With the following data protection declaration, we would like to explain to you which types of your personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer” ).
The terms used are not gender specific.
As of March 8, 2020
betubed packaging GmbH
Borsteler Chaussee 85 - 99a / Haus 7
22453
Hamburg
Persons authorized to represent: Stefan Thiel
E-Mail-Adresse: info@betubed.de
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
In the following we inform you about the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.
National data protection regulations in Germany : In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the law on the protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Shortening of the IP address: : If it is possible for us or if it is not necessary to store the IP address, we will shorten your IP address or have it shortened. If the IP address is shortened, also referred to as “IP masking”, the last octet, ie the last two digits of an IP address, is deleted (the IP address in this context is an Internet connection through the online access provider individually assigned identifier). The purpose of shortening the IP address is to prevent or make it much more difficult to identify a person based on their IP address.
SSL encryption (https): : In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data can include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing within the framework of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies takes place, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or pass the data in third countries with a recognized level of data protection, which includes the US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligations so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Cookies are text files containing data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit to an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the place where a video was viewed. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
The following cookie types and functions are distinguished:
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies ( collectively referred to as “opt-out”). You can initially declare your objection using the settings in your browser, e.g. by deactivating the use of cookies (which can also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info und https://www.youronlinechoices.com/ will. In addition, you can receive further objection notices as part of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: : Before we process or have data processed as part of the use of cookies, we ask users to give their consent, which can be revoked at any time. Before consent has not been given, cookies that are necessary for the operation of our online offer will be used. They are used on the basis of our interest and the interest of the user in the expected functionality of our online offer.
We process the data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships and related measures and within the framework of communication with the contractual partners (or pre-contractual), e.g respond.
We process this data to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information and the corporate organization. We only pass on the data of the contractual partners to third parties within the framework of the applicable law to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the contractual partners (e.g. to telecommunications, transport and other auxiliary services involved as well as subcontractors , banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contracting parties which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after statutory warranty and comparable obligations have expired, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. for as long as it has to be kept for legal archiving reasons (e.g. for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Customer account : Contractual partners can create an account within our online offer (e.g. customer or user account, “customer account” for short). If it is necessary to register a customer account, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent registrations and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the customer’s responsibility to back up their data upon termination of the customer account.
Shop and e-commerce : We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution.
The required information is marked as such in the context of the ordering or comparable acquisition process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.
As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service provider includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information with confirmation or negative information about the payment. Under certain circumstances, the payment service provider may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this we refer to the terms and conditions and the data protection information of the payment service provider.
The terms and conditions and data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to this for the purpose of further information and the assertion of revocation, information and other data subject rights.
Services and service providers used:
In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.
Collection of access data and log files : We ourselves (or our web hosting provider) collect data for each access to the server (so-called server log files). The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong.
The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilization and stability.
Services and service providers used:
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. Our newsletter also contains information about our services and us.
In order to register for our newsletters, it is generally sufficient if you enter your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else’s e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blocking list (so-called “blacklist”) solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Notes on the legal basis: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising for existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.
Content : Information about us, our services, promotions and offers.
measurement of success: The newsletters contain a so-called “web beacon”, ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. Technical information is initially collected as part of this retrieval , such as information about the browser and your system, as well as your IP address and the time of retrieval.
This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider to monitor individual users. Rather, the evaluations serve us 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.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system, which serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the performance measurement is not possible. In this case, the entire newsletter subscription must be canceled or objected to.
Services and service providers used:
We process personal data for the purpose of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke their consent at any time or to object to advertising communication at any time.
After revocation or objection, we can store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete them. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.
The web analysis (also referred to as “reach measurement”) serves to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, identify the time at which our online offer or its functions or content are used most frequently or invite users to reuse them. We can also understand which areas need optimization.
In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offering or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar processes can be used for the same purpose. This information can include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this can also be processed depending on the provider.
The IP addresses of the users are also saved. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
Services and service providers used:
We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar processes are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information can include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the users are also saved. However, we use available IP masking procedures (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) are stored as part of the online marketing process, but pseudonyms. This means that we and the providers of the online marketing process do not know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar processes. These cookies can later generally also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
As an exception, plain data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network connects the user’s profile with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie to a contract with us, for example. The conversion measurement is only used to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
Target group building with Google Analytics: We use Google Analytics to display the ads placed within the advertising services of Google and its partners only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products that are based on the visited website). websites are determined), which we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interests of users
Facebook pixel: With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel so that the Facebook ads placed by us are only available to users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network”). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).
Extended comparison for the Facebook pixel: When using the Facebook pixel, the additional function “extended comparison” is used. In this context, data such as user e-mail addresses or Facebook IDs are transmitted (encrypted) to Facebook to form target groups.
Facebook – Target group education via data upload: uploading data such as telephone numbers, email addresses or Facebook IDs to the Facebook platform. The data is encrypted here. The upload process only serves to display advertisements to the owners of the data or persons whose user profiles correspond to any user profiles of the owners of the data on Facebook. We want to ensure that the ads are only displayed to users who are interested in our information and services.
Services and service providers used:
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
We would like to point out that user data can be processed outside of the European Union. This can result in risks for the user because, for example, the enforcement of the user’s rights could be made more difficult. With regard to US providers who are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they undertake to comply with the data protection standards of the EU.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the user. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the possibility of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Services and service providers used:
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known 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 can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and the operating system, websites to be referred to, the time of the visit and other information on the use of our online offer and can also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
Services and service providers used:
The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).
If the data is not deleted because it is required for other, legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be provided in the context of the individual data protection information in this data protection declaration.
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.
As a data subject, you have various rights under the GDPR, which result in particular from Articles 15 to 18 and 21 GDPR:
This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.