Privacy policy

Digit. 1: Data processor and data protection officer; scope of application

Digit. 2: General policies on the processing of your personal data

Digit. 3: Log data and cookies when using our WEBSITE

Digit. 4: Further functions and offers (contact, newsletter, contact form)

Digit. 5: Statistics and marketing tools (etracker, LeadLab, Matomo)

Digit. 6: Third-party content (Monotype web fonts, YouTube)

Digit. 7: Data protection

Digit. 8: Your rights

Digit. 9: Amendment of this privacy policy

1. DATA PROCESSOR AND DATA PROTECTION OFFICER; SCOPE OF APPLICATION

(1) We, RAFI GmbH & Co. KG, Ravensburger Straße 128-134, 88276 Berg / Ravensburg, Germany, Phone: +49 751 89-0, Fax: +49 751 89-1300, Email: info.headquarters@rafi-group.com, are the operator of the web pages, accessible at www.rafi-group.com, www.kisme.com and www.rafi-schulungszentrum.de (hereinafter also “WEBSITE”), and controller of the processing of personal data of you as a user of our WEBSITE pursuant to. Art. 4 No. 7 of the EU General Data Protection Regulation (“GDPR”). If you are an applicant or intern/trainee, we will also inform you about the handling of your personal data in our area specially set up for applicants.

(2) Our external data protection officer is Mr. Ioannis Dimas, c/o ETES GmbH, Talstraße 106, 70188 Stuttgart, Germany, Email: datenschutz@rafi-group.com.

(3) In the following, we would like to inform you in detail about the processing of your personal data when visiting our WEBSITE and using our other offers and functions (hereinafter also referred to as “services”) on our WEBSITE as part of our duty to inform you. Furthermore, we would like to inform you about the accompanying protective measures that we have also taken in technical and organizational terms on our WEBSITE, as well as your rights with regard to the processing of personal data concerning you.

(4) We have included links to third-party websites on our WEBSITE. This privacy policy does not regulate the processing of personal data on these third-party websites. We recommend that you read the privacy notices on the external websites you visit that we link to.

2. GENERAL PRINCIPLES FOR THE PROCESSING OF YOUR PERSONAL DATA

(1) Personal data means any information relating to an identified or identifiable natural person. Your personal data therefore includes all data that can be directly or indirectly assigned to your person, such as, for example. Your name, address, phone number or email address.

(2) Personal data shall be processed by us primarily only if and to the extent that

– you have given us your consent to the processing of data for one or more specific purposes (Art. 6 para. 1 UAbs. 1 letter a DSGVO), or

– processing is necessary for the performance of a contract to which you are a party or for the implementation of pre-contractual measures taken at your request (Art. 6 para. 1 UAbs. 1 letter b DSGVO), or

– the data processing is necessary for compliance with a legal obligation to which we are subject (Art. 6 para. 1 UAbs. 1 letter c DSGVO), or

– the data processing is necessary for the protection of our legitimate interests or those of a third party, unless your interests or fundamental rights and freedoms requiring the protection of personal data override (Art. 6 para. 1 UAbs. 1 lit. f DSGVO).

(3) On which of the in par. 2 or other legal bases on which we base the processing of your personal data in individual cases are set out in the following provisions of this data protection declaration.

(4) In some cases, we use external service providers to process your data. They have been carefully selected and commissioned by us, are bound by our instructions and are regularly inspected. Furthermore, we may pass on your personal data to third parties if contract conclusions or similar services are offered by us together with partners. You will receive more detailed information on this when you provide your personal data or in the following regulations of this data protection declaration. If our service providers or partners are located in a country outside the European Economic Area (EEA), we will also inform you about the consequences of this circumstance in the following provisions of this privacy policy.

3. LOG DATA AND COOKIES WHEN USING OUR WEBSITE

3.1 Log data

(1) In connection with the use of our WEBSITE, we collect those of your data that your Internet browser automatically transmits to our server. The following data is collected:

– IP address of the network access device of the respective requesting computer

– Date and time of the request (made in GMT)

– Time zone difference from Greenwich Mean Time (GMT)

– Content of the request (concrete page)

– Access status/HTTP status code

– Data volume transferred in each case

– Website from which the request comes

– Browser

– Operating system and its interface

– Language and version of the browser software.

(2) This data is technically necessary for us to enable you to use and function our WEBSITE, in particular to display the WEBSITE and to ensure the security and stability of the WEBSITE. A linkage of these data with personal data of a certain natural person does not take place. In a functioning WEBSITE lies our legitimate interest. The legal basis is Art. 6 para. 1 UAbs. 1 letter f DSGVO.

(3) We delete this data as soon as it is no longer required to achieve the purpose for which it was collected. Your IP address is stored for up to seven days in full, and then in anonymized form. In the process, your IP address is shortened by the last octet (or a corresponding subsegment in the case of IPv6). The temporary storage of the IP address by our system is necessary in order to eliminate malfunctions of our WEBSITE as well as to avert dangers. Otherwise, the deletion takes place when the respective session has ended.

3.2 Cookies

In addition to the previously mentioned data, cookies are stored on your computer when you use our WEBSITE. For more information on the cookies we use, please see our Cookie Directive on https://kisme.com/en/cookie-directive-eu/. We inform you about the statistical and marketing tools we use on our WEBSITE that use cookies in Ziff. 5 of this privacy policy.

3.2 Complianz

(1) This website uses Complianz’s Privacy Suite for WordPress to collect and record browser- and device-based consent. For this function, your IP address is anonymized and stored in our database. This service does not process any personally identifiable information and does not share any data with the service provider. For more information, please see the Complianz Privacy Policy.

3.3 WPML

(1) WPML uses cookies to determine the visitor’s current language, the last visited language and the language of users who have logged in.

While you are using the plugin, WPML will share the data regarding the page via the installer. No data is shared by the user himself.

4. OTHER FUNCTIONS AND OFFERS

In connection with various services on our WEBSITE, which you can use if you are interested, you usually have to provide additional personal data. In detail:

4.1 Ordering brochures and contact / feedback

(1) If you contact us, e.g. when ordering our printed flyers, brochures and/or catalogs or to inform us of your request, the processing of your voluntarily provided contact data (e.g. first and last name, address, telephone number, fax, e-mail address, etc.) is carried out to answer your inquiries and/or suggestions made via the contact form, by e-mail or in any other way. The processing of your data serves exclusively to process the contact as well as to prevent misuse and to ensure the security of our information technology systems.

(2) The legal basis for the processing of the data is Art. 6 para. 1 UAbs. 1 letter f DSGVO. If your message aims at the conclusion of a contract, the additional legal basis for the processing of your data is Art. 6 para. 1 UAbs. 1 letter b DSGVO.

(3) Insofar as no legal retention periods prevent the deletion of your personal data, we will delete it as soon as it is no longer required to achieve the purpose for which it was collected.

4.2 Ordering our newsletters

(1) With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers and activities. The advertised offers and activities are named in the consent form.

(2) The newsletter is sent via the technical service provider CleverReach GmbH & Co. KG (Mühlenstraße 43, 26180 Rastede, Germany; “CleverReach”). For this purpose, it is necessary that we transmit your data provided in the context of the newsletter registration to CleverReach. This data is stored on CleverReach’s servers in Germany or Ireland. For more information on data protection, please see CleverReach’s privacy policy at: www.cleverreach.com/de/datenschutz/.

(3) For the registration to our newsletter we use the so-called double-opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. Darüber hinaus speichern wir jeweils Ihre eingesetzten IP-Adressen und Zeitpunkte der Anmeldung und Bestätigung. The purposes of the procedure are to be able to prove your registration and, if necessary, to clarify or assist in the clarification of a possible misuse of your personal data.

(4) The only mandatory information for sending the newsletter is your e-mail address. The provision of further, separately marked data is voluntary and will be used to address you personally. After your confirmation, we store your e-mail address for the purpose of sending you the newsletter. The legal basis is Art. 6 para. 1 UAbs. 1 letter a DSGVO.

(5) You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You may revoke by clicking on the link provided in each newsletter e-mail, by sending an e-mail to info.headquarters@rafi-group.com or by sending a message to the address specified in para. 1 contact details provided. You can also unsubscribe at any time via this link here.

(6) We delete your data as soon as it is no longer required to achieve the purpose for which it was collected, your e-mail address becomes unreachable or if you revoke your declaration of consent to receive newsletters. Accordingly, your data will be stored as long as the subscription to the newsletter is active.

4.3 Contact form

(1) If you wish to send us an inquiry or message (e.g. about our products) via our contact forms, the processing of your voluntarily provided contact data (e.g. first and last name, address, telephone number, fax, e-mail address, etc.) is carried out for the purpose of processing and responding to your message sent via the contact form. For a pure contact request or the request for information material, your e-mail address is sufficient. If you request a quotation, it is necessary that you provide us with further data required for the preparation of the quotation.

(2) The legal basis is Art. 6 para. 1 UAbs. 1 letter f DSGVO. If your message aims at the conclusion of a contract (for example, because you wish to receive an offer), the additional legal basis for the processing of your data is Art. 6 para. 1 UAbs. 1 letter b DSGVO.

(3) We may also process the data you provide to inform you about other interesting offers or to send you e-mails with technical information. The legal basis for this is Art. 6 para. 1 UAbs. 1 letter f DSGVO.

(4) Insofar as no legal retention periods prevent the deletion of your personal data, we will delete it as soon as it is no longer required to achieve the purpose for which it was collected.

5. STATISTICAL AND MARKETING TOOLS

5.1 Etracker

(1) Our WEBSITE uses the web analytics service etracker provided by etracker GmbH (Erste Brunnenstraße 1, 20459 Hamburg, Germany; “etracker”) to analyze and regularly improve the use of our WEBSITE.

(2) For this purpose, we do not use cookies by default. Insofar as we use analysis and optimization cookies, we obtain your explicit consent separately in advance. If this is the case and you agree, cookies will be used, which allow statistical analysis of the use of the application. Cookies are small text files that are stored by the Internet browser on the user’s terminal device. etracker cookies do not contain any information that allows identification of a user.

(3) The data generated with etracker is processed and stored exclusively in Germany and is thus subject to strict German and European data protection laws and standards. etracker has been independently audited and certified in this regard and awarded the ePrivacyseal data protection seal of approval.

(4) If you consent to the analysis and optimization cookies, the processing is based on this consent pursuant to. Art. 6 par. 1 UAbs. 1 letter a DSGVO. You can revoke this at any time with effect for the future, e.g. via the buttons “Change your consent” or “Revoke your consent” in our cookie declaration [https://www .rafi-group.com/cookieerklaerung /]

(5) Furthermore, the data processing is carried out on the basis of our legitimate interest pursuant to Art. 6 par.1 UAbs. 1 letter f DSGVO . Our legitimate interest is the optimization of our WEBSITE to improve our offer and to make it more interesting for you as a user. Since the privacy of our customers is important to us, data that may allow a reference to an individual person, such as the IP address, login or device identifiers, are anonymized or pseudonymized as soon as possible. No other use, combination with other data or disclosure to third parties will take place.

(6) Further information on data protection at etracker can be found here .

You may object to the aforementioned data processing based on our legitimate interest at any time. The objection has no adverse consequences.

Disable tracking

5.2 Leadlab

Our website uses the pixel-counting technology of WiredMinds GmbH (www.wiredminds.de) to analyze visitor behavior. Here, the IP address of a visitor is processed. The processing takes place exclusively for the purpose of collecting company-relevant information such as the company name. IP addresses of natural persons are excluded from further use (whitelist procedure). The IP address is not stored in LeadLab under any circumstances. When processing data, it is our particular interest to safeguard the data protection rights of natural persons. Our interest is based on Art. 6 para. 1 lit. (f) GDPR. At no time does the data we collect allow us to draw conclusions about an identifiable person.

WiredMinds GmbH uses this information to compile anonymous usage profiles relating to visitor behavior on our website. The data obtained in this process is not used to personally identify the visitor to our website.

Exclude from tracking (To exclude you permanently from tracking by WiredMinds LeadLab on this website, a technically necessary cookie is set).

5.3 Matomo

(1) Our WEBSITE uses the web analytics service Matomo of matomo.org to analyze and regularly improve the use of our WEBSITE.

(2) For this purpose, we do not use cookies by default. Insofar as we use analysis and optimization cookies, we obtain your explicit consent separately in advance. If this is the case and you agree, cookies will be used, which allow statistical analysis of the use of the application. Cookies are small text files that are stored by the Internet browser on the user’s terminal device. Cookies do not contain information that allows identification of a user.

(3) The data generated with Matomo is processed and stored exclusively in Germany and is thus subject to strict German and European data protection laws and standards.

(4) If you consent to the analysis and optimization cookies, the processing is based on this consent pursuant to. Art. 6 par. 1 UAbs. 1 letter a DSGVO. You can revoke this at any time with effect for the future, e.g. via the buttons “Change your consent” or “Revoke your consent” in our cookie declaration https://kisme.com/en/cookie-directive-eu/.

(5) Furthermore, the data processing is carried out on the basis of our legitimate interest pursuant to Art. 6 par.1 UAbs. 1 letter f DSGVO . Our legitimate interest is the optimization of our WEBSITE to improve our offer and to make it more interesting for you as a user. Since the privacy of our customers is important to us, data that may allow a reference to an individual person, such as the IP address, login or device identifiers, are anonymized or pseudonymized as soon as possible. No other use, combination with other data or disclosure to third parties will take place.

You can object to the mandatory data processing based on our legitimate interest at any time. The objection has no adverse consequences.

Disable tracking

6. THIRD PARTY CONTENT

6.1 Web Fonts from Monotype

(1) Our WEBSITE uses so-called web fonts of the provider Monotype Inc, Monotype, 600 Unicorn Park Drive, Woburn, MA 01801, USA (“Monotype”) for the uniform display of fonts.

(2) The tracking code of the web fonts does not collect, process or store any personal data. When you access our WEBSITE, Monotype collects the project identification number of the web font (anonymized), the URL of the licensed website linked to a customer number to identify the licensee and the licensed web fonts, and the URL of the previously visited page.

(3) Monotype will store the anonymized project identification number of the Web Fonts in encrypted log files containing such data for a period of 30 days to determine the monthly number of page views. After such determination and storage of the number of page views, the log files are deleted.

(4) Monotype shares anonymized data with subsidiaries and affiliates.

(5) For more information on this and Monotype, please see Monotype’s Privacy Policy: https://www.monotype.com/de/rechtshinweise/datenschutzrichtlinie/datenschutzrichtlinie-zum-tracking-von-webschriften

6.2 Youtube

(1) We have integrated videos from YouTube, a service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”), into our online offering. www.YouTube.com and are playable from our WEBSITE, provided that you give us your prior consent to do so via our cookie banner. We have no influence on this data transmission. Alternatively, you can click on the link “to YouTube” next to the respective video to go directly to the YouTube website and watch the video there. In this case, Google’s privacy policy for YouTube applies, which you can find on YouTube’s website.

2) If you play YouTube videos on our WEBSITE, YouTube receives the information that you have accessed the corresponding subpage of our WEBSITE. In addition, the provisions set out under para. 3.1 of this statement and cookies are used to collect information about user behavior. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data is directly assigned to your account. If you do not want the assignment with your profile at YouTube, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation is carried out in particular (even for users who are not logged in) for the provision of tailored advertising and to inform other users of the social network about your activities on our WEBSITE. You have the right to object to the creation of these user profiles, and you must contact YouTube to exercise this right.

3) Legal basis for the use of YouTube on our WEBSITE is your consent according to. Art. 6 par. 1 UAbs. 1 letter a DSGVO. You can revoke your consent at any time with effect for the future, e.g. via the buttons “Change your consent” or “Revoke your consent” in our cookie declaration https://kisme.com/en/cookie-directive-eu/ widerrufen.

4) In the context of the use of YouTube, it can furthermore not be excluded that a transmission of personal data to the servers of Google LLC in the USA occurs. The legal basis for the transfer of your personal data to the USA is your consent pursuant to Art. 49 para. 1 UAbs. 1 letter a GDPR. Please note that you are at risk for such transfers of personal data without the existence of an adequacy decision by the European Commission and without appropriate safeguards. In particular, government agencies in the U.S. may be able to gain access to your information without effective remedies. Information on the handling of your data by the US authorities is also only possible to a very limited extent, if at all. Accordingly, a level of data protection in accordance with the requirements of the GDPR cannot be guaranteed.

5) For more information on the purpose and scope of data collection and processing by YouTube, please see Google’s privacy policy. There you will also receive further information about your rights and setting options to protect your privacy: www.google.de/intl/de/policies/privacy

7. DATA SECURITY

(1) We use technical and organizational security measures to protect personal data that is generated or collected, in particular against accidental or intentional manipulation, loss, destruction or against attack by unauthorized persons. Our security measures are continuously improved in line with technological developments.

(2) Our WEBSITE is encrypted using SSL technology to prevent access by unauthorized third parties. You can recognize secure transmission by the protocol designation “https://” in the URL line.

8. YOUR RIGHTS

(1) With regard to the processing of personal data concerning you, you are entitled to the rights listed below under letters a – h under the statutory conditions. Please contact us or our data protection officer for this purpose. The contact details can be found under no. 1.

a) Right to information

You can request from us acc. Article 15 GDPR request confirmation as to whether personal data concerning you is being processed by us. In this case you have according to. Art. 15 par. 1 GDPR a right to information about the processing purposes, the categories of personal data processed, the recipients or categories of recipients to whom we have disclosed or will disclose the personal data, the planned storage period or criteria for determining the storage period, the existence of a right to rectification or erasure as well as to restriction of processing or objection to processing, the existence of a right of appeal to a supervisory authority. the criteria for determining the storage period, the existence of a right to rectification or erasure of your personal data as well as to restriction of processing or objection to processing, the existence of a right to lodge a complaint with a supervisory authority, the origin of the data if we have not collected your data from you, the existence of automated decision-making, including profiling, as well as, pursuant to Art. Art. 15 par. 2 GDPR the right to be informed about the appropriate safeguards pursuant to. Art. 46 GDPR in the context of the transfer of personal data to third countries.

b) Right to rectification

You can request from us acc. Art. 16 GDPR the immediate correction and/or, taking into account the purposes of the processing, the completion of your personal data, if your data are inaccurate or incomplete.
c) Right to deletion

You can request from us acc. Art. 17 GDPR demand the immediate deletion of your personal data, provided that there is a reason according to Art. 17 para. 1 letters a-f GDPR is present. However, the right to erasure of your personal data does not exist, in particular, insofar as its processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims (Article 17 (3) GDPR).

d) Right to restriction of processing

You may request us to restrict the processing of your personal data pursuant to. Art. 18 GDPR as long as we verify the accuracy of your data that you dispute, if you refuse the erasure of your data due to unlawful processing and instead request the restriction of the use of your data, if you need your data for the assertion, exercise or defense of legal claims, or if you have objected to the processing as long as it is not yet clear whether our legitimate grounds prevail.

e) Right to information

We share acc. Art. 19 GDPR to all recipients to whom your personal data have been disclosed, any rectification or erasure of your personal data or restriction of their processing pursuant to Art. 16, 17 para. 1 and 18 GDPR, unless this proves impossible or involves a disproportionate effort. You are entitled to the following pursuant to Art. 19 S. 2 GDPR, you have the right to be informed about these recipients upon request.

f) Right to data portability

You have according to. Art. 20 GDPR the right to receive your personal data that you have provided to us in a structured, common and machine-readable format and to transfer this data to another controller, provided that the further requirements of Art. 20 GDPR are met, in particular that this is technically feasible.

g) Right of objection

Insofar as we base the processing of your personal data on the balance of interests pursuant to Art. 6 para. 1 UAbs. 1 letter f GDPR, you have the right to withdraw your consent in accordance with. Art. 21 GDPR to object to the processing. This is the case if the processing is not necessary, in particular, for the performance of a contract with you, which is presented by us in each case in the above description of the offers. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the merits of the case and, in accordance with §§ 3 and 4 of the German Civil Code (BGB), we will notify you accordingly. Art. 21 par. 1 p. 2 GDPR either no longer process the personal data or demonstrate to you our compelling legitimate grounds for processing which override your interests, rights and freedoms. Further processing is also reserved if the processing serves the assertion, exercise or defense of legal claims.

Of course, you can use acc. Art. 21 par. 2 GDPR to the processing of your personal data for purposes of advertising and profiling, insofar as it is related to direct marketing, at any time.

You can notify us or our data protection officer of your objection at the addresses listed in para. 1 mentioned contact details.

h) Right to withdraw consent

You have according to. Art. 7 par. 3 GDPR, you have the right to revoke any data protection consent you may have given us at any time with effect for the future. However, this does not affect the lawfulness of the processing that took place on the basis of your consent up to the time of revocation.

(2) If you are of the opinion that the processing of your data violates the provisions of data protection law, you also have the right to lodge a complaint with a supervisory authority in accordance with §§ 3 and 4 of the Data Protection Act. Article 77 of the GDPR. Please contact a supervisory authority in the member state of your residence, workplace or the location of the potential infringement. An overview can be found here, among other places: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

9. AMENDMENT OF THESE DATA PROTECTION PROVISIONS

We reserve the right to change this privacy policy at any time with effect for the future. A current version is available on our WEBSITE. Please visit the WEBSITE regularly and inform yourself about the applicable privacy policy.

Status: 09 May 2022