Privacy Policy
1) Information on the collection of personal data and the controller’s contact details
1.1 We are pleased that you are visiting our website and thank you for your interest. Below, we explain how we handle your personal data when you use our website. Personal data are all data by which you can be personally identified.
1.2 The controller for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is allSMT GmbH & Co. KG, Am Windrad 1b, 52156 Monschau, Germany, Tel.: 024729127040, email: infoatsasinno.eu. The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data.
1.3 For security reasons and to protect the transmission of personal data and other confidential content (for example, orders or enquiries to the controller), this website uses SSL/TLS encryption. You can recognise an encrypted connection by the ‘https://’ string and the padlock icon in your browser’s address bar.
2) Data collection when visiting our website
When you use our website for information only, meaning that you do not register or otherwise provide us with information, we collect only the data that your browser sends to our server (‘server log files’). When you visit our website, we collect the following data, which are technically necessary for us to display the website to you:
- Our website visited
- Date and time of access
- Amount of data sent in bytes
- Source/referral from which you reached the page
- Browser used
- Operating system used
- IP address used (where applicable, anonymised)
Processing takes place pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data are not disclosed or used otherwise. However, we reserve the right to review the server log files subsequently if there are concrete indications of unlawful use.
3) Cookies
To make visiting our website attractive and enable certain functions, we use cookies, small text files stored on your device. Some are automatically deleted when the browser is closed (‘session cookies’); others remain on your device longer and enable page settings to be saved (‘persistent cookies’). In the latter case, you can find the storage period in your web browser’s cookie settings overview.
Where cookies used by us also process personal data, processing takes place pursuant to Art. 6(1)(b) GDPR for performance of a contract, Art. 6(1)(a) GDPR where consent has been given, or Art. 6(1)(f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a user-friendly and effective design of the visit.
You can configure your browser to inform you when cookies are set and decide individually whether to accept them, or exclude the acceptance of cookies in certain cases or generally.
Please note that declining cookies may limit the functionality of our website.
4) Contacting us
4.1 – Tawk.to
On this website, technologies of tawk.to inc., 187 East Warm Springs Rd, SB298 Las Vegas, NV 89119, USA (www.tawk.to), collect and store anonymised data for web analysis and operation of the live chat system to answer live support enquiries. Usage profiles may be created from this anonymised data under a pseudonym. Cookies may be used for this purpose. Cookies are small text files stored locally in the cache of the visitor’s internet browser. Cookies enable the internet browser to be recognised.
Data collected with tawk.to technologies are not used to personally identify visitors to this website without their separate consent and are not combined with personal data about the holder of the pseudonym. To prevent tawk.to cookies from being stored, you can configure your browser so that no cookies can be placed on your computer in future or delete cookies already placed there. Disabling all cookies may, however, mean that some functions of our websites no longer work. You may object at any time, with future effect, to the collection and storage of data for creating a pseudonymised usage profile by sending an informal email to the address given in the legal notice.
We have concluded a data processing agreement with tawk.to Inc., the provider of tawk.to, obliging it to protect our customers’ data and not disclose it to third parties.
4.2 When you contact us (for example, by contact form or email), personal data are processed solely to handle and answer your enquiry and only to the extent necessary for that purpose. The legal basis is our legitimate interest in answering your enquiry pursuant to Art. 6(1)(f) GDPR. If your contact relates to a contract, Art. 6(1)(b) GDPR is an additional legal basis. Your data will be deleted when the circumstances indicate that the matter has been conclusively resolved, provided no statutory retention obligations prevent deletion.
5) Data processing when opening a customer account
Pursuant to Art. 6(1)(b) GDPR, personal data are also collected and processed to the extent necessary if you provide them when opening a customer account. The data required to open an account are shown in the input fields of the corresponding form on our website. You may delete your customer account at any time by sending a message to the controller at the address stated above. After your account is deleted, your data will be deleted provided that all contracts concluded through it have been fully performed, no statutory retention periods prevent deletion and we have no continuing legitimate interest in retaining them.
6) Use of customer data for direct advertising
6.1 Subscription to our email newsletter
If you subscribe to our email newsletter, we will regularly send you information about our offers. Only your email address is required to send the newsletter. Providing other data is voluntary and is used to address you personally. We use the double opt-in procedure for sending the newsletter, ensuring that you receive it only after expressly confirming your consent by activating a verification link sent to the email address you provided.
By activating the confirmation link, you consent to the use of your personal data pursuant to Art. 6(1)(a) GDPR. We store the IP address entered by your internet service provider (ISP), together with the date and time of subscription, so that any later misuse of your email address can be traced. Data collected when you subscribe are used strictly for this purpose. You may unsubscribe at any time using the link in the newsletter or by notifying the controller named at the beginning. After you unsubscribe, your email address is immediately deleted from our newsletter distribution list unless you have expressly consented to further use of your data or we reserve the right to use the data beyond this in a manner permitted by law and explained in this notice.
6.2 – Newsletter delivery via rapidmail
Our email newsletters are sent through the technical service provider rapidmail GmbH, Augustinerplatz 2, 79098 Freiburg (‘rapidmail’), to which we disclose the data you provided when subscribing. This disclosure takes place pursuant to Art. 6(1)(f) GDPR and serves our legitimate interest in using an effective, secure and user-friendly newsletter system. Data entered to receive the newsletter (such as your email address) are stored on rapidmail’s servers in Germany.
rapidmail uses this information to send and statistically analyse the newsletters on our behalf. For analysis, the emails sent contain web beacons or tracking pixels: one-pixel image files stored on our website. These show whether a newsletter was opened and which links, if any, were clicked. Conversion tracking also makes it possible to analyse whether a predefined action (for example, purchasing a product on our website) follows a click on a newsletter link. Technical information is also collected (for example, access time, IP address, browser type and operating system). Data are collected solely in pseudonymised form and are not linked to your other personal data; direct identification of a person is excluded. These data are used solely for statistical analysis of newsletter campaigns. The results may be used to adapt future newsletters more closely to recipients’ interests.
If you wish to object to data analysis for statistical evaluation, you must unsubscribe from the newsletter.
We have concluded a data processing agreement with rapidmail obliging it to protect our customers’ data and not disclose them to third parties.
Further information on rapidmail’s data protection can be found in rapidmail’s privacy policy: https://www.rapidmail.de
7) Data processing for order handling
7.1 To the extent necessary for contract performance, delivery and payment, personal data collected by us are disclosed to the commissioned transport company and credit institution pursuant to Art. 6(1)(b) GDPR.
If, under a corresponding contract, we owe you updates for goods with digital elements or for digital products, we process the contact details provided with your order (name, address, email address) to inform you personally, by an appropriate communication channel (such as post or email), of upcoming updates within the statutory period in fulfilment of our legal information obligations pursuant to Art. 6(1)(c) GDPR. Your contact details are used strictly for notices about updates owed by us and processed only to the extent necessary for each notice.
To process your order, we also work with the service providers named below, which support us wholly or partly in performing concluded contracts. Certain personal data are disclosed to them as described below.
7.2 Disclosure of personal data to shipping service providers
– Deutsche Post
If goods are delivered by Deutsche Post (Deutsche Post AG, Charles-de-Gaulle-Straße 20, 53113 Bonn), we disclose your email address to Deutsche Post before delivery, pursuant to Art. 6(1)(a) GDPR, to arrange a delivery date or announce delivery if you expressly consented to this during the order process. Otherwise, pursuant to Art. 6(1)(b) GDPR, we disclose only the recipient’s name and delivery address to Deutsche Post for delivery. Disclosure occurs only to the extent necessary to deliver the goods. In this case, arranging the delivery date with Deutsche Post in advance or receiving a delivery announcement is not possible.
Consent may be withdrawn at any time with future effect by notifying the controller named above or Deutsche Post.
– DHL
If goods are delivered by DHL (DHL Paket GmbH, Sträßchensweg 10, 53113 Bonn), we disclose your email address to DHL before delivery, pursuant to Art. 6(1)(a) GDPR, to arrange a delivery date or announce delivery if you expressly consented to this during the order process. Otherwise, pursuant to Art. 6(1)(b) GDPR, we disclose only the recipient’s name and delivery address to DHL for delivery. Disclosure occurs only to the extent necessary to deliver the goods. In this case, arranging the delivery date with DHL in advance or receiving a delivery announcement is not possible.
Consent may be withdrawn at any time with future effect by notifying the controller named above or DHL.
– FedEx
If goods are delivered by FedEx (FedEx Express Germany GmbH, Langer Kornweg 34 k, 65451 Kelsterbach), we disclose your email address and telephone number to FedEx before delivery, pursuant to Art. 6(1)(a) GDPR, to arrange a delivery date or announce delivery if you expressly consented to this during the order process. Otherwise, pursuant to Art. 6(1)(b) GDPR, we disclose only the recipient’s name and delivery address to FedEx for delivery. Disclosure occurs only to the extent necessary to deliver the goods. In this case, arranging the delivery date with FedEx in advance or receiving a delivery announcement is not possible.
Consent may be withdrawn at any time with future effect by notifying the controller named above or FedEx.
– Schenker
If goods are delivered by Schenker (Schenker Deutschland AG, Lyoner Straße 15, 60528 Frankfurt am Main), we disclose your email address to Schenker before delivery, pursuant to Art. 6(1)(a) GDPR, to arrange a delivery date or announce delivery if you expressly consented to this during the order process. Otherwise, pursuant to Art. 6(1)(b) GDPR, we disclose only the recipient’s name and delivery address to Schenker for delivery. Disclosure occurs only to the extent necessary to deliver the goods. In this case, arranging the delivery date with Schenker in advance or receiving a delivery announcement is not possible. Consent may be withdrawn at any time with future effect by notifying the controller named above or Schenker.
– UPS
If goods are delivered by UPS (United Parcel Service Deutschland Inc. & Co. OHG, Görlitzer Straße 1, 41460 Neuss), we disclose your email address to UPS before delivery, pursuant to Art. 6(1)(a) GDPR, to arrange a delivery date or announce delivery if you expressly consented to this during the order process. Otherwise, pursuant to Art. 6(1)(b) GDPR, we disclose only the recipient’s name and delivery address to UPS for delivery. Disclosure occurs only to the extent necessary to deliver the goods. In this case, arranging the delivery date with UPS in advance or receiving shipment status information is not possible.
Consent may be withdrawn at any time with future effect by notifying the controller named above or UPS.
7.3 Use of payment service providers (payment services)
– PayPal
For payment via PayPal, credit card via PayPal, direct debit via PayPal or, if offered, purchase on account or instalment payment via PayPal, we pass your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg (‘PayPal’) as part of payment processing. Disclosure takes place pursuant to Art. 6(1)(b) GDPR and only to the extent necessary to process payment.
For credit card or direct debit via PayPal, or where offered, purchase on account or instalment payment via PayPal, PayPal reserves the right to obtain a credit check. Your payment data may be disclosed to credit agencies pursuant to Art. 6(1)(f) GDPR on the basis of PayPal’s legitimate interest in assessing your ability to pay. PayPal uses the result concerning the statistical probability of default to decide whether to offer the payment method. Credit information may include probability values (‘score values’) based on a scientifically recognised mathematical and statistical procedure. Address data are among the data used. For further data protection information, including credit agencies used, see PayPal’s privacy policy: https://www.paypal.com
You may object to this processing at any time by notifying PayPal. PayPal may, however, remain entitled to process your personal data where necessary for contractual payment processing.
8) Web analytics services
Google (Universal) Analytics
This website uses Google (Universal) Analytics, a web analytics service of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (‘Google’). It uses cookies, text files stored on your device that enable analysis of website use. Cookie-generated information about your use of this website, including your shortened IP address, is generally transferred to and stored on a Google server; it may also be transferred to Google LLC servers in the USA.
This website uses Google (Universal) Analytics only with the ‘_anonymizeIp()’ extension, which shortens and anonymises the IP address and excludes direct identification. Google first shortens your IP address within EU member states or other states party to the European Economic Area Agreement. Only exceptionally is the full IP address transferred to a Google LLC server in the USA and shortened there. On our behalf, Google uses this information to evaluate your use of the website, compile website activity reports and provide us with other website and internet-related services. The IP address sent by your browser within Google (Universal) Analytics is not combined with other Google data.
The ‘demographics’ function of Google Analytics also enables statistics about visitors’ age, gender and interests based on interest-based advertising and third-party information. This allows groups of website users to be defined and differentiated for targeted marketing. Data collected through ‘demographics’ cannot, however, be attributed to a particular person.
Details of processing initiated by Google Analytics and Google’s handling of website data can be found here: https://policies.google.com
All processing described above, especially Google Analytics cookies reading information from your device, takes place only if you have expressly consented pursuant to Art. 6(1)(a) GDPR. Without consent, Google Analytics is not used during your visit.
You may withdraw consent at any time with future effect by disabling the service in the website’s ‘Cookie Consent Tool’. We have concluded a data processing agreement with Google for Google Analytics, obliging it to protect visitors’ data and not disclose them to third parties.
For transfers from the EU to the USA, Google relies on the European Commission’s standard contractual clauses, intended to ensure European data protection standards in the USA.
Further information on Google (Universal) Analytics can be found here: https://policies.google.com
9) Retargeting / remarketing / referral advertising
releva.nz (releva GmbH)
This website uses retargeting technology from releva GmbH, Feilnerstr. 10, 10969 Berlin (www.releva.nz), enabling visitors to be addressed with personalised, interest-based advertising. Advertisements are displayed based on cookie-based analysis of previous use, without storing personal data. A cookie on your computer or mobile device collects pseudonymised data about your interests within a pseudonymised user profile so advertising can be tailored to the stored information. These cookies are small text files on your device. This lets us display advertising likely to match your product and information interests. Cookie-generated information in the pseudonymous profile is not used to identify visitors personally and is not combined with personal data about the pseudonym’s holder.
All processing described above, especially cookies reading information from your device, takes place only with your express consent pursuant to Art. 6(1)(a) GDPR. You may withdraw consent at any time with future effect by disabling the service in the website’s ‘Cookie Consent Tool’.
10) Website functionality
10.1 Use of Vimeo videos
Our website incorporates plugins from the Vimeo video portal of Vimeo, LLC, 555 West 18th Street, New York, NY 10011, USA. When you access a page containing a plugin, your browser connects directly to Vimeo’s servers. Vimeo transmits the plugin content to your browser and embeds it in the page. Vimeo thereby learns that your browser accessed that page, even without a Vimeo account or login. This information, including your IP address, is sent directly from your browser to a Vimeo server in the USA and stored there.
If you are logged in, Vimeo can directly associate your visit with your Vimeo account. Interactions with plugins, such as pressing a video’s start button, are also sent directly to and stored on a Vimeo server.
If you do not want Vimeo to associate data collected through our website directly with your account, log out of Vimeo before visiting.
For the purpose and scope of data collection, Vimeo’s further processing and use, and your related rights and privacy settings, see Vimeo’s privacy notice: https://vimeo.com
Vimeo videos embedded on our site automatically incorporate Google Analytics tracking from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. This is Vimeo’s own tracking, to which we have no access and over which our site has no influence. Google Analytics uses cookies, text files stored on your computer that enable analysis of your website use. Cookie-generated information about your use is generally transferred to and stored on a Google server; it may also be transferred to Google LLC servers in the USA.
All processing described above, especially reading information from your device through the tracking pixel, takes place only with your express consent pursuant to Art. 6(1)(a) GDPR. Without consent, Vimeo videos are not used during your visit.
You may withdraw consent at any time with future effect by disabling this service in the website’s ‘Cookie Consent Tool’ or through alternative options explained on the website.
10.2 – TeamViewer
We use TeamViewer from TeamViewer Germany GmbH, Bahnhofsplatz 2,
73033 Göppingen, to conduct online meetings, video conferences and/or webinars.
When TeamViewer is used, various data are processed. The scope depends on what you disclose before or during an online meeting, video conference or webinar. Participants’ data are processed and stored on TeamViewer Germany GmbH servers. These may include registration data (name, email address, telephone number (optional), password) and meeting data (subject, participant IP address, device information, description (optional)). Participants’ visual and audio contributions and chat entries may also be processed.
Where processing is necessary to perform a contract with you, including pre-contractual measures, Art. 6(1)(b) GDPR is the legal basis. Where you have consented, processing is based on Art. 6(1)(a) GDPR. Consent may be withdrawn at any time with future effect.
Otherwise, the legal basis for data processing during online meetings, video conferences or webinars is our legitimate interest in conducting them effectively pursuant to Art. 6(1)(f) GDPR.
We have concluded a data processing agreement with TeamViewer Germany GmbH obliging it to protect visitors’ data and not disclose them to third parties. Further information on TeamViewer’s use of data can be found in its privacy policy at https://www.teamviewer.com
– Google Meet
We use Google Meet from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, to conduct online meetings, video conferences and/or webinars.
When Google Meet is used, various data are processed. The scope depends on what you disclose before or during an online meeting, video conference or webinar. Participants’ data are processed and stored on Google servers. These may include registration data (name, email address, telephone number (optional), password) and meeting data (subject, participant IP address, device information, description (optional)). Participants’ visual and audio contributions and chat entries may also be processed. Data may also be transferred to Google LLC servers in the USA.
Where processing is necessary to perform a contract with you, including pre-contractual measures, Art. 6(1)(b) GDPR is the legal basis. Where you have consented, processing is based on Art. 6(1)(a) GDPR. Consent may be withdrawn at any time with future effect.
Otherwise, the legal basis for processing during online meetings, video conferences or webinars is our legitimate interest in conducting them effectively pursuant to Art. 6(1)(f) GDPR. Further information about Google Meet’s use of data is available in Google’s privacy policy at https://www.google.de
– GoToMeeting
You can register for our webinars on our website. Registration data (first and last name, email address and, where applicable, payment data) are collected and stored solely for your participation in and conduct of the relevant webinar pursuant to Art. 6(1)(b) GDPR. We use GoToMeeting from LogMeIn Ireland Limited, Bloodstone Building Block C, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland, which processes data collected for the seminar on our behalf to provide the technical infrastructure and manage access rights. We have concluded a data processing agreement obliging GoToMeeting to protect our customers’ data and not disclose them to third parties. In individual cases, personal user data may be transferred to GoToMeeting servers in the USA. For EU-to-USA transfers, GoToMeeting relies on the European Commission’s standard contractual clauses, intended to ensure European data protection standards in the USA.
To confirm webinar registration, you receive an invitation link by email. Clicking it establishes a connection to GoToMeeting servers. To associate webinar access unambiguously with you and verify and ensure individual admission, GoToMeeting collects on our behalf information about the pages you visited on our website and your IP address pursuant to Art. 6(1)(b) GDPR.
Your data are processed solely to conduct the booked webinar and are generally deleted afterwards unless statutory retention periods require further storage in a particular case. Your data are not otherwise used or disclosed.
Further information about handling user data is available in GoToMeeting’s privacy policy at: https://www.logmeininc.com
– Microsoft Teams
We use Microsoft Teams from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, to conduct online meetings, video conferences and/or webinars.
When Microsoft Teams is used, various data are processed. The scope depends on what you disclose before or during an online meeting, video conference or webinar. Participants’ data are processed and stored on Microsoft Teams servers. These may include registration data (name, email address, telephone number (optional), password) and meeting data (subject, participant IP address, device information, description (optional)). Participants’ visual and audio contributions and chat entries may also be processed.
Where processing is necessary to perform a contract with you, including pre-contractual measures, Art. 6(1)(b) GDPR is the legal basis. Where you have consented, processing is based on Art. 6(1)(a) GDPR. Consent may be withdrawn at any time with future effect.
Otherwise, the legal basis for processing during online meetings, video conferences or webinars is our legitimate interest in conducting them effectively pursuant to Art. 6(1)(f) GDPR. Further information on Microsoft Teams’ use of data is available in its privacy policy at https://privacy.microsoft.com
– Zoom
We use Zoom from Zoom Video Communications Inc., 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA, to conduct online meetings, video conferences and/or webinars.
When Zoom is used, various data are processed. The scope depends on what you disclose before or during an online meeting, video conference or webinar. Participants’ data are processed and stored on Zoom servers. These may include registration data (name, email address, telephone number (optional), password) and meeting data (subject, participant IP address, device information, description (optional)). Participants’ visual and audio contributions and chat entries may also be processed.
Where processing is necessary to perform a contract with you, including pre-contractual measures, Art. 6(1)(b) GDPR is the legal basis. Where you have consented, processing is based on Art. 6(1)(a) GDPR. Consent may be withdrawn at any time with future effect.
Otherwise, the legal basis for processing during online meetings, video conferences or webinars is our legitimate interest in conducting them effectively pursuant to Art. 6(1)(f) GDPR. Further information on Zoom’s use of data is available in its privacy policy at https://zoom.us
10.3 – Google Web Fonts
This site uses web fonts provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, for uniform display of typefaces. When you open a page, your browser loads the required fonts into its cache so that text and fonts display correctly.
For this purpose, your browser must connect to Google servers. Personal data may also be transferred to Google LLC servers in the USA. Personal data are processed when connecting to the font provider only if you have given express consent pursuant to Art. 6(1)(a) GDPR. You may withdraw consent at any time with future effect by disabling the service in the website’s ‘Cookie Consent Tool’. If your browser does not support web fonts, a standard font from your computer is used.
Further information about Google Web Fonts is available at https://developers.google.com
10.4 Google reCAPTCHA
We also use the reCAPTCHA function of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Its main purpose is to distinguish human input from misuse through automated processing. The service transmits the IP address and, where applicable, other data Google requires for reCAPTCHA to Google. This takes place pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in determining individual responsibility online and preventing misuse and spam. Use of Google reCAPTCHA may also transfer personal data to Google LLC servers in the USA.
Further information on Google reCAPTCHA and Google’s privacy policy is available at: https://www.google.com
Where legally required, we have obtained your consent to the processing described above pursuant to Art. 6(1)(a) GDPR. You may withdraw consent at any time with future effect by following the objection procedure described above.
11) Tools and other matters
11.1 – DATEV
For accounting, we use cloud-based accounting software from DATEV eG, Paumgartnerstr. 6–14, 90429 Nuremberg (‘DATEV’).
DATEV processes incoming and outgoing invoices and, where applicable, our company’s bank transactions to capture invoices automatically, match them to transactions and prepare financial accounting through a partly automated process.
Where personal data are processed, processing takes place pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in efficiently organising and documenting our business transactions.
Further information about DATEV, automated data processing and its data protection provisions is available at https://www.datev.de
11.2 Cookie Consent Tool
This website uses a ‘Cookie Consent Tool’ to obtain valid user consent for cookies and cookie-based applications requiring consent. It appears as an interactive interface when users access the website and lets them consent to certain cookies and/or cookie-based applications by ticking boxes. The tool ensures that such cookies and services are loaded only after the relevant user has consented by ticking the boxes, so they are placed on the user’s device only with consent.
The tool sets technically necessary cookies to store your cookie preferences. In principle, no personal user data are processed.
If personal data, such as an IP address, are processed in individual cases to store, attribute or record cookie settings, this takes place pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in lawful, user-specific and user-friendly consent management and thus a legally compliant website.
Art. 6(1)(c) GDPR is a further legal basis. As controller, we have a legal obligation to make the use of technically non-essential cookies conditional on the user’s consent.
Further information on the tool’s operator and settings is available directly in the corresponding interface on our website.
11.3 LeadForensic
This website uses Leadforensic, headquartered at 3000 Lakeside, North Harbour, Portsmouth PO3 3EN, to track visits by companies and their usage behaviour. Lead Forensics uses reverse business IP tracking without cookies. It compares identified business IP addresses with a global database of companies and business information. According to Lead Forensics, it uses almost exclusively business-related information to link a business IP address with wider business data and provide us with information about business visitors. It says it does not identify personal IP addresses, mobile devices or other data unconnected with a company. Where IP addresses are collected, they are anonymised immediately. Lead Forensics therefore assumes in its own privacy policy that the service falls outside the GDPR. Even if this is incorrect because the GDPR distinguishes legal from natural persons, rather than businesses from private individuals, the scope of information collected and supplied to us is covered by our legitimate interest (Recital 47 GDPR). For marketing purposes, identifying visitors to our site and associating them with companies helps us find prospective customers and inform them about our products and services. Further information on Lead Forensics and its approach to data protection is available at https://www.leadforensics.com/software-data-compliance/.
12) Rights of the data subject
12.1 Applicable data protection law grants you the following rights as a data subject against the controller with regard to processing of your personal data (rights to information and intervention). The legal bases cited govern the respective conditions for exercising them:
- Right of access 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 notification 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.
12.2 RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTERESTS FOLLOWING A BALANCING OF INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH FUTURE EFFECT ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, FURTHER PROCESSING REMAINS POSSIBLE IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF PROCESSING SERVES TO ESTABLISH, EXERCISE OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING. YOU MAY OBJECT AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
13) Duration of personal data storage
The duration of personal data storage depends on the relevant legal basis, the purpose of processing and, where applicable, the relevant statutory retention period (for example, commercial and tax-law retention periods).
Where personal data are processed on the basis of express consent pursuant to Art. 6(1)(a) GDPR, they are stored until the data subject withdraws consent.
Where statutory retention periods apply to data processed within contractual or similar obligations on the basis of Art. 6(1)(b) GDPR, the data are routinely deleted when those periods expire, provided they are no longer needed to perform or initiate a contract and we have no continuing legitimate interest in retaining them.
Where personal data are processed on the basis of Art. 6(1)(f) GDPR, they are stored until the data subject exercises the right to object under Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for processing that override the data subject’s interests, rights and freedoms, or processing serves to establish, exercise or defend legal claims.
Where personal data are processed for direct marketing on the basis of Art. 6(1)(f) GDPR, they are stored until the data subject exercises the right to object under Art. 21(2) GDPR.
Unless other information in this notice about specific processing situations indicates otherwise, stored personal data are deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.