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DATA PRIVACY STATEMENT

Information on data protection

We are issuing this data privacy statement to tell you how we process your personal data and to tell you about your rights. We are aware how important the processing of personal data is for you as a concerned user, and so we comply with all relevant legislation. Protecting your privacy is of utmost importance to us. We process your data in compliance with the General Data Protection Regulation of the EU (GDPR) and national data protection legislation.

Names and contact data of the representatives

pulpo GmbH

pulpo GmbH, Mühlenrain 38
79576 Weil am Rhein

Telephone: +49 7621 168 01 03
Email: info@pulpoproducts.com

General Managers authorised to represent the company: Patrick L’hoste and Ursula L’hoste

Definitions

This data privacy statement uses the definitions as set out in the General Data Protection Regulation (GDPR).

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); 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;

‘processing’ means 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;

‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

‘profiling’ means 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;

‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;

‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

What data do we process?

We collect and process the following personal data relating to you:

• contact and address information, if you have transmitted your contact information to us or registered on our site;
• online identifiers, such as your IP address, browser type and browser version, the operating system you are using, the referrer URL, the IP address, file names, access status, transmitted data volume , date and time of the server request;
• payment information within the scope of the ordering process,
• social media identifiers.

Purposes of processing

We process your data for the following reasons:

• for the establishment of contact requested by you;
• to enable us to make the catalogue and the download function available;
• for purposes of direct marketing;
• for sending you our email newsletter if you have subscribed to it;
• for quality assurance;
• for our statistics;
• for carrying out contracts with you, especially processing of orders and invoicing;
• for managing your customer account;
• for updating the services we offer you, including informing you about new services or special promotions.

Legal basis of data processing

We process data on the legal basis of

• your consent in accordance with Art. 6 (1) a) of the GDPR;
• performance of a contract with you in accordance with Art. 6 (1) b) of the GDPR;
• compliance with legal obligations in accordance with Art. 6 (1) c) of the GDPR;
• the purposes of pursuing our legitimate interest in accordance with Art. 6 (1) f) of the GDPR.

Legitimate interest

Where we process your personal data for the purpose of pursuing our legitimate interests within the meaning of Art. 6 (1) f) of the GDPR, these legitimate interests are

• improving the services we provide;
• protecting against misuse;
• managing our statistics.

Data sources

We obtain the data from you (including via the devices used by you). If we do not collect your personal data directly from you, we will additionally inform you of the sources from which the personal data originates and, where applicable, if they come from publicly accessible sources.

Recipients or categories of recipients of personal data

In processing your data we collaborate with the following service providers, which have access to your data:

• providers of web analysis tools;
• web hosting service providers;
• payment service providers;
• shipping firms and mail order partners;
• service providers which have access to your personal data and contractually agreed processors for the processing of credit requests.

Data are transmitted to third countries outside the European Union on the basis of contractual arrangements prescribed by law which are intended to ensure adequate protection of your data and which you may see upon request.

Duration of storage

We store your personal data for only as long as is necessary to carry out the purpose for which we process them or if storage is subject to a statutory retention period.

We store your data

• if you have consented to their processing, but only until you withdraw your consent;
• if your data are necessary for the performance of a contract with you, but only for as long as the contract exists or for the duration of a statutory retention period, if any;
• if we use your data on the basis of a legitimate interest, unless overridden by your interest in erasure or anonymisation.

Your rights

You have the right – if applicable under certain conditions –

• to obtain free of charge information about the processing of your data and to obtain a copy of your personal data. The information you may obtain includes the purposes of processing, the categories of personal data being processed, the recipients of the data (if they are being transferred), the duration of their storage and the criteria for determining such duration;
• to rectification of your data. If your personal data are incomplete, you have the right to have the data completed, taking account of the purposes of processing;
• to have your data erased or blocked. Your data may be erased or blocked if you withdraw the consent on which processing is based, if you as data subject object to the processing of your personal data or if your personal data are being unlawfully processed;
• to restriction of the processing;
• to object to the processing of your data;
• to withdraw your consent to future processing of your data;
• to lodge a complaint with the responsible supervisory authority about unlawful data processing.

Requirement or obligation to provide data

Except as otherwise explicitly stated when the data are being collected, providing data is neither required nor obligatory. There may be statutory requirements or contractual arrangements that make it obligatory to provide data.

Other information on data protection

Contact form / customer support

The contact form on our website enables you to contact us quickly. Some fields are marked as obligatory, which means that you must fill them in in order to contact us. When you fill in the fields and then click ‘Send’ you are consenting to your personal data being sent to us by email with the message. Your data will not be stored on the web server.

You may contact us via our Internet site for customer support. In this connection you voluntarily transmit your contact data to us. The personal data you send us will be automatically stores and will be processed only for the purpose of processing your enquiry to us. Your data will not be transmitted to third parties.

Email newsletter

If you subscribe to our newsletter, we use the data necessary for this or data transmitted separately by you to send you our regular email newsletter. You may unsubscribe our newsletter at any time by sending a message to our contact address as given above or by using the unsubscribe link provided in our newsletter.

Data security

We have taken extensive technical and organisational measures to make your personal data secure against potential risks such as unauthorised access, unauthorised inspection, changing or dissemination, and against loss, destruction and misuse of your personal data.

We use SSL encryption as necessary to protect your personal data against unauthorised access by third parties during transmission. SSL encryption is a standardised encryption process for online services, especially for the web.

Log files

Every time you access our Internet pages your user data are transmitted by your browser and stored in server log files. The data sets which are stored include the domain from which you have accessed the site, the date and time of your request, the IP address of your accessing computer, web pages visited by you while on our site, data volume transmitted, your browser type and version, operating system used by you, name of your Internet service provider and notification as to whether the request was successful. These log file data sets are evaluated in an anonymised form to enable us to improve our service and make it more user friendly, to find and remove errors and to control the capacity of our servers.

Cookies

This website uses cookies. Cookies are small text files with an identification number which, when you use our website, are transmitted to your computer together with the other files you have actually requested and stored there. The data are then ready on your computer for your next visit to authenticate you as the user. As cookies are simple files and not executable programs, they present no risk to your computer. Depending on your browser settings, your browser accepts these cookies automatically. You may, however, change this setting and deactivate the storage of cookies or set the browser to notify you if a cookie has been placed. If you deactivate cookies, this may prevent or restrict your use of certain functions of the website. You may at any time configure your browser to prevent the placing of cookies by our Internet site, thus permanently blocking the placing of cookies. Already active cookies may be erased at any time via a browser or other software programs. It is possible that we will work with marketing partners who help us to make our Internet offering more interesting for you. If this is the case, cookies from our partner companies may also be placed on your hard disk (cookies from third-party providers) for this purpose when you visit our website. If we are working with such marketing partners, you will be individually and separately informed about the use of such cookies and the information collected within the scope of the following paragraphs.

We use the following types of cookies:

– First-party cookies: first-party cookies are transmitted by the platform you are currently visiting.

– Third-party cookies: third-party cookies are cookies transmitted by a provider other than the one whose platform the user is visiting. If a user accesses a platform and another unit transmits a cookie via this platform, this is a third-party cookie.

– Absolutely essential cookies: these cookies are necessary to allow you to navigate the platform and use its functions such as accessing secure areas of the platform. Without these cookies certain services cannot be provided, such as the display of content tailored to your computer or device.

– Performance cookies: these cookies collect information about how visitors use the platform, such as which pages are most frequently accessed and whether they get error messages from websites. However, these cookies do not collect any information about the identity of the visitor. All information collected by these cookies is compiled and is therefore anonymous. It is only used to optimise the platform.

– Functionality cookies: these cookies enable the platform to remember the choices you make, such as language settings and your region and to offer you improved, personal functions. They may also be used to remember your settings for text size, font and other individualisable parts of the website. They can also be used to provide services requested by you such as the displaying of a video or the commentary function in a blog. The information collected by these cookies may be anonymised. Your surfing activities cannot be tracked on other platforms.

– Social media cookies: these cookies are used when you click on a button on the platform to share information on social media. The social network registers this action and may use it for marketing or advertising purposes.

– Marketing and advertising cookies: these cookies are used to show you advertisements which could be relevant for you on the basis of your interests. They are also used to limit the frequency with which you are shown any particular advertisement. We also place cookies to measure the effectiveness of advertising campaigns. They are normally placed by advertising networks with our permission and register your visit to our website. This information is transmitted to other organisations such as advertisers. Marketing and advertising cookies are often linked to certain platform functions. Our advertising cookies also allow you to take part in customer surveys and give us your feedback so that we can improve your user experience when you visit us.

Paypal

The PayPal service is provided by PayPal (Europe) S.àr.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. When you pay using PayPal you are referred via a link to the PayPal website. So that you can use this service, PayPal collects, stores and processes your personal data including your name, your address, your telephone number and your email address, as well as your credit card or bank account details. PayPal is alone responsible for protecting and handing the data collected by PayPal. In this respect the PayPal Conditions of Use apply, which you can access at www.PayPal.com. You can access further information about how PayPal deals with your data in the PayPal privacy policy statement at https://www.paypal.com/at/webapps/mpp/ua/privacy-full?locale.x=en_AT

Stripe

If you choose to pay by credit card, payment will be processed through Stripe Payments Europe Ltd, Block 4, Harcourt Center, Harcourt Road, Dublin 2, Ireland, to whom we provide your information and information in the ordering process about your order (name, address, account number, bank code, possibly credit card number, invoice amount, currency and transaction number). The transfer of your data is exclusively for the purpose of payment processing with the payment service provider Stripe Payments Europe Ltd. For more information about Stripe privacy, visit https://stripe.com/en-ch/privacy.

Facebook

Plugins of the social network Facebook, provider Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA,, are integrated into our pages. You can recognise the Facebook plugins by the Facebook logo or the ‘Like’ button on our site. You can find a list of Facebook plugins at http://developers.facebook.com/docs/plugins/. When you visit our site, the plugin creates a direct connection between your browser and the Facebook server. This informs Facebook that you have visited our site using your IP address. If you click on the Facebook ‘Like’ button while you are logged into your Facebook account you may link our pages to your Facebook profile and Facebook can then attribute your visit to our pages to your user account. We would point out that we as the provider of the pages obtain no knowledge of the content of the transmitted data or how Facebook uses them. You can find more information about this in the Facebook privacy policy statement at http://de-de.facebook.com/policy.php.

Instagram

We also use the functions of the Instagram service which are operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (‘Instagram’). The relevant plugins are flagged with an Instagram logo such as an Instagram camera. You can find a list of the Instagram plugins and what they look like at: http://blog.instagram.com/post/36222022872/introducing-instagram-badges. When you access a page on our website which includes one of these plugins, your browser creates a direct connection to the Instagram servers. The content of the plugin is transmitted by Instagram directly to your browser and integrated into the page. This integration informs Instagram that your browser has accessed the page in question of our web presence even if you do not have an Instagram profile or are not currently logged into Instagram. This information (including your IP address) is transmitted by your browser directly to the Instagram servers in the USA and stored there. If you are logged into Instagram, Instagram can directly attribute your visit to our website to your Instagram account. If you interact with the plugins, by for instance clicking on the ‘Instagram’ button, this information is likewise transmitted directly to an Instagram server and stored there. The information is also posted on your Instagram account and displayed there to your contacts. We would explicitly point out that we as the provider of this website obtain no knowledge of the content or scope of the transmitted data or how Instagram uses them. You can find more information about this in the Instagram privacy policy statement at https://help.instagram.com/155833707900388 and from the general information provided at https://help.instagram.com/.

LinkedIn

Our website uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Every time you access one of our pages containing LinkedIn functions a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our Internet pages using your IP address. If you click on the LinkedIn ‘Recommend’ button and are logged into your LinkedIn account, LinkedIn is able to attribute your visit to our Internet site to you and to your user account. We would point out that we as the provider of the pages obtain no knowledge of the content of the transmitted data or how LinkedIn uses them.

You can find more information about this in the LinkedIn privacy policy statement at https://www.linkedin.com/legal/privacy-policy.

Pinterest

We use social plugins on our website of the social network Pinterest, which is operated by Pinterest Inc., 808 Brannan Street, San Francisco, CA 94103-490, USA (“Pinterest”). When you access a page containing such a plugin, your browser creates a direct connection to the Pinterest servers. The plugin then transfers log files to the Pinterest server in the USA. These log files may include your IP address, the addresses of websites you have visited which also contain Pinterest plugins, the type and settings of your browser, the date and time of your request, information about how you use Pinterest and cookies. You can find more information about the purpose, scope and further processing and use of your data by Pinterest and your rights in this regard and how you can protect your privacy in the Pinterest data privacy policy statement athttps://about.pinterest.com/de/privacy-policy.

This data privacy statement was last amended in

September 2019

We reserve the right to amend this data privacy statement at any time with effect for the future.