Privacy Policy

1. GENERAL

We take the protection and security of your personal data extremely seriously and collect, process, store and use your personal data exclusively in the scope of the provisions of the European General Data Protection Regulation (GDPR) and the data protection legislation in the Federal Republic of Germany.

With the aim of providing you with optimal control over your data, this privacy policy aims to provide you with information about what personal data are collected when our website “www.knowledge4retail.org” (referred to in the following simply as the “website”) is visited, how we use said data and what rights and configuration options are available to you.

The term “personal data” includes all data referring to identified or identifiable individuals, e.g., first name, surname, e-mail address.

2. COLLECTION, PROCESSING, STORAGE AND USE OF YOUR DATA
   • COLLECTION, PROCESSING, STORAGE AND USE OF YOUR DATA WHEN USING OUR WEBSITE
     • LOG FILES WHEN VISITING OUR WEBSITE

Our website is available to everyone without the need for prior registration. When you access our website, your Internet browser or mobile end device automatically sends the following data to our web server for technical reasons:

• the IP address of your device;
• the date and time of your visit;
• the URL of the website from which the request is received;
• the HTTP response code;
• the name of the file opened;
• the quantity of data transferred;
• the browser type and version; and
• the operating system employed by your device.

These data are stored in log files on our web server. Said data are not stored together with other personal data.

The legal basis for the storage of these data is Article 6 Para. 1 (f) of the GDPR.

We use these data to permit the use of our website and its technical administration, to ensure the security of our IT systems, to prevent misuse of our website and to optimise our website. These purposes are the legitimate interests we pursue through the data processing in accordance with Article 6 Para. 1 (f) of the GDPR.

The data are deleted as soon as they are no longer required for achievement of the purpose for which they were collected. Where the data are stored in log files, these data are deleted after seven days at the latest. Storage of the log files beyond this scope is possible if the IP address of your device is deleted or distorted in such a way that it is no longer possible to identify the IP address as yours.

• COOKIES

Our website uses cookies. Cookies are small files stored at our web server’s instigation on the hard drive of the device you use. They allow unambiguous identification of your computer system when you revisit our website.

We use cookies to analyse how you use our website (non-technical cookies). When you open our websites, an info banner informs you of the use of non-technical cookies for analysis purposes and refers you to this privacy policy.

The legal basis for the processing of your data using cookies is Article 6 Para. 1 (f) of the GDPR.

We use the non-technical cookies to design our website to suit requirements and to optimise it continuously. These purposes are the legitimate interests in accordance with Article 6 Para. 1 (f) of the GDPR that we pursue through data processing.

Cookies are accepted automatically by the majority of browsers and operating systems. If you do not wish to take advantage of this function, you should configure your browser in such a way that the saving of cookies is prohibited (deactivation). In addition, already saved cookies can be deleted at any time. Please note that deactivating cookies can affect the proper functioning of our websites and that you may not be able to use all the functions of our websites to their full extent as a result.

• COLLECTION, PROCESSING, STORAGE AND USE OF YOUR DATA WHEN CONTACTING US
  • CONTACTING US VIA E-MAIL

You can contact us using our e-mail address

info@team-neusta.de

and sending us a message (electronic contact). In this case, we store the personal data provided to us via e-mail.

The legal basis for the processing of the personal data that you provide to us when contacting us electronically via e-mail is Article 6 Para. 1 (f) of the GDPR. If the aim of this electronic contact via e-mail is to conclude a contract with us, the legal basis for the processing of your personal data is additionally Article 6 Para. 1 (b) of the GDPR.

We use your data for the processing of your request and to contact you. These purposes are the legitimate interests we pursue through the data processing in accordance with Article 6 Para. 1 (f) of the GDPR.

Your data are deleted – insofar as no contractual or legal obligations prohibit their deletion – as soon as they are no longer required for achievement of the purposes outlined above. This is the case once the grounds for your contacting us electronically have been completely resolved. If you conclude a contract with us as a result of the electronic contact, your data are only deleted once they are no longer required for performance of the contract or the implementation of pre-contractual measures. Please note that it may also prove necessary to store your data after performance of the contract in order to comply with contractual or legal obligations.

You may object to the use of your personal data at any time without incurring any costs other than the transmission costs. In such cases, the personal data stored in the scope of your electronic contact are deleted; it is not possible to continue processing your request. If your data are required for performance of a contract or implementation of pre-contractual measures, (premature) deletion of your data is only possible insofar as no contractual or legal obligations prohibit their deletion.

• LOG FILES WHEN CONTACTING US VIA E-MAIL

In addition, when you visit our website, the data in accordance with Point 2.1. of this privacy policy are also collected and stored automatically.

• CONTACTING US VIA OUR CONTACT FORM

You have the possibility of contacting us and sending us a message via our contact form providing compulsory information.

The legal basis for the processing of the personal data that you provide to us when contacting us is Article 6 Para. 1 (f) of the GDPR. If the aim of this contact is to conclude a contract with us, the legal basis for the processing of your data is additionally Article 6 Para. 1 (b) of the GDPR.

Your data are exclusively used for the purposes of processing your request, performing any contract that may be concluded as a result and contacting you. These purposes are the legitimate interests we pursue through data processing in accordance with Article 6 Para 1 (f) of the GDPR.

Your data are deleted – insofar as no contractual or legal obligations prohibit their deletion – as soon as they are no longer required for achievement of the purposes outlined above. This is the case once the grounds for your contacting us electronically have been completely resolved. If you conclude a contract with us as a result of the contact, your data are only deleted once they are no longer required for performance of the contract or the implementation of pre-contractual measures. Please note that it may also prove necessary to store your data after performance of the contract in order to comply with contractual or legal obligations.

You can object to the use of your personal data at any time without incurring any costs other than the transmission costs. In such cases, the personal data stored in the scope of your contact are deleted; it is not possible to continue processing your request. If your data are required for performance of a contract or implementation of pre-contractual measures, (premature) deletion of your data is only possible insofar as no contractual or legal obligations prohibit their deletion.

3. PASSING ON OF PERSONAL DATA
   • Your personal data are not passed on, sold or provided in any other form to third parties unless explicitly required for the purpose of performance of a contract. In all other cases, we only provide your data to third parties insofar as this is permissible or required by law or pursuant to your consent, which can be withdrawn at any time with immediate effect for the future, and only in the scope necessary for the fulfilment of our contractual obligations.
   • Our service partners (e.g., hosting service providers) require your personal data and process them exclusively on our behalf in the scope of processing of personal data, which is expressly foreseen in accordance with Article 28 Para. 3 of the GDPR.
   • We only provide your personal data to state institutions and authorities if we are obliged to do so by law.

4. ANALYSIS OF USAGE
   • GOOGLE ANALYTICS

Our website uses Google Analytics, a web analysis service

from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (“Google”).

Google Analytics employs tracking code and “cookies”, small text files that are stored on the device you use and permit analysis of your use of our website. The data generated by the cookie concerning your use of our website are generally sent to a Google server in the USA and stored there.

However, as a result of the activation of IP anonymisation “anonymizelp”, your IP address is shortened in advance within Member States of the European Union and other contracting states of the EEA Agreement. Google does not merge the IP address sent by your browser in the scope of Google Analytics with other data.

The legal basis for this processing of your data is Article 6 Para. 1 (f) of the GDPR. Insofar as you have given your consent, the legal basis for this processing of your data is additionally Article 6 Para. 1 (a) of the GDPR.

We use the web analysis service from Google to design our website to suit requirements and to optimise it continuously. Google employs the data and information collected on our behalf to analyse your use of our website, to compile reports about the website activities and to perform further services associated with the use of our website and the Internet for us. These purposes are the legitimate interests we pursue through the data processing in accordance with Article 6 Para. 1 (f) of the GDPR.

You may prevent the storage of cookies by adjusting your browser software setting accordingly, but please note that this may make it no longer possible to use all of the functions of our website to their full extent. In addition, you may prevent Google from collecting the data generated by the cookie concerning your use of the website (incl. your IP address) and processing said data by downloading and installing the browser plug-in available here:

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

Further information on the terms of service and data protection can be found at: https://marketingplatform.google.com/about/analytics/terms/us/ and https://https://policies.google.com/?hl=en&gl=de.

You may withdraw your consent to our processing of your data with immediate effect for the future at any time. However, withdrawal of your consent does not affect the legitimacy of the processing of your data performed on the basis of your consent up until the point of its withdrawal. Please note that the withdrawal of your consent can affect the proper functioning of our websites and that you may not be able to use all the functions of our websites to their full extent as a result.

• GOOGLE ADWORDS CONVERSION TRACKING

Our website also uses Google Adwords Conversion Tracking, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

Google Adwords employs tracking code and “cookies”, small text files that are stored on the device you use if you access our website via a Google ad. The cookie’s validity expires after 30 days. If you revisit our page within these 30 days, Google can identify that you have clicked on a Google ad and been forwarded to our website.

The legal basis for this processing of your data is Article 6 Para. 1 (f) of the GDPR. Insofar as you have given your consent, the legal basis for this processing of your data is additionally Article 6 Para. 1 (a) of the GDPR.

We use the web analysis service from Google to compile statistics concerning the use of our website and in order to improve and optimise our website continuously. Google employs the data and information collected on our behalf to analyse your use of our website and compile reports (conversion statistics) for us. These conversion statistics tell us how many users have clicked on our ad and been forwarded to our specified website with a conversion tracking tag. These purposes are the legitimate interests we pursue through data processing in accordance with Article 6 Para. 1 (f) of the GDPR.

You may prevent the storage of cookies by adjusting your browser software setting accordingly, but please note that this may make it no longer possible to use all of the functions of our website to their full extent.

Further information on privacy can be found at https://services.google.com/sitestats/en.html

You may withdraw your consent to our processing of your data with immediate effect for the future at any time. However, withdrawal of your consent does not affect the legitimacy of the processing of your data performed on the basis of your consent up until the point of its withdrawal. Please note that the withdrawal of your consent can affect the proper functioning of our websites and that you may not be able to use all the functions of our websites to their full extent as a result.

5. RESPONSIBLE ENTITY

The responsible entity for the processing of your personal data is:

team neusta GmbH

Konsul-Smidt-Straße 24

28217 Bremen
Germany

Phone: +49 (0)421 / 20696-0

Fax: +49 (0)421 / 20696-99

E-mail: info@team-neusta.de

6. DATA PROTECTION OFFICER

We have appointed Mr Günther Ewald

HEC GmbH

Konsul-Smidt-Straße 20

28217 Bremen
Germany

Phone: +49 (0)421 / 207500
E-mail: datenschutz@neusta.de as our data protection officer.

7. LOCATION OF YOUR DATA / DATA SECURITY
   • Our servers and data centres are stored at infrastructure services GmbH. Data processing is performed by team neusta GmbH.
   • As a general rule, we process your personal data within the European Union. However, we also use services provided by some third parties. Insofar as these third parties operate in areas in which the level of data protection does not correspond to that guaranteed by the regulations in force within the European Union, we take all the necessary steps to ensure that your personal data are sufficiently protected. We do so either by means of concluding data privacy agreements or by verifying that the third parties are certified in accordance with suitable safety standards (e.g., the EU–US Privacy Shield).
   • We implement different physical, technical and organisational measures as well as administrative security measures in order to protect your data to a suitable degree depending on their sensitivity.
   • We employ SSL encryption on our website for security reasons and in particular for the protection of your personal data. The encrypted connection is indicated by the lock symbol in your browser’s address bar.

8. YOUR RIGHTS
   • RIGHT OF ACCESS
     • You are entitled to obtain confirmation from us at any time and free of charge as to whether we are processing personal data concerning you. If this is the case, you have the right to access these personal data and be provided with the following information:
   • the purposes for which the personal data relating to you are being processed;
   • the categories of personal data concerned;
   • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
   • 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 us as the controller rectification or erasure of personal data, the right to restriction of processing of personal data and the right to object to such processing;
   • the right to lodge a complaint with a supervisory authority;
   • any available information as to their source, if the personal data were not collected from you;
   • the existence of automated decision-making, including profiling, referred to in Article 22 Para. 1 and 4 of the 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.

In addition, you are also entitled to obtain information about whether your personal data have been transferred to a third country or to an international organisation. In this context, you may ask us to inform you of the appropriate safeguards pursuant to Article 46 of the GDPR.

• We reserve the right to request proof of identity in the interest of protecting your data.
• We may provide the data protection information in a commonly used electronic form.

• RIGHT TO RECTIFICATION

In addition, you also have the right to obtain from us the rectification of inaccurate personal data. Moreover, taking into consideration the purposes for the processing of your personal data, you have the right to have us complete incomplete personal data.

• RIGHT TO RESTRICTION OF PROCESSING
  • You have the right to obtain from us restriction of processing where one of the following applies:
• if you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
• if the processing is unlawful and you oppose the erasure of the personal data relating to you and request the restriction of the use of the personal data instead;
• we no longer need the personal data for the purposes of the processing, but you do require them for the establishment, exercise or defence of legal claims;

or

• you have objected to processing pursuant to Article 21 Para. 1 of the GDPR and verification of whether our legitimate grounds override yours is still pending.
  • Where processing of your personal data has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
  • If you have obtained restriction of processing, you will be informed by us before the restriction of processing is lifted.

• RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)

• You have the right to obtain from us the erasure of personal data concerning you without undue delay and we have the obligation to erase personal data without undue delay where one of the following grounds applies:

• the personal data relating to you are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw the consent on which the processing is based according to Article 6 Para. 1 (a) of the GDPR or Article 9 Para 2 (a) of the GDPR and where there is no other legal ground for the processing;
• you object to the processing pursuant to Article 21 Para. 1 of the GDPR and there are no overriding legitimate grounds for the processing or you object to the processing pursuant to Article 21 Para. 2 of the GDPR;
• the personal data relating to you have been unlawfully processed;
• the personal data relating to you have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;
• the personal data relating to you have been collected in relation to the offer of information society services referred to in Article 8 Para. 1 of the GDPR.

• Where we have made the personal data public and are obliged pursuant to Article 17 Para. 1 of the GDPR to erase the personal data, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing your personal data that you have asked us to erase all links to your personal data and copies or replications of your personal data.

• The right to erasure does not apply to the extent that processing is necessary:

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
• for reasons of public interest in the area of public health in accordance with Article 9 Para. 2 (h) and (i) as well as Article 9 Para. 3 of the GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 Para. 1 of the GDPR insofar as the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing;

or

• for the establishment, exercise or defence of legal claims.

• If you have exercised your right over us to rectification, erasure or restriction of processing of your personal data, we are obliged to notify all recipients to whom your personal data were disclosed of the rectification, erasure or restriction of processing of your personal data, unless this proves impossible or involves disproportionate effort. You have the right to be informed by us of the recipients of your personal data.

• RIGHT TO DATA PORTABILITY
  • You have the right to receive the personal data concerning you, which you have provided us, in a structured, commonly used and machine-readable format. Furthermore, you have the right to transmit those data to another controller without hindrance from us, where:
• the processing is based on consent pursuant to Article 6 Para. 1 (a) of the GDPR or Article 9 Para. 2 (a) of the GDPR or on a contract pursuant to Article 6 Para. 1 (b) of the GDPR; and
• the processing is carried out by automated means.
  • In exercising your right to data portability, you also have the right to have the personal data transmitted directly from one controller to another, without hindrance from us, where technically feasible. This shall not adversely affect the rights and freedoms of others.
  • The right to data portability shall not apply to processing of your personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

• RIGHT TO OBJECT
  • You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on point Article 6 Para. 1 (e) or (f) of the GDPR, including profiling based on those provisions.
  • We shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing of your personal data which override your interests, rights and freedoms or the further processing of your personal data is required for the establishment, exercise or defence of legal claims.

• RIGHT TO WITHDRAW CONSENTS ON WHICH PROCESSING IS BASED

You have the right to withdraw consents on which processing is based at any time. Withdrawal of your consent does not affect the legitimacy of the processing of your personal data performed on the basis of your consent up until the point of its withdrawal.

• RIGHT TO LODGE A COMPLAINT

Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.

9. UPDATE
   • We reserve the right to amend this privacy policy occasionally. We shall inform you in advance if we plan to make considerable changes to the privacy policy.
   • The use of your personal data is always subject to the latest version of the privacy policy, which can be viewed under “PRIVACY POLICY” on our website. By continuing to visit our website after any changes have entered into force, you agree to the updated privacy policy.

Should you have questions or remarks concerning this privacy policy, please do not hesitate to contact us by sending an e-mail to datenschutz@neusta.de

Last amended: June 2019