PRIVACY POLICY
I. Name and address of the responsible party
Responsible Party under Data Protection Legislation:
HPP Europe GmbH i.Gr.
Nikolaistrasse 2
80802 Munich
Telephone: 089 4111 864-0
Email: datenschutz@hpp-europe.com
II. General information on data processing
1. Scope of processing personal data
We generally process our users' personal data only to the extent necessary for providing a functional website and our content and services. The processing of our users' personal data regularly only occurs with the user's consent. An exception applies in cases where obtaining prior consent is not possible for practical reasons and the processing of the data is permitted by law.
2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.
When processing personal data necessary for the performance of a contract to which the data subject is a party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations necessary for carrying out pre-contractual measures.
Where the processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Article 6(1)(c) GDPR serves as the legal basis.
In the event that the processing of personal data is necessary to protect the vital interests of the data subject or of another natural person, Article 6(1)(d) GDPR serves as the legal basis.
If processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, and the interests or fundamental rights and freedoms of the data subject do not override those interests, then Article 6(1)(f) GDPR serves as the legal basis for the processing.
3. Data deletion and storage period
The personal data of the data subject will be erased or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this is provided for by European or national legislation in EU regulations, laws, or other provisions to which the controller is subject. Data will also be blocked or erased when a storage period prescribed by the aforementioned regulations expires, unless further storage of the data is necessary for the conclusion or performance of a contract.
III. Provision of the website and creation of log files
1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.
The following data is collected:
This section needs to be adjusted accordingly. Remove any irrelevant data and add any missing data.
Information about the browser type and version used
The user's operating system
The user's internet service provider
The user's IP address
Date and time of access
Websites from which the user's system accessed our website
Websites accessed by the user's system via our website
Option 1: The log files contain IP addresses or other data that allow identification of a user. This could be the case, for example, if the link to the website from which the user accessed the website, or the link to the website the user navigates to, contains personal data.
The data is also stored in our system's log files. This data is not stored together with other personal data of the user.
Option 2: The log files do not contain IP addresses or other data that would allow identification of a user.
The data is also stored in our system's log files. This does not include the user's IP address or other data that would allow the data to be linked to a specific user. This data is not stored together with other personal data of the user.
2. Legal basis for data processing
If IP addresses are stored in log files:
The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 lit. f GDPR.
If IP addresses are not stored in log files:
The legal basis for the temporary storage of the data is Art. 6 para. 1 lit. f GDPR.
3. Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable the delivery of the website to the user's computer. For this purpose, the user's IP address must be stored for the duration of the session.
If IP addresses are stored in log files:
The data is stored in log files to ensure the website's functionality. We also use this data for the technical optimization of the website and to ensure the security of our IT systems. The data is not used for marketing purposes.
These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR.
4. Storage duration
The data will be deleted as soon as it is no longer needed for the purpose for which it was collected. In the case of data collected for the provision of the website, this is the case when the respective session has ended.
If IP addresses are stored in log files:
If the data is stored in log files, this occurs after a maximum of seven days. Storage beyond this period is possible. In this case, the users' IP addresses are deleted or anonymized so that it is no longer possible to identify the requesting client.
5. Right to object and have the matter removed
The collection of data for the provision of the website and the storage of data in log files is essential for the operation of the website. Therefore, there is no possibility for the user to object.
IV. Use of Cookies
1. Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in or by the internet browser on the user's computer system. When a user visits a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic string that enables the browser to be uniquely identified when the website is visited again.
If technically necessary cookies are used:
We use cookies to make our website functional. Some elements of our website require that the requesting browser can be identified even after a page change.
The following data is stored and transmitted in the cookies:
The following is a list of the stored data. Examples include:
Language settings
Items in a shopping cart
Login information
In addition, if cookies that are not technically necessary are used:
We also use cookies on our website that allow us to analyze users' browsing behavior.
The following data can be transmitted in this way:
The following is a list of the data collected. This may include, for example:
Entered search terms
Frequency of page views
Use of website functions
Section 25(1) of the German Telemedia Act (TDDDG) stipulates that the storage of information on the end user's terminal equipment or access to information already stored on the terminal equipment is only permitted if the end user has given their consent based on clear and comprehensive information. This consent must be obtained in accordance with the GDPR.
According to Section 25 Paragraph 2 TDDDG, consent is not required in narrowly limited exceptional cases:
If the sole purpose of storing information in the end-user's terminal equipment or the sole purpose of accessing information already stored in the end-user's terminal equipment is to carry out the transmission of a message over a public telecommunications network
If the storage of information on the end user's terminal equipment or access to information already stored on the end user's terminal equipment is strictly necessary for the provider of a digital service to provide a digital service explicitly requested by the user.
Therefore, cookies that are not technically necessary require consent.
When you visit our website, you will be informed about the use of cookies for analytical purposes and asked to consent to the processing of the personal data used in this context. You will also be referred to this privacy policy.
2. Legal basis for data processing
If only technically necessary cookies are used, or if technically necessary cookies are used:
The legal basis for the processing of personal data using technically necessary cookies within the meaning of Section 25 Paragraph 2 TDDDG is Article 6 Paragraph 1 Letter f GDPR.
If technically necessary and non-essential cookies are used with prior consent from the user:
The legal basis for the processing of personal data using cookies for analytical purposes is, if the user has given their consent, Article 6(1)(a) GDPR.
The legal basis for the processing of personal data using technically necessary cookies is otherwise Art. 6 para. 1 lit. f GDPR.
3. Purpose of data processing
If technically necessary cookies are used:
The purpose of using technically necessary cookies is to enable users to use websites. Some functions of our website cannot be offered without the use of cookies. For these functions, it is necessary that the browser is recognized even after a page change.
We require cookies for the following applications:
The following is a list of applications. Examples include:
Shopping cart
Language settings applied
Login information
The user data collected through technically necessary cookies is not used to create user profiles.
In addition, if cookies that are not technically necessary are used:
The use of analytics cookies is for the purpose of improving the quality of our website and its content. These cookies allow us to understand how the website is used and thus continuously optimize our offerings.
The exact purpose of the analytics cookies should be described in more detail here.
These purposes also constitute our legitimate interest in the subsequent processing of personal data pursuant to Art. 6 para. 1 lit. f GDPR.
4. Duration of storage, right to object and erasure
Cookies are stored on the user's computer and transmitted from there to our site. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the storage of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, some of its functions may no longer be fully available.
V. Contact form and email contact
1. Description and scope of data processing
Our website includes a contact form that can be used to contact us electronically. If a user chooses to use this form, the data entered will be transmitted to us and stored. This data includes:
The following is a list of the data from the input form.
The following data is also stored at the time the message is sent:
The following is a list of the relevant data. Examples include:
The user's IP address
Date and time of registration
Your consent for the processing of your data will be obtained during the submission process, and you will be referred to this privacy policy.
Alternatively, you can contact us via the provided email address. In this case, the personal data you transmit with your email will be stored.
In this context, no data will be shared with third parties. The data will be used exclusively for processing the conversation.
2. Legal basis for data processing
The legal basis for processing the data is, if the user has given their consent, Art. 6 para. 1 lit. a GDPR.
The legal basis for processing data transmitted via email is Article 6(1)(f) GDPR. If the email contact aims at concluding a contract, the additional legal basis for processing is Article 6(1)(b) GDPR.
3. Purpose of data processing
The processing of personal data from the input form serves solely to process your contact request. In the case of contact via email, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.
4. Storage duration
The data will be deleted as soon as it is no longer required for the purpose for which it was collected. For personal data from the contact form and data transmitted by email, this is the case when the respective conversation with the user has ended. A conversation is considered ended when it is clear from the circumstances that the matter in question has been resolved.
The additional personal data collected during the sending process will be deleted no later than seven days after collection.
5. Right to object and have the matter removed
The user has the right to withdraw their consent to the processing of their personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.
The user has the right to withdraw their consent to the processing of personal data at any time without giving reasons. The withdrawal can be made informally, for example by email to datenschutz@hpp-europe.com .
Furthermore, the user can object to the storage and use of their personal data at any time. In this case, no further data will be processed, and data already stored will be deleted immediately, unless there are legal retention obligations.
All personal data stored during the contact process will be deleted in this case.
VI. Rights of the data subject
1. Right to information
You can request confirmation from the data controller as to whether personal data concerning you is being processed by us.
If such processing takes place, you can request the following information from the controller:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the planned duration of the storage of personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) all available information about the source of the data if the personal data are not collected from the data subject;
(8) the existence of automated decision-making, including profiling, pursuant to 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.
You have the right to request information as to whether your personal data is being transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.
In AI-based data processing:
In the case of AI-based data processing, your right to information extends to processing activities and the functioning of the AI systems used for data processing.
2. Right to rectification
You have the right to rectification and/or completion from the data controller if the processed personal data concerning you is inaccurate or incomplete. The data controller must carry out the rectification without undue delay.
3. Right to restriction of processing
Under the following conditions, you can request the restriction of the processing of your personal data:
(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request the restriction of their use instead;
(3) the controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims, or
(4) if you have objected to the processing pursuant to Article 21(1) GDPR and it is not yet clear whether the legitimate grounds of the controller override your grounds.
If the processing of your personal data has been restricted, this data – apart from being stored – may 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 processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4. Right to erasure
a. Obligation to delete
You can request that the controller erase your personal data without undue delay, and the controller is obliged to erase such data without undue delay where one of the following grounds applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You withdraw your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.
(4) Your personal data has been processed unlawfully.
(5) The erasure of personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you were collected in relation to information society services offered pursuant to Article 8(1) GDPR.
b. Information an Dritte
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) GDPR, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you, as the data subject, have requested the erasure of all links to, or copies or replications of, that personal data.
c. Exceptions
The right to erasure does not apply insofar as the processing is necessary.
(1) to exercise the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, insofar as the right referred to in point (a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
(5) for the establishment, exercise or defense of legal claims.
5. Right to information
If you have asserted your right to rectification, erasure or restriction of processing against the controller, the controller is obliged to communicate this rectification or erasure of data or restriction of processing to all recipients to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort.
They have the right to be informed about these recipients by the data controller.
6. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. Furthermore, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that
(1) the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR and
(2) processing is carried out using automated procedures.
In exercising this right, you also have the right to have your personal data transmitted directly from one controller to another, where technically feasible. This must not adversely affect the rights and freedoms of others.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions.
The controller will no longer process your personal data unless they can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of establishing, exercising or defending legal claims.
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
You have the option, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.
8. Right to withdraw consent under data protection law
You have the right to withdraw your consent to data processing at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
9. Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is permitted under Union or Member State law to which the controller is subject and which contains appropriate measures to safeguard your rights and freedoms and legitimate interests or
(3) with your express consent.
However, these decisions must not be based on special categories of personal data pursuant to Article 9(1) GDPR, unless Article 9(2)(a) or (g) GDPR applies and appropriate measures to protect your rights and freedoms and legitimate interests have been taken.
With regard to the cases referred to in (1) and (3), the controller shall implement suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, 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.
10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the 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 of the progress and outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 GDPR.