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Transparency and information obligations under the General Data Protection Regulation (GDPR)

Kögel Trailer GmbH’s privacy policy

Welcome and thank you for visiting our website. We are delighted you are interested in our company. We take the protection of your personal data very seriously. We process your data in accordance with the applicable legal provisions regulating the protection of personal data, particularly the General Data Protection Regulation (GDPR) and the country-specific implementing laws that are applicable to us. By way of this privacy policy, we would like to provide you with comprehensive information about how Kögel Trailer GmbH processes your personal data and the rights you are entitled to under data protection legislation.

Personal data is information that makes it possible to identify a natural person. In particular, this includes your name, date of birth, address, telephone number and email address, as well as your IP address.

Data is considered anonymous when the user is not personally identifiable.

Controller and data protection officer

Kögel Trailer GmbH
Am-Kögel-Werk 1

89349 Burtenbach

Tel.: +49 (0)8285 88-0
Fax: +49 (0)8285 88-17905
Email: info@koegel.com
Web: www.koegel.com

Privacy Officer Contact: datenschutz@koegel.com

Your rights as a data subject

Firstly, we would like to inform you here about your rights as a data subject. These rights are standardised in Arts. 15 to 22 of the GDPR. This includes:

- The right to information (Art. 15 DS-GVO),
- The right to erasure (Art. 17 DS-GVO),
- The right to rectification (Art. 16 DS-GVO),
- The right to data portability (Art. 20 EU GDPR),
- The right to restriction of data processing (Art. 18 DS-GVO),
- The right to object to data processing (Art. 21 DS-GVO).

The same applies if you have questions about data processing in our company or would like to revoke consent that you have granted.
You also have the right to lodge a complaint with a data protection supervisory authority.

If your personal data are being processed for the purpose of protecting our legitimate interests, you can object thereto for reasons relating to your specific circumstances. This applies also to profiling based on these provisions.
Your personal data will not be processed by us unless we are able to provide compelling legitimate grounds for the processing which override your own interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

If your personal data are processed for direct marketing purposes, you have the right to object without giving any reason, which includes profiling if this is linked to direct marketing. We will not process your personal data for direct marketing purposes if you object thereto.

Purposes and legal bases of data processing

Your personal data are processed in compliance with the requirements of the GDPR, BDSG and any other relevant legislation.

Your personal data is processed exclusively for the purpose of implementing pre-contractual measures (e.g., to prepare quotes for products or services) and for the fulfilment of contractual obligations (e.g., to provide our service, implement the supplier contract or to handle purchase orders/orders/payments) (Art. 6 (1) (b) of the GDPR) or if there is a legal obligation for processing (e.g., due to requirements under tax law) (Art. 6 (1) (c) of the GDPR). The personal data was originally collected for these purposes.

Of course, your consent to the processing of your personal data may be for specific purposes as defined in the General Data Protection Regulation [Article 6(1)(a) GDPR]. You will be informed prior to giving consent of the purpose for processing your personal data and your right to withdraw your consent in accordance with Article 7(3) of the GDPR.

Kögel Trailer GmbH wishes to remain in contact with you, as our customer and to email or phone you with information about our products, services and any offers. Your personal data are processed in order for us to send you information and offers or to contact you by phone [Article 6(1)(f) GDPR].

Your personal data will only be processed for background checking purposes under the conditions provided in Article 10 of the GDPR.

 

Disclosure to third parties

We will only disclose your data to third parties in the context of statutory provisions or with the corresponding consent. Otherwise, data will not be disclosed to third parties unless we are obligated to do so due to mandatory legal provisions (disclosure to external bodies such as supervisory authorities or law enforcement authorities).

 

Recipients of the data/categories of recipients

Our company takes care that your personal data are shared only with those departments and individuals that require them to fulfil contractual and legal obligations.

In some cases, service providers support our departments in fulfilling these obligations. Required data protection agreements have been concluded with these service providers.

In addition, the law obliges us to provide certain information to public authorities such as fiscal authorities, law enforcement and customs.

Transfer to third countries/intention to transfer data to a third country

Personal data are transferred to third countries (countries outside of the European Union or the European Economic Area) only when it is necessary for performing a contract, in a supplier relationship or when the law requires it, or if you consent thereto.

Your personal data are being transferred to a service provider(s) or company outside of the European Economic Area, specifically to the United States of America.

Compliance with the level of personal data protection is ensured in standard contractual clauses.

 

Data storage periods

Your personal data will be deleted either as soon as it is no longer needed for the purposes listed above or when you withdraw your consent. The data will only remain stored after the contractual relationship has been terminated, where we are required or entitled to do so. Regulations that oblige us to store the data may be found, for example, in the German Commercial Code (Handelsgesetzbuch) or in the German Tax Code (Abgabenordnung). The retention period can be up to ten years. In addition, the company is required to comply with statutory retention periods.

Secure transfer of your data

We use appropriate technical and organisational security measures to protect the data that we store in the best possible way against accidental or deliberate manipulation, loss, destruction or access by unauthorised individuals. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.

Data exchange from and to our website is always encrypted. We offer HTTPS as the transfer protocol for our website, using the current encryption protocols in each case. You also have the option of using alternative communication channels (e.g., post).

Obligation to provide data

Various pieces of personal data are necessary for establishing, implementing and terminating the contractual relationship and fulfilling the associated contractual and legal obligations. The same applies to using our website and the various functions it provides.

We have summarised the details for you in the point above. In certain cases, data must also be collected or provided due to legal requirements. Please note that we cannot process your request or implement the underlying contractual relationship if you do not provide this data.

Categories, sources and origin of data

The data we process is determined by the context: This depends on whether, for example, you place an order online or enter a request in our contact form, or whether you send us an application or submit a complaint.

Please note that we may also provide information separately at an appropriate place for special processing situations (e.g., when sending application documents or a contact request).

We collect and process the following data when you visit our website:

- Name of the Internet service provider
- Information about the website from which you are visiting us
- Web browser and operating system used
- The IP address assigned by your Internet Service Provider.
- Files requested, amount of data transferred, downloads/file export
- Information about the web pages that you call up from us incl. date and time

We collect and process the following data as part of a contact request by email:

- Name, first name
- Contact details
- Salutation
- Information about wishes and interests

We process the following data when you register in our Parts Shop:

- Salutation
- Name, first name
- Address
- UID number
- Customer number
- E-mail address

We process the following data as part of the ordering process:

- Salutation
- Name, first name
- Address
- UID number
- Customer number
- E-mail address

We collect and process the following data for applications by email:

- Name, first name
- Address
- Contact details
- Applicant data (qualifications, certificates, etc.)

We collect and process the following data for newsletters:

- E-mail address

Automated individual decisions

We do not use purely automated processing methods for decision-making.

Cookies (Art. 6 (1), sentence 1, (a) and (f) of the GDPR, Section 25 (1) and (2) of the German Telecommunications and Telemedia Data Protection Act)

Our website uses what are known as ‘cookies’. We use cookies to make our website more user-friendly, effective and secure. Cookies are small text files that are stored on your terminal device and saved (locally) by your browser. Cookies only contain pseudonymous (usually even anonymous) data. Some cookies remain stored for the duration of a browser session (‘session cookies’), while others are stored for longer periods of time (‘persistent cookies’, such as consent settings, or the shopping basket in the Parts Shop). Persistent cookies are automatically deleted once the specified time in question has elapsed (usually 12 months). In addition to our own cookies, cookies controlled by third-party providers are also used. Third-party providers use the information that the cookies contain to show you content or record the pages you have visited for example.

Based on our legitimate interest (Art. 6 (1), sentence 1, (f) of the GDPR), we use cookies that are technically necessary to operate the website and ensure its functionality. Furthermore, we use cookies without your consent insofar as their sole purpose is the storage of, or access to, information stored in the terminal device for the transfer of messages, or they are absolutely necessary so we can provide the service that you expressly requested (as per Section 25 (2) of the German Telecommunications and Telemedia Data Protection Act).

Provided that you have given your consent, additional cookies that enable us or third parties to evaluate how our services are used, for example, are used. This allows us to design the content to suit user needs. Additionally, the cookies enable us to measure how effective a particular ad is and to have it placed to suit users’ subject-related interests, for example. The legal basis for this is your express consent (Art. 6 (1), sentence 1, (a) of the GDPR, Section 25 (1) of the German Telecommunications and Telemedia Data Protection Act).

You can revoke your consent via our consent banner at any time with effect for the future and change the cookie settings. Please note that changes must be made separately for each terminal device.

[At this point please insert a button to call the Consent Tool].

If you maintain accounts with the third-party providers we use and are logged in there, your data may be linked to the account in question. You can avoid such aggregation either by not giving or by revoking your consent to the cookies in question or by logging out of the respective accounts held with third-party providers in advance.

Most browsers accept cookies automatically. You can also disable, restrict or delete cookies on your terminal device either manually using your browser’s settings or with the help of software. If you disable the setting of cookies, you will not be able to use our website in full, or will only be able to use it to a limited extent.

Please also note our instructions in the section concerning the particular service that is using the cookies.

Web tracking methods: Statistical evaluations with Matomo (formerly Piwik) (Art. 6 (1) (f) of the GDPR, Section 25 (2) of the German Telecommunications and Telemedia Data Protection Act)

Our website uses Matomo, which is a so-called web analysis service. Matomo uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. For this purpose, the usage information generated by the cookie (including your shortened IP address) is transmitted to our server and stored for usage analysis purposes, which serves to optimize the website on our part. Your IP address is immediately anonymized during this process, so that you as a user remain anonymous to us. The information generated by the cookie about your use of this website will not be passed on to third parties. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
If you do not agree with the storage and analysis of this data from your visit, then you can object to the storage and use at any time by clicking on the Consent banner. In this case, a so-called opt-out cookie is stored in your browser, which means that Matomo does not collect any session data.
Attention: If you delete your cookies, this will result in the opt-out cookie also being deleted and you may have to activate it again.

Google Tag Manager (Art. 6 para. 1 sentence 1 lit. a GDPR)

The Google Tag Manager of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google") or Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) is used to manage and control various tags. A cookie is created in your browser for this purpose. The tag manager only manages other tags and does not collect any data itself.
Both tools are used on the basis of your consent in accordance with Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time by https://adssettings.google.com click. The revocation only applies to the device and the web browser on which it was set, please repeat the process on all devices if necessary. If you delete the opt-out cookie, you will be asked again for your consent to the transfer of data.
You can also configure your browser accordingly to prevent ads from third-party providers. You can also use a corresponding plug-in for common web browsers, which you can download here: https://support.google.com/ads/answer/7395996 and install it, you can permanently prevent tracking by Google
Your data will be transmitted to Google for analysis. If you have an account with Google, Google may also merge the data obtained from tracking. Data is transferred to a third country. We have concluded a corresponding data processing agreement with Google on the basis of the GDPR.
You can find more information about Google and Google's privacy policy at www.google.com/privacy/ads/

 

OpenStreetMap

We use OpenStreetMap (https://www.openstreetmap.de), an open-source service provided by the OpenStreetMap Foundation (OSMF, St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom), on our website to display maps and create route plans. The legal basis for processing is your consent according to Art. 6 (1), sentence 1, (a) of the GDPR. By giving your consent, you are agreeing to the collection, processing and use of the data that you enter and that is automatically collected by OpenStreetMap, one of its representatives, or third-party providers.
OpenStreetMap may also transfer the information it has obtained to third parties if doing so is required by law or if third parties process this data on OpenStreetMap’s behalf. It is technically possible that OpenStreetMap could identify at least individual users based on the data received. We have no influence over whether OpenStreetMap processes website users’ personal data and personality profiles for other purposes.
You have the option of modifying your consent to data processing at any time with effect for the future. To do this, simply call up our consent banner:
[Consent Banner Link]

 

Links to social media

On our website you will find links to the social media services of Meta / Facebook, YouTube, LinkedIn and Instagram. You can recognize links to the websites of the social media services by the respective company logo. If you follow these links, you will reach the Kögel Trailer GmbH company website at the respective social media service. When you click on a link to a social media service, a connection to the servers of the social media service is established. This transmits to the servers of the social media service that you have visited our website. In addition, further data is transmitted to the provider of the social media service.

These are for example:
- Address of the web page where the activated link is located
- Date and time of the call of the web page or the activation of the link
- Information about the browser and operating system used
- IP address
If you are already logged into the corresponding social media service at the time the link is enabled, the social media service provider may be able to determine your username and potentially even your real name from the transferred data and assign this information to your personal user account with the social media service. You can eliminate the possibility of this assignment to your personal user account by logging out of your user account beforehand.
The social media services’ servers are located in the USA and other countries outside of the European Union. The social media service provider may thus also process data in countries outside of the European Union. Please note that companies in these countries are subject to data protection legislation that does not generally protect personal data to the same extent as legislation in member states of the European Union.
Please also note that we have no influence over the scope, type and purpose of data processing carried out by the social media service provider. For more information about how your data is used by the social media services integrated into our website, please refer to the privacy policy for the social media service in question.

 

Contact form/contact by email (Art. 6 (1) (a) and (b) of the GDPR)

If you contact us by email, we will use the personal data provided in the email for the sole purpose of processing your request.

Newsletter (Art. 6 (1) (a) of the GDPR)

You can subscribe to a free newsletter on our website. The email address you provide when subscribing to the newsletter will be used for sending the newsletter.

The principle of data minimisation and data avoidance is observed since only the email address is required. When you order the newsletter, your IP address is also processed for technical reasons and to provide legal protection.

We use the ‘double opt-in procedure’ to send newsletters by email. This means that you will only receive advertising by email if you have previously expressly confirmed that you want us to enable the newsletter service. To this end, we send you a notification email asking you to confirm that you wish to receive our newsletter on this email address by clicking on a link contained in the email.

You can, of course, unsubscribe at any time using the Unsubscribe option provided in the newsletter and, in so doing, revoke your consent. You can also unsubscribe from the newsletter at any time directly using our website.

Application (Art. 6 para. 1 lit. a, b EU-DS-GVO

Thank you for your interest in working for Kögel Trailer GmbH. We are aware of the importance of your data and process the personal data you provide in the application form only for the purpose of effective and correct processing of the application procedure and for contacting you as part of the application process as well as for information about potential job offers. No data will be passed on to third parties without your consent.

As part of the application form, you will be asked to provide personal data. In doing so, we observe the principle of data economy and data avoidance by only requiring you to provide us with the data that we need to fully review your application documents, such as your first and last name, e-mail address and your application documents, or which we are legally obligated to collect. This mandatory information is marked with a *(red asterisk). For technical necessity as well as for legal protection, your IP address is also processed.

Without this data, we are unfortunately unable to check your application documents, which is why our application system does not allow the application documents to be uploaded in this case. Of course, you have the option to provide voluntary information in the application form.

To protect the security and confidentiality of your data as best as possible, we implement appropriate security measures. Your application documents are transmitted to us encrypted by our application system.

We store your data for the above-mentioned purposes until the application process has been completed and any deadlines in this regard have expired - at the latest six months after receipt of a decision. If you have given your consent to the processing, you can of course revoke your consent at any time without giving reasons with effect for the future by sending an e-mail to datenschutz@koegel.com. 

Registration/customer account (Art. 6 (1) (a) and (b) of the GDPR)

Our website offers users the opportunity to register by providing personal data so they can then make purchases in our Parts Shop. We only use the data provided in this context for the purpose of implementing or processing the contractual relationship unless you consent to further use.

Registration is therefore either necessary or possible to fulfil a contract with you (through our online shop) or to implement pre-contractual measures.

The principle of data minimisation and data avoidance is observed here since only the data required for registration is marked as a mandatory field with an asterisk (*). Such mandatory data includes email address and password (including repetition of your password), your name, your address and your VAT ID number.

The user’s IP address and the date and time of registration are also stored (technical background data) when you register on our website. By clicking on the ‘Register’ button, you consent to processing of your data.

Please note: We store the password you assign in encrypted form. Our company’s employees cannot read this password. They cannot, therefore, provide you with any information if you have forgotten your password.

In this case, use the ‘Forgotten your password?’ function, which will send you an automatically generated new password by email. Employees are not authorised to request your password from you over the phone or in writing. Therefore, please do not disclose your password if you receive such requests.

Once the registration process is complete, we store your data so you can use the secured customer area. As soon as you register on our website with your email address as your username and password, this data is made available for operations you carry out on our website (e.g., for placing orders in our online shop). Orders that have been placed can be tracked in the order history. You can specify changes to the billing or delivery address here.

Registered individuals are free to make changes/corrections to the address on their own. Our Customer Service Team will also be happy to make changes/corrections if you contact them. You can, of course, cancel or delete the registration or your customer account also.

Payment systems (Art. 6 (1) (a) and (b) of the GDPR), credit check (Art. 6 (1) (f) of the GDPR)

In our Parts Shop, you have the option of paying by credit card, PayPal or instant bank transfer. To this end, the payment-related data is collected so we can place your order and process the payment. Your IP address is also processed for technical reasons and for legal protection.

The principle of data minimisation and data avoidance is observed in that you only have to provide us with the data that we absolutely need to process the payment, and thus the contract, or that we are legally required to collect.

Without this data, we will unfortunately have to refuse to conclude the contract as we will then be unable to do so.

The payment system we use applies SSL encryption to protect transfer of your data.

Information about paying by credit card: As is usual with credit card payments, the credit card details are checked.

Note about PayPal:

PayPal is a company of 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 a payment option during the ordering process in our online store, data of the data subject will be automatically transmitted to PayPal.

By selecting this payment option, the data subject consents to the transfer of personal data that is required to process the payment. The personal data transferred to PayPal usually includes the first name, surname, address, email address, IP address, telephone number, mobile phone number or other data that is necessary to process the payment.

Personal data that is related to the order in question is also necessary for processing the purchase contract. Details of PayPal’s data protection practices can be found at: https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev (for the legal basis from 25 May 2018).

Advertising purposes for existing customers (Art. 6 (1) (f) of the GDPR)

Kögel Trailer GmbH is interested in maintaining our customer relationship with you and in sending you information about, and offers for, our products. We therefore process your data so we can send you relevant information and offers by email.

If you do not wish to do so, you may object at any time to the use of your personal data for the purpose of direct marketing; this also applies to profiling insofar as it is related to direct marketing. If you object, we will no longer process your data for this purpose.

The objection can be made free of charge and without formalities without giving any reasons and should be sent if possible to +49 8285 88-0, by e-mail to info@koegel.com or by post to Kögel Trailer GmbH, Am Kögel-Werk 1 89349 Burtenbach.

Links to other providers

Our website also contains (clearly recognisable) links to other companies’ websites. If there are links to other providers’ websites, we have no influence over the contents of same. We cannot, therefore, give any guarantee or accept any liability for these contents. The relevant site provider or operator is always responsible for the contents of these sites.

The linked sites were checked for potential legal violations and identifiable legal infringements at the time of linking. No unlawful contents were recognisable at the time of linking. However, it is unreasonable to permanently monitor the contents of the linked sites without concrete evidence of a legal violation. If we become aware of legal violations, we will remove such links without delay.