We at KLUDI are delighted that you are interested in our company, our products and our services. In order to protect your privacy when you are using our web pages, we would like to inform you about the collection of your personal data in dealing with our website.

1. Responsible for data processing

The controller (responsible entity) according to the GDPR and other national data protection laws of the member states as well as of any other data privacy regulations is:

Kludi GmbH & Co. KG
Am Vogelsang 31–33
58706 Menden
Germany

2. Data protection officer

The company has appointed a data protection officer who you can contact by email at datenschutzbeauftragter[at]kludi.de or via the contact data referred to in Item 1. To postal addresses, please add the words “Data Protection – private/confidential”.

3. General information on data protection

As a service provider Kludi GmbH & Co. KG (hereinafter referred to as the “provider”) takes the obligation to protect your personal data very seriously. As a matter of course, we adhere to the provisions of any applicable data protection laws. The use of incoming data is based exclusively on the respective particular purpose.

As the controller (responsible entity) for data processing, KLUDI has implemented numerous technical and organisational measures to ensure a level of protection of the personal data processed via this website that is as complete and consistent as possible. Nevertheless, security gaps may occur in principle in internet-based data transmissions, so that absolute protection cannot be guaranteed.

Personal data is only made available to persons who have been informed about the applicable statutory regulations on data protection and have undertaken to comply with these regulations. With the following terms, in our capacity as the provider, we notify you about which of your personal data we collect and how we as provider handle your personal data:

4.  Definition of terms

The Privacy Policy of Kludi GmbH & Co. KG is based on the terms used by the European institutions responsible for legislation and the enactment of regulations while issuing the EU General Data Protection Regulation (GDPR). Our Privacy Policy shall be easily readable and comprehensible both for the general public and for our customers and business partners. To ensure such comprehensibility, we wish to explain the terms used in advance.

In this Privacy Policy, we use the following terms amongst others:

5. Legal basis for the processing of personal data

Insofar as the provider obtains consent from the person concerned with the data processing activities in relation to personal data, Art. 6 (1) a GDPR serves as the legal basis.

In regards to the processing of personal data that is required to fulfil a contract, of which the person concerned is a contracting party, Art. 6 (1) b GDPR serves as the legal basis. This also refers to data processing activities required for the implementation of pre-contractual measures.

As far as the processing of personal data is required to fulfil a legal obligation, which our company is subject to, Art. 6 (1) c GDPR serves as the legal basis.

In the event that vital interests of the person concerned or another private individual require the processing of personal data, Art. 6 (1) d GDPR serves as the legal basis.

If the data processing is required to protect a legitimate interest of the provider or a third party and if the interests, basic rights and basic freedoms of the person concerned do not override the aforementioned interest. Art. 6 (1) f GDPR serves here as the legal basis.

6. Data erasure and storage period

The personal data of the person concerned will be erased or blocked once the purpose of storage has ceased to apply. Storage beyond that point in time may result if stipulated accordingly by the European or national legislator in EU regulations, laws or other provisions, which the provider is subject to. Data will also be blocked or erased if the stipulated storage period expires as a result of the aforementioned norms/regulations, unless further storage of the data is necessary for the purpose of contract conclusion or contract performance.

7. Collection, processing and utilisation of personal data

7.1. Provision of the website and creation of logfiles

Whenever our website is accessed, our system automatically records data and information from the computer system of the retrieving computer.

The following data are collected in this context:

1) Information on the browser type and version used
(2) User’s operating system
(3) User’s IP address
(4) Date and time of access
(5) URL of the referring website
(6) The file retrieved
(7) The volume of data transmitted

The data are likewise stored in the logfiles of our system. Any storage of these data together with other personal data of the user does not take place.

The legal basis for the temporary storage of the data and the logfiles is Art. 6 (1) f GDPR.

The temporary storage of the IP address by the system is necessary to render possible the delivery of the website to the user’s computer. For this purpose, the user’s IP address has to be stored over the duration of the session.

The storage in logfiles results to ensure the functional capability of the website. In addition, the data help us optimise the website and ensure the security of our information technology systems.

The legal basis for processing of the data is Art. 6 (1) f GDPR, as a legitimate interest of the company arises from the aforementioned purpose. In our view, there are no interests of the person concerned that would override our respective interests.

The data will be erased as soon as they are no longer necessary to achieve the purpose of their collection. This is the case once the respective session has ended in the event that the data are recorded in order to make the website available.

The recording of data to make the website available and the storage of data in logfiles is indispensable for the operation of the web page. As a consequence, there is no possibility for the user to raise objections.

7.2. Basic data

Where a contractual relationship shall be established, shaped or modified between you and the provider, the latter will collect and use personal data (name, address, telephone number, email address, account data) from you as far as this is necessary to achieve the purpose of contract performance. In this respect, the legal basis for the processing of data is Art. 6 (1) b GDPR.

7.3. Newsletter data

In order to be able to provide regularly updated information about our company, we offer a newsletter subscription. When you register for our newsletter we thereby process the data you entered (name, email address, your information on company category, and assign you to a target group).

The option exists, on our websites, to subscribe to a newsletter free of charge. If you wish to receive this newsletter, we require an email address and information from you (such as the IP address of the accessing computer, and the date and time of registration), which allow us to verify that you are the owner of the aforementioned email address and that you agree with receiving the newsletter.

In the framework of the registration process, your consent to the processing of data will be obtained and this Privacy Policy will be referred to. The legal basis for the processing of data after a user has signed up for the newsletter is Art. 6 (1) a GDPR, provided the user has given his/her consent.

For its registration system, the provider makes use of the Double-Opt-In procedure in order to confirm that you explicitly wish to receive email or contact via other mediums. In the framework of this Double Opt-In procedure, an additional confirmation email, which contains a confirmation link, will be sent to the email address indicated by you. The newsletter subscription will only be activated once you click on this confirmation link.

You may withdraw your provided consent to storage of the data, the email address and its utilisation for sending the newsletter at any time without incurring any transmission costs. The provider will erase your personal data, which it has stored in this respect, at the latest once you object to its further use.

7.4. reCAPTCHA
In order to protect our web pages’ entry forms against spam and abuse, we use the external service reCAPTCHA. This is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter Google). reCAPTCHA enables a differentiation between entries of human origin and those abusively made by automated software (also known as bots). When the service is used the following data are thereby transferred to Google in the USA:

• Referrer URL
• User’s IP address
• the user’s entry behaviour and the mouse movements in the area of the “reCAPTCHA” check boxes
• Google account: If the user is at the same time logged in to his/her Google account, the following is recognised and assigned
• Information about what browser is used, browser size, browser resolution, browser plug-ins, language settings, date
• mouse and touch actions within the page
• the website’s scripts and presentation instructions
• Cookies

The processing is performed because of our overriding legitimate interest in the security of our website pursuant to Art. 6 (1) f GDPR.

Google is certified according to the Privacy Shield Agreement and hence guarantees compliance with European Data Protection Legislation:

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

You can find further information about data privacy at:

https://policies.google.com/privacy?hl=en&gl=en

7.5. Contact form

KLUDI provides a contact form on its website that can be used to make contact electronically. If you as a user choose to make use of this option, the data entered in the input mask will be transmitted to and stored by the provider. This pertains to the following personal data: Your name, your postal address, your email address and, optionally, your company affiliation as well as the telephone and fax number of the company. No data are forwarded to third parties in this context. The data are used exclusively for the purpose of processing the inquiry/request.

For processing the data your consent will be obtained within the framework of the transmission process, and this Privacy Policy will be referred to. The legal basis for the processing of data is Art. 6 (1) a GDPR, provided the user has given his/her consent. For the provider, the processing of personal data from the input mask exclusively serves the purpose of processing the initial contact. Once the inquiry/request submitted via the contact form is dealt with, the provider will erase your personal data stored in that respect.

7.6. Customer account

If you open a customer account, you thereby consent to your inventory data (name, address, email address, banking details) and your usage data (user name, password) being stored. This enables us to identify you as a customer, and affords you the possibility of managing your orders.

We thereby obtain the following consent: “I would like to create a customer account. Please process my data for this purpose. I may withdraw my consent at any time with immediate effect for the future by sending an email to the stipulated email address.”

On every individual registration page you will find specific contact information on exercising your rights, including your right to withdraw your consent.

Your data are processed on the basis of your consent pursuant to Art. 6 (1) a) GDPR.

8. External content on the KLUDI website

We use external dynamic content in order to optimise our website’s presentation and offer. When the website is visited a query is sent via API to the server of the respective content provider, during which certain log data (for instance, the user’s IP address) are transferred. The dynamic content is subsequently transferred to our website and presented there.

We use external content in connection with the following functionalities:

8.1. Google Maps

On our website we use the map service “Google Maps” from Google, in order to provide you with an interactive map. In presenting the map, data, including your IP address and your location, are transferred to the Google’s server in den USA and stored there. This processing is performed because of our overriding legitimate interest in an optimal marketing of our offer pursuant to Art. 6 (1) f GDPR.

Google is certified according to the Privacy Shield Agreement and hence guarantees compliance with European Data Protection Legislation:

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

You can find further information about data privacy at:

https://policies.google.com/privacy?hl=en&gl=en

8.2. Facebook visitor tracker

We use the “visitor action pixel” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website. This allows user behaviour to be tracked after the user has been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way are anonymous to us, i.e. we do not see the personal data of individual users.

When the website is accessed, the pixel is integrated directly by Facebook and can store a cookie on your device. If you subsequently log in to Facebook or are already logged in to Facebook, your website visit will be noted in your profile. The collected user data are anonymous for us and thus do not allow us to determine the user identity. However, these data are stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy:

https://www.facebook.com/about/privacy/

You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 (1), sentence 1 f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address:

https://www.facebook.com/settings?tab=ads

Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation

https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active

8.3. YouTube

On the basis of a consent pursuant to the first sentence of Art. 6(1) sentence 1 f GDPR, we use components (videos) of the company YouTube, LLC 901 Cherry Ave., 94066 San Bruno, CA, USA (hereinafter: “YouTube”), a company of Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA on our internet pages.

In so doing we use the option of “extended data protection mode” provided by YouTube.

When you access a page containing an embedded video, a connection to the YouTube servers is established and the contents are displayed on the internet page through a notification to your browser.

Pursuant to YouTube specifications, in the “extended data protection mode” your data – especially which of our internet pages you have visited as well as device-specific information including the IP address – is sent to the YouTube servers in the US only when you view the video. By clicking on the video, you give your consent to this transfer.

If you are simultaneously logged in to YouTube, this information is assigned to your YouTube member account. You may prevent this by logging out of your member account before visiting our website.

Google respects the data protection regulations of the US Privacy Shield and is registered with the US Privacy Shield program of the US Department of Commerce.

For more information on data protection in connection with YouTube, please refer to Google’s data protection regulations.

 

8.5 Use of Cloudflare

Our website uses the Content Delivery Network (CDN) of Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich Germany (Cloudflare) to increase the security and delivery speed of our website. This is in accordance with the legitimate interest (Art. 6 para. 1 lit. f DSGVO). A CDN is a network of servers distributed worldwide that is able to deliver optimized content to the website user. For this purpose, personal data may be processed in server log files by Cloudflare. Please compare the explanations under "L. Hosting".

Cloudflare is a recipient of your personal data and acts as a processor for us. This corresponds to our legitimate interest within the meaning of Art. 6 (1) p. 1 lit. f DSGVO not to operate a content delivery network ourselves.

You have the right to object to the processing. Whether the objection is successful is to be determined as part of a balancing of interests.

The processing of the data provided under this section is not required by law or contract. The functionality of the website is not guaranteed without the processing.

Your personal data will be stored by Cloudflare for as long as necessary for the purposes described.

For more information on objection and removal options vis-à-vis Cloudflare, please visit: https://www.cloudflare.com/cloudflare-customer-dpa

Cloudflare has implemented compliance measures for international data transfers. These apply to all global activities where Cloudflare processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs).

For more information, please visit: https://www.cloudflare.com/de-de/cloudflare-customer-scc

 

9. Transfer of personal data

9.1. Data transfer to third parties

In no circumstances are personal data leased or sold to third parties for advertising purposes. Personal data are not passed on to third parties for advertising purposes without notification and explicit consent from the customer pursuant to Art. 6 (1) a GDPR.

9.2. Disclosure of data to public authorities

Personal customer data will only be disclosed to public authorities, such as public prosecutors and courts, if a written and enforceable official or court order is issued and/or in accordance with applicable regulations to the extent that the provider is required to do so.

10. Use of Google Analytics

This website makes use of Google Analytics, a web analysis service of Google Inc, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). This use includes the operating mode Universal Analytics. This renders it possible to allocate data, sessions and interactions across several devices to one pseudonymised User ID and thus to analyse the activities of a user on a cross-device basis.

Google Analytics uses so-called “cookies”, text files that are stored on the user’s computer and that permit an analysis of their utilization of the website. The information generated by the cookie about your use of this website (including your IP address) is sent to and stored on a Google server in the USA. If IP anonymisation is activated on this website, your IP address will be shortened beforehand within the member states of the European Union or other contractual states of the Treaty on the European Economic Area. Only in exceptional cases is the full IP address sent to and truncated on a Google server in the USA. The IP address sent by your browser as part of Google Analytics is not combined with other data held by Google.

Google uses this information on behalf of the website operator to evaluate the way you use the website, to collate reports on website activities and to provide the website operator other services related to website and internet use. These purposes also constitute our legitimate interest in the data processing.

The legal basis for the use of Google Analytics is Section 15, subsection 3 of the German Telemedia Act (TMG) and Art. 6 (1) f GDPR. The provider has a legitimate interest in the analysis of user behaviour in order to optimise both its website/internet offer and its advertising activities. In our opinion, there are no interests of the person concerned that would outweigh our respective interests. The data transmitted and connected by us with cookies, user identifications (e.g. User ID) or Advertising IDs shall be erased automatically after 14 months. The erasure of data, the storage period of which has been reached, will take place automatically once a month.

You can change your browser settings to prevent cookies from being stored; however, the provider draws your attention to the fact that, in these circumstances, you may find that you are unable to make full use of functions on the website. Furthermore, you may prevent the collection of data generated through cookies (including your IP address) and related to your use of this website as well as the processing of such data by Google by downloading and installing the available browser plug-in (https://tools.google.com/dlpage/gaoptout?hl=en).

Through your consent in the cookie declaration the future collection of data by Google Analytics can be made when you visit this website. If you no longer agree to the data collection at a later point in time, you can prevent this from occurring in the future through the one-time installation of the browser add on for deactivation of Google Analytics.

Furthermore, the provider uses Google Analytics to evaluate data from AdWords and the DoubleClick cookie for purely statistical purposes. If you object, you can opt out using Ads Preferences (https://www.google.com/settings/ads/onweb/?hl=en). You can find more detailed information about Google Analytics in the Google data privacy statement at: (https://support.google.com/analytics/answer/6004245?hl=en)

11. Photo and Video Recordings

We may take photo and/or video recordings at functions, including trade fairs, exhibitions, and other events, that are not based on an invitation. We will draw your attention to the recording activity as soon as possible, and at the latest before you enter the relevant area where recordings are being made, by providing informational notices and handouts. You always have the opportunity to object to an individual recording with the respective film team.

This does not apply to overall shots in which the focus is on the presentation of the event and not on the presentation of a single person.

Kludi GmbH & Co. KG will use the documentation to accompany communication measures in print, on the internet and/or social media, as well as for internal training and communication purposes. We process the data on the basis of our legitimate interests pursuant to Art. 6 (1) f GDPR.

12. Competitions and Marketing Campaigns

As part of our business activities, we organize contests and marketing campaigns (hereinafter “campaigns”) at irregular intervals.

We request personal data from you via web forms in order to carry out campaigns. This data is required so that you can participate in the respective campaign.

We process the data provided by you to carry out the respective campaign. In doing so, we obtain the following consent:
“I would like to participate in the KLUDI campaign according to the promotion page & call to action. For this purpose, I consent to the processing of the personal data provided by me. I can withdraw my consent at any time with effect for the future by sending a message to the email address provided in the campaign.”

The participation in these campaigns is voluntary. With your participation you agree to these data processing activities.

We process your data on the basis of your consent in accordance with Art. 6 (1) a GDPR.

To carry out campaigns, we make use of other service providers who support us in implementing the campaign. You will find further campaign-specific regulations on the respective campaign pages.

13. Use of Social Media Plug-Ins

On our website social media plug-ins (“plug-ins“) of the following listed companies are used. These services are offered by the respective companies (“providers“).

13.1. Facebook and Instagram

facebook™, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The Facebook “like” button is marked with the Facebook logo, an “f”, or the supplement “Social Plugin from Facebook”. You can find an overview of the Facebook plug-ins and their appearance at https://developers.facebook.com/docs/plugins.

Whenever you access a page on our website that contains a plug-in from facebook™, your browser establishes a direct link to servers of the respective provider. The content of the plug-in is transferred by the respective provider directly to your browser and integrated into the web page. As a result of the integration of the plug-ins, the providers receive the information that your browser has accessed the corresponding page of our website even if you do not have a profile or are not logged in at this point in time. Such information (including your IP address) is transmitted directly by your browser to a server of the respective provider in the USA, where it is then stored. If you are logged in to one of these services, the respective provider can assign the visit to our website to your profile (for instance Instagram, Facebook). If you interact with the plug-ins, for instance by clicking on the “Like”, the “+1”, the “Twitter” or the “Instagram” button, the corresponding information will likewise be transmitted directly to a server of the providers and stored there. In addition, the information is published in the social media network, on your Twitter or Instagram account, and is visible to your contacts there.

Why do we collect these data?

These data are only collected when consent is given for them to be used for the purpose of direct marketing. Please refer to the providers’ data protection information for further information on this.

facebook™: http://www.facebook.com/policy.php.

For what duration will the data be stored?

Please refer to the providers’ data protection information with regard to this.

facebook™: http://www.facebook.com/policy.php.

How can I deactivate the social media plug-in?

If you do not want the provider to directly allocate the data collected via our website to your profile in the respective service, you will have to log out from the respective service prior to visiting our website. You can also prevent the plug-in from loading entirely by installing add-ons for your browser, e.g. using the “NoScript” script blocker. You can find details about this at http://noscript.net/.

Visitor action pixel On our website we use the “visitor action pixel”, also known as “custom audience pixel” of

Facebook Inc. (“Facebook”)
1601 S. California Ave.
Palo Alto, CA 94304, USA

Through this pixel, pseudonymised information is collected on your use of our website (for instance information on articles/products that have been viewed). The collected information can be used to send adverts to you, for instance on your Facebook account.

13.2. Pinterest

On our website we use the service pinterest.com. Pinterest.com is a service of Pinterest, Inc., 808 Brannan St, San Francisco, CA 94103, USA. Through the integrated “Pin it” button on our page, Pinterest receives the information that you have called up on the respective page of our website. If you are logged in to Pinterest, Pinterest can assign your visit on our page to your Pinterest account and hence link the data. By clicking the “Pin it“ button the transferred data are stored by Pinterest. With regard to the purpose and scope of the data collection, their processing and use as well as your related rights and settings options for protecting your privacy, you can find further information in the Pinterest data privacy statement, accessible via http://pinterest.com/about/privacy/.

To prevent Pinterest from being able to assign the visit to our website to your Pinterest account, you have to log out of your Pinterest account before you visit our website.

13.3 XING

On our website we use components of the network XING.com. These components are a service of XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany.

Every time you access our website, which incorporates such a component, this component prompts the browser you are using to download a corresponding version of the XING component.

To our knowledge, XING does not store any personal data of the user regarding access to our website. XING also does not store IP addresses. Furthermore, no evaluation of user behaviour via the utilisation of cookies in connection with the ”XING Share Button” occurs. You will find further information about this in the data protection information for the XING Share Button at: https://www.xing.com/app/share?op=data_protection

13.4 LinkedIn

On our website we use components of the network LinkedIn. LinkedIn is a service of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Every time you access our website, which incorporates such a component, this component prompts the browser you are using to download a corresponding version of the LinkedIn component.

Through this process LinkedIn is notified regarding what particular page of our website is being visited. If you click the LinkedIn “Like” button while logged in to your LinkedIn account, you can link the content of our websites to your LinkedIn account. This enables LinkedIn to assign the visit to our page to your LinkedIn user account.

We have influence over neither the data which LinkedIn collects through this nor the scope of these data collected by LinkedIn. We also do not know the content of the data transferred to LinkedIn. You can find details on data collection by LinkedIn as well as your rights and settings options in LinkedIn’s data protection information. You can find this information at http://www.linkedin.com/legal/privacy-policy

13.4 YouTube

This website uses the YouTube embedding function for displaying and playing videos from YouTube. We use the extended data protection mode, which according to provider information only starts storing user information when the video is played. The moment the embedded video starts playing, YouTube uses cookies to collect information about the user behaviour.

According to information from YouTube, these are amongst other things used to improve user friendliness and prevent abusive behaviour.

Irrespective of whether the embedded video is played, every time this website is accessed a connection is established to the Google network “DoubleClick”, which may trigger further data processing procedures without our influence.

You can find further information on data privacy at YouTube in the provider’s Data Privacy Policy at: https://policies.google.com/privacy?hl=en

14. Data subject rights

14.1. Consent and right to revocation

Insofar as KLUDI obtains consent from the person concerned with the data processing activities in relation to personal data, Art. 6 (1) a GDPR serves as the legal basis. In the event that you have furnished the provider with your consent to the collection, processing or utilisation of your data, the provider advises you that this consent is revocable at any time, with effect for the future, pursuant to Art. 7 (3) GDPR without a need to comply with certain formal requirements or time limits.

Consent may be withdrawn by sending an email to datenschutzbeauftragter[at]kludi.de. Alternatively, you may also withdraw your consent by fax or letter. The provider’s address and fax number are as follows: Kludi GmbH & Co. KG, Am Vogelsang 31-33, 58706 Menden, Germany, telefax: + 49 (0) 23 73 90 44 65. You will be informed via email by the provider about the content of any consent explicitly given by you.

14.2. Right to erasure

a) Obligation to erase

You may demand from the provider the erasure of any personal data relating to you without delay, and the provider will be under obligation to erase such data without delay if one of the following reasons is applicable:

(1) The personal data relating to you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You withdraw your consent, on which the data processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a GDPR, and another legal basis justifying the data processing is lacking.
(3) You raise an objection to the data processing pursuant to Art. 21 (1) GDPR, and there exist no overriding legitimate reasons for the processing, or you raise an objection to the data processing pursuant to Art. 21 (2) GDPR.
(4) The personal data relating to you were processed in an unlawful manner.
(5) The erasure of the personal data relating to you is necessary to fulfil a legal obligation under Union or Member State law, which the provider is subject to.
(6) The personal data relating to you were collected with reference to services offered by the information society in accordance with Art. 8 (1) GDPR.

b) Provision of information to third parties

Where the provider has published the personal data relating to you and is obliged to erase them pursuant to Art. 17 (1) GDPR, it will take appropriate measures, including technical measures, in consideration of the available technology and the cost of implementation, to inform the persons/entities responsible for data processing, which process the personal data, that you as a person concerned have demanded they erase all links to these personal data or all copies or replications of these personal data.

c) Exceptions

The right to erasure does not apply if the data processing is necessary

(1) to exercise the right of free speech and information;
(2) to fulfil a legal obligation, which necessitates the data processing activities according to Union or Member State law, which the provider is subject to, or to perform a task in which there is a public interest or which is performed in the exercise of public authority that has been assigned to the person/entity responsible for data processing;
(3) for reasons of a public interest in the area of public health pursuant to Art. 9 (2) h and i and Art. 9 (3) GDPR;
(4) for archival purposes, scientific purposes or historical research purposes in the public interest, or for statistical purposes pursuant to Art. 89 (1) GDPR, as far as the right referred to under a) is likely to render the achievement of the objectives of these data processing activities impossible or seriously affect them, or
(5) for the assertion, exercise or defence of legal claims.

14.3. Right to complain with the responsible supervisory authority

Regardless of any other legal remedy under administrative law or any judicial remedy, you are entitled to lodge a complaint with a supervisory authority, especially in the member state of your place of domicile, your place of work or the place of the presumable infringement, if you are of the opinion that the processing of personal data relating to you is in breach of the GDPR.

The supervisory authority, to which the complaint has been submitted, will inform the complainant on the state and outcome of the complaint, including the possibility of a judicial remedy in accordance with Art. 78 GDPR.

The supervisory authority responsible for the provider is:

Landesbeauftragte für Datenschutz und Informationsfreiheit North Rhine-Westphalia
P.O. Box 20 04 44
40102 Düsseldorf, Germany
Phone: 0211/38424-0
Fax: 0211/38424-10

14.4. Right to information

You may demand confirmation from the provider as to whether the latter processes personal data in relation to you.

Where such data processing activities are conducted, you are entitled to demand the following information from the provider:

(1) the purposes for which personal data are processed;
(2) the categories of personal data that are processed;
(3) the recipients or categories of recipients, to which the personal data relating to you have been disclosed or will be disclosed in the future;
(4) the scheduled duration of storage of the personal data relating to you or, if specific information thereon is not possible, criteria for the determination of the storage period;
(5) the existence of a right to have the personal data relating to you corrected or erased, a right to restriction of the data processing by the provider or a right to raise objections against such data processing;
(6) the existence of the right to lodge a complaint with the supervisory authority;
(7) all available information on the origin of the data if the personal data are not collected from the person concerned;
(8) the existence of an automated decision-making process including profiling pursuant to Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information on the involved logic and the impact and intended consequences of such data processing activities for the person concerned.

You are entitled to demand information as to whether the personal data relating to you are transmitted to a third country or an international organisation. In this context, you may demand to be provided with information on the appropriate guarantees pursuant to Art. 46 GDPR in connection with the data transmission.

14.5. Right to correction

You are entitled to correction and/or completion of your data by the provider if the processed personal data relating to you is incorrect or incomplete. The provider shall correct any such data without delay.

14.6. Right to restriction of the data processing

You are entitled to demand the restriction of the processing of personal data relating to you under the following conditions:

(1) if you dispute the correctness of the personal data relating to you for a period of time, which enables the provider to review the correctness of the personal data;
(2) if the processing is unlawful and if you reject the erasure of the personal data and instead demand the restriction of utilisation of those personal data;
(3) if the provider no longer requires the personal data for the purpose of data processing, but if you require these data for the assertion, exercise or defence of legal claims, or
(4) if you have raised an objection to the data processing pursuant to Art. 21 (1) GDPR and if it is still uncertain whether the legitimate interests of the provider override your own reasons.

Where the processing of personal data relating to you has been restricted, these data may only be processed – except for their storage – with your consent or for the assertion, exercise or defence of legal claims, or for the protection of the rights of another private individual or legal entity, or for reasons relating to a significant public interest of the EU or a member state.

Where the restriction of personal data processing itself has been restricted in accordance with the aforementioned prerequisites, you shall be notified by the provider before the restriction is lifted.

14.7. Right to notification

If you have asserted the right to correction, erasure or restriction of data processing vis-à-vis the provider, the latter will be under obligation to communicate this correction or erasure of data or the restriction of data processing to all recipients, to which the personal data relating to you have been disclosed, unless it turns out that this is impossible or requires disproportionate expenditure.

You are entitled to be notified by the provider on the provider’s provision of corresponding information to such recipients.

14.8. Right of data portability

You are entitled to receive the personal data relating to you, which you have made available to the provider, in a structured, well-established and machine-readable format. You also have the right to transfer these data to another controller (responsible entity) without hindrance by the provider to whom the personal data were provided, insofar as

(1) the processing is based on consent pursuant to Art. 6 (1) a GDPR or Art. 9 (2) a GDPR or on a contract pursuant to Art. 6 (???) b GDPR and
(2) the processing is carried out using an automated procedure.

In exercising this right, you are furthermore entitled to ensure that the personal data relating to you is transmitted directly from one controller/entity responsible for data processing to another controller/entity responsible for data processing to the extent that this is technically feasible. The freedoms and rights of other people must not be adversely affected by this transmission.

The right of data portability does not apply to any processing of personal data that is necessary to perform a task in the public interest, or to fulfil a task that is performed in the exercise of public authority, which has been assigned to the person /entity responsible for data processing.

14.9. Right to raise objections

You are entitled, for reasons arising from your particular situation, to raise an objection at any time against the processing of personal data relating to you, which is conducted on the grounds of Art. 6 (1) e or f GDPR; the same also applies to any profiling activities conducted on the basis of these provisions.

The provider will cease processing the personal data relating to you unless it is able to provide evidence of compelling reasons for the processing, which must be worthy of protection and outweigh your interests, rights and freedoms, or if the data processing serves to assert, exercise or defend legal claims.

If the personal data relating to you is processed for the purpose of direct advertising activities, you are entitled to raise an objection at any time against the processing of personal data relating to you for the purpose of such advertising activities; the same shall apply to profiling as far as it is connected with such advertising activities.

If you raise an objection against the processing of data for the purpose of direct advertising, the personal data relating to you will no longer be used for such purposes.

In connection with the utilisation of services of the information society, you have the opportunity – regardless of Regulation 2002/58/EC – to exercise your right of objection through automated procedures that make use of technical specifications.

15. Automated decision in the individual case including profiling

You have the right not to be made subject to any decision based exclusively on automated processing – including profiling – insofar as this decision has legally effective consequences for you or significantly affects you in a similar manner. This does not apply if the decision

(1) is necessary for concluding or fulfilling a contract between you and the provider,
(2) is permissible based on legal regulations of the EU or the Member States to which the provider is subject, and these legal regulations contain appropriate measures to preserve your rights and freedoms, as well as your legitimate interests or
(3) is performed with your explicit consent.

However, these decisions must not be based on particular categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) a or g GDPR is applicable and appropriate measures have been taken for the protection of rights and freedoms and of your legitimate interests.

In regards to the cases referred to in (1) and (3), the provider will take appropriate measures to protect the rights and freedoms and your legitimate interests, which shall include at least the right to enforce the intervention from a person on behalf of the provider, to explain one’s own position and to challenge the decision.

As a company that thinks and acts responsibly, we do not utilise automated decision-making or profiling.

16. Cookies

This website uses cookies. Cookies are small text files that are used by websites to more efficiently structure the user experience. We use cookies to personalise contents and adverts, to be able to offer functions for social media and to analyse accesses to out website. We also forward information on your use of our website to our partners for social media, advertising and analyses. Our partners may compile this information together with other data, which you have provided to them or which they collected in the framework of your use of the services. You provide your consent to our cookies if you want to continue using our website.

Most of the cookies used by us are “Session Cookies”, which are erased automatically after the end of your website visit. Other cookies remain stored on your terminal device until you erase them. These cookies enable us to recognise your browser on the occasion of your next visit.

According to legislation, we are allowed to store these cookies on your device if these are absolutely necessary for operating this page. We require your permission for all other types of cookies.

This page uses different types of cookies. Some cookies are placed by third parties who appear on our pages.

You may change or withdraw your consent from the cookies statement on our website.

If you wish to prevent cookies from being stored on your computer in the future, please refer to the instructions provided by your browser producer by clicking the browser’s “Help” tab. Please note that if you do delete cookies sent by the provider or if you deactivate cookies in the future, this may prevent you from accessing certain areas or functions of the provider’s website. The legal basis for the processing of data is a legitimate interest of the company pursuant to Art. 6 (1) f GDPR, as a legitimate interest of the company results from the aforementioned purpose. In our opinion, there are no interests of the person concerned that would outweigh our respective interests.

We use cookies in connection with the following functionalities:

16.1. Google Analytics

We use Google Analytics, a service of Google LLC, 1600 Amphitheater Parkway Mountain View, CA 94043 USA. Google uses certain cookies. The information generated by the cookie about your use of this website (including your IP address) will be transmitted to and stored by Google on servers in the United States. We use the information stored to evaluate your use of the website, to compile reports on website activity for website operators, and to provide other website-related services. Due to our overriding interest, we process the data thus obtained for the optimal marketing of our online offer according to Art. 6 (1) f GDPR. Google will never associate your IP address with other Google data.

You may opt out of the collection of data at any time by using the Google Analytics opt-out browser add-on, found here:

http://tools.google.com/dlpage/gaoptout?hl=en

Please also see the notes on the use of Google data in the Google Partner Network at:

https://policies.google.com/technologies/partner-sites?hl=en

https://www.google.com/policies/privacy/ads/ 

Google is certified according to the Privacy Shield Agreement and hence guarantees compliance with European Data Protection Legislation:

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

You can find further information about data privacy at:

https://policies.google.com/privacy?hl=en&gl=en 

16.2. Google AdWords

In order to measure the success of our Google Adwords campaigns, we use Google’s conversion tracking procedure. Insofar as you access our website through a Google advert, Google uses a cookie to record the process for statistical purposes. As a matter of principle the data are erased as soon as the purpose for collecting them has been fulfilled. For details please refer to the service providers’ privacy policy. Google: https://policies.google.com/privacy?hl=en 

16.3. Google Remarketing

To present the most interesting possible internet offer we use Google Remarketing on the website. This technology enables additional offers to be presented to customers in the Google Partners network. The displaying of the advertising on the partner pages is achieved by placing a cookie and analysis of user behaviour. No personal data of any kind is thereby stored.

As a matter of principle the data are erased as soon as the purpose for collecting them has been fulfilled. For details please refer to the service providers’ privacy policy.

Google: https://policies.google.com/privacy?hl=en

In our Data Protection Directive (Privacy Policy) you will find out who we are, how you can contact us and how we process your personal data.

Your consent applies to the following domain: www.kludi.com 

17. Up-to-Dateness and Amendments to this Data Protection Information

This data protection information as amended in March 2021 is currently valid.

It may become necessary to change this data protection information according to the further development of our website and its offers or due to amended legal or official requirements. You may access and print the latest data protection information at any time on the website via this link: https://www.kludi.com/en/data-policy/