Martin Alders / ALDERS electronic GmbH
47906 Kempen, Germany
Managing Director: Martin Alders
Link to the imprint
Types of processed data:
– Inventory data (e.g. names, addresses).
– contact information (e.g. e-mail, phone numbers).
– content data (e.g. text input, photographs, videos).
– usage data (e.g. websites visited, interest in content, access times).
– Meta / communication data (e.g. device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach Measurement / Marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g., cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term covers a wide range of aspects and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data is not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse and predict aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behaviour, whereabouts or relocation of that natural person.
“Responsible person” means the natural or legal person, public authority, institution or other body that alone or together with others decides on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with art. 13 GDPR, we inform you about the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, art. 6 para. 1 lit. d GDPR is the legal basis.
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in accordance with art. 32 GDPR.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly presettings (art. 25 GDPR).
Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to art. 6 (1) (b) GDPR to fulfil the contract), you have consented to a legal obligation or based on our legitimate interests (e.g., the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfil our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of art. 44 et seq. GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects
You have the right to ask for confirmation as to whether the data in question is being processed, and for information about this data as well as for further information and a copy of the data in accordance with art. 15 GDPR.
According to art. 16 GDPR, you have the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with art. 20 GDPR and request their transmission to other persons responsible.
According to art. 77 GDPR, you have the right to file a complaint with the competent supervisory authority.
Right of revocation
You have the right to revoke consents granted in accordance with art. 7 para. 3 GDPR with effect for the future.
Right of objection
You can object to the future processing of your data in accordance with art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object in direct advertising
“Cookies” are small files that are stored on a users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g., the contents of a shopping cart in an online shop or a login status are saved. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g., the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called “first-party cookies”).
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 (1) AO, 257 (1) Nos. 1 and 4, (4) HGB (German Commercial Code) (books, records, management reports, accounting documents, trading books, relevant for taxation Documents, etc.) and 6 years in accordance with § 257 (1) nos. 2 and 3, (4) HGB (commercial letters).
According to legal regulations in Austria the storage takes place especially for 7 years according to § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
In addition we process
– contract data (e.g. subject, term, customer category).
– payment data (e.g. bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with art. 6 para. 1 lit. b. GDPR in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g. names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g. services used, contract contents, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).
We do not process special categories of personal data, unless these are part of a commissioned or contractual processing.
We process data which are necessary for the establishment and fulfilment of the contractual services and point out the necessity of their indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as the legal requirements.
As part of the use of our online services, we can save the IP address and the time of each user action. The storage is based on our legitimate interests, as well as the interests of the user in the protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is to pursue our claims acc. To art. 6 para. 1 lit. f. GDPR required or there is a legal obligation in accordance with. art. 6 para. 1 lit. c. GDPR.
The data will be deleted if the data is no longer required for the fulfilment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are art. 6 para. 1 lit. c. GDPR, art. 6 para. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors.
The purpose and our interest in the processing lies in the administration, financial accounting, office organization, and archiving of data, thus tasks which serve the maintenance of our business activities, perception of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this majority of company-related data permanently.
Business analysis and market research
In order to operate our business economically, to recognize market trends, wishes of the contractors and users, we analyse the data available to us for business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata based on the nature 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analysis are carried out for the purpose of business analysis, marketing and market research. In doing so, we can provide the profiles of registered users with information, e.g. take into account their services. The analysis serve us to increase the user-friendliness, the optimization of our offer and the business economics. The analysis are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analysis.
If these analysis or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analysis and general trend provisions are created anonymously if possible.
We process the applicant’s data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant’s data takes place in order to fulfil our (pre-) contractual obligations in the context of the application process within the meaning of art. 6 para. 1 lit. b. GDPR art. 6 para. 1 lit. f. GDPR if the data processing e.g. is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).
Insofar as special categories of personal data within the meaning of art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with art. 9 (2) lit. b GDPR (e.g. health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).
If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us according to the state of the art.Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by post.
The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to at any time.
The deletion is subject to a legitimate revocation of the candidate, after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details for processing the contact enquiry and its processing is according to art. 6 para. 1 letter b. (in the context of contractual/pre-contractual relationships), art. 6 para. 1 lit. f. (other requests) GDPR; information can be stored in a customer relationship management system (“CRM System”) or similar organization.
We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send newsletters, e-mails, and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us.
Double opt-in and logging: Registration for our newsletter is done in a so-called double opt-in procedure. That means after registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with questionable e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.
Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.
The dispatch of the newsletter and the associated performance measurement are based on a consent of the recipients acc. art. 6 para. 1 lit. a, art. 7 GDPR in connection with § 7 Abs. 2 No. 3 UWG or if consent is not required, based on our legitimate interests in the direct marketing acc. art. 6 para. 1 lt. F. GDPR in connection with. § 7 Abs. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with. art. 6 para. 1 lit. f GDPR. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent.
Termination / Revocation – You may terminate the receipt of our newsletter at any time, therefore revoking your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter – CleverReach
The shipping service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of shipping and the presentation of newsletters or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties.
Newsletter – Success Measurement
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the server when opening the newsletter from our server, or if we use a shipping service provider. This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval.
This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters will be opened, when they will be opened and which links will be clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us mostly to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
A separate revocation of the performance measurement is unfortunately not possible, in this case, the entire newsletter subscription must be terminated.
Hosting and e-mailing
The hosting services we use are designed to provide the following services: we use infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services to operate this online service.
We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. art. 6 para. 1 lit. f GDPR in connection with. art. 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We or our hosting provider collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of art. 6 para. 1 lit. f. GDPR. The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and is then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google 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.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
The personal data of users will be deleted or anonymized after 14 months.
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users, and to inform them about our services.
We point out that data of the users outside the area of the European Union can be processed. This may result in risks for the users because, e.g., enforcement of user rights could be made more difficult. With respect to US providers certified under the Privacy Shield, we point out that they are committed to respecting EU privacy standards.
Furthermore, the data of the users are usually processed for market research and advertising purposes. Thus, e.g. user profiles are created from the user behaviour and the resulting interests of the users. The usage profiles can in turn be used to e.g. place advertisements inside and outside the platforms that are allegedly in line with users’ interests. For these purposes, cookies are usually stored on the computers of the users, in which the user behaviour and the interests of the users are stored. Furthermore, in the usage profiles, data can also be stored independently of the devices used by the users (in particular if the users are members of the respective platforms and logged in to them).
The processing of the personal data of users is based on our legitimate interests in an effective information of users and communication with users in accordance with. art. 6 para. 1 lit. f. GDPR. If the users are asked by the respective providers for a consent to the data processing (that is, they declare their agreement, for example, by ticking a check box or confirming a button), the legal basis of the processing is art. 6 para. a., art. 7 GDPR.
For a detailed description of the respective processing and the possibilities of revoking (opt-out), we refer to the following linked information of the provider.
Even in the case of requests for information and the assertion of user rights, we point out that these can be claimed most effectively from the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.
Integration of services and contents of third parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to provide their content and services, such as including videos or fonts (collectively referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring to web pages, visit time, and other information regarding the use of our online offer.