DATA POLICY

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the SEA ME GmbH. The use of the Internet pages of the SEA ME GmbH is possible without any indication of personal data. However, if a person concerned wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the SEA ME GmbH. By means of this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.
As the controller, the SEA ME GmbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. DEFINITIONS

The data protection declaration of the SEA ME GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this privacy policy

a) Personal Data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Person concerned

Betroffene Person ist jede identifizierte oder identifizierbare natürliche Person, deren personenbezogene Daten von dem für die Verarbeitung Verantwortlichen verarbeitet werden.

c) Processing

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

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of restricting its future processing.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

i) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. NAME AND ADDRESS OF THE DATA CONTROLLER

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is the:

SEA ME GmbH
Reeperbahn 1
20359 Hamburg
Germany
Phone: 0049 40 31767659
Mail: info@sea-me.com
Website: www.sea-me.com

3. NAME AND ADDRESS OF THE DATA PROTECTION OFFICER

The data protection officer of the controller is:

Lars Buck
SEA ME GmbH
Reeperbahn 1
20359 Hamburg
Germany
Phone: 0049 40 31767659
Mail: lars.buck@sea-me.com
Website: www.sea-me.com

Any data subject can contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

4. COOKIES

The Internet pages of the SEA ME GmbH use cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.
Through the use of cookies, the SEA ME GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie for a shopping basket in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

5. COLLECTION OF GENERAL DATA AND INFORMATION

The website of the SEA ME GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. The following can be recorded
(1) browser types and versions used,
(2) the operating system used by the accessing system
(3) the website from which an accessing system reaches our website (so-called referrer)
(4) the sub-websites which are accessed via an accessing system on our website
(5) the date and time of access to the website
(6) an internet protocol address (IP address),
(7) the internet service provider of the accessing system and
(8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using these general data and information, the SEA ME GmbH does not draw any conclusions about the data subject. Rather, this information is required in order to
(1) deliver the content of our website correctly
(2) optimize the content of our website and the advertising for it,
(3) ensure the long-term functionality of our information technology systems and the technology of our website, and
(4) to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. Therefore, the SEA ME GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

6. REGISTRATION ON OUR WEBSITE

The data subject has the option of registering on the controller’s website by providing personal data. Which personal data is transmitted to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller’s own purposes. The controller may arrange for the data to be passed on to one or more processors, such as a parcel service provider, who will also use the personal data exclusively for internal use attributable to the controller.
By registering on the controller’s website, the IP address assigned by the data subject’s Internet service provider (ISP), the date and time of registration are also stored. This data is stored against the background that this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate criminal offenses committed. In this respect, the storage of this data is necessary to safeguard the controller. This data is not passed on to third parties unless there is a legal obligation to pass it on or it serves the purpose of criminal prosecution.

The registration of the data subject with voluntary provision of personal data serves the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the controller’s database.

The controller shall provide any data subject at any time upon request with information about what personal data is stored about the data subject. Furthermore, the controller shall rectify or erase personal data at the request or indication of the data subject, insofar as this does not conflict with any statutory retention obligations. All of the controller’s employees are available to the data subject as contact persons in this context.

7. SUBSCRIPTION TO OUR NEWSLETTER

On the website of the SEA ME GmbH, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted to the controller when the newsletter is ordered.

The SEA ME GmbH informs its customers and business partners regularly by means of a newsletter about enterprise offers. The newsletter of our company can only be received by the data subject if
(1) the data subject has a valid e-mail address and
(2) the data subject registers to receive the newsletter. For legal reasons, a confirmation e-mail is sent to the e-mail address entered by a data subject for the first time for the newsletter mailing using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject’s e-mail address at a later date and therefore serves as legal protection for the controller.

The personal data collected when registering for the newsletter will be used exclusively to send our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail if this is necessary for the operation of the newsletter service or a registration in this regard, as could be the case in the event of changes to the newsletter offer or changes to the technical circumstances. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be canceled by the data subject at any time. The consent to the storage of personal data, which the data subject has given us for the newsletter dispatch, can be revoked at any time. There is a corresponding link in every newsletter for the purpose of revoking consent. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website or to inform the controller of this in another way.

7.1 NEWSLETTER DISPATCH VIA MAILCHIMP

Our email newsletters are sent via the technical service provider The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (http://www.mailchimp.com/), to whom we pass on the data you provided when registering for the newsletter. This transfer takes place in accordance with Art. 6 para. 1 lit. f GDPR and serves our legitimate interest in using an effective, secure and user-friendly newsletter system. Please note that your data is usually transferred to a MailChimp server in the USA and stored there. MailChimp uses this information to send and statistically analyze the newsletter on our behalf. For evaluation purposes, the emails sent contain so-called web beacons or tracking pixels, which are one-pixel image files stored on our website. This allows us to determine whether a newsletter message has been opened and which links, if any, have been clicked on. Mailchimp uses the web beacons to automatically generate general, non-personal statistics on the response behavior to newsletter campaigns. On the basis of our legitimate interest in the statistical evaluation of newsletter campaigns to optimize advertising communication and better focus on recipient interests, the web beacons also collect and use data of the respective newsletter recipient (email address, time of retrieval, IP address, browser type and operating system) in accordance with Art. 6 para. 1 lit. f GDPR. This data allows individual conclusions to be drawn about the newsletter recipient and is processed by Mailchimp to automatically generate statistics that show whether a particular recipient has opened a newsletter message. If you wish to deactivate the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter. MailChimp may also use this data itself in accordance with Art. 6 para. 1 lit. f GDPR on the basis of its own legitimate interest in the needs-based design and optimization of the service as well as for market research purposes, for example to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties. To protect your data in the USA, we have concluded a data processing agreement with MailChimp based on the standard contractual clauses of the European Commission to enable the transfer of your personal data to MailChimp. If you are interested, this data processing agreement can be viewed at the following Internet address: https://mailchimp.com/legal/data-processing-addendum/ You can view MailChimp’s privacy policy here: https://mailchimp.com/legal/privacy/

8. NEWSLETTER-TRACKING

The newsletters of SEA ME GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails that are sent in HTML format to enable log file recording and analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, the SEA ME GmbH may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the controller in order to optimize the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After revocation, this personal data will be deleted by the controller. The SEA ME GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.

9. CONTACT POSSIBILITY VIA THE WEBSITE

The website of the SEA ME GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

10. ROUTINE DELETION AND BLOCKING OF PERSONAL DATA

The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

11. RIGHTS OF THE DATA SUBJECT

a) Right to confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right to information

Any person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller free information about the personal data stored about him or her and a copy of this information at any time. Furthermore, the European legislator has granted the data subject access to the following information:
the purposes of the processing the categories of personal data being processed the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing the existence of the right to lodge a complaint with a supervisory authority if the personal data are not collected from the data subject:

All available information about the origin of the data
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary

The personal data have been collected or otherwise processed for purposes for which they are no longer necessary. The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.
The personal data have been processed unlawfully.

The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the SEA ME GmbH, he or she may, at any time, contact any employee of the controller. An employee of SEA ME GmbH shall promptly ensure that the erasure request is complied with immediately.

If the personal data has been made public by SEA ME GmbH and our company is obliged to delete the personal data in accordance with Art. 17 para. 1 GDPR, SEA ME GmbH shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other persons responsible for data processing who process the published personal data, that the person concerned has requested the deletion of all links to this personal data or of copies or replications of this personal data from these other persons responsible for data processing, insofar as the processing is not necessary. An employees of the SEA ME GmbH will arrange the necessary measures in individual cases.

e) Right to restriction of processing

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to require the controller to restrict the processing if one of the following conditions is met:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.

The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the SEA ME GmbH, he or she may at any time contact any employee of the controller. The employee of the SEA ME GmbH will arrange the restriction of the processing.

f) Right to data portability

Each person concerned by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which was made available to a controller, in a structured, common and machine-readable format. He or she also has the right to transmit these data to another controller without hindrance from the controller to which the personal data was made available, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may contact an employee of SEA ME GmbH at any time.

g) Right for contradiction

Any person affected by the processing of personal data has the right granted by the European legislator to object at any time to the processing of personal data concerning him or her based on Art. 6 (1) e) or f) GDPR, for reasons related to his or her particular situation. This also applies to profiling based on these provisions.
In the event of an objection, SEA ME GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If SEA ME GmbH processes personal data in order to conduct direct advertising, the data subject has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling insofar as it is associated with such direct advertising. If the data subject objects to SEA ME GmbH to the processing for direct marketing purposes, SEA ME GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right to object to the processing of personal data concerning him or her by SEA ME GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, unless such processing is necessary to perform a task carried out in the public interest, for reasons related to his or her particular situation.
To exercise the right to object, the data subject may contact any employee of SEA ME GmbH or another employee directly. Furthermore, the data subject is free to exercise his or her right of objection by automated means using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.

h) Automated decisions in individual cases including profiling

Any person concerned by the processing of personal data shall have the right granted by the European legislator not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not made with the data subject’s explicit consent.
Where the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) is made with the data subject’s explicit consent, SEA ME GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise rights with regard to automated decisions, he or she may contact any employee of the controller at any time.

i) Right to revoke consent to data protection

Any person affected by the processing of personal data has the right granted by the European legislator to withdraw his or her consent to the processing of personal data at any time.
If the data subject wishes to exercise his or her right to withdraw consent, he or she may contact any employee of the controller at any time.

12. DATA PROTECTION PROVISIONS ON THE APPLICATION AND USE OF GOOGLE ADSENSE

The controller has integrated Google AdSense on this website. Google AdSense is an online service that enables advertising to be placed on third-party websites. Google AdSense is based on an algorithm that selects the advertisements displayed on third-party websites to match the content of the respective third-party website. Google AdSense allows interest-based targeting of Internet users, which is implemented by generating individual user profiles.

The operating company of the Google AdSense component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. The purpose of the Google AdSense component is to integrate advertisements on our website. Google AdSense sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Alphabet Inc. is enabled to analyze the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google AdSense component has been integrated, is called up, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google AdSense component to transmit data to Alphabet Inc. for the purpose of online advertising and the settlement of commissions. As part of this technical procedure, Alphabet Inc. receives knowledge of personal data, such as the IP address of the data subject, which Alphabet Inc. uses, among other things, to trace the origin of visitors and clicks and subsequently enable commission settlements.

The data subject can prevent the setting of cookies through our website, as already explained above, at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Alphabet Inc. from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Alphabet Inc. can be deleted at any time via the Internet browser or other software programs.

Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in Internet pages to enable log file recording and log file analysis, which enables statistical evaluation to be carried out. Using the embedded tracking pixel, Alphabet Inc. can determine whether and when a website was opened by a data subject and which links were clicked by the data subject. Tracking pixels are used, among other things, to evaluate the flow of visitors to a website.

Via Google AdSense, personal data and information, which also includes the IP address and is necessary for the recording and billing of the advertisements displayed, is transferred to Alphabet Inc. in the United States of America. This personal data is stored and processed in the United States of America. Alphabet Inc. may pass on this personal data collected via the technical process to third parties.

Google AdSense is explained in more detail at this link https://www.google.de/intl/de/adsense/start/.

13. DATA PROTECTION PROVISIONS ON THE APPLICATION AND USE OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)

The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, gathering and evaluation of data on the behavior of visitors to websites. A web analysis service collects, among other things, data on which website a data subject came to a website from (so-called referrers), which subpages of the website were accessed, or how often and for how long a subpage was viewed. Web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.

The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. Using this addition, the IP address of the data subject’s internet connection is shortened and anonymized by Google if our website is accessed from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us that show the activities on our websites, and to provide other services related to the use of our website.

Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject is automatically prompted through the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google receives knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently enable commission settlements.

The cookie is used to store personal information, such as the access time, the location from which access was made and the frequency of visits to our website by the data subject. Whenever our website is visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

The data subject can prevent the setting of cookies through our website, as already explained above, at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to the collection of data generated by Google Analytics relating to the use of this website as well as the processing of this data by Google and of preventing such collection. To do so, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information relating to visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is regarded by Google as an objection. If the information technology system of the data subject is deleted, formatted, or reinstalled at a later date, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable data protection provisions can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link https://www.google.com/intl/de_de/analytics/.

14. DATA PROTECTION PROVISIONS ON THE APPLICATION AND USE OF GOOGLE REMARKETING

The controller has integrated Google Remarketing services on this website. Google Remarketing is a function of Google AdWords that enables a company to display advertisements to Internet users who have previously visited the company’s website. The integration of Google Remarketing therefore allows a company to create user-related advertising and thus display advertisements relevant to the Internet user’s interests.

The operator of the Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Remarketing is to display interest-relevant advertising. Google Remarketing enables us to display advertisements via the Google advertising network or on other websites that are tailored to the individual needs and interests of Internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is able to recognize the visitor to our website when he or she subsequently visits websites that are also members of the Google advertising network. Whenever a website is accessed on which the Google Remarketing service has been integrated, the Internet browser of the data subject automatically identifies itself with Google. As part of this technical process, Google receives knowledge of personal data, such as the IP address or the surfing behavior of the user, which Google uses, among other things, to display interest-relevant advertising.
The cookie is used to store personal information, such as the websites visited by the data subject. Whenever our website is visited, personal data, including the IP address of the Internet connection used by the data subject, is therefore transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

The data subject can prevent the setting of cookies through our website, as already explained above, at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to interest-based advertising by Google. To do so, the data subject must access the link www.google.de/settings/ads from each of the Internet browsers they use and make the desired settings there.
Further information and Google’s applicable data protection provisions can be found at https://www.google.de/intl/de/policies/privacy/.

15. DATA PROTECTION PROVISIONS ON THE APPLICATION AND USE OF GOOGLE ADWORDS

The controller has integrated Google AdWords on this website. Google AdWords is an internet advertising service that allows advertisers to place ads in both Google’s search engine results and in the Google advertising network. Google AdWords enables an advertiser to pre-define certain keywords, using which an ad will only be displayed in Google’s search engine results if the user retrieves a keyword-relevant search result using the search engine. In the Google advertising network, the ads are distributed on topic-relevant websites using an automatic algorithm and taking into account the previously defined keywords.
The operating company of the Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. The purpose of Google AdWords is to promote our website by displaying interest-relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine and by displaying third-party advertising on our website. If a data subject reaches our website via a Google ad, a so-called conversion cookie is stored on the information technology system of the data subject by Google. What cookies are has already been explained above. A conversion cookie expires after thirty days and is not used to identify the data subject. The conversion cookie is used, provided the cookie has not yet expired, to track whether certain sub-pages, such as the shopping cart of an online shop system, were accessed on our website. The conversion cookie enables both us and Google to track whether a data subject who reached our website via an AdWords ad generated sales, i.e. completed or canceled a purchase.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. We in turn use these visit statistics to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could be used to identify the person concerned.

The conversion cookie is used to store personal information, such as the websites visited by the data subject. Each time our website is visited, personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical process to third parties.
The data subject can prevent the setting of cookies through our website, as already explained above, at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a conversion cookie on the information technology system of the data subject. In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.

16. DATA PROTECTION PROVISIONS ON THE USE AND APPLICATION OF INSTAGRAM

The data controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform and allows users to share photos and videos and also to redistribute such data in other social networks.

The operating company of the Instagram services is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which an Instagram component (Insta button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Instagram component of Instagram. As part of this technical process, Instagram receives information about which specific subpage of our website is visited by the data subject.
If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to our website by the data subject-and for the entire duration of their stay on our Internet site-which specific sub-page of our Internet page was visited by the data subject. This information is collected by the Instagram component and assigned by Instagram to the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated on our website, the data and information transmitted with it is assigned to the personal Instagram user account of the data subject and stored and processed by Instagram.

Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is logged in to Instagram at the same time as accessing our website; this takes place regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want this information to be transmitted to Instagram, they can prevent the transmission by logging out of their Instagram account before accessing our website.
Further information and the applicable data protection provisions of Instagram may be retrieved under https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

17. PAYMENT METHOD: DATA PROTECTION PROVISIONS ON PAYPAL AS A PAYMENT METHOD

The data controller has integrated PayPal components on this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which are virtual private or business accounts. PayPal also offers the option of processing virtual payments via credit cards if a user does not have a PayPal account. A PayPal account is managed via an e-mail address, which is why there is no classic account number. PayPal makes it possible to initiate online payments to third parties or to receive payments. PayPal also assumes trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.
If the data subject selects “PayPal” as the payment option during the ordering process in our online store, the data of the data subject is automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transfer of personal data required for payment processing.

The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, cell phone number or other data required for payment processing. Personal data that is necessary for processing the purchase contract is also data that is related to the respective order.

The purpose of transmitting the data is to process payments and prevent fraud. The controller will transmit personal data to PayPal in particular if there is a legitimate interest in the transmission. The personal data exchanged between PayPal and the controller may be transmitted by PayPal to credit reference agencies. The purpose of this transmission is to check identity and creditworthiness.

PayPal may pass on the personal data to affiliated companies and service providers or subcontractors if this is necessary to fulfill the contractual obligations or if the data is to be processed on behalf of PayPal.

The data subject has the option of withdrawing consent to the handling of personal data from PayPal at any time. A revocation does not affect personal data that must be processed, used or transmitted for (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved under https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

18. LEGAL BASIS OF THE PROCESSING

Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, it may be necessary to process personal data in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

19. LEGITIMATE INTERESTS IN PROCESSING PURSUED BY THE CONTROLLER OR BY A THIRD PARTY

Where the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.

20. DURATION FOR WHICH THE PERSONAL DATA IS STORED

The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period has expired, the corresponding data is routinely deleted, provided that it is no longer required for contract fulfillment or contract initiation.

21. STATUTORY OR CONTRACTUAL REQUIREMENTS FOR THE PROVISION OF PERSONAL DATA; NECESSITY FOR THE CONCLUSION OF THE CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

22. EXISTENCE OF AUTOMATED DECISION-MAKING

As a responsible company, we do not use automatic decision-making or profiling. This Privacy Policy has been generated by the Privacy Policy Generator of the DGD – Your External DPO that was developed in cooperation with German Lawyers from WILDE BEUGER SOLMECKE, Cologne.

23. NOTE ON THE MULTI-WAY GOODIE CAMPAIGN ON THE DISPLAY AT MÜLLER DROGERIE (back)

Have you seen the back of our display showing the SEA ME shower range (or other brands)? Great! We’ll be happy to send you a reusable goodie pack if you actively send us an e-mail with the subject on the display. This campaign can be terminated by us at any time. Furthermore, this is voluntary and is part of our marketing activities. There is no obligation on our part to send a package.

zerooo – Returnable packaging system für personal & home care

Mail: info@zerooo.com