Privacy Policy

We are pleased that you are visiting our website and accordingly about your interest in our company and our products. The protection of your personal data is very important for us. Dethleffs GmbH & Co. KG (hereinafter “Dethleffs”, “we” or “us”) attaches great importance to the security of the data of the users and the compliance with provisions under data protection law.

Table of Contents

1. Definitions
2. Principles for the collection and processing of personal data
3. Processing of personal data
   3.1 Automated data collection
   3.2 Use of cookie tracking
   3.3 Google services
   3.4. Analysis and communication tools
   3.5 Social media
   3.6 Our services
4. Data transfer
5. Existence of automated decision-making including profiling
6. Duration of the storage
7. Technical security
8. Legal basis for the processing
9. Note on minors
10. Rights of the data subjects
11. Revocation of your consent to the data processing
12. External links
13. Changes to our privacy policy
14. The data controller and contact details of the external data protection officer
15. Registration for "Apprenticeship Day" and "Taster Afternoon in the Trainee Workshop”

1. Definitions

The technical terms in this Privacy Policy are used in accordance with their legal definitions pursuant to Art. 4 GDPR.

2. Principles for the collection and processing of personal data

Use of our websites is principally possible without entering any personal data. If you would like to use special services of our company via our website it could however be necessary to process personal data. If it is necessary to process personal data and if there is no statutory basis for such processing we will generally obtain the consent of the data subject.

3. Processing of personal data

3.1 Automated data collection

You can visit our site without actively providing any details relating to your person. However, we will automatically store access data each time the website is called (server log files) such as the name of your internet service provider, the used operating system, the website, from which you visit us, the date and the duration of the visit or the name of the requested file, as well as for security reasons, e.g. for the recognition of attacks on our websites, the IP address of the used computer for the duration of 60 days. This data is exclusively evaluated to improve our offer and does not allow any conclusions to be drawn about your person. This data will be not aggregated with other data sources. The legal basis for the processing of the data is Art. 6 (1) (f) GDPR. We process and use the data for the following purposes: 1. Provision of the Dethleffs websites, 2. Improvement of our websites and 3. Prevention and recognition of errors/malfunctions as well as of misuse of the websites. The data processing of this kind is carried out either to fulfil the contract via the use of the Dethleffs websites or we pursue a legitimate interest in ensuring the functionality and the error-free operation of the Dethleffs websites as well as adjusting these websites to the requirements of the users.

3.2 Use of cookie tracking

We use so-called cookies on our websites in order to make the visit to our website attractive and to enable the use of certain functions. The use of cookies serves our legitimate interest in making your visit to our website as pleasant as possible and is based on Art. 6 (1) (f) GDPR. This concerns a standard internet technology for the storage and retrieval of login and other use-related information for all users of the Dethleffs websites. Cookies are small text files, which are placed on your terminal device, they enable us among other things to store user settings so that our websites can be displayed in a format that is customised for your device. Several of the cookies used by us are deleted again after the end of the browser session, therefore after your browser is closed (so-called session cookies). Other cookies remain on your terminal device and enable us or our partner companies to recognise your browser the next time you visit the website (so-called permanent cookies).

You can set your browser so that you are informed about the setting of cookies and can make individual decisions about their acceptance or exclude the acceptance of cookies for certain cases or generally. The cookies can furthermore be deleted subsequently in order to remove data that websites have filed on your computer. The deactivation of the cookies can lead to several restrictions to the functionality of the Dethleffs websites.

Deactivate or remove cookies (Opt-Out)

Each web browser offers possibilities in order to restrict and delete cookies. You can find further information in this respect on the following websites:

• Internet Explorer: support.microsoft.com/de-de/help/17442
• Firefox: support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Google Chrome: support.google.com/chrome/answer/95647
• Safari: support.apple.com/de-de/HT201265

3.3 Google services

In order to make visiting our website a pleasant experience and to simplify the use of certain features for you, we use cookie-based Google programs. The use of these Google programs serves our legitimate interest pursuant to Art. 6 (1) (f) GDPR to make visiting our website clear, uncomplicated and as pleasant to use as possible.

You can read Google's data protection information at policies.google.com/privacy.

3.3.1 Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google). Google Analytics uses so-called “cookies”, text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookies regarding your use of this website (including your IP address) is transferred to a server of Google in the USA and stored there. Google will use this information to evaluate your use of the website in order to compile reports on the website activities for the website operators and to provide further services associated with the website use and the internet use. Google will also, if applicable, transfer this information to third parties if this is stipulated by law or insofar as third parties process this data by order of Google.

Prevent storage of the cookies
You can prevent the storage of the cookies via a corresponding setting in your browser software; however we would like to point out that in this case you will, if applicable, not be able to use all functions of this website in full. By the use of this website you declare that you agree with the processing of the data collected about you by Google in the manner as described above and for the previously mentioned purpose.

Objecting to the collection of data
If you do not want Google to receive data from your browser when you visit the respective pages, you can find the link to the Google Analytics opt-out solution here:

tools.google.com/dlpage/gaoptout

This plug-in prevents the browser from requesting the Analytics code so that Google does not receive any data when the page is called up. The plug-in is only available for Microsoft Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera. According to Google, the browser blocks the Google Analytics script after installation. More information on terms of use and data protection can be found at www.google.com/analytics/terms/de.html or at policies.google.com/privacy

As an alternative to this browser plug-in or for browsers on mobile devices, you can use the following link to the opt-out solution: http://tools.google.com/dlpage/gaoptout?hl=de

Retention period
We have used the Google Analytics data retention controls to determine how long user-level and event-level data is retained before it is automatically deleted from the Analytics servers. For this purpose, we have chosen the following retention period:
14 months
IP anonymisation
We wish to point out that the code "gat.anonymizeIp" has been added to Google Analytics on this website in order to ensure anonymised collection of IP addresses (so-called IP masking). This way your IP address is abbreviated by Google within member states of the European Union or in other contracting states of the Treaty on the European Economic Area before transmission to the USA.

Demographic features with Google Analytics
This website uses the “demographics” function of Google Analytics. Reports can thus be created that contain information about the age, sex and interests of the site visitors. This data stems from interest-based advertising served by Google as well as from visitor data from third-party providers. This data cannot be associated with any specific person. You can deactivate this function at all times via the display settings in your Google account or generally forbid the entry of your data by Google Analytics as explained under “Objecting to the collection of data”.

3.3.2 Google Ajax search API

Ajax is used on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”). This tool is used to optimise the loading speed. This optimisation is achieved by retrieving program libraries such as jQuery from Google servers and using CDN (content delivery network). If you have already used jQuery, the copy stored in your cache is accessed. If this is not the case, a download is required, whereby data from your browser is transferred to Google. This data is transferred to the USA. You can find more detailed information pertaining to conditions of use and data protection under: www.google.de/policies/privacy/

3.3.3 Google Maps

We use Google Maps to present maps and to create route maps. Google Maps is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google).

By using this website you declare that you agree with the entry, processing as well as the use of the automatically collected data as well as the data entered by you by Google, one of its representatives or third party providers. You can find further details in the data protection centre at google.com: Transparency and options as well as data protection provisions under policies.google.com/privacy

3.3.4 Google Tag Manager

This website uses the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”). Website tags can be managed via an interface through this service. The Google Tag Manager merely implements tags. This means: No cookies are used and no personal data is entered. The Google Tag Manager triggers off other tags, which on the other hand, if applicable, enter data. However, the Google Tag Manager will not access this data. If a deactivation was carried out on domain or cookie level then it will continue to exist for all tracking tags if these are implemented with the Google Tag Manager.

You can find further details in the data protection centre at google.com: Transparency and options as well as data protection provisions under policies.google.com/privacy

3.4 Analysis and communication tools

3.4.1 Hotjar
We use Hotjar by Hotjar Limited (Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta) on our website to statistically analyse visitor data. Hotjar is a service that analyses your behaviour and feedback as a user on our website through a combination of analytics and feedback tools. We receive reports and visual representations from Hotjar that show us where and how you “move” around our site. Personal data is automatically anonymised and never reaches Hotjar's servers. This means that website users are not personally identified; we nevertheless still learn a lot about your user behaviour.

What is Hotjar?
As mentioned above, Hotjar helps us analyse the behaviour of visitors to our website. The tools that Hotjar offers include heatmaps, conversion funnels, visitor recording, incoming feedback, feedback polls and surveys (you can find out more about these at www.hotjar.com/). In this way, Hotjar helps us to provide you with a better user experience and service. Furthermore, it provides a good analysis of online behaviour and also gives us good feedback on the quality of our website. Ultimately, besides all the analytical aspects, we naturally also simply want to know your opinion about our website. And with this feedback tool, that's exactly what we can determine.

Why do we use Hotjar on our website?
In recent years, the importance of user experience on websites has increased dramatically. And for good reason. A website should be built in such a way that makes visitors feel comfortable and enables them to find their way around easily. Thanks to Hotjar's analysis and feedback tools, we can make our website and our offer more attractive. Hotjar's heatmaps are particularly valuable to us. Heatmaps are a form of representation for the visualisation of data. Through Hotjar's heat maps, we can see very precisely what you like to click or tap on and where you scroll to, for example.

What data is stored by Hotjar?
As you browse our website, Hotjar automatically collects information about your user behaviour. In order to collect this information, we have installed our own tracking code on our website. The following data can thus be collected via your computer or browser:

IP address of your computer (collected and stored in an anonymous format)
Screen size
Browser info (which browser, version, etc.)
Your location (but only the country)
Your preferred language setting
Web pages visited (subpages)
Date and time you accessed one of our subpages (web pages)

In addition, cookies also store data that is placed on your computer (usually in your browser). No personal data is collected via these cookies. In principle, Hotjar does not pass on any collected data to third parties. However, Hotjar explicitly points out that it is sometimes necessary to share data with Amazon Web Services. In this case, parts of your information are stored on their servers. However, Amazon is bound by a confidentiality obligation not to disclose this data.

Only a limited number of people (Hotjar employees) have access to the stored information. The Hotjar servers are protected by firewalls and IP restrictions (access only to approved IP addresses). Firewalls are security systems that protect computers from unwanted network access. They are designed to act as a barrier between Hotjar's secure internal network and the internet. Furthermore, Hotjar also uses third-party companies, such as Google Analytics or Optimizely, for its services. These companies may also store information that your browser sends to our website.

The following cookies are used by Hotjar. Since we refer to the cookie list from Hotjar's privacy policy at www.hotjar.com/legal/policies/cookie-information, among other things, an exemplary value is not available for every cookie. The list shows examples of Hotjar cookies and does not claim to be exhaustive.

Name: ajs_anonymous_id
Value: %2258832463-7cee-48ee-b346-a195f18b06c3%22331614759439-5
Purpose: this cookie is usually used for analytics purposes and helps count visitors to our website by tracking whether you have been to this page before.
Expiry date: after one year

Name: ajs_group_id
Value: 0
Purpose: this cookie collects data about user behaviour. This data can then be assigned to a specific visitor group based on commonalities between website visitors.
Expiry date: after one year

Name: _hjid
Value: 699ffb1c-4bfb-483f-bde1-22cfa0b59c6c
Purpose: this cookie is used to maintain a Hotjar user ID that is unique to the website in the browser. This allows user behaviour to be associated with the same user ID on subsequent visits.
Expiry date: after one year

Name: _hjMinimizedPolls
Value: 462568331614759439-8
Purpose: whenever you minimise a Feedback Poll widget, Hotjar sets this cookie. The cookie ensures that the widget remains minimised when you browse our pages.
Expiry date: after one year

Name: _hjIncludedInSample
Value: 1
Purpose: this session cookie is set to inform Hotjar whether you are part of the selected people (sample) used to generate funnels.
Expiry date: after one year

Name: _hjClosedSurveyInvites
Purpose: this cookie is set when you see an invitation to a feedback survey via a pop-up window. The cookie is used to ensure that this invitation only appears once for you.
Expiry date: after one year

Name: _hjDonePolls
Purpose: as soon as you finish a feedback “question round” with the so-called Feedback Poll Widget, this cookie is set in your browser. This prevents Hotjar from sending you the same surveys again in the future.
Expiry date: after one year

Name: _hjDoneTestersWidgets
Purpose: this cookie is used as soon as you enter your data in the “Recruit User Tester Widget”. We use this widget to recruit you as a tester. The cookie is used so that this form does not appear repeatedly.
Expiry date: after one year

Name: _hjMinimizedTestersWidgets
Purpose: this cookie is set so that the “Recruit User Tester” remains minimised on all our pages once you have minimised it.
Expiry date: after one year

Name: _hjShownFeedbackMessage
Purpose: this cookie is set when you have minimised or completed the incoming feedback. This is done so that the incoming feedback is immediately loaded as minimised when you navigate to another page where it should be displayed.
Expiry date: after one year

Where and for how long is the data stored?
We have included a tracking code on our website that is transmitted to the Hotjar servers in Ireland (EU). This tracking code contacts Hotjar's servers and sends a script to your computer or device that you use to access our site. The script collects certain data relating to your interaction with our website. This data is then sent to Hotjar's servers for processing. Hotjar has imposed a 365-day data retention period on itself. This means that all data collected by Hotjar that is older than one year is automatically deleted.

How can I delete my data or prevent its storage?
Hotjar does not store any of your personal data for analysis. The company even advertises with the slogan “We track behaviour, not individuals”. You also always have the option to prevent the collection of your data. To do so, simply go to the “Opt-out page” and click on “Deactivate Hotjar”. Please note that deleting cookies, using your browser’s private mode or using another browser will cause data to be collected again. Furthermore, you can also activate the “Do Not Track” button in your browser. In the Chrome browser, for example, you have to click on the three bars at the top right and go to “Settings”. There, in the “Privacy” section, you will find the option “Send a “Do Not Track” request with browser access”. Simply activate this button and no data will be collected by Hotjar.

More details about the Hotjar privacy policy as well as which data is collected via which methods can be found at www.hotjar.com/legal/policies/privacy.

3.4.2 Zendesk CRM system

We use the “Zendesk” CRM system from the provider Zendesk, Inc., 989 Market Street #300, San Francisco, CA 94102, USA, in order to process user enquiries more quickly and efficiently (legitimate interest pursuant to Art. 6 (1) (f) GDPR). Zendesk is certified under the Privacy Shield agreement and thus offers an additional guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG&status=Active).

Zendesk only uses the users' data for the technical processing of the requests and does not pass them on to third parties. To use Zendesk, at least a correct email address is required. Pseudonymous use of Zendesk is possible. In the course of processing service requests, it may be necessary to collect further data (name, address). The use of Zendesk is optional and serves to improve and accelerate our customer and user service.

If users do not consent to the collection of their data and its storage in Zendesk's external system, we can provide them with alternative means of contact for submitting service requests by email, telephone, fax or post.

Users can find more information in Zendesk's privacy policy: www.zendesk.de/company/customers-partners/privacy-policy/.

3.5 Social media

3.5.1 Our offers on social media platforms

We make offers (e.g. Fanpages) available online on various social media platforms, which provide information about Dethleffs and give us the possibility to contact you. We would like to point out that we have no influence on the processing of your personal data on these platforms and merely the respective operator of the platform has full knowledge of the content of the transmitted data and their use.

As a rule, the respective platform cookies are stored in your browser during your visit.

You can also be affected by this data collection if you are not registered on the respective platform. We have no knowledge whether and to what extent the data can be taken outside of the European Economic Area.

The processing of personal data on the platforms by us is based on Art. 6 (1) (f) GDPR. Our legitimate interest lies in being able to present Dethleffs externally in many different ways and to use the communication possibilities with our customers as effectively as possible.

A consent to the data processing pursuant to Art. 6 (1) (a) GDPR can also be a legal basis if you have granted this to the platform operator.

You will receive detailed information about the data processing of the platform operators relating to the respective possibilities to object, the rights to information as well as specific information pertaining to the respective platforms through the following data protection notices of the respective operators:

Facebook

Provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Privacy statement: www.facebook.com/about/privacy/
Cookie-information: www.facebook.com/policies/cookies/
Specific information pertaining to Facebook-Fanpages: When visiting our Facebook Fanpage, Facebook processes your personal data (Facebook Insights). This data is transmitted to us anonymously by Facebook within the scope of Facebook Insights. These anonymised data concern um statistical data about our Fanpage subscribers.

In addition, we are informed of profile data from Facebook in relation to you if you interact with us or our site, for example you like or comment on contributions or write to us via Facebook or follow our site.

YouTube

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Privacy statement: policies.google.com/privacy
Cookie information: policies.google.com/technologies/ads
Opt-Out: adssettings.google.com/anonymous
Specific information pertaining to YouTube accounts or channels: When visiting our YouTube presence, YouTube processes your personal data. This data is transmitted to us anonymously by YouTube within the scope of the YouTube STUDIO use. These anonymised data concern statistical data about our channel subscribers.

In addition, we are informed by YouTube of the user name of your “Google+” profile if you interact with us or our site, for example like or comment on videos or subscribe to our channel.

Vimeo

Provider: Vimeo, Inc., 555 West 18th Street, New York, New York 10011, USA
Privacy statement: www.vimeo.com/privacy
Opt-Out: vimeo.com/cookie_policy  
Specific information pertaining to Vimeo accounts or channels: When visiting our Vimeo presence, Vimeo processes your personal data. This data is however only transmitted to us anonymised. Therefore, we merely have the access to statistical data, which however do not feature any reference to persons. Within the scope of a statistical presentation we receive information about the following data types: geographical data (country, region /federal state/canton and town) and device-specific data (Desktop, mobile phone, tablet and TV).

In addition, we are informed of your profile name if you interact with us. This is achieved by the fact that data is transmitted about your interaction and the progress, such as the following data: Plays (number of video calls), Finishes (number of fully played videos), number of likes and comments. Moreover, we receive extended statistics about videos which were shared on further social media such as Facebook, YouTube, Twitter or LinkedIn and anonymised data about the interaction and the progress on these platforms.

Instagram

Provider: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
Privacy statement: help.instagram.com/155833707900388
Cookie information: help.instagram.com/1896641480634370
;Specific information pertaining to Instagram profiles: When visiting our Instagram corporate site, Instagram processes your personal data. This data is transmitted to us anonymously by Instagram within the scope of Instagram Insights. These anonymised data concern statistical data about our profile subscribers.

In addition, we are informed of your username by Instagram if you interact with us or our site, for example like or comment on contributions or follow our site.

3.5.2 Social Media Plug-ins

YouTube
Our website features videos from the YouTube platform, which is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”).
We use these services on the basis of Art. 6 (1) (f) GDPR, as we have a legitimate interest in disseminating and increasing awareness of our online presence. If you are logged into your YouTube account and play the video, you enable YouTube to assign your surfing behaviour directly to your personal profile. This association takes place regardless of whether you click on the video or not. You can prevent this association with your YouTube account by logging out of your YouTube account.
For more information on the handling of user data, please see YouTube's privacy policy at: www.google.de/intl/de/policies/privacy.

Vimeo

Videos from the Vimeo platform of the provider Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA (hereinafter “Vimeo”) are integrated on our website. Data protection information from Vimeo can be found at vimeo.com/privacy. We use these services on the basis of Art. 6 (1) (f) GDPR, as we have a legitimate interest in disseminating and increasing awareness of our online presence.
We would like to point out that Vimeo may use Google Analytics and refer to Google's privacy policy: policies.google.com/privacy as well as to the opt-out options of Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for the use of data for marketing purposes (https://adssettings.google.com/)

Pinterest

We use the service pinterest.com on our website. Pinterest.com is a service of Pinterest, Inc., 808 Brannan St, San Francisco, CA 94103, USA. Through the integrated “Pin it” button on our site, Pinterest receives the information that you have accessed the corresponding page of our website. If you are logged in to Pinterest, Pinterest can assign this visit to our site to your Pinterest account and thus link the data. The data transmitted by clicking the “Pin it” button is stored by Pinterest. For more information on the purpose and scope of data collection, its processing and use, as well as your rights in this regard and setting options for protecting your privacy, please refer to the Pinterest privacy policy, which you can access at pinterest.com/about/privacy/.

To prevent Pinterest from associating your visit to our site with your Pinterest account, you must log out of your Pinterest account before visiting our site.

3.6 Our services

3.6.1 Contact form/enquiries

On our site you have the possibility to send us enquiries by using the contact form. Your details from the contact form (contacts of your enquiry, subject of your enquiry and date) including the contact data entered by you there (segment, salutation, first name, last name, country, vehicle ID number) will be stored in our company for the purpose of processing the enquiry and for any follow-up questions. The legal basis for the collection and processing of the data is Art. 6 (1) (a) GDPR.

The data entered by you in the contact form will remain in our company until you request us to erase these, revoke your consent for the storage or the purpose for the data storage ceases to apply (e.g. after completed processing of your enquiry). Mandatory statutory provisions – in particular storage deadlines – shall remain unaffected.

3.6.2 E-mail contact

If you send us enquiries by e-mail or information your details (e-mail address, contents of your e-mail, subject of your e-mail and date) including the contact data entered by you there (first name, last name, if applicable phone number, address) will be stored by us for the purpose of processing the enquiry and for the event of follow-up questions. We will not forward this data without your consent. The legal basis for the collection and processing of the data is Art. 6 (1) (a) GDPR.

The user is pointed out that e-mails on the transmission channel may be read or changed without authorisation and unnoticed. Dethleffs uses software to filter unsolicited e-mails (spam filter). E-mails can be rejected by the spam filter if these have been falsely identified as spam by certain features. The data entered by you will remain in our company until you request us to erase these, revoke your consent for the storage or the purpose for the data storage ceases to apply (e.g. after the completed processing of your enquiry). Mandatory statutory provisions – in particular storage deadlines – shall remain unaffected.

3.6.3 Information material (brochures, price lists etc.)

On our website you have the possibility to use an online form to request information material relating to our products and services. Your details from the order form including the contact data entered by you there (title, first name, last name, company, address, phone number and email) will be stored in our company for the purpose of processing your order and for the event of follow-up questions and forwarded to the contract data processor commissioned by us to send the documents. The legal basis for the collection and processing of the data is Art. 6 (1) (a) GDPR.

The data entered by you in the online form will remain in our company until you request us to erase these, revoke your consent for the storage or the purpose for the data storage ceases to apply (e.g. after a reached agreement of a date). Mandatory statutory provisions – in particular storage deadlines – shall remain unaffected.

In the context of sending out information material, we reserve the right to use your postal address for our own direct advertising purposes. This processing is based on Art. 6 (1) (f) GDPR. If you do not wish to be contacted any further, you can object to the processing of your data at any time. The lawfulness of the data processing carried out until the objection shall remain unaffected by such an objection. Please send your objection to: datenschutz@dethleffs.de

3.6.4 Competitions

You have the opportunity to participate in competitions on our website. When registering for the competition, you must provide us with your e-mail address (and, if applicable, your first and last name and address). The purpose of collecting your data is to conduct the competition and to determine the winner and distribute the prize. The legal basis for this is Art. 6 (1) (b) GDPR. No other data will be collected except on a voluntary basis.
We only store the data you provide until the competition has been completed. Mandatory legal provisions – in particular retention periods – remain unaffected.

3.6.5 Subscription to our newsletters

On our website you have the possibility to subscribe to the newsletter of our company. We hereby inform our customers and business partners at regular intervals about offers from our company. For this purpose we need a valid e-mail address from you. Further data is not collected except on a voluntary basis. For legal reasons, a one-time confirmation e-mail is sent to the e-mail address entered by a data subject for receipt of the newsletter as part of a double opt-in procedure. We use this data exclusively for sending the newsletter and do not pass it on to third parties. The legal basis for the collection and processing of the data is Art. 6 (1) (a) GDPR.

When you subscribe to our newsletter we also store the IP address allocated by the Internet-Service-Provider (ISP) of the computer system used by the data subject at the time of the registration as well as the date and the time of the registration. The collection of this data is necessary in order to be able to determine (possible) misuse of a data subject’s e-mail address at a later time and therefore serves to protect our interests.

You can revoke your previously granted consent for the storage of the data, your e-mail address as well as its use for receipt of the newsletter at any time, for example via the “unsubscribe”/“de-registration” link in each newsletter.

Alternatively, you are also welcome to send your unsubscription request at any time to datenschutz@dethleffs.de by e-mail. The lawfulness of the previous data processing will remain unaffected by this revocation. After the revocation of your consent, this personal data will be erased by the data controller responsible for the processing. Unsubscribing from the newsletter will be interpreted as an automatic revocation of your consent.

Newsletter tracking

The newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in such e-mails, which are sent in HTML format, in order to enable a log file recording and a log file analysis. This way a statistical evaluation of the success or failure of online marketing campaigns can be carried out. On the basis of the embedded tracking pixel we can recognise whether and when an e-mail was opened by a data subject and which links in the e-mail were called by the data subject.

Such personal data collected via the tracking pixel contained in the newsletters will be stored by us owing to the legitimate interest and evaluated in order to optimise the sending of the newsletter and to adjust the contents of future newsletters even better to the interests of the data subject. The legal basis is Art. 6 (1) (f) GDPR.

4 Data transfer

4.1 Transfer of data internally within Dethleffs

We transmit your data internally to the administration and Human Resources department in order to fulfil our contractual or legal obligations. Your data will only be transferred or disclosed to the extent necessary for this purpose and in compliance with the relevant data protection regulations.

4.2 Transfer of data within the group

The data you provide to us will be stored in our centralised customer database in Germany and shared within the group/corporation for administrative purposes. If data is exchanged within the group/corporation, this is done to fulfil a contract or as a condition of use for the websites. In addition, there may be an interest in sharing this data for internal, administrative purposes. Should the processing of your data take place outside the European Economic Area (EEA), this will be carried out in compliance with all applicable data protection laws and in particular in accordance with Art. 44 ff. GDPR.

Data transfer for the purpose of a dealer consultation

Via our website, you have the option of transmitting your data to a dealer in order to arrange a consultation appointment. For this purpose, the following personal data is collected and transmitted to the dealer you have selected: your name, title, e-mail address; if you wish to be contacted by telephone or post by your selected dealer, the telephone number and/or your address will also be collected and transmitted as voluntary information. This collection and transmission of data is based on the initiation of a contract (Art. 6 (1) p. 1 (b) GDPR) for the execution of a consultation appointment by the selected dealer. The transmitted data is processed by the dealer for the purpose of arranging a consultation appointment with you via the contact channel selected by you. The dealer regularly deletes the data after the end of the test drive, provided that no other retention periods (e.g. tax retention periods) conflict with this. You can also assert your rights against the dealer. To do this, contact the dealer you have selected.

4.3 Transfer of data to third parties

We would like to inform you that the provision of personal data is sometimes required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes, in order to conclude a contract, it may be necessary 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 him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.
Should the processing of your data take place outside the EEA, this transfer will take place in compliance with all applicable data protection laws and in particular pursuant to Art. 44 ff. GDPR.

4.4 Transfer of data to a third country

We transfer your data to countries outside the EEA (so-called third countries). This takes place due to the above-mentioned purposes (transfer group-wide and transfer to further recipients). The transfer only takes place for the fulfilment of our contractual and legal obligations or based on your consent. In addition, this transfer takes place in compliance with all applicable data protection laws and especially in accordance with Art. 44 ff. DSGVO. In particular, either due to adequacy decisions issued by the European Commission or due to certain guarantees (e.g. standard data protection clauses, etc.).

4.5 Transfer of data to an international organisation

We also transfer your data to an international organisation. This transfer also takes place in compliance with all applicable data protection laws and in particular in accordance with Art. 44 ff. GDPR.

5. Existence of automated decision-making including profiling

We partly process your data automatically with the aim to assess certain personal aspects (Profiling). We only use profiling in the following case: In order to be able to inform and advise you about products in a targeted manner, we use evaluation tools. These enable needs-based communication and advertising, including market and opinion-based research.
Each person affected by the processing of personal data has the right granted by the European legislator of directives and regulations not to be subjected to a decision that is exclusively made based on an automated processing— including profiling —, which has a legal effect towards him or substantially impairs him in a similar manner if the decision (1) is not necessary for the conclusion or the fulfilment of a contract between the data subject and the data controller, or (2) owing to legal regulations of the Union or the member states, which the data controller is subject to, is permitted and these legal regulations contain appropriate measures for safeguarding the rights and freedoms as well as the legitimate interests of the data subject or (3) is carried out with the explicit consent of the data subject.

6. Duration of the storage

We principally store your data as long as this is necessary to provide our services or if this was envisaged by the European legislator of directives and regulations or another legislator in laws or regulations, which the data controller responsible for the processing is subject to. In all other cases we erase your personal data after settlement of the purpose, with the exception of those data, which we must continue to store in order to fulfil legal obligations (e.g. we are obligated owing to tax and commercial law storage obligations to keep documents in reserve such as e.g. contracts and invoices for a certain period of time).

7. Technical security

Dethleffs uses technical and organisational security measures in order to protect your data managed by us against accidental or wilful manipulations, loss, destruction or against the access of unauthorised persons. Our security measures are continuously improved in line with the technological development. For security reasons and to protect the transfer of confidential contents, such as for example the enquiries, which you send to us as the operator of the sites, this site uses an SSL encryption (Secure Socket Layer) in conjunction with the respective maximum level of encryption that is supported by your browser. As a rule, this is a 256-bit encryption. If your browser does not support any 256-bit encryption we use instead 128-bit v3 technology. You can recognise whether an individual page of our internet presence is transferred encrypted by the fact that the address line of the browser shifts from “http://” to “https://” and by the lock symbol in your browser line.
When the SSL encryption is activated the data, which you transmit to us, cannot be read by third parties.
We would like to point out that the data transmission in the internet (e.g. with the communication per e-mail) may feature security gaps. A consistent protection of the data against the access by third parties is not possible.

8. Legal basis for the processing

Art. 6 (I) (a) GDPR serves our company as the legal basis for processing activities, with which we obtain a consent for a certain processing purpose. If the processing of personal data is necessary to fulfil a contract, of which the data subject is a contractual party, as this for example is the case with processing activities, which are necessary for a delivery of goods or the provision of any other service or consideration, then the processing is based on Art. 6 (I) (b) GDPR. The same shall apply to those processing activities which are necessary to carry out pre-contractual measures, for example in cases of enquiries for our products or services.

If our company is subject to a legal obligation, through which a processing of personal data becomes necessary, such as for example to fulfil tax obligations then the processing is based on Art. 6 (1) (c) GDPR.

If the processing of personal data is necessary to protect the vital interests of the data subject or another natural person, then the processing is based on Art. 6 (1) (d) GDPR. Lastly, the processing could be based on Art. 6 (1) (f) GDPR.

Processing operations are carried out on this legal basis if the processing is necessary to protect a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden.

9. Note on minors

This website is not aimed at children below the age of 16. Persons who have not yet reached the age of 16 may not transmit any personal data to Dethleffs without the consent of their legal guardians.

10. Rights of the data subjects

In accordance with Art. 15 GDPR, you have the right to request confirmation as to whether we are processing data relating to you. You can request information about this data as well as the further information listed in Art. 15 (1) DSGVO and a copy of your data.
In accordance with Art. 16 GDPR, you have the right to request the correction or completion of the data concerning you and processed by us.
You have the right under Article 17 GDPR to request the immediate deletion of the data relating to you. Alternatively, you may request that we restrict the processing of your data in accordance with Article 18 GDPR.
In accordance with Article 20 GDPR, you have the right to request that the data you have provided to us be made available and transferred to another controller. You also have the right to complain to the supervisory authority responsible for you in accordance with Article 77 of the GDPR.

11. Revocation of your consent to the data processing

Several data processing activities are only possible with your explicit consent. You have the possibility to revoke an already granted consent at all times. For this purpose an informal notification to datenschutz@dethleffs.de via e-mail is sufficient. The lawfulness of the data processing carried out until the revocation will remain unaffected by the revocation.

12. External links

On our website you will find links to the websites of other providers. We hereby point out that we have no influence on the content of the linked websites and their providers‘ compliance with data protection regulations.

13. Changes to our privacy policy

We reserve the right to amend this data protection notice at any time in the event of changes on our website and in compliance with the applicable data protection regulations to ensure that it meets the legal requirements.

14. The data controller and contact details of the external data protection officer

Data controller:
Dethleffs GmbH & Co. KG
Arist-Dethleffs-Straße 12
88316 Isny
Germany
Tel.: +49 (0)7562 987 0
E-mail: datenschutz@dethleffs.de

Contact details of the external data protection officer:
Stefan Fischerkeller
Deutsche Datenschutzkanzlei
Tel.: +49 (0)7544 904 96 91
E-Mail: fischerkeller@ddsk.de
Note: Your enquiries will be treated confidentially and forwarded directly to the data protection officer.
This Privacy Policy was created by Deutsche Datenschutzkanzlei – Lake Constance Office.