Data protection declaration of Schwan-STABILO Promotion Products GmbH & Co.KG

 

Preamble

Schwan-STABILO Promotion Products GmbH & Co.KG is pleased that you are visiting our website. Data protection and data security while using our website play a very important role for us. We would therefore like to inform you at this point which of your personal data we collect when you visit our joint website and for what purposes this is used. Since changes in the law or changes in our internal company processes may make it necessary to adapt this data protection declaration, we ask you to read it regularly. The data protection declaration applies to the Schwan-STABILO Promotion Products website, which can be accessed under the domain https://www.stabilo-promotion.com/.

1. Name and address of the responsible entity

The responsible entity is Schwan-STABILO Promotion Products GmbH & Co.KG, Schwanweg 1 in 90562 Heroldsberg (hereinafter referred to as "Schwan Promotion").

2. Names and addresses of the data protection officers

Our data protection officer is Mr. Sebastian Meyer, Schwanweg 1 - 90562 Heroldsberg. You can contact our data protection officer at any time with any questions concerning data protection. The best way to do this is by e-mail to: datenschutz@schwan-stabilo.com.

3. General information on data processing

As a matter of principle, we collect and use personal data of our users only insofar as this is necessary for the provision of a functional website as well as our contents and services.

3.1 Personal data

Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behaviour. Information for which we cannot (or can only with a disproportionate effort) establish a link to your person, e.g. by anonymising the information, is not personal data.

3.2 Processing of personal data

Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3.3 Legal basis for the processing of personal data

The collection and use of our users' personal data regularly takes place only with the user's consent. Insofar as we obtain the consent of the data subject for processing operations involving personal data, the legal basis is Article 6 (1) (a) of the General Data Protection Regulation (GDPR).

An exception applies in cases where obtaining consent in advance is not possible for factual reasons and the processing of the data is permitted by legal regulations. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) GDPR is the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

If processing of personal data is necessary for compliance with a legal obligation to which we are subject, Art. 6 (1) (c) GDPR is the legal basis.

If the processing is necessary to protect a legitimate interest pursued by us or a third party and the interests, fundamental rights and freedoms of the data subject do not overridden by the interests or fundamental rights and freedoms of the data subject, Art. 6 (1) (f) GDPR is the legal basis.

4. Data processing operations

Personal data is collected via this website, if you provide it to us on your own accord, e.g. by filling in forms or sending e-mails. We use this data for the purposes stated in each case or those resulting from the enquiry, e.g. providing your e-mail address, in order to contact you. Data is only transmitted to third parties if this is expressly permitted by law or if you have consented to the transmission in the course of an active business relationship.

4.1 Informational use of the website

You can visit our website without providing any personal information. If you only use our website for informational purposes, i.e. you do not provide us with any information about yourself, we do not process any personal data, with the exception of the data that your browser transmits to enable you to visit the website. For the purpose of the technical provision of our website, it is necessary that we process certain automatically transmitted information from you, so that your browser can display our website and you can use the website. This information is automatically collected each time you visit our website and stored in our server log files. This information relates to the computer system of the visiting computer. The following information is processed:

• Host
• IP address of the user
• Date and time of access
• Method of access (Get/Post)
• Request
• Protocol (e.g. https)
• Status (e.g. error messages)
• Amount of data retrieved
• Referrer
• Browser and operating system of the user

Legal basis for the above-mentioned data processing is Art. 6 (1) (f) GDPR. The processing of the aforementioned data is necessary for the provision of a website and thus serves to protect a legitimate interest of our company.

As soon as the aforementioned data is no longer required to display the website, it will be deleted. The collection of the data for the provision of the website and the (temporary) storage of the data in log files is absolutely necessary for the operation of the website. Further storage may take place in individual cases if required by law.

In addition to the purely informative use of our website, you can also actively use our website, for example to contact us. In this case, we process the following personal data from you in addition to the aforementioned processing:

4.2 Active use of the website

4.2.1 Contact form

On our website we offer you the possibility to contact us in different ways. One possibility is to contact us via our contact forms.

In principle, we require your e-mail address, your name and your individual message as mandatory information in order to answer your enquiry. Without this data, we cannot fulfil your contact request. In addition, you can voluntarily provide us with your customer status, your company, your address, your telephone number for a callback as well as your preferred method of contact.

It is your free decision whether you provide us with this data. The purpose of providing your data is to be able to allocate your enquiry and respond to you. When using the contact form, your personal data will not be passed on to third parties.

Section 25 (2) no. 2 of the Telecommunications Telemedia Data Protection Act (hereinafter: TTDSG) serves as the legal basis for the possible reading of stored information on your end device.

The subsequent processing of this data is based on Art. 6 (1) lit. b GDPR, insofar as your request is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the enquiries addressed to us (Art. 6 (1) lit. f GDPR).

As soon as the enquiry you have made has been dealt with and the relevant matter has been conclusively clarified, the personal data processed by you via the contact form will be deleted. Further storage may take place in individual cases if this is required by law.

4.2.2 Live chat via Tawk

If you have consented to all cookies and similar technologies in the cookie banner, you can also contact us via our live chat. For our live chat we use Tawk.to, a live chat software of Tawk.to Inc (inc. 187 East Warm Springs Rd, SB298 Las Vegas, NV, 89119). The chat is integrated into the source code of the website via a plug-in. By using the chat, you automatically use the services of Tawk.to. We collect the following data and transmit it to Tawk.to:

• Name
• E-mail address
• Individual message
• Chat history, IP address at the time of the chat and country of origin

The processing of the data that we collect and that is transmitted by us to Tawk.to is based on Art. 6 (1) (b) GDPR, insofar as your request is related to the performance of a contract or is necessary for the implementation 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) GDPR).

The use of the Tawk.to plugin and the subsequent processing of the data collected with the help of the cookie is based solely on your consent. You can find more information on this in our Cookie Policy at: Cookies - STABILO Promotion Products (stabilo-promotion.com).

As soon as the enquiry you have made has been dealt with and the matter in question has been conclusively clarified, the personal data processed by you via the contact form will be deleted. Further storage may take place in individual cases if this is required by law.

4.2.3 Other contact

If you would like to contact us, make an offer or submit a press enquiry, our website also contains our general e-mail address and the e-mail address of the relevant contact person. You can send us a message via the e-mail addresses provided. In this case, we will process your first and last name and your e-mail address and the personal data transmitted with the e-mail. Furthermore, you can send us an individual message via the message field. You can also call our Customer Service Team on +49 911 567 3455; we will then process all the data you have provided. It is your free decision whether you provide us with this data. Without this information, however, we may not be able to fulfil your contact request in full or at all.

In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation.

The legal basis for processing the data transmitted in the course of contacting us is Art. 6 (1) (f) GDPR.  In the case of contact, the necessary legitimate interest in processing the data lies in the processing of your enquiry.

If the contact is aimed at concluding a contract, the legal basis for the processing is Art. 6 (1) (b) GDPR.

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. The conversation is terminated when the circumstances indicate that the matter in question has been conclusively clarified. Further storage may take place in individual cases if this is required by law.

4.2.4 Newsletter

In order to be able to subscribe to our e-mail newsletter, we require, in addition to your consent, at least your e-mail address and your name as well as the type of newsletter for which you would like to subscribe. Furthermore, you can voluntarily state your company and country. It is your free decision whether you provide us with this data. However, we cannot send you a personalised newsletter without this information.

We would like to point out that we currently work together with Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, United States of America, who processes your data on our behalf and ensures that the e-mails are sent correctly. Your data will not be passed on to third parties in connection with the sending of newsletter.  Further information about Automattic Inc. as well as your corresponding data protection rights and setting options for the protection of your privacy can be found at: Privacy Policy - Automattic

In order to optimise or personalise the newsletter and if you have additionally consented, we look at how often it is opened by users and which links the users click (analysis of usage behaviour). By using the newsletter software, personal recipient responses can be accessed. By subscribing to our newsletter, you agree to the tracking permission and the processing of personal responses. You can cancel the tracking permission at any time by clicking on the link at the end of each newsletter.

We use the so-called double opt-in procedure for sending the newsletter, i.e. we will only send you the newsletter if you first confirm your registration via a confirmation e-mail sent to you for this purpose using the link contained therein. In this way, we ensure that only you yourself, as the owner of the e-mail address provided, can register for the newsletter. Your confirmation must be sent promptly after receipt of the confirmation e-mail, otherwise your newsletter registration will be automatically deleted from our database.

In the context of sending the newsletter, personal data may be transferred to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event of the transfer of personal data to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with Automatic Inc. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and for monitoring purposes, possibly also without any legal remedy. Furthermore, where possible, we are in exchange with the service provider to ensure the protection of your personal data with any additional measures that may be necessary.

The legal basis for the processing of data after the user has registered for the newsletter is Art. 6 (1) (a) GDPR if the user has given his or her consent.

When registering to the newsletter, your e-mail address will be used for our own advertising purposes until you unsubscribe from the newsletter. To unsubscribe and revoke your consent for the future, you can send us an informal email to service@stabilo-promotion.com at any time and without giving reasons or unsubscribe via the link provided in our newsletters.

Your data will be stored as long as you have subscribed to the newsletter. After unsubscribing from the newsletter, your data will be deleted. Further storage may take place in individual cases if required by law.

4.2.5 Registration process (customer account)

On our website, we offer you the opportunity to register by providing personal data. With the processed data, we create an individualised user account for you, with which you can use certain contents and services. For example, you can conveniently log in with your chosen username and password for future visits to the website and orders of our products.

We process your e-mail address in the course of this so that we can send you new access data if you should forget it.

The following overview shows you in detail which personal data we process when you register:

• Company
• Salutation
• First and last name
• E-mail address
• Address with street, postcode, city and country
• Telephone number (optional)
• Fax number (voluntary)
• Department (voluntary)
• Branch (voluntary)
• Function (voluntary)
• Category (voluntary)

Pursuant to Art. 6 (1) (b) GDPR, the processing of the personal data presented serves the purpose of carrying out pre-contractual measures.

As soon as the registration on our website is cancelled or modified, the data processed during the registration process will be deleted. Further storage may take place in individual cases if this is required by law.

4.2.6 Inquiry form

On our website, we offer you the possibility of enquiring about products via the enquiry form without registering.

The following overview shows you in detail which personal data we process in the case of an enquiry without registration:

• Salutation (voluntary)
• Company (optional)
• First and last name
• E-mail address
• Address with street, postcode, city and country
• State / County (voluntary)
• Telephone number (voluntary)

Pursuant to Art. 6 (1) (b) GDPR, the processing of the personal data presented serves the purpose of carrying out pre-contractual measures.

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Further storage may take place in individual cases if this is required by law.

4.2.7 Sample request form

Our newsletter will take you to our sample request form. Here you have the possibility to request the samples presented in our newsletter. However, it is only possible for us to send you the corresponding samples if we receive at least your company name, your first and last name, your address and your e-mail address. You can also voluntarily provide us with your telephone number in case we have any queries.

The following overview shows you in detail which personal data we process for a sample request:

• Company
• First and last name
• Address with street, postcode, town and country
• E-mail address
• Telephone number (optional)

The processing of the personal data presented serves the purpose of carrying out pre-contractual measures in accordance with Art. 6 (1) (b) GDPR.

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Further storage may take place in individual cases if this is required by law.

4.2.8 STABILO online advice

We offer STABILO online consultation through our personal consultants on our website. We use the calendly tool of the provider Calendly LLC, 71 17th St NW, Ste 1000, Atlanta, Georgia, 30363, United States, to make appointments easily, quickly and without complications. Calendly acts as our processor within the meaning of Art. 4 No. 8 GDPR. A contract for order processing in accordance with Art. 28 GDPR has been concluded with the provider, which ensures compliance with the provisions of data protection law.

Book online consultation - STABILO Promotion Products (stabilo-promotion.com)

For an online consultation, the first step is to book your desired appointment online or arrange it by telephone. We will ask for your name, e-mail address and the e-mail addresses of any guests, as well as your consultation request, so that we can prepare for the consultation in the best possible way. You are free to decide whether or not to provide us with this information. Without this information, however, we may not be able to meet your request for consultation, or not to the full extent. You can also voluntarily provide us with your telephone number and the products you are interested in.

In the second step, you will receive an appointment invitation from STABILO by e-mail, which you must confirm, if you wish to attend the appointment.

In the third step, you can log in to your personal online consultation via the link contained in the invitation. The consultation will take place via the video conferencing service TEAMS of the provider Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. You decide whether you want to turn on your camera during our online counselling and what content you share. Stream data such as image, sound and text data, and possibly profile data such as name and email address are transmitted to the provider.

The legal basis for the processing of your data is your consent according to Art. 6 (1) (a) GDPR. You can revoke this consent at any time without giving reasons with effect for the future by sending an email to service@stabilo-promotion.com.

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. The conversation is terminated when the circumstances indicate that the matter in question has been conclusively clarified. Further storage may take place in individual cases if this is required by law.

For further information on the handling of data protection at Calendly and Microsoft, please see Privacy Policy | Calendly and Privacy – Microsoft privacy.

4.2.9 Applicant management (career)

a. Application by e-mail and post

If you are interested in one of our vacancies listed on the website, you can send us an application at any time by e-mail to jobs.de@stabilo.com or jobs@schwan-stabilo.com or by post to our contact details. In doing so, we will process all the information you provide.

We assure you that we will only process the personal data you provide for the purpose of carrying out the application process. The legal basis for the processing of your personal data from your application documents is Section 26 (1) BDSG (German Data Protection Act) and Article 6 (1) (b) GDPR.

The storage period is 6 months after completion of the application process for the defence against any claims arising from the General Equal Treatment Act (AGG).

In the event that your application cannot be considered at the moment, you also have the option of agreeing to us storing the documents you submitted as part of this application, as well as other data you provided, in our applicant database in accordance with Art. 6 (1) (a) GDPR, in order to be able to contact you in the future, if necessary, if a position matching your application profile is to be filled. You must explicitly agree to the corresponding use of your application details again at the appropriate point when you submit your application. You can revoke your consent to the storage of your application data for a maximum period of 12 months at any time with effect for the future. To do so, simply send an email to the email address: datenschutz@schwan-stabilo.com

b. Application via the career portal and application management system

For the efficient implementation of application procedures, we use a career portal and applicant management system of softgarden e-Recruiting GmbH, Tauentzienstr. 14, 10789 Berlin (contact: datenschutz@softgarden.de), which operates the applicant management as a processor within the meaning of Art. 4 No. 8 GDPR. A contract for order processing in accordance with Art. 28 GDPR has been concluded with the provider, which ensures compliance with the provisions of data protection law.

As part of the application process, you can set up and manage an account in the career portal after configuring a username and password. You can use further options in the applicant management system beyond the individual application and make your individual settings (e.g. inclusion in a talent pool).

For an efficient and promising application, you can provide the following information as part of your application to us:

• Contact details (title, first and last name, email address, address, telephone number).
• Curriculum vitae data, e.g. school education, vocational training, work experience, language skills
• Profiles in social networks (e.g. XING, LinkedIn)
• Documents related to job applications (application photos, cover letter, references, work samples etc.)
• Current notice period
• Salary expectations (gross annual salary)

The legal basis for processing for the purpose of carrying out the application procedure and initiating an employment relationship is Art. 6 (1) (b) sentence 1 GDPR in connection with Section 26 (1) sentence 1 BDSG. Furthermore, the use of the applicant management system by us is in the legitimate interest pursuant to Art. 6 (1) (f) GDPR.

If consent within the meaning of Art. 6 (1) (a) is required for a specific processing activity, we will obtain this separately and transparently from you.

The storage period is 6 months after completion of the application procedure for the defence against any claims arising from the General Equal Treatment Act (AGG). After the retention period has expired, the data is completely anonymised. The processing of anonymised data records is not subject to the material scope of the data protection provisions, so that anonymised data may be processed for statistical and analytical purposes, for the preparation of market studies or for product development.

In the event that your application cannot be considered at the moment, you also have the option of agreeing to us storing the documents you submitted as part of this application as well as other data you provided in our applicant database in accordance with Art. 6 (1) (a) GDPR in order to be able to contact you in the future, if necessary, if a position matching your application profile is to be filled. You must explicitly agree to the corresponding use of your application details again at the appropriate point when you submit your application. You can revoke your consent to the storage of your application data for a maximum period of 12 months at any time with effect for the future. To do so, simply send an email to the email address: datenschutz@schwan-stabilo.com

aa. Feedback module

Accompanying your application, we may ask you to submit your feedback after an interview and 3 months after you have been hired. For this purpose, we will send you an invitation link that will lead you to the rating system to submit your feedback. The purpose of the processing is the further development and optimisation of our recruiting and application processes as well as the corporate image. For this purpose, the following data are processed automatically:

• Contact details (name, e-mail)
• Position title of the job you have applied for
• Location of the position
• Job category
• Applicant identifier

The feedback itself is stored anonymously in the database. No personal reference is made. In addition to a star rating for individual questions, you have the opportunity to leave comments here. We expressly ask you not to leave any personal data in the comments. The information collected in this way can be displayed together with your feedback on our rating page or transmitted to external partners such as kununu.

Participation is purely voluntary and only takes place with your consent, without which it is not possible to provide feedback. The legal basis is Art. 6 (1) (a) GDPR. Consent can be revoked at any time and without giving reasons with effect for the future by sending an email to: datenschutz@schwan-stabilo.com.

bb. Job subscription

To be informed about new job offers, you can subscribe to the job newsletter or have suitable jobs displayed on our career board (RSS feed). You can define the subscription in more detail by specifying the desired job as well as the location.

You will need to provide your e-mail address in order to subscribe. The legal basis for this is your consent to receive the newsletter in accordance with Art. 6 (1) a GDPR. You can revoke your consent to receive the newsletter at any time via the unsubscribe link in the newsletter or by sending an email to: datenschutz@schwan-stabilo.com.

No personal data is processed via the RSS feed itself to inform you about new job advertisements.

Your data will be stored for as long as you have subscribed to the newsletter. After unsubscribing from the newsletter, your data will be deleted. Further storage may take place in individual cases if required by law.

cc. Salary statistics

As part of the application process, we offer the opportunity to provide feedback on your salary expectations and salaries offered to you. The information submitted in this context is processed anonymously and without linking it to your name and contact details. The processing only takes place with your express consent and on a purely voluntary basis. The legal basis is thus Art. 6 (1) (a) GDPR.

You can withdraw your consent at any time by sending an email to datenschutz@schwan-stabilo.com. to revoke your consent with effect for the future.

Your data will be stored for as long as it is required to achieve the purpose and you have not revoked your consent.

dd. Talent pool

As part of your application or via the "Get in touch" button, you have the opportunity to recommend yourself for our talent pool. The processing is necessary in order to be automatically considered for further job advertisements, i.e. for similar or otherwise suitable positions.

If you register for the talent pool via the "Get in touch" button, the following information will be requested:

• Salutation, academic title (optional)
• First name, last name, e-mail address
• Job fields of interest
• Current career level
• Preferred location(s)
• XING and LinkedIn profile or CV

Inclusion in the talent pool is purely voluntary and only based on your consent. The legal basis is thus Art. 6 (1) (a) GDPR. Furthermore, we will write to you after 6 (six) months to ask whether you would still like to be part of the talent pool.

You can revoke your consent at any time by sending an email to: datenschutz@schwan-stabilo.com with effect for the future.

Your data will be stored for as long as it is required to achieve the purpose and you have not revoked your consent.

ee. CV parsing "Textkernel"

We use the software Extract! CV Parsing of the provider Textkernel BV, Nieuwendammerkade 28A17, Amsterdam, Noord-Holland 1022 AB, The Netherlands, to have the documents you uploaded processed and analysed by means of AI, thus extracting your CV data and converting it into a structured form (so-called "CV parsing"). Textkernel processes your data exclusively on our behalf and according to our instructions.

The uploaded documents are transferred to Textkernel for evaluation via a secure https call, parsed there and sent back to us as an XML file. Textkernel's tool extracts only the following information and stores it briefly on a server in Amsterdam between:

• First and last name
• City
• Country
• Phone number
• Profile picture
• Gender
• Date of birth
• Curriculum vitae
• Title
• Academic title
• Education and training
• Work experience
• Languages spoken
• Skills

The legal basis for this processing is our legitimate interest pursuant to Art. 6 (1) (f) GDPR. This is to create comparability of the applications received and thus to design application processes efficiently.

After processing and retransmission (a few seconds), the data is automatically deleted. For technical reasons, we cannot guarantee the complete and correct transfer of the information contained in your documents. We therefore ask you to check the recognised and transferred data after the upload.

ff. Social share buttons for applications

Different buttons are offered for each network. After clicking on one of these buttons, you will be referred to the respective networks and will be taken to their login pages. These buttons are not plug-ins and do not transmit any personal data directly to the operators of the social networks until you have actively opted in. To use the "share" function, you must have registered with the respective network and actively click on the link. Only then will your data be transferred to the respective provider. We use the "Shariff" function for this purpose. "Shariff" was developed to enable more privacy on the net and to replace the usual social plugins of the social networks.

Currently, the job advertisements can be shared on the following social networks:

• LinkedIn (https://www.linkedin.com/legal/privacy-policy)
• Xing (https://privacy.xing.com/de/datenschutzerklaerung)

The following data is transmitted when the content is "shared":

• Internet address
• Date and time of accessing the website or clicking the "share" icon
• Information about the browser and operating system used
• IP address
• the content you have shared

The shared content (job postings) can then also be viewed by other users of the same network, depending on the data protection settings you have made for your own account on the various networks. Provided that you are already logged in to the network at the time of pressing the "share" icon, its provider is also able to determine your username and, if applicable, your real name from the above-mentioned data.

In this context, personal data may be transferred to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee an adequate protection of your personal data in case of transfer of personal data to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with our service providers. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and for monitoring purposes, possibly also without any legal remedy. Furthermore, where possible, we are in exchange with the service provider to ensure the protection of your personal data with any additional measures that may be necessary.

The legal basis for data processing when using the "Share" function is Art. 6 (1) (f) GDPR. The legitimate interest on our part lies in the fact that we want to enable our users to participate in an active exchange in the networks via the "Share" function. The user must actively register in the network before any data is transferred and then additionally click on the link.

Under the links provided, you can find out how the aforementioned social networks process your personal data. We have no influence on the processing of your personal data by the social networks.

Your data is routinely deleted from the cache once a week.

5. Transmission of personal data to third parties

As a matter of principle, your personal data will not be transmitted. Your personal data will only be passed on to third parties or otherwise transferred if

• We are legally obliged to do so by official or court order,
• We are entitled to do so, e.g. because this is necessary for the prosecution of criminal offences or for the exercise and enforcement of our rights, or,
• If you have given your prior consent.

6. Cookies and external services

Cookies are small files that enable specific information related to the device to be stored on the user's access devices (PC, smartphone or similar). They serve the user-friendliness of websites and thus the users. Some functions of our website cannot be offered without the use of technically necessary cookies. In addition, they can be used to collect statistical data on website use and analyse it for the purpose of improving the website. Users can influence the use of cookies. For more information on the use of cookies on our website and for individual cookie settings, click here: Cookies - STABILO Promotion Products (stabilo-promotion.com)

7. Fan pages on Facebook, Instagram, YouTube, LinkedIn

We operate fan pages on the social networks Facebook, Instagram, YouTube and LinkedIn. As operators of these fan pages, we are jointly responsible with the operators of these networks within the meaning of Art. 4 No. 7 GDPR. When you visit one of our fanpages, personal data is processed by the responsible parties. As the controller of the fan pages, we have entered into agreements with the social networks which, among other things, regulate the conditions for using these pages. We have integrated this data protection policy into the corresponding fan pages, from which you can obtain further information, or at https://www.stabilo-promotion.com/de/:

• Facebook Data Policy
• Instagram Data Policy
• YouTube Data Policy
• LinkedIn Data Policy

8. Social plugins

Our websites contain social plugins of the social network LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2 Ireland). It is possible that personal data about visitors to the website are also collected via these plugins, transmitted to the respective service and linked to the visitor's respective service. STABILO Promotion itself does not collect any personal data via the social plugins and their use.

In order to increase the protection of your data on our website, the social plugins are integrated on our website using the so-called "2-click solution". This ensures that when a page of our website containing such social plugins is called up, no automatic connection is established with the servers of the respective providers.

The activation of the function of the respective social plugin takes place in two stages. To activate a social plugin, you must first click on the link located on our website. This first activates the social plugin and your browser establishes a connection to the servers of the respective provider. By clicking a second time, you can now interact with the social plugin and, for example, submit your recommendation. After clicking on a social plugin, the respective service provider receives the information that you have visited the corresponding page of our online offer. Please note that you do not need to have a user account with the service in question, nor do you need to already be logged in to the service. However, if you already have a user account with the relevant service provider and are already logged in to this account while visiting our website, the data collected by the social plugin will be directly assigned to your account. If you do not want the assignment to your profile with the service provider, you must log out of your user account before clicking on one of the social plugins.

Please note that Schwan-STABILO Promotion Products GmbH & Co. KG has no influence on whether and to what extent the respective service providers collect personal data. We are not aware of the scope, purpose and storage periods of the respective data collection. However, we would like to point out that it must be assumed that at least the IP address and device-related information are used and collected via social plugins. It is also possible that the respective service providers use cookies.

With the help of social plugins, personal data may be transmitted to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event of the transfer of personal data to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with Google. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and for monitoring purposes, possibly also without any legal remedy. Furthermore, where possible, we are in exchange with the service provider to ensure the protection of your personal data with any additional measures that may be necessary.

The legal basis for the use of the social plugins for the associated storage of information on your end device as well as their subsequent readout is your expressly granted consent pursuant to Section 25 (1) sentence 1 TTDSG (German Telecommunications-Telemedia Data Protection Act). You can revoke this consent for the future at any time by deactivating the cookies in your browser settings or in our cookie content manager. The following processing of your personal data is based on your explicit consent according to Art. 6 (1) (a) GDPR. You can revoke this consent for the future at any time by deactivating cookies in your browser settings or in our Cookie Consent Manager.

For the scope and purpose of the data collection by the respective service and the further processing and use of your data there, please refer to the data protection information directly from the website of the respective service. There you will also receive further information about your corresponding data protection rights and setting options to protect your privacy.

a) LinkedIn, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2 Ireland

https://de.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy https://www.linkedin.com/psettings/data-privacy https://www.linkedin.com/help/linkedin/answer/89876).

9. Security measures for the protection of the data stored with us

We are committed to protecting your privacy and treating your personal data confidentially. In order to prevent loss or misuse of the data stored with us, we take extensive technical and organisational security precautions, which are regularly reviewed and adapted to technological progress. However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions who are not in our area of responsibility. In particular, data disclosed without encryption - even if this is done by e-mail - can be read by third parties. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

10. Hyperlinks

Our website contains so-called hyperlinks to websites of other providers. When activating these hyperlinks, you will be forwarded from our website directly to the website of the other provider. These can also be the company websites of the partners of Schwan-STABILO Promotion Products. You will recognise this by the change of URL, among other things. We cannot accept any responsibility for the confidential handling of your data on other websites. Please inform yourself about the handling of your personal data on other websites directly on the respective websites.

11. External service providers

We use service providers to provide services and to process your data relating to our services. The service providers process the data exclusively within the scope of our instructions and have been obligated to comply with the applicable data protection regulations. All service providers have been carefully selected and will only have access to your data to the extent and for the period of time necessary to provide the services or to the extent that you have consented to the processing and use of the data.

In this context, personal data may be transferred to countries outside the EU/EEA, in particular to the USA. In order to be able to guarantee adequate protection of your personal data in the event of the transfer of personal data to such so-called third countries, we have concluded so-called EU-US standard contractual clauses with our service providers. The USA is assessed by the European Court of Justice as a country with an inadequate level of data protection according to EU standards. Due to the lack of an adequacy decision and without appropriate safeguards, there is a particular risk that your data may be processed by US authorities for control and for monitoring purposes, possibly also without any legal remedy. In addition, where possible, we are in communication with the service provider to ensure the protection of your personal data with any additional measures that may be necessary.

12. Storage period

Your personal data will be deleted as soon as the respective purpose for processing has been achieved or has subsequently ceased to apply.

In order to fulfil contractual obligations, data collected from you may be retained for as long as the contract exists and, depending on the scope of the contract, for 6 or 10 years beyond that to comply with legal retention obligations and to resolve any enquiries or claims that may arise after the contract expires.

If, at our discretion, data is necessary to investigate or defend claims against us or to bring a prosecution or claim against you, us or a third party, we may retain it for as long as such proceedings might be brought.

For customer service purposes, data collected from you may be retained for 3 to 10 years after collection unless you request that we delete this data and there are no contractual or statutory retention obligations that prevent this request for deletion.

Relevant obligations to provide proof and to retain data result, among others, from the German Commercial Code (Handelsgesetzbuch) and the German Fiscal Code (Abgabenordnung).

In this case, the legal basis for the processing is the respective legal regulations in conjunction with Art. 6 (1) © GDPR.

If a contract is not concluded, we will delete your data after 3 years at the end of the statutory limitation period.

13. Data subject rights

13.1 Right to information, Art. 15 GDPR

You have the right to request information from us at any time about the data we have stored about you, as well as about its origin, recipients or categories of recipients to whom this data is passed on and the purpose for which it is stored.

13.2 Right of revocation, Art. 7 (3) GDPR

If you have given your consent to the use of data, you may revoke this consent at any time without giving reasons with effect for the future. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. For this purpose, an e-mail to Datenschutz@schwan-stabilo.com or a written notification to Schwan-STABILO Promotion Products GmbH & Co.KG, Schwanweg 1 in 90562 Heroldsberg shall suffice.

13.3 Right of rectification, Art. 16 GDPR

You may request the correction of incorrect or the completion of your data stored by us.

13.4 Right to erasure and blocking, Art. 17 and 18 GDPR

You have the right to block and delete your personal data stored by us. If legal storage obligations or other legally anchored reasons contradict the deletion, only the blocking of your data can be carried out instead of the deletion.

13.5 Right of data transfer, Art. 20 GDPR

Should you request the release of your personal data provided to us, we will release or transfer the data to you or another responsible party in a structured, common and machine-readable format if you so request. The latter, however, only if this is technically possible.

13.6 Right to object, Art. 21 GDPR

You have the right to object to the processing of personal data relating to you at any time on grounds relating to your particular situation within the framework of the requirements of Art. 21 GDPR, provided that the data processing is carried out on the basis of our legitimate interests pursuant to Art. 6 (1) (f) GDPR.

13.7 Contact for the assertion of data subject rights

To assert your data subject rights, you can contact us by e-mail at: Datenschutz@schwan-stabilo.com - or by post at Schwan-STABILO Promotion Products GmbH & Co.KG, Schwanweg 1 in 90562 Heroldsberg.

When you contact us, the data you provide (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your questions or respond to your request. We delete the data collected in this context after the storage is no longer necessary or restrict the processing if there are legal obligations to retain the data.

14. Right to file a complaint with the supervisory authority, Art. 77 GDPR

You have the right to file a complaint with the competent supervisory authority against the processing of your personal data if you consider that your rights under the GDPR have been violated.

15. Data transfer to affiliated companies

For operational reasons and to ensure IT operations and IT security, data may be transferred to affiliated companies of the Schwan-STABILO Group.

16. Automated decision-making/profiling

We do not use automated decision making or profiling (an automated analysis of your personal circumstances).

 

Status: September 2023