for internal communication and for corresponding administrative purposes. If you are a business partner, we regularly check your creditworthiness in certain cases (e.g. when concluding contracts). Our legitimate interest is the minimization of the financial risk. For this purpose, we cooperate with credit agencies from which we receive the necessary data. For this purpose, we transmit your name and your contact data to the credit agencies.

If you are a business customer or partner, it may be necessary to transfer your personal data to prospective buyers as part of a company transaction. In the course of due diligence, usually anonymized data is processed. However, it may be necessary in specific individual cases to process personal data. Our legitimate interest lies in the execution of the company transaction.

We transfer the collected data to the relevant internal departments for processing and/to external service providers, contract processors (e.g. hosting, call center service providers) in accordance with the purposes required (e.g. for establishing contacts, business related correspondence and customer care). Platform/hosting providers will have access to personal data from a third country (countries outside the European Economic Area). As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR with these providers. More information on this topic is published here:

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

Deletion /Objection:

We delete the data arising in this context once storage is no longer necessary, unless statutory retention obligations exist or periods of limitation must be observed.

In case of consumer inquiries through our internal consumer management tool the personal data will be usually deleted after one year. As an exception, the data will be kept longer if the data is necessary for the establishment, exercise or defense of legal claims.

You can object to these processes according to the requirements under 4.

Legal basis:

Art. 6 (1) b GDPR (when processing in the context of a contract or a situation similar to a contract)

Art. 6 (1) c GDPR (when processing is necessary for compliance with a legal obligation)

Art. 6 (1) f GDPR (when processing according to the legitimate interest described above)

3.2. Newsletter

Purpose / Information:

The newsletter contains news, offers and further information on the selected Thrimana Books brands. By subscribing to the newsletter, you will receive in accordance with the consent you have given in each case personalized information about the products, services or suggestions for participation in promotions, such as competitions or product tests by e-mail.

With your registration for the newsletter, you will receive a newsletter tailored to your needs (if the newsletter is “personalized”, “individualized” or “customized”). We evaluate your purchase and click behavior on our websites or within the newsletter in order to compile the information relevant to you.

We also use remarketing measures to show you the relevant online advertising.

Recipients:

The data will be forwarded to our customer management platform, which service providers may also have access to support and implement the newsletter. Platform/hosting providers will have access to personal data from a third country (countries outside the European Economic Area). As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR with these providers. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

Deletion / Withdrawal:

These collected data are automatically deleted after 24 months at the latest if they no longer respond to the newsletter, e.g. open (inactivity). If you no longer wish to receive the newsletter, you can unsubscribe at any time. Click on the link contained in each newsletter, you will then be guided through the unsubscribe process, or send us your withdrawal by email.

Legal basis:

Art. 6 (1) a GDPR (consent)

3.3. Campaigns (e.g., Surveys, Product Tests)

Purpose / Information:

When you participate in campaigns, we use the personal information you provide to conduct the campaign. Further information on the purposes can be found in the respective terms and conditions of the campaign.

The provision of your personal data is necessary for the performance of a contract. You are not obliged to provide your personal data. If your data is not provided, you cannot participate in the campaign.

Further information can be found in the respective terms and conditions of the campaign.

Recipients:

We transfer the collected data to the relevant internal departments for processing and /or to external service providers, contract processors (e.g. hosting, shipping, processing service providers) in accordance with the purposes required (to carry out the campaign). Platform/hosting providers will have access to personal data from a third country (countries outside the European Economic Area). As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR with these providers. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

Deletion:

Your data will be deleted after the final processing of the campaign (see terms and conditions of participation), unless this conflicts with statutory retention obligations or statutes of limitations.

Legal basis:

Art. 6 (1) b GDPR (situation similar to a contract)

3.4. Postal mailings

Purpose / Information:

As a selected customer, business partner, test person and/or consumer, you will also receive individual product information, offers, news and product samples from us by post (letter).

This is a special form of direct marketing, which is also our legitimate interest and intensifies loyalty by providing the above-mentioned persons exclusive information.

Recipients:

We transfer the collected data to the relevant internal departments for processing and / or to external service providers, contractors (e.g. customer/consumer management service providers, marketing agency, postal service provider) in accordance with the required purposes (postal mailings). Platform/hosting providers will have access to personal data from a third country (countries outside the European Economic Area). As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR with these providers. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

Deletion / Objection:

Your data will be deleted as soon as you have unsubscribed, unless this conflicts with legal storage obligations or statutes of limitations. You can unsubscribe or object to further postal mailings as stated within the letter or in the section objection below. We further delete your personal data automatically after 24 months inactivity .

Legal basis:

Art. 6 (1) f GDPR (legitimate interest)

3.5. Surveys

Purpose / Information:

When you participate in surveys or similar campaigns, we process the personal information for the purpose described in the consent. The collected data covers questions around the intended purpose of the survey or similar campaign, as well as additional socio-demographic information about you. You may participate without identifying yourself, unless this has been part of the consent.

Recipients:

We transfer the collected data to the relevant internal departments for processing and /or to external service providers, contract processors (e.g. platform, hosting, analysts) in accordance with the purposes required (to carry out the surveys). Platform/hosting providers will have access to personal data from a third country (countries outside the European Economic Area). As an appropriate safeguard we have agreed on standard contractual clauses pursuant to Art. 46 GDPR with these providers. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

Deletion:

Your data will be deleted after the final processing of the survey or similar campaign (see terms and conditions of participation), unless this conflicts with statutory retention obligations or statutes of limitations. Usually, data will be deleted after two years.

Legal basis:

Art. 6 (1) a GDPR (consent)

  1. OBJECTION OR WITHDRAWAL OF YOUR CONSENT TO THE PROCESSING OF PERSONAL DATA

If you have given your consent (Art. 6 (1) a GDPR) to the processing of your data, you can withdraw your consent at any time. Such a withdrawal influences the permissibility of processing your personal data after you have given it to us.

If we base the processing of your personal data on the weighing of interests (Art. 6 (1) f GDPR), you may object to the processing. This is the case if processing is not necessary in particular to fulfil a contract with you, which is described by us in the description of the functions / services. When exercising such objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and either stop or adjust data processing or point out to you our compelling reasons worthy of protection, on the basis of which we will continue processing.

Of course, you can object to the processing of your personal data for purposes of advertising and data analysis at any time. You can inform us about your objection under the above-mentioned contact details for the controller.

THE PROTECTION OF YOUR DATA IS IMPORTANT TO US!

 

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