Privacy policy of PolePosition Solutions Ltd
Your data is safe with PolePosition. Strict compliance with the GDPR is guaranteed. All data is stored on ISO 27001-certified servers in Germany. All data is transmitted in encrypted form.
Thank you for your interest in our company. We take data protection seriously.
You can use our website without providing any personal data. If a data subject wishes to make use of our company's services via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we always obtain the consent of the data subject.
The processing of personal data (e.g. name, address, e-mail address or telephone number of a data subject) is always carried out in accordance with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to us.
With the following privacy policy, we would like to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. This privacy policy also informs data subjects about the rights to which they are entitled.
As the data controller, we have implemented numerous technical and organizational measures to ensure that the personal data processed via our website is protected as completely as possible. However, data transmissions over the Internet can generally contain security gaps. It is therefore not possible to guarantee 100% protection. Therefore, any data subject can of course also transmit personal data to us alternatively, e.g. by telephone.
1. Definition of Terms
This data protection declaration is based on the terms used by the European legislator for the adoption of the GDPR (Article 4 GDPR). This privacy policy should be both easy to read and easy to understand for everyone. To ensure this, we would first like to explain the terms used. Among other things, these definitions are used in this privacy policy
- "Personal data" any information relating to an identified or identifiable natural person (hereinafter referred to as "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;
- "Person concerned" any identified or identifiable natural person whose personal data are processed by the controller.
- "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, organization, 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" the marking of stored personal data with the aim of restricting its future processing;
•„Profiling“ jede Art der automatisierten Verarbeitung personenbezogener Daten, die darin besteht, dass diese personenbezogenen Daten verwendet werden, um bestimmte persönliche Aspekte, die sich auf eine natürliche Person beziehen, zu bewerten, insbesondere um Aspekte bezüglich Arbeitsleistung, wirtschaftliche Lage, Gesundheit, persönliche Vorlieben, Interessen, Zuverlässigkeit, Verhalten, Aufenthaltsort oder Ortswechsel dieser natürlichen Person zu analysieren oder vorherzusagen;
- "Responsible" 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;
- "Receiver" 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" 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 authorized to process personal data;
- "Consent" 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.
2. Name and Contact details of the controller
This data protection information applies to data processing by:
Responsible: PolePosition Solutions GmbH, represented by the data protection officer Mr. Giorgi Devrisashvili, eMail: [email protected].
3. Collection and storage of personal data and the nature and purpose of their use
a) When you visit the website
You can use our website without disclosing your identity. When you visit our website, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected without any action on your part and stored until it is automatically deleted:
- IP address of the requesting computer,
- The date and time of access,
- Name and URL of the retrieved file,
- Website from which access is made (referrer URL),
- The browser used and, if applicable, the operating system of your computer and the name of your access provider.
We process the aforementioned data for the following purposes:
- Ensuring a smooth connection to the website,
- To ensure a comfortable use of our website,
- Evaluation of system security and stability and
- For other administrative purposes.
The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above. Under no circumstances do we use the data collected for the purpose of drawing conclusions about your person.
We also use cookies and analysis services when you visit our website. You can find more detailed explanations in sections 5 and 7 of this privacy policy.
b) When you use our contact form
For questions of any kind, we offer you the opportunity to contact us via a form provided on our website. It is necessary to provide a valid e-mail address, your gender, first name and surname so that we know who sent the request and can answer it. Further information can be provided voluntarily. You are free to decide whether you wish to enter this data in the contact form.
Data processing for the purpose of contacting us is carried out in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntarily given consent.
The personal data collected by us for the use of the contact form will be automatically deleted after your request has been dealt with.
c) For orders via our website
Orders can only be placed via our website by registering as a customer in the store. Registration has the advantage for you that you can log in to our store directly with your e-mail address and password in the event of a future order without having to enter your contact details again.
Your personal data is entered into an input mask and transmitted to us and stored. If you place an order via our website, the following data is initially collected when you register in the store:
- Title, first name, last name,
- A valid e-mail address,
- Phone number (landline and/or mobile),
- Customer / company name,
- Type of company,
- Type of customer / company,
- Address,
- VAT ID no., if applicable
This data is collected,
- To be able to identify you as our customer;
- In order to process, fulfill and process your order;
- For correspondence with you;
- For invoicing purposes;
- For the settlement of any existing liability claims and the assertion of any claims against you;
- To ensure the technical administration of our website;
- In order to manage our customer data.
Your consent to the processing of this data is obtained as part of the ordering process.
The data processing takes place in response to your order and/or registration and is required in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR for the purposes mentioned for the appropriate processing of your order and for the mutual fulfillment of obligations arising from the purchase contract.
The personal data collected by us for the processing of your order will be stored until the expiry of the statutory retention obligation and then deleted, unless we are obliged to store it for a longer period of time in accordance with Article 6 para. 1 sentence 1 lit. c GDPR due to tax and commercial law storage and documentation obligations (from HGB, StGB or AO) or you have consented to further storage in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.
4. Transfer of data
Your personal data will only be passed on by us to third parties to the service partners involved in the processing of the contract, such as the credit institution commissioned with payment matters. However, in cases where your personal data is passed on to third parties, the scope of the data transmitted is limited to the minimum necessary.
Bei Zahlung via PayPal, Kreditkarte via PayPal, Lastschrift via PayPal oder “Kauf auf Rechnung” via PayPal geben wir Ihre Zahlungsdaten im Rahmen der Zahlungsabwicklung an die PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (im Folgenden “PayPal”), weiter. PayPal behält sich für die Zahlungsarten Kreditkarte via PayPal, Lastschrift via PayPal oder “Kauf auf Rechnung” via PayPal die Durchführung einer Bonitätsauskunft vor. Das Ergebnis der Bonitätsprüfung in Bezug auf die statistische Zahlungsausfallwahrscheinlichkeit verwendet PayPal zum Zwecke der Entscheidung über die Bereitstellung der jeweiligen Zahlungsart. Die Bonitätsauskunft kann Wahrscheinlichkeitswerte enthalten (sog. Score-Werte). Soweit Score-Werte in das Ergebnis der Bonitätsauskunft einfließen, haben diese ihre Grundlage in einem wissenschaftlich anerkannten mathematisch-statistischen Verfahren. In die Berechnung der Score-Werte fließen unter anderem Anschriftendaten ein. Weitere datenschutzrechtliche Informationen können Sie den PayPal Datenschutzgrundsätzen entnehmen: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
Your personal data will not be transferred to third parties for purposes other than those mentioned above.
We also only pass on your personal data to third parties if:
- you have given your express consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR,
- the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
- in the event that there is a legal obligation for disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR, and
- this is legally permissible and necessary for the processing of contractual relationships with you in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.
As part of the ordering process, your consent is obtained for your data to be passed on to third parties.
5. Use of cookies
We use cookies on our website. These are small files that your browser automatically creates and that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not cause any damage to your end device and do not contain any viruses, Trojans or other malware.
Information is stored in the cookie that results in each case in connection with the specific end device used. However, this does not mean that we obtain direct knowledge of your identity.
On the one hand, the use of cookies serves to make the use of our website more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your end device for a specified period of time. If you visit our site again to make use of our services, it is automatically recognized that you have already visited us and which entries and settings you have made so that you do not have to enter them again.
On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you (see section 7). These cookies enable us to automatically recognize that you have already visited our website when you visit it again. These cookies are automatically deleted after a defined period of time.
The data processed by cookies is required for the purposes mentioned to protect our legitimate interests and those of third parties in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR.
Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, completely deactivating cookies may mean that you cannot use all the functions of our website.
6. Links to third party websites
The links published on our website have been researched and compiled by us with the greatest possible care. However, we have no influence on the current and future design and content of the linked pages. We are not responsible for the content of the linked pages and expressly do not adopt the content of these pages as our own. The provider of the linked website is solely liable for illegal, incorrect or incomplete content and for damages resulting from the use or non-use of the information. The liability of those who merely refer to the publication via a link is excluded. We are only responsible for external references if we have positive knowledge of them, i.e. also of any illegal or punishable content, and if it is technically possible and reasonable for us to prevent their use.
7. Analysis and tracking tools
The tracking measures listed below and used by us are carried out on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR. With the tracking measures used, we want to ensure a needs-based design and the continuous optimization of our website. On the other hand, we use the tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision.
The respective data processing purposes and data categories can be found in the corresponding tracking tools.
a) Google Analytics
Zum Zwecke der bedarfsgerechten Gestaltung und fortlaufenden Optimierung unserer Seiten nutzen wir Google Analytics, ein Webanalysedienst der Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; im Folgenden „Google“). In diesem Zusammenhang werden pseudonymisierte Nutzungsprofile erstellt und Cookies (siehe unter Ziffer 5) verwendet. Die durch den Cookie erzeugten Informationen über Ihre Benutzung dieser Website wie
- Browser type/version,
- The operating system used,
- Referrer URL (the previously visited page),
- Host name of the accessing computer (IP address),
- Time of the server request,
are transmitted to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage for the purposes of market research and the needs-based design of this website. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that they cannot be assigned (IP masking).
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).
As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on the aforementioned link. An opt-out cookie will be set to prevent the future collection of your data when you visit our website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.
Further information on data protection in connection with Google Analytics can be found under the following link in the Google Analytics Help: https://support.google.com/analytics/answer/6004245?hl=de
b) Google Adwords Conversion Tracking
We also use Google Conversion Tracking to statistically record the use of our website and to evaluate it for the purpose of optimizing our website for you. Google Adwords places a cookie (see section 5) on your computer if you have reached our website via a Google ad.
These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer's website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page.
Each Adwords customer receives a different cookie. Cookies can therefore not be tracked via the websites of Adwords customers. The information collected using the conversion cookie is used to generate conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers find out the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.
If you do not wish to participate in the tracking process, you can also reject the setting of a cookie required for this - for example, by using a browser setting that generally deactivates the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting your browser to block cookies from the domain "www.googleadservices.com". Google's privacy policy on conversion tracking can be found at the following link: https://services.google.com/sitestats/de.html
c) Cloudflare
We use the Content Delivery Network (CDN) of Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich, Germany (Cloudflare) to enhance the security and delivery speed of our website. This is in line with our legitimate interests (Art. 6 para. 1 lit. f GDPR). A CDN is a network of distributed servers capable of delivering optimized content to website users. For this purpose, personal data may be processed in server log files by Cloudflare. Please refer to the details under “Hosting.”
Cloudflare ist Empfänger Ihrer personenbezogenen Daten und als Auftragsverarbeiter für uns tätig. Die entspricht unserem berechtigten Interesse im Sinne des Art. 6 Abs. 1 S. 1 lit. f DSGVO, selbst kein Content Delivery Network zu betreiben.
Cloudflare is the recipient of your personal data and acts as a processor on our behalf. This aligns with our legitimate interest under Art. 6 para. 1 sentence 1 lit. f GDPR, as we do not operate our own content delivery network.
You have the right to object to the processing of your data. Whether the objection is successful will be determined as part of a balancing of interests.
Your personal data will be stored by Cloudflare for as long as it is necessary for the purposes described.
Further information on objection and deletion options with respect to Cloudflare can be found at: Cloudflare DPA.
Cloudflare has implemented compliance measures for international data transfers. These measures apply to all global activities where Cloudflare processes personal data of individuals in the EU. They are based on the EU Standard Contractual Clauses (SCCs). For more information, please visit: [https://www.cloudflare.com/cloudflare_customer_SCCs-German.pdf](https://www.cloudflare.com/cloudflare_customer_SCCs-German.pdf)
d) jQuery
This website uses jQuery Migrate to ensure the stability of jQuery technologies. For this purpose, program libraries are loaded from the jQuery Foundation servers, using Google’s Content Delivery Network (CDN). If you have previously used jQuery Migrate from another website via the Google CDN, your browser will access the locally stored copy from the cache. Otherwise, the file will be downloaded again, which requires a connection between your browser and the jQuery Foundation servers (“jQuery.org”). This notifies the jQuery Foundation that our website was accessed via your IP address. The use of code.jquery.com and jQuery Migrate is intended to optimize the loading speed of our online offerings and serves our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.
Further information about jQuery can be found at [https://code.jquery.com/](https://code.jquery.com/). The code of conduct of the jQuery Foundation can be viewed at [https://js.foundation/community/code-of-conduct](https://js.foundation/community/code-of-conduct).
8. Social Media Plugins
We use social plugins of social networks (e.g. Facebook, Twitter, Google+) on our website on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR in order to make our company better known. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of the GDPR. Responsibility for data protection-compliant operation must be guaranteed by the respective provider. We integrate these plugins using the so-called two-click method to protect visitors to our website in the best possible way.
9. Rights of the data subject
You have the right:
- to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of appeal, the origin of your data if it was not collected by me, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information on its details;
- in accordance with Art. 16 GDPR, to immediately request the correction of incorrect or incomplete personal data stored by us;
- in accordance with Art. 17 GDPR, to demand the deletion of your personal data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
- in accordance with Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR;
- in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller
- in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given to us at any time. As a result, we may no longer continue the data processing that was based on this consent in the future and
- to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.
10. Right of objection
If your personal data is processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation.
If you would like to exercise your right of revocation or objection, simply send an e-mail to: [email protected]
11. Data Security
We use the widespread SSL (Secure Socket Layer) method in conjunction with the highest level of encryption supported by your browser when you visit our website. As a rule, this is 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can tell whether an individual page of our website is transmitted in encrypted form by the closed display of the key or lock symbol in the lower status bar of your browser.
We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.
12. Up-to-dateness and amendment of this privacy policy
This privacy policy is currently valid and is dated June 2024.
Due to the further development of our website and offers on it or due to changed legal or official requirements, it may become necessary to change this privacy policy. The current privacy policy can be accessed and printed out at any time on our website under the following link:
https://PolePositionSolutions.de/Datenschutz