Data Privacy Statement

Please find below our statement on the processing of personal data by our company in accordance with the legal requirements, especially with the EU General Data Protection Regulation (GDPR - available athttp://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679).

Contents:

I.       General information

1.      Definition of main terms

2.      Scope of validity

3.      Controller

4.      Data protection officer

II.      Itemisation of data processing operations

1.      General information about the data processing operations

2.      Accessing our services

3.      Newsletter subscriptions

4.      Tracking

III.    Rights of data subjects

1.      Right to object

2.      Right of access

3.      Right to rectification

4.      Right to erasure ("right to be forgotten")

5.      Right to restriction of processing

6.      Right to data portability

7.      Right to withdraw consent

8.      Right to lodge a complaint

 

I.                  General information

This section of the privacy statement contains information on the scope of validity, the person responsible for data processing, the data protection officer and data security. It also begins with a list of definitions of important terms used in the data privacy statement.

1.                Definition of main terms 

Browser: Computer program used to display websites (e.g., Chrome, Firefox, Safari)

Cookies: Text files which the web server places on the user's computer by means of the browser which is used. The stored cookie information may contain both an identifier (cookie ID) for recognition purposes and content data, such as login status or information about websites visited. The browser sends the cookie information back to the web server with each new request upon subsequent repeat visits to these sites. Most browsers accept cookies automatically. Cookies can be managed using the browser functions (usually under "Options" or "Settings"). The storage of cookies may be disabled in this way or it may be made dependent on the user’s approval in any given case or otherwise restricted. Cookies may also be deleted at any time.

Third countries: Countries outside the European Union (EU)

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679

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

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

Services: Our offers to which this data privacy statement applies (cf. Scope of validity).

Tracking: The collection of data and their evaluation regarding the behaviour of visitors in response to our services.

Tracking technologies: Actions can be tracked either via the activity records (log files) stored on our web servers or by collecting data from end devices via pixels, cookies or similar tracking technologies.

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

Pixel: Pixels are also called tracking pixels, web beacons or web bugs. These are small, invisible graphics in HTML emails or on websites. When a document is opened, this small image is downloaded from a server on the Internet and the download is registered there. This allows the operator of the server to see if and when an email has been opened or a website has been visited. This function is usually carried out by calling up a small program (JavaScript). Certain types of information can be detected on your computer system in this way and shared, such as the content of cookies, the time and date of the visit, and a description of the page on which the tracking pixel is located.

2.                Scope of validity

This data privacy statement applies to the following offers:

-           our website PackVERTISE, most notably available at http://www.packvertise.co.uk/

-           whenever reference is made to this data privacy statement from one of our offers (e.g., websites, subdomains, mobile applications, web services or integrations in third-party websites), regardless of the way in which it is accessed or used

All these offers are also collectively referred to as "services".

3.                Controller

The following party is responsible for the processing of data in relation to the services, i.e., this is the person who determines the purposes and means of processing personal data:

PaketPLUS GmbH

Schleiermacherstr. 14

D-10961 Berlin, GERMANY

Tel.: +49 30 94 88 79 10
email: datenschutz@paketplus.de

4.                Data protection officer

Our data protection officer can be contacted under the data given in paragraph III.., for the attention of the data privacy department or via paketplus@datenschutzanfrage.de.

 

II.               Itemisation of data processing operations

This section of the data privacy statement contains detailed information about the processing of personal data in the context of our services. The information is subdivided for greater clarity into certain functions in connection with our services. In case of the normal use of the services, different functions and therefore also different processing operations can be implemented consecutively or simultaneously.

1.                General information about the data processing operations

The following applies to all the processing operations listed below, unless stated otherwise:

a.      No obligation to provide personal data & consequences of failure to provide such data

The provision of personal data is not required by law or contract, and you are under no obligation to provide any data. We will inform you during the data entry process when personal information needs to be provided for the relevant service (e.g., by indicating "mandatory fields"). In cases where the provision of data is required, the consequence of not providing data will be that the service in question cannot be provided. Otherwise, failure to provide data may result in our inability to provide our services in the same form and quality.

b.      Consent

In various cases, you may also grant us your consent to the further processing of data (or some of the data, where applicable) in connection with the operations listed below. In this case, we will inform you separately in connection with the submission of the respective declaration of consent about all the procedures and the scope of the consent and about the purposes which we pursue in these processing operations. The processing operations based on your consent are therefore not listed again here (Art. 13, subs. 4, GDPR).

c.       Transfer of personal data to third countries

When we send data to third countries, i.e., countries outside the European Union, the data are then transmitted strictly in compliance with the statutory conditions of admissibility.

If the transmission of the data to a third country does not serve the purpose of fulfilling our contract with you, if we do not have your consent, if the transmission is not required for the establishment, exercise or defence of legal claims, and if no other exemption applies under Art. 49 GDPR, we will only transmit your data to a third country if in possession of an adequacy decision pursuant to Art. 45 GDPR or appropriate safeguards under Art. 46 GDPR.

One of these adequacy decisions is the Commission Implementing Decision (EU) 2016/1250 of 12.07.2016 on the "EU-US Privacy Shield" for the USA. The level of data protection is generally considered to be appropriate according to Art. 45 GDPR for transfers to companies which are certified under the EU-US Privacy Shield.

Alternatively or additionally, safeguards under Art. 46 subs. 2 c) GDPR through the conclusion of the EU standard data protection clauses adopted by the European Commission with the receiving body provide appropriate safeguards and an adequate level of data protection. Copies of the standard EU data protection clauses are available on the website of the European Commission at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en .

d.      Hosting at external service providers

Our data processing work is carried out to a large extent with the involvement of hosting service providers who provide us with storage space and processing capacities at their data centres and who also process personal data on our behalf according to our instructions. It may be the case that personal data are transmitted to hosting service providers in respect of all of the functions listed below. These service providers process data either exclusively in the EU or subject to guaranteed levels of data protection which we have put in place based on the standard EU data protection clauses (cf. subsection c.). 

e.      Transmission to government authorities

We send personal information to government authorities (including law enforcement agencies) when required to fulfil a legal obligation to which we are subject (legal basis: Art. 6, subs. 1 c), GDPR) or when it is necessary for the assertion, exercise or defence of legal claims (legal basis: Art. 6, subs. 1 f), GDPR).

f.        Period of storage

The time specified in the "period of storage" paragraph indicates how long we use the data for the purposes in any given case. At the end of this period, the data will no longer be processed by us but will be deleted at regular intervals, unless continued processing and storage are required by law (in particular, because it is necessary to fulfil a legal obligation or for the establishment, exercise or defence of legal claims) or unless you grant us extended consent.

g.      Data categories

The category names listed below are used for specific types of data in the following sections:

o   Account data: Login/user ID and password

o   Personal master data: Title, salutation, forename, surname

o   Address data: Street, house number, additional address lines (where applicable), postcode, city, country

o   Contact data: Telephone number(s), fax number(s), email address(es)

o   Login data: Information about the service via which you logged on; times and technical information on login, authentication and logout; data entered by you when logging on

o   Inserts order data: Ordered inserts and delivery information

o   Newsletter user profile data: Opening of newsletter (date and time), contents, selected links, as well as the following information relating to the computer system accessing the newsletter: Internet Protocol address used (IP address), browser type, browser version, device type, operating system and similar technical information.

o   Access data: Date and time of visit to our service; the page from which the system accessed our site; pages visited during the session; session identification data (session ID), as well as the following information relating to the computer system accessing the service: Internet Protocol address used (IP address), browser type, browser version, device type, operating system and similar technical information.

2.                Accessing our services 

The passages below set out how your personal data are processed when you access our services (e.g., loading and viewing the website, opening the mobile app and navigating within the app). We would point out, in particular, that it is impossible not to send access data to external content providers (cf. subsection b.) due to the technical processes involved in transmitting information over the Internet. The third-party providers are themselves responsible for the privacy-compliant operation of the IT systems which they use. The service providers are required to decide how long the data will be stored.

a.                  Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

 

Data category

Intended purposes

Legal basis

Legitimate interest, where applicable

Storage period

Access data

Establishing connection, presenting contents of the service, detecting attacks on our site due to unusual activities, fault diagnosis

Art. 6, subs. 1 f), GDPR

Proper functioning of services, security of data and business processes, prevention of misuse, prevention of damage through interference in information systems



4 weeks

 

b.                 Recipients of personal data

 

Recipient category

Data concerned

Legal basis

Legitimate interests, where applicable

External content providers who provide content which is needed to display the service (e.g., images, videos, embedded postings from social networks, banner ads, fonts, update information)

Access data

Art. 6, subs. 1 f), GDPR; in case of transmission to the USA  also Art. 45 GDPR in conjunction with the Commission Implementing Decision (EU) 2016/1250 of 12.07.2016 on the "EU-US Privacy Shield 

Proper functioning of services, (accelerated) display of content

IT security service providers

Access data

Art. 6, subs. 1 f), GDPR

Prevention of attacks through exploitation of security gaps / vulnerabilities

 

3.                Newsletter subscriptions

The tables below show how your personal data are processed when you subscribe to a newsletter:

a.                  Purposes of data processing, legal basis, legitimate interests (where applicable), and period of storage

 

Data category

Intended purposes

Legal basis

Legitimate interest, where applicable

Period of storage

Email address

Verification of the application (double opt-in procedure), sending of the newsletter

Art. 6, subs. 1 b), GDPR

 

Duration of newsletter subscription

Personal master data

Personalisation of newsletter

Art. 6, subs. 1 b), GDPR

 

Duration of newsletter subscription

Login data

Traceability of newsletter registration / confirmation / deregistration

Art. 6, subs. 1 b), f), GDPR

Proof of successful newsletter registration / confirmation / deregistration

Duration of newsletter subscription

Newsletter user profile data

Reflection of interests in the composition of the newsletter

Art. 6, subs. 1 f), GDPR

Improvement of our service, promotional purposes

Duration of newsletter subscription

 

b.                 Recipients of personal data

 

Recipient category

Data concerned

Legal basis

Legitimate interests, where applicable

Newsletter distribution service providers

All data listed in 2.a.

Processing on behalf of a controller (Art. 28 GDPR)

 

 

4.                Tracking

Below we describe how your personal information is processed using tracking technologies to analyze and optimize our services and for promotional purposes.

The description of the tracking methods also includes information on how to prevent or contradict the processing of data. Please note that this so-called "opt-out", ie the rejection of processing, is usually stored via cookies. If you use our services via a new device or in another browser, or if you have deleted the cookies set by your browser, you must explain the refusal again.

The tracking methods described process personal data only in pseudonymous form. A connection with a specific, identified natural person, ie a combination of the data with information about the carrier of the pseudonym, does not take place.

a.                  Tracking to analyze and optimize our services and their use

(1)               Purpose of processing

The analysis of user behavior by means of tracking helps us to check the effectiveness of our services, to optimize them and to adapt them to the needs of the users and to correct errors. It also serves to statistically determine parameters for the use of our services (range, intensity of use, user surfing behavior) on the basis of standardized standard procedures and thus to obtain comparable market values

(2)               Legal basis of processing

For services provided by us in connection with a contract, tracking and the associated analysis of user behavior are performed to fulfill our contractual obligations. The legal basis for this processing of personal data is Article 6 (1) (b) GDPR. The evaluation of information obtained through tracking is necessary in order to provide you with optimized services according to the contractual purpose and to ensure you the greatest possible benefit.

Otherwise, i. outside the context of a contractual relationship, the legal basis for this processing of personal data is Article 6 (1) (f) GDPR. With her, we have the legitimate interest in providing attractive services as efficiently as possible on the basis of the information gained through tracking and marketing them in the best possible way.

(3)               The tracking methods used in detail

 

Name of the service

Google Analytics

Functionality

This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer and that allow an analysis of the use of the website by you. The information provided by the cookie about your use of this website, namely

·         Browser type / version,

·         used operating system,

·         Referrer URL (the previously visited page),

·         Host name of the accessing computer (IP address),

·         Time of server request,

are usually transmitted to a Google server in the US and stored there. However, due to the activation of IP anonymization on this website, your IP address will be truncated by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website usage and internet usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by a corresponding setting of your browser software; however, we point out that in this case you may not be able to use all functions of this website in full. In addition, you can prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by using the link below (tools.google.com/dlpage/gaoptout?hl=en) to download and install the available browser plug-in. You can also find out about the browser add-on under the link mentioned.

For more information about Google Analytics privacy, please visit http://www.google.com/intl/en/policies/privacy/

Possibility to prevent processing (opt-out)

You can prevent the collection by Google Analytics by clicking on the following link. An opt-out cookie will be set that will prevent the future collection of your data when you visit this website: disable Google Analytics

 

Name of the service

Google Adwords

Functionality

We also use Google Conversion Tracking, an analysis service provided by Google Inc. In doing so, Google Adwords sets a cookie on your computer ("conversion cookie") if you have reached our website via one of our Google ads. These cookies lose their validity after 30 days and are not used for personal identification. If you visit certain pages of us and the cookie has not expired, we and Google may recognize that someone clicked on the ad and was redirected to our site. The information gathered using the conversion cookie is used to generate conversion statistics. We're learning the total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive any information that personally identifies users.

Possibility to prevent processing (opt-out)

If you do not wish to participate in the tracking process, you can generally disable the automatic setting of cookies in the browser settings or disable cookies for conversion tracking by setting your browser to use cookies from the domain "googleadservices.com" be blocked.

 

III.       Rights of data subjects 

1.                Right to object

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing with future effect, which includes profiling to the extent that it is related to such direct marketing.

You also have the right, at any time with future effect and for reasons relating to your particular situation, to object to the processing of personal data concerning you which is based on Art. 6, subs. 1 e) or f), GDPR, including profiling based on these provisions.

The right to object may be exercised free of charge. In order to be able to process your request faster, please preferably use the form available at the following link: https://datenschutzanfrage.de/?source=paketplus&lang=de

 

Alternatively, you may reach us, for example, using the contact information provided in paragraph

Via Mail to: paketplus@datenschutzanfrage.de

Via Phone: +49 - (0)781-639 6100

 

2.                Right of access

You have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and the other information listed in Art. 15 GDPR .

 

3.                Right to rectification

You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay (Art. 16 GDPR). Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

4.                Right to erasure ("right to be forgotten")

You have the right to obtain from us the erasure of personal data concerning you without undue delay if one of the reasons listed in Art. 17, subs. 1, GDPR is applicable and the processing operations are not required for one of the purposes approved in Art. 17, subs. 3, GDPR.

 

5.                Right to restriction of processing

You are entitled to obtain from us the restriction of the processing of personal data if one of the conditions laid down in Art. 18, subs. 1 a) to d), GDPR is met.

 

6.                Right to data portability

Under the conditions set out in Art. 20, subs. 1, GDPR, you have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance on our part. In exercising your right to data portability, you have the right to have the personal data transmitted directly by us to another controller where technically feasible.

 

7.                Right to withdraw consent

If the processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

 

8.                Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authority responsible for our company. The supervisory authority responsible for our company is:

Berliner Beauftragte für Datenschutz und Informationsfreiheit, An der Urania 4-10, 10787 Berlin, http://www.datenschutz-berlin.de/