Privacy

The purpose of this notice is to inform you which of your personal data we process and for what purposes.

Data protection according to Art. 13, 14 DSGVO

Your privacy is important to us. With this notice we want to inform you which personal data of yours we process and for which purposes. Personal data is any information relating to an identified or identifiable natural person. This person is referred to by law as the "data subject".

Objective and responsibility

This privacy policy informs you about the nature, scope and purpose of the processing of personal data in relation to our online offer and the associated websites, functions and content (hereinafter collectively referred to as "online offer" or "website"). Details on these processing activities can be found in section 2.

Details on data processing for the purpose of carrying out our business processes are described in section 3.

The provider of the online offer and responsible for data protection is KTB Import-Export Handelsgesellschaft mbH & Co. KG (Großmoorring 9, 21079 Hamburg, Germany) - hereinafter referred to as KTB, "provider", "we" or "us".

Our online offer is provided by 1&1 Internet SE (Elgendorfer Strasse 57, 56410 Montabaur, Germany).

Our data protection officer is: Sven Meyzis - IT.DS Beratung (phone: 0049 40-21091514 / e-mail: [email protected]).

The term "user" includes all customers and visitors of the online offer.

Legal basis

We collect and process personal data based on the following legal bases:

Consent pursuant to Article 6(1)(a) of the General Data Protection Regulation (GDPR). Consent is any voluntary, specific, informed and unambiguous expression of will in the form of a statement or other unambiguous affirmative act by which the data subject indicates his or her agreement to the processing of personal data relating to him or her.

Necessity for the fulfillment of the contract or the implementation of preparatory measures pursuant to Article 6(1)(b) DSGVO, i.e. the data is necessary so that we can fulfill our contractual obligations towards you or we need the data to prepare for the conclusion of a contract with you.

Processing for compliance with a legal obligation pursuant to Article 6 (1) lit c DSGVO, i.e. that, for example, processing of the data is required by law or other regulations.

Processing for the purposes of legitimate interests pursuant to Article 6(1)(f) DSGVO, i.e. that the processing is necessary to protect legitimate interests on our part or on the part of third parties, unless such interests are overridden by the interests or fundamental rights and freedoms of you which require the protection of personal data.

Data subject rights

You are entitled to the following rights regarding data processing by us:

Right of appeal to a supervisory authority pursuant to Article 13(2)(d) DSGVO and Article 14(2)(e) DSGVO.

Right of access according to Article 15 DSGVO

Right of rectification pursuant to Article 16 DSGVO

Right to erasure ("right to be forgotten") pursuant to Article 17 DSGVO

Right to restriction of processing pursuant to Article 18 DSGVO

Right to data portability pursuant to Article 20 DSGVO

Right to object according to Article 21 DSGVO

Note: Users may object to the processing of their personal data in accordance with the legal requirements at any time with effect for the future. The objection can be made in particular against the processing for purposes of direct advertising.

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Data deletion and storage period

The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Blocking or deletion of data also takes place when a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

Processing safety

We have implemented appropriate and state-of-the-art technical and organizational security measures (TOMs). Thus, the data processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.

The security measures include, in particular, the encrypted transmission of data between your browser and our server.

Data transfer to third parties, subcontractors and third-party providers

Personal data is only transmitted to third parties within the framework of legal requirements. We only pass on users' data to third parties if this is necessary, for example, for billing purposes or for other purposes if the transfer is necessary to fulfill contractual obligations to users.

If we use subcontractors for our online services, we have taken suitable contractual precautions and appropriate technical and organizational measures vis-à-vis these companies.

If we use content, tools or other means from other companies (hereinafter collectively referred to as "third party providers") and their named registered office is located in a third country, it is to be assumed that a transfer of data to the third party providers' countries of domicile will take place. The transfer of personal data to third countries by us will only take place if there is an adequate level of data protection, user consent or otherwise legal permission.

Collection of information on the use of the online offer

When using the online offer, information is automatically transmitted to us by the user's browser; this includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

The processing of this information is based on legitimate interests pursuant to Article 6 paragraph (1) lit. f DSGVO (e.g. optimization of the online offer) as well as to ensure the security of the processing pursuant to Article 5 paragraph (1) lit. f DSGVO (e.g. for defense and reconnaissance of cyber attacks).

The information is automatically deleted 30 days after the end of the connection - i.e. use of the online offer - provided that there are no other retention periods.

The collection of the data and the storage of the data in log files is absolutely necessary for the provision of the online offer. Therefore, there is no deletion, objection or correction option on the part of the user.

Cloudflare

This website uses services from "Cloudflare" (provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA). Cloudflare operates a content delivery network (CDN) and provides protection functions for the website (web application firewall). The data transfer between your browser and our servers flows through Cloudflare's infrastructure and is analyzed there to prevent attacks. Cloudflare uses cookies for this purpose to enable you to access our website. The use of Cloudflare is in the interest of a secure use of our Internet presence and the defense of harmful attacks from the outside. This represents a legitimate interest within the meaning of Art. 6 (1) lit. f DSGVO.

The location of the CDN server is Netherlands.

For more information, please see the Cloudflare Privacy Policy: https://www.cloudflare.com/de-de/privacypolicy.

Information about Google services

We use various services of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland on our website.

For more information on the individual concrete services of Google that we use on this website, please refer to the further privacy policy.

Through the integration of Google services, Google may collect information (including personal data) and process it. It cannot be ruled out that Google also transmits the information to a server in a third country.

The transmission to the USA depends on the function in which personal data is transmitted. As the responsible party, we ourselves may transfer data to Google in the USA for further use.

Currently, there is no adequacy decision pursuant to Art. 45 GDPR. However, the transfer can be based on standard contractual clauses. Google has committed to comply with the Standard Contractual Clauses (SCC) for the transfer of personal data to third countries.

More information on the standard contractual clauses is available at

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractuals-clauses-scc_de

as well as under

https://policies.google.com/privacy/frameworks?hl=de

We ourselves cannot influence which data Google actually collects and processes. However, Google states that in principle the following information (also personal data) can be processed, among others:

Log data (especially the IP address)

Site-related information

Unique application numbers

Cookies and similar technologies

Information on the types of cookies used by Google can be found at https://policies.google.com/technologies/types.

If you are logged into your Google account, Google may add the processed information to your account and treat it as personal data, depending on your account settings.

Google states the following about this, among other things:

"If you are not signed into a Google account, we store the data we collect with unique identifiers associated with the browser, app, or device you are using. This allows us to ensure, for example, that your language settings are maintained across all browsing sessions.

If you are logged into a Google account, we also collect data that we store in your Google account and consider to be personal data." (https://privacy.google.com/take-control.html)

You can prevent this data from being added directly by logging out of your Google account or also by making the corresponding account settings in your Google account. Furthermore, you can change your cookie settings (e.g. delete cookies, block cookies, etc.).

You can find more information in Google's privacy policy, which you can access here:

https://www.google.com/policies/privacy/

You can find information on Google's privacy settings at https://privacy.google.com/take-control.html.

Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited (Gordon House Barclays Dublin Ireland - hereinafter "Google"), on the basis of your consent for the analysis, optimization and economic operation of our online offer pursuant to Article 6 (1) (a) DSGVO. Google uses cookies and other technologies. The information generated by the service about the use of the online offer by users is transmitted to a Google server in the USA and processed there.

Google acts on our behalf as part of the order processing pursuant to Article 28 DSGVO. We have concluded a data protection agreement with Google that includes the EU standard data protection clauses.

We use Google Analytics with IP anonymization enabled.

Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you on future visits to the website. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/¬dlpage/gaoptout?hl=en.

The collected data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 26 months. Other data remains stored in aggregated form indefinitely.

You can find more information about Google's use of data, settings and revocation options on Google's websites:

https://policies.google.com/technologies/partner-sites?hl=de ("Data use by Google when you use our partners' websites or apps").

https://policies.google.com/technologies/ads ("Data use for advertising purposes")

https://adssettings.google.com/¬authenticated ("Manage information Google uses to serve ads to you").

Google Fonts

In order to display our content correctly and in a graphically appealing manner across browsers, we use "Google Web Fonts" from Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google") on this website to display fonts.

The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy/

Calling up script libraries or font libraries automatically triggers a connection to the operator of the library. It is theoretically possible - although it is currently also unclear whether and, if so, for what purposes - that the operator collects Google data in this case. Google processes your data in the USA. We do not collect any personal data through the integration of Google Web Fonts.

The provision of personal data is neither legally nor contractually required. However, the correct display of the contents of the website may not be possible due to standard fonts.

The JavaScript programming language is regularly used to display the content. You can therefore object to data processing by deactivating the execution of JavaScript in your browser or installing a JavaScript blocker. Please note that this may result in functional restrictions on the website.

The processing of this information is based on legitimate interests pursuant to Article 6 (1) (f) DSGVO.

Google Recaptcha

We use the reCAPTCHA service from Google, which protects our website from spam and abuse. The service prevents automated software (so-called bots) from carrying out abusive activities on our websites, i.e. it checks whether the input actually comes from a human. Google collects the following data:

- Referrer (address of the page where the captcha is used)

- IP address of the user

- Google account (if the user is registered with Google, this is recognized and assigned)

- The user's input behavior (e.g., speed of input into the form fields, order in which the user selects the input fields) is used to improve Google's pattern recognition.

- Browser, browser size and resolution, browser plugins, date, language settings.

- Website display instructions (CSS) and scripts (Javascript)

- Mouse and touch events within the page

Google also reads cookies from other Google services, such as Gmail, Search, and Analytics. All data is sent to Google in encrypted form. No reading or saving of personal data from the input fields of the respective form takes place.

For more information about Google's privacy policy, please visit http://www.google.com/policies/privacy/.

The processing of this information is based on legitimate interests pursuant to Article 6 (1) (f) DSGVO.

Google Tag Manager

We use the Google Tag Manager on our website. The Google Tag Manager is a service of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

The Google Tag Manager allows us to integrate various codes and services on our website in an orderly and simplified manner. The Google Tag Manager implements the tags or "triggers" the embedded tags. When a tag is triggered, Google may process information (including personal data) and process it. It cannot be ruled out that Google also transmits the information to a server in a third country.

Information on the standard contractual clauses and the transmission to the USA by us to Google and other relevant data on data processing by Google in the context of the use of Google services can be found in this privacy policy under section 2.3 "Information on Google services".

In particular, the following personal data are processed by Google Tag Manager:

Online identifiers (including cookie identifiers) IP address

In addition, you can find more detailed information about the Google Tag Manager on the following websites

https://www.google.de/tagmanager/use-policy.html

as well as under

https://www.google.com/intl/de/policies/privacy/index.html (section "Data we receive based on your use of our services").

Furthermore, we have concluded an order processing agreement with Google for the use of the Google Tag Manager (Art. 28 DSGVO). Google processes the data on our behalf in order to trigger the stored tags and to display the services on our website. Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google.

If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation remains in place for all affected tracking tags that are integrated by the Google Tag Manager.

By integrating the Google Tag Manager, we pursue the purpose of being able to carry out a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services.

The legal basis for the processing of personal data described here as part of the measurement process is your express consent pursuant to Art. 6 (1) lit. a DSGVO.

Unpkg

We use the service unpkg of the provider Npm, Inc, 1999 Harrison Street #1150, CA 94612 Oakland - hereinafter "unpkg". Unpkg enables shorter and more stable loading times of data and information even with higher accesses.

The legal basis for the data processing is the balance of interests pursuant to Art. 6 para.1 lit. f DSGVO. Our legitimate interest is to ensure the functionality of our website.

For more information about unpkg, see the provider's privacy policy at https://www.npmjs.com/policies/privacy.

You can prevent the collection as well as the processing of your data by unpkg by deactivating the execution of script code in your browser or by installing a script blocker in your browser (you can find this, for example, at www.noscript.net or www.ghostery.com).

Consent Management

Our website uses the cookie consent technology of "Complianz GDPR/CCPA Cookie Consent" to obtain your consent to store certain cookies in your browser and to document this in a privacy compliant manner. The provider of this technology is Complianz B.V., Atoomweg 6b, 9743 AK Groningen, Netherlands (hereinafter Complianz).

When you enter our website, a Complianz cookie is stored in your browser, which stores the consents you have given or revoked.

The collected data will be stored until you request us to delete it or delete the Complianz cookie yourself, or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected.

Details on Complianz's data processing can be found at https://complianz.io/privacy-statement.

The use of Complianz Cookie Consent Technology takes place in order to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6 para. 1 p. 1 lit. c DSGVO.

Elementor

We use the plugin "Elementor Website Builder for WordPress", from the provider Elementor 8 THE GRN STE A DOVER, DE 19901 USA. This plugin does not process any personal data. More about the privacy policy of Elementor can be found here: https://elementor.com/about/privacy/

Links to other websites

While using some of our services, you will be automatically redirected to other websites. Please note that this privacy policy is not valid there. The privacy policy of the linked website may differ significantly from this one.

Links to other websites

While using some of our services, you will be automatically redirected to other websites.

Please note that this privacy policy is not valid there. The privacy policy of the linked website may differ significantly from this one.

Personnel application

For reasons of better readability, the simultaneous use of masculine and feminine and various forms of language is dispensed with - within the framework of the following explanations. All personal designations apply to all genders: m/f/d.

Direct applications

We offer you the opportunity to apply to us (e.g. by e-mail or post). In the following, we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that the collection, processing and use of your data will be carried out in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

Scope and purpose of data collection

If you send us an application, we will process your associated personal data (e.g. contact and communication data, application documents, notes taken during interviews, etc.) to the extent that this is necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 BDSG (initiation of an employment relationship), Art. 6 para. 1 lit. b DSGVO (general contract initiation) and - if you have given your consent - Art. 6 para. 1 lit. a DSGVO. The consent can be revoked at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.

If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of Section 26 BDSG and Art. 6 (1) lit. b DSGVO for the purpose of implementing the employment relationship.

Data retention period

If we are unable to make you a job offer, if you reject a job offer, or if you withdraw your application, we reserve the right to retain the data you have provided on the basis of our legitimate interests (Art. 6 Para. 1 lit. f DSGVO) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. This storage serves in particular as evidence in the event of a legal dispute. If it is apparent that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), it will not be deleted until the purpose for continued storage no longer applies.

A longer storage can also take place if you have given a corresponding consent (Art. 6 para. 1 lit. a DSGVO) or if legal storage obligations oppose the deletion.

Inclusion in the applicant pool

If we do not make you a job offer, it may be possible to include you in our applicant pool. In the event of inclusion, all documents and details from the application will be transferred to the applicant pool in order to contact you in the event of suitable vacancies.

Inclusion in the applicant pool takes place exclusively on the basis of your express consent (Art. 6 para. 1 lit. a DSGVO). The provision of consent is voluntary and is not related to the current application process. The data subject may revoke his/her consent at any time. In this case, the data will be irrevocably deleted from the applicant pool, unless there are legal reasons for retention.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been given.

KTB Service Desk

In the KTB Service Desk area you have the possibility to download the TeamViewer software and install it on your end device. This enables us to provide efficient remote support.

Please note that you download, install, and use Teamviewer at your own responsibility.

You can view the Teamviewer security policy via the TeamViewer GmbH homepage. Please direct any questions about this directly to [email protected]

Contact form and contact by e-mail

When contacting us (via online form or e-mail), the data provided by the user will be processed exclusively for the purpose of handling the request and its processing.

Any other use of the data only takes place on the basis of consent by the user.

User data is stored in our customer relationship management system ("CRM system"). The statutory retention periods for business letters apply.

Direct marketing

If you have given us your consent, we will inform you regularly by e-mail about new offers. We will use your name and e-mail address for this purpose. The legal basis for the data processing is Art. 6 para. 1 UAbs. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future, e.g. via the link at the end of each email.

Our newsletter is only sent by e-mail with your prior express consent according to the double opt-in principle: After registering for the newsletter on our website, you will receive an e-mail asking you to confirm your newsletter registration. This ensures that no third party has misused your data.

When you register for the newsletter, we also obtain your consent to newsletter tracking for the purpose of personalized advertising and market research by us. With the help of so-called tracking pixels or web beacons and links, each of which is linked to an individual ID, we collect the following personal tracking information in connection with the use of our newsletter:

Opening the newsletter, clicking on the links contained therein, submitting a form on our website after clicking on a link contained in the newsletter (along with the time of these actions).

Type of terminal device used when you access images in the newsletter or click on links

Behavior on our website when you access it via a link from our newsletter (along with the time of these actions). Location of retrieval when you call up images in the newsletter or click on links (by means of assignment of your IP address, which we do not store, however)

We save this data to your user profile, which is assigned to the data you entered when you registered for the newsletter. We use this data to evaluate and optimize our e-mail marketing and for purposes of personalized advertising and market research. This enables us to send you personalized product, service and offer information that is of particular interest to you within the scope of our newsletter. You can revoke your consent to this data processing at any time with future effect by unsubscribing from the newsletter. An isolated deactivation of the newsletter tracking is (currently) technically not possible. We delete the tracking data when you unsubscribe from our newsletter. Data that has been stored by us for other purposes remains unaffected by this.

Existing customer advertising

Insofar as you have already made use of paid services from us, we may inform you from time to time by e-mail or letter about similar services from us (in particular new offers), if you have not objected to this.

The legal basis for the data processing is Art. 6 para. 1 UAbs. 1 lit. f DSGVO. Our legitimate interest lies in direct advertising (recital 47 DSGVO). You can object to the use of your e-mail address and postal address for advertising purposes at any time without additional costs with effect for the future.

Cookie Policy

Cookies are pieces of information that are transmitted from our web server or third-party web servers to users' web browsers, where they are stored for later retrieval. Cookies may be small files or other types of information storage.

If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

Cookie overview, objection

For an up-to-date overview of the cookies used on this website, please refer to the Consent Management Platform "Complianz GDPR/CCPA Cookie Consent" (see paragraph 2.9.).

There you can also manage your individual consents or preferences.

Changes to the privacy policy

We reserve the right to amend this data protection declaration with regard to data processing in order to adapt it to changes in the legal situation, to changes in the online offer or to data processing.

Insofar as user consents are required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes shall only be made with the consent of the users.

Users are requested to inform themselves regularly about the content of this privacy policy.

Status: July 2022