Privacy Policy and Consents

1. data protection at a glance

General notes

The following notices provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data collection on this website

Who is responsible for the data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the responsible office” in this data protection declaration.

How do we collect your data?

On the one hand, your data is collected by you providing it to us. This may be, for example, data that you enter in a contact form.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. Internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time with regard to this and other questions on the subject of data protection.

Third-party analytics and tools

When visiting this website, your surfing behavior can be statistically analyzed. This is done mainly with so-called analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. hosting

We host the content of our website with the following provider:

Strato

The provider is Strato AG, Otto-Ostrowski-Straße 7, 10249 Berlin (hereinafter “Strato”). When you visit our website, Strato collects various log files including your IP addresses.

For more information, please refer to Strato’s privacy policy: https://www.strato.de/datenschutz/.

The use of Strato is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in ensuring that our website is presented as reliably as possible. If a corresponding consent has been requested, the processing is based exclusively on Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Job processing

We have concluded an order processing agreement (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that this processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. general notes and mandatory information

Privacy

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data are collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how this is done and for what purpose.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of the data against access by third parties is not possible.

Note on the responsible entity

The responsible party for data processing on this website is:

PAPI Ltd
Jan Fritz
Poller Hauptstrasse 25 – 27
51105 Köln

Phone: + 49 (0) 2 21-9 83 85-0
E-Mail: info@papi.info

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified within this data protection declaration, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted after these reasons no longer apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO, insofar as special categories of data pursuant to Art. 9 para. 1 DSGVO are processed. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of § 25 para. 1 TTDSG. The consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data insofar as this is necessary for the fulfillment of a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. The data processing may further be based on our legitimate interest according to Art. 6 para. 1 lit. f DSGVO shall take place. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this data protection declaration.

Note on data transfer to the USA and other third countries

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. When these tools are active, your personal data may be transferred to and processed in these third countries. We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in these countries. For example, U.S. companies are obligated to release personal data to security authorities without you, the data subject, being able to take legal action against this. It can therefore not be ruled out that U.S. authorities (e.g. intelligence agencies) process, evaluate and permanently store your data located on U.S. servers for surveillance purposes. We have no influence on these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct marketing (Art. 21 DSGVO)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 ABS. 1 LIT. E OR F DSGVO, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS DATA PROTECTION DECLARATION. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS FOR THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION UNDER ARTICLE 21(1) DSGVO).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 DSGVO).

Right of appeal to the competent supervisory authority

In the event of breaches of the GDPR, data subjects shall have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. The right of appeal is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, deletion and correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time with regard to this and other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restrict processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data happened/is happening unlawfully, you may request the restriction of data processing instead of erasure.
  • If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.
  • If you file an objection pursuant to Art. 21 para. 1 DSGVO, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to demand the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the browser address bar changes from “http://” to “https://” and by the lock symbol in your browser bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. data collection on this website

Cookies

Our Internet pages use so-called “cookies”. Cookies are small data packets and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your terminal device. Session cookies are automatically deleted after the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your terminal device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is based exclusively on this consent (Art. 6 Para. 1 lit. a DSGVO and § 25 Para. 1 TTDSG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. When cookies are disabled, the functionality of this website may be limited.

If cookies are used by third-party companies or for analysis purposes, we will inform you about this separately within the framework of this data protection declaration and, if necessary, request your consent.

WPML Cookies

These are used by the WPML plugin to identify the user’s preferred language, as our website is multilingual. Detailed information about the browser cookies stored by WPML can be found at https://wpml.org/documentation/support/browser-cookies-stored-wpml/.

Wordfence

We have integrated Wordfence on this website. The provider is Defiant Inc, Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter “Wordfence”).

Wordfence is used to protect our website from unwanted access or malicious cyberattacks. For this purpose, our website establishes a permanent connection to Wordfence’s servers so that Wordfence can check its databases against the accesses made to our website and block them if necessary.

The use of Wordfence is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its website against cyberattacks as effectively as possible. If a corresponding consent has been requested, the processing is based exclusively on Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/.

Job processing

We have concluded a contract on order processing (AVV) for the use of the above service. This is a contract required by data protection law, which ensures that this processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

Request by e-mail, phone or fax

If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your request. We do not share this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b DSGVO, provided that your request is related to the performance of a contract or is necessary for the performance of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the requests addressed to us (Art. 6 (1) f DSGVO) or on your consent (Art. 6 (1) a DSGVO) if this has been requested; the consent can be revoked at any time.

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. Our newsletter also contains information about our services and us.

In order to register for our newsletters, it is generally sufficient if you enter your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else’s e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.

Notes on the legal basis: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising for existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

Content: Information about us, our services, promotions and offers.

Analysis and measurement of successThe newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes 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 aim nor, if used, that of the shipping service provider to monitor individual users. Rather, the evaluations serve us 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 evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system, which serves both our business interests and meets the expectations of the users.

Unfortunately, a separate revocation of the performance measurement is not possible. In this case, the entire newsletter subscription must be canceled or objected to.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: communication partners.
  • Purposes of processing: direct marketing (e.g. by email or post).
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, ie revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail.

Services and service providers used:

5. social media

Instagram

On this website, functions of the service Instagram are integrated. These functions are offered by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

When the social media element is active, a direct connection is established between your end device and the Instagram server. Instagram thereby receives information about your visit to this website.

If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to this website with your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Instagram.

Insofar as consent has been obtained, the aforementioned service is used on the basis of Art. 6 Para. 1 lit. a DSGVO and § 25 TTDSG. The consent can be revoked at any time. Unless consent has been obtained, the use of the service is based on our legitimate interest in achieving the greatest possible visibility on social media.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of data and its transfer to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The text of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook or Instagram tool and for implementing the tool on our website in a manner that is secure from a data protection perspective. Facebook is responsible for the data security of the Facebook or Instagram products. You can assert data subject rights (e.g. requests for information) regarding the data processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875 and https://de-de.facebook.com/help/566994660333381.

For more information, please see Instagram’s privacy policy: https://instagram.com/about/legal/privacy/.

Source: https://www.e-recht24.de