Privacy policy - Poulten Graf

1) Introduction and contact details of the controller

1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we will inform you about how we handle your personal data when you use our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Poulten & Graf GmbH, Karl-Carstens-Str. 10, 97877 Wertheim, Deutschland, Phone: +49 (0)9342 / 922 90, E-Mail: H.Fahrenkrog-Keller@poulten-graf.com. The controller responsible for the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

1.3 The controller has appointed a data protection officer, who can be contacted as follows: “Christian Schwab, Karl-Carstens-Str. 10, 97877 Wertheim, +49 (0)9342/9229-0, datenschutz@poulten-graf.com”

2) Data collection when visiting our website

2.1 When you use our website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to the site server (so-called “server log files”). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:

Our visited website
Date and time at the time of access
Amount of data sent in bytes
Source/reference from which you reached the page
Browser used
Operating system used
IP address used (if applicable: in anonymized form)

The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of unlawful use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser line.

3) Hosting & content delivery network

For the hosting of our website and the presentation of the page content, we use a provider that provides its services itself or through selected subcontractors exclusively on servers within the European Union.

All data collected on our website is processed on these servers.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

4) Cookies

In order to make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. Some of these cookies are automatically deleted after you close your browser (so-called “session cookies”), while others remain on your device for longer and enable page settings to be saved (so-called “persistent cookies”). In the latter case, you can find the storage period in the cookie settings overview of your web browser.

If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the performance of the contract, pursuant to Art. 6 para. 1 lit. a GDPR in the case of consent given or pursuant to Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.

You can set your browser so that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that if you do not accept cookies, the functionality of our website may be restricted.

5) Making contact

When you contact us (e.g. via contact form or e-mail), personal data is processed exclusively for the purpose of processing and responding to your request and only to the extent necessary for this purpose.

The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact is aimed at a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

6) Data processing for order processing

6.1 Insofar as necessary for contract processing for delivery and payment purposes, the personal data collected by us will be processed in accordance with Art. 6 para. 1 lit. b GDPR to the commissioned transport company and the commissioned credit institution.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you within the scope of our statutory information obligations pursuant to Art. 6 para. 1 lit. a GDPR. 1 lit. c GDPR by suitable means of communication (e.g. by post or email) about upcoming updates within the legally stipulated period. Your contact details will be used strictly for the purpose of notifications about updates owed by us and will only be processed by us for this purpose to the extent necessary for the respective information.

To process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.

6.2 Use of payment service providers (payment services)

– Paypal

One or more online payment methods of the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg

If you select a payment method of the provider for which you make advance payment, the payment data you provide during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be transmitted to the provider in accordance with Art. 6 para. 1 lit. a GDPR. 1 lit. b DSGVO passed on. In this case, your data will only be passed on for the purpose of payment processing with the provider and only to the extent that it is necessary for this purpose.

If you select a payment method for which we make advance payments, you will also be asked to provide certain personal data (first and last name, street, house number, zip code, city, date of birth, e-mail address, telephone number, data on an alternative means of payment if applicable) during the order process.

In order to safeguard our legitimate interest in determining your solvency in such cases, we process this data in accordance with Art. 6 para. 1 lit. f GDPR to the provider for the purpose of a credit check. On the basis of the personal data provided by you and other data (such as shopping cart, invoice amount, order history, payment experience), the provider checks whether the payment option you have selected can be granted with regard to payment and/or default risks.

The credit report may contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data.

You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for contractual payment processing.

7) Page functionalities

7.1 Facebook plugins

Our website uses plugins from the social network of the following provider: Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

These plugins enable direct interaction with content on the social network.

In order to increase the protection of your data when you visit our website, the plugins are initially deactivated and integrated into the page using the so-called “2-click” or “Shariff” solution.

This integration ensures that no connection to the provider’s servers is established when a page of our website containing such plugins is accessed.

Only when you activate the plug-ins and thus consent in accordance with Art. 6 Para. 1 lit. a GDPR, your browser establishes a direct connection to the provider’s servers. Regardless of whether you have logged into an existing user profile, a certain amount of information about the device you are using (including your IP address), your browser and your page history will be transmitted to the provider and may be processed there.

If you are logged into an existing user profile on the provider’s social network, information on interactions carried out via the plugins will also be published there and displayed to your contacts.
You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no influence on the data that has already been transmitted to the provider.

Data may also be transferred to: Meta Platforms Inc, USA

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

7.2 LinkedIn plugins

Our website uses plugins from the social network of the following provider LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland

These plugins enable direct interaction with content on the social network.

This integration ensures that no connection to the provider’s servers is established when a page of our website containing such plugins is accessed.

Data may also be transferred to: LinkedIn Inc., USA

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

For the transfer of data to the USA, the provider refers to standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

7.3 X-Plugins

Our website uses plugins from the social network of the following provider: Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland

These plugins enable direct interaction with content on the social network.

This integration ensures that no connection to the provider’s servers is established when a page of our website containing such plugins is accessed.

Data may also be transferred to: X Corp., USA

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

7.4 Google reCAPTCHA

On this website, we use the CAPTCHA service of the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data may also be transmitted to: Google LLC, USA. For the visual design of the captcha window, the provider uses “Google Fonts”, i.e. fonts downloaded from the Internet by Google. No information other than that already transmitted to Google via the ReCaptcha functionality will be processed.

The service checks whether an entry is made by a natural person or abusively by machine and automated processing, and blocks spam, DDoS attacks and similar automated malicious access. In order to ensure that an action is carried out by a person and not by an automated bot, the provider collects the IP address of the end device used, identification data of the browser and operating system type used as well as the date and duration of the visit and transmits these to the provider’s servers for evaluation.

The legal basis is our legitimate interest in determining individual responsibility on the Internet and avoiding abuse and spam in accordance with Art. 6 para. 1 lit. f GDPR.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

Further information on Google’s privacy policy can be found here: https://business.safety.google/intl/de/privacy/

8) Tools and miscellaneous

8.1 Cookie Consent Tool

This website uses a so-called “cookie consent tool” to obtain effective user consent for cookies and cookie-based applications that require consent. The “cookie consent tool” is displayed to users when they access the page in the form of an interactive user interface on which consent for certain cookies and/or cookie-based applications can be given by ticking a box. By using the tool, all cookies/services requiring consent are only loaded if the respective user gives the corresponding consent by ticking the box. This ensures that such cookies are only set on the user’s end device if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is not processed in this process.

If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) (f) GDPR. 1 lit. f GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.

Another legal basis for the processing is Art. 6 para. 1 lit. c GDPR. As the controller, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.

Where necessary, we have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

Further information about the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

8.2 Wordfence

For security purposes, this website uses the service of the following provider: Defiant Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA

The provider protects the website and the associated IT infrastructure from unauthorized third-party access, cyberattacks, viruses and malware. The provider collects the IP addresses of users and, if necessary, other data on your behavior on our website (in particular URLs accessed and header information) in order to detect and ward off illegitimate page access and threats. The IP address recorded is compared with a list of known attackers. If the recorded IP address is recognized as a security risk, the provider can automatically block it from accessing the site. The information collected in this way is transmitted to a server of the provider and stored there.

The data processing described is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interests in protecting the website from harmful cyber attacks and in maintaining structural and data integrity and security.

If visitors to the website have login rights, the provider also places cookies (= small text files) on the visitor’s device. With the help of cookies, certain location and device information can be read, which enables an assessment of whether the login-authorized access originates from a legitimate person. At the same time, access rights can be evaluated via the cookies and released via an internal site firewall according to the authorization level. Finally, the cookies are used to register irregular access by site administrators from new devices or new locations and to notify other administrators of this.
These cookies are only set if a user has login rights. The provider does not set cookies for site visitors without login authorization.
If personal data is processed via the cookies, the processing is carried out in accordance with Art. 6 para. 1 lit f. GDPR on the basis of our legitimate interest in preventing illegitimate access to the site administration and preventing unauthorized administrator access.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

9) Rights of the data subject

9.1 The applicable data protection law grants you the following data subject rights (information and intervention rights) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the stated legal basis for the respective exercise requirements:

Right to information pursuant to Art. 15 GDPR;
Right to rectification pursuant to Art. 16 GDPR;
Right to erasure pursuant to Art. 17 GDPR;
Right to restriction of processing pursuant to Art. 18 GDPR;
Right to information pursuant to Art. 19 GDPR;
Right to data portability pursuant to Art. 20 GDPR;
Right to withdraw consent granted pursuant to Art. 7 (3) GDPR;
Right to lodge a complaint pursuant to Art. 77 GDPR.

9.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA AS PART OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS.

IF YOUR PERSONAL DATA IS PROCESSED BY US 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. YOU CAN EXERCISE YOUR OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

10) Duration of storage of personal data

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing and – if relevant – additionally by the respective statutory retention period (e.g. retention periods under commercial and tax law).

When processing personal data on the basis of express consent pursuant to Art. 6 para. 1 lit. a GDPR, the data concerned will be stored until you withdraw your consent.

If there are statutory retention periods for data that are required in the context of legal or quasi-legal obligations on the basis of Art. 6 para. 1 lit. b GDPR, this data will be routinely deleted after expiry of the retention periods, provided that it is no longer required for contract fulfillment or contract initiation and/or we no longer have a legitimate interest in further storage.

When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 (2) GDPR.

Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data is deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.

1) Introduction and contact details of the controller

2) Data collection when visiting our website

3) Hosting & content delivery network

4) Cookies

5) Making contact

6) Data processing for order processing

7) Page functionalities

8) Tools and miscellaneous

9) Rights of the data subject

10) Duration of storage of personal data

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