Privacy Policy - Poulten Graf

1) Introduction and contact details of the responsible person

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 any data with which you can be personally identified.

1.2 The person responsible for data processing on this website within the meaning of the General Data Protection Regulation (DSGVO) is Poulten & Graf GmbH, Karl-Carstens-Str. 10, 97877 Wertheim, Germany, Tel.: +49 (0)9342 / 922 90, e-mail: H.Fahrenkrog-Keller@poulten-graf.com. 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.

1.3 The data controller has appointed a data protection officer, who can be reached 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 During the mere informational use of our website, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to the page server (so-called “server log files”). When you call up 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 anonymised form)

The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO 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 illegal 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 enquiries to the person responsible). You can recognise an encrypted connection by the string “https://” and the lock symbol in your browser line.

3) Cookies

In order to make visiting our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called “session cookies”), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called “persistent cookies”). In the latter case, you can find the storage period in the overview of the cookie settings 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 DSGVO either for the performance of the contract, in accordance with Art. 6 para. 1 lit. a DSGVO in the case of consent given or in accordance with Art. 6 para. 1 lit. f DSGVO to protect our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

You can set your browser in such a way that you are informed about the setting of cookies and can decide individually about their acceptance or can exclude the acceptance of cookies for certain cases or generally.
Please note that if you do not accept cookies, the functionality of our website may be limited.

4) Contacting

When contacting us (e.g. via contact form or e-mail), personal data is processed – exclusively for the purpose of processing and answering 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 (1) lit. f DSGVO. If your contact is aimed at a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DSGVO. Your data will be deleted when the circumstances indicate that the matter concerned has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

5) Data processing for order handling

5.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Para. 1 lit. b DSGVO.

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

In order 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.

5.2 Use of payment service providers (payment services)

– Paypal

One or more online payment methods from 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 an advance payment, your payment data provided 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 passed on to the provider in accordance with Art. 6 (1) lit. b DSGVO. In this case, your data will only be passed on for the purpose of processing payment with the provider and only insofar as 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, postcode, town, date of birth, e-mail address, telephone number, if applicable data on an alternative means of payment) during the ordering process.

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

The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised 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 the contractual processing of payments.

6) Page functionalities

6.1 Facebook plugins with Shariff solution
Plugins of the social network of the following provider are used on our website: Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

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

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

This integration ensures that when a page of our website containing such plugins is called up, no connection is yet established with the provider’s servers.

Only when you activate the plugins and thus give your consent to the data transfer in accordance with Art. 6 para. 1 lit. a DSGVO, does your browser establish a direct connection to the provider’s servers. Here, regardless of a login to an existing user profile, information about your end device used (including your IP address), your browser and your page history is transmitted to the provider to a certain extent and processed there if necessary.

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 our site visitors’ data and prohibits unauthorised 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.

6.2 LinkedIn plugins with Shariff solution
Plugins of the social network of the following provider are used on our website: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

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

This integration ensures that when a page of our website containing such plugins is called up, no connection is yet established with the provider’s servers.

Data may also be transferred to: LinkedIn Inc., USA
We have concluded an order processing contract with the provider, which ensures the protection of our site visitors’ data and prohibits unauthorised disclosure to third parties.

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

6.3 X-Plugins with Shariff solution
Plugins of the social network of the following provider are used on our website: Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland.

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

This integration ensures that when a page of our website containing such plugins is called up, no connection is yet established with the provider’s servers.

Data may also be transferred to: X Corp, USA
We have concluded an order processing contract with the provider, which ensures the protection of our site visitors’ data and prohibits unauthorised disclosure to third parties.

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

6.4 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 loaded from the Internet by Google. No information other than that mentioned above, which is already transmitted to Google via the functionality of ReCaptcha, is processed.

The service checks whether an input is made by a natural person or abusively by machine and automated processing, and blocks spam, DDoS attacks and similar automated malicious access. To ensure that an action is performed by a human being and not by an automated bot, Cloudflare Turnstile collects the IP address of the end device used, recognition data of the browser and operating system type used, as well as the date and duration of the visit, and transmits these to servers of the provider for evaluation.
The legal basis is our legitimate interest in establishing individual ownership on the Internet and preventing abuse and spam in accordance with Art. 6 (1) lit. f DSGVO.

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

7) Tools and miscellaneous

7.1 Cookie-Consent-Tool (Borlabs Cookie)

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 in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box. Through the use of the tool, all cookies/services requiring consent are only loaded if the respective user gives the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user 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) lit. f DSGVO 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.

Further legal basis for the processing is Art. 6 para. 1 lit. c DSGVO. As the responsible party, 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 agreement with the provider, which ensures the protection of our site visitors’ data and prohibits unauthorised disclosure to third parties.

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

» Customise cookie settings

7.2 – 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 against unauthorised third-party access, cyber attacks and viruses and malware. The provider collects the IP addresses of users and, if necessary, further data on their behaviour on our website (in particular URLs called up and header information) in order to recognise and ward off illegitimate page accesses and threats. In doing so, the collected IP address is compared with a list of known attackers. If the captured IP address is identified 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 above is carried out pursuant to Art. 6 (1) lit. f DSGVO 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 sets cookies (= small text files) on the respective end device of the visitor. With the help of the cookies, certain location and device information can be read, which enables an assessment of whether the login-authorised access originates from a legitimate person. At the same time, access rights can be evaluated via the cookies and released via a site-internal firewall according to the authorisation 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 authorisation.

If personal data is processed via the cookies, the processing is carried out in accordance with Art. 6 para. 1 lit f. DSGVO on the basis of our legitimate interest in preventing illegitimate access to the site administration and defence against unauthorised administrator access.
We have concluded an order processing contract with the provider, which ensures the protection of our site visitors’ data and prohibits unauthorised disclosure to third parties.

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

8) Rights of the person concerned

8.1 The applicable data protection law grants you the following data subject rights (rights of information and intervention) 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 prerequisites:

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 Article 77 of the GDPR.

8.2 RIGHT OF OBJECTION
IF WE PROCESS YOUR PERSONAL DATA WITHIN THE FRAMEWORK OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE AT ANY TIME ON GROUNDS ARISING FROM 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 PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING. YOU CAN EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

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

9) Duration of the storage of personal data

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

When processing personal data on the basis of explicit consent pursuant to Art. 6 (1) a DSGVO, the data concerned will be stored until you revoke your consent.

If there are statutory retention periods for data that is processed within the scope of legal or quasi-legal obligations on the basis of Art. 6 Para. 1 lit. b DSGVO, this data will be routinely deleted after expiry of the retention periods, insofar as it is no longer required for the fulfilment of the contract or the initiation of the contract and/or there is no justified interest on our part in the continued storage.

When processing personal data on the basis of Art. 6(1)(f) DSGVO, this data is stored until you exercise your right to object pursuant to Art. 21(1) DSGVO, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

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

Unless otherwise indicated in the other information in this statement on specific processing situations, stored personal data are otherwise deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.

1) Introduction and contact details of the responsible person

2) Data collection when visiting our website

3) Cookies

4) Contacting

5) Data processing for order handling

6) Page functionalities

7) Tools and miscellaneous

8) Rights of the person concerned

9) Duration of the storage of personal data

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