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Privacy Policy Riese & Müller GmbH take the security of your personal data seriously. We take measures to ensure this security. As part of our digital offerings, we also use services from third-party providers in Germany, other European countries and the USA. In the following we would like to inform you of how your data are processed (a) when you visit our website www.r-m.de (hereinafter "website" or "websites"), including the use of a Riese & Müller user account 'My Bike', (b) when using cookies on the website, (c) when using our RX Connect App for smartphones, (d) when using our RX Services and also (e) when using our social media offerings. Table of contents Data processing when visiting our website, when using our contact forms and when applying for a job Use of cookies on the website Data processing when using the Riese & Müller RX Connect App Your rights as a data subject Privacy Notice for the Facebook fan page and Instagram page Controller, data protection officer Contacting the data protection officers Data processing when using our Fan Page and Instagram Page Processing of your data by Facebook Storage of your personal data Changes to this Privacy Policy Privacy Notice for YouTube Channel Contacting the data protection officer Data processing when using our YouTube Channel Processing of your data by YouTube Storage of your personal data Changes to this Privacy Policy Privacy notice for the Twitter profile Contacting the data protection officer Data processing when using our Twitter profile Processing of your data by Twitter Storage of your personal data Amendment of this privacy policy Data processing controller Riese & Müller GmbH Am Alten Graben 2 64367 Mühltal, Germany e-mail: [email protected] are responsible for processing personal data in the context of our digital offerings pursuant to the provisions of the General Data Protection Regulation (GDPR). In this Privacy Policy, we would like to inform you about the type, scope as well as purpose of processing your personal data (hereinafter: "data") within the context of our digital offerings. Data processing when visiting our website, when using our contact forms and when applying for a job We process data when you contact us, use our services (e.g. register for our newsletter) and also when you visit our website. We use and process personal data exclusively for the purpose for which you have made such data available to us, e.g. where you have given your consent or for us to fulfill our contractual obligations. In addition, data are processed to safeguard our legitimate interests. Your data may also be processed by other departments within Riese & Müller GmbH. In some instances, we also use external service providers for processing. They have been carefully selected and commissioned by us, are bound by our instructions and are checked regularly. The specific processing purposes, the data concerned as well as the legal basis for data processing in the context of a visit to our website are listed below: a) Purpose of website visit We log your visit to our websites. The following data are processed: the name of the respective website viewed, date and time of access, amount of data transferred, browser type and version, your operating system, referrer URL (the last site visited before calling up our site), your IP address and the requesting provider. We collect such data based on our legitimate interests within the meaning of point (f) of Article 6(1) GDPR, since the collection serves our legitimate interest to ensure the protection of our systems and servers and the stability and security of our website. b) Contact If you contact us via one of our contact forms or by e-mail, your data will be processed exclusively for the purpose of processing and handling your request. The data concerned are: your e-mail address, last and first name, subject, message as well as other data you optionally provide. The legal basis for this data processing is point (b) of Article 6(1) GDPR. c) My Bike Account and registration of a bike On the My Bike service platform on our website, you have the option of creating a My Bike Account, for which you can assign a password yourself. To register the My Bike Account, we need the following data from you: e-mail address, last name and first name. You may optionally provide additional data. The legal basis for this data processing is point (b) of Article 6(1) GDPR. We need the data to register your My Bike Account and to make the My Bike service platform available. You may add your Riese & Müller bike to your My Bike Account and register the bike in this My Bike Account for warranty after purchase. For the warranty registration, we need the following additional information: address, dealer, frame number, serial number and date of purchase. These data are processed by us for the registration of the warranty and for a later instance of a possible fulfillment and handling of the warranty service. The legal basis for this data processing is point (b) of Article 6(1) GDPR. d) Transmission of your data to dealers If you contact us with the objective of establishing direct contact with a specified or with the nearest dealer (e.g. if you use our forms to make a purchase inquiry with the nearest dealer or to arrange a test ride with the nearest dealer), we will transmit your data and case-related information (such as the bike you have configured in the case of a purchase inquiry) to the respective nearest dealer. Processing and handling your request is not possible without this transmission. The legal basis for this data processing is point (b) of Article 6(1) GDPR. Similarly, in the event of a warranty claim, we will pass on the data you have already provided to us during warranty registration as well as information on the warranty claim to the dealer in order to process the warranty claim. The legal basis for this data processing is point (b) of Article 6(1) GDPR. e) Transmission of your data to payment service providers Some of our services and products cannot be purchased from local retailers. If you purchase something directly on our website, we use a payment service provider to process your payment with the highest security standards. We transmit your transaction data (name, booking date, payment method, amount and payee, and, if applicable, bank account or credit card details) to the payment service providers commissioned to process payments. We use the service provider Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, The Netherlands, for the technical processing of payments. If you pay by SEPA direct debit, the trust of Mollie B.V., Stichting Mollie Payments, Keizersgracht 126, 1015 CW Amsterdam, The Netherlands, will collect the money. Payments are settled via payment service provider Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, The Netherlands. f) Press distribution list To receive press information by e-mail, you can subscribe to our press distribution list. When you subscribe to the press distribution list, we use the data entered by you. The data concerned are: your e-mail address, last and first name, and editorial department as well as other data you optionally provide. Transmission of your data to third parties and third countries Messages are sent via the MailChimp service of Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. Your e-mail address, last and first name as well as other data you optionally provide will be stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. MailChimp is our processor within the meaning of Article 28 GDPR and is contractually bound to compliance with GDPR. An adequate level of protection is guaranteed by standard data protection clauses issued by the European Commission, concluded between us and MailChimp. For further information on data protection visit https://www.intuit.com/privacy/statement/ Inclusion in the press distribution list is based exclusively on your prior consent in accordance with point (a) of Article 6(1) GDPR. g) Newsletter You can subscribe to our newsletter to receive advertising information, e.g. about our products and special offers, by e-mail. When you subscribe to the newsletter, we use the data entered by you. The data concerned are: your e-mail address, last and first name as well as other data you optionally provide. Transmission of your data to third parties and third countries Messages are sent via the MailChimp service of Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. Your e-mail address, last and first name as well as other data you optionally provide will be stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. MailChimp is our processor within the meaning of Article 28 GDPR and is contractually bound to compliance with GDPR. An adequate level of protection is guaranteed by standard data protection clauses issued by the European Commission, concluded between us and MailChimp. For further information on data protection visit https://www.intuit.com/privacy/statement/ The newsletter is send exclusively on the basis of your prior consent in accordance with point (a) of Article 6(1) GDPR. If you are under 16 years of age, registration for the newsletter requires the consent of your legal guardian. The registration for the newsletter requires a so-called double opt-in. To prevent abuse, we will send you an e-mail after your registration, asking you to confirm your registration. To be able to demonstrate that the registration process complies with the legal requirements, your newsletter registration is logged. This includes both saving the login and confirmation time as well as the IP address. Changes are logged by the newsletter service provider engaged by us. You may revoke your consent to receiving our e-mail newsletter at any time. At the end of each newsletter, you will also find a link to unsubscribe. If you have registered only for our newsletter and have unsubscribed, your personal data will be deleted. h) Processing of external applications as well as in-house applications by Riese & Müller employees Your message, the application data transmitted by you (such as your name, e-mail address, date of birth, postal address and phone number), the application documents transmitted (such as CV, certificates, cover letter, including the personal details and information on qualifications contained therein) as well as additional information and notices provided by you as part of an application are processed by us exclusively for the purpose of processing and handling your application. The legal basis for this data processing is primarily the first sentence of Section 26(1) of the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). The processing of data is permitted if such data are required in connection with the decision to establish an employment relationship. If your application is successful, your data will be stored to your personnel file. If your application is not successful, we will store your data for a maximum of six months after completion of the application process and delete it afterwards. The reason for processing data even after conclusion of the application process is the need for comprehensive documentation of the application process in the event that former applicants assert and/or defend claims under labor law. The legal basis for this data processing is our overriding legitimate interest in a full legal defense in accordance with point (f) of Article 6(1) GDPR. If, during the application process, you expressly consent to being included in our talent pool, data will be processed beyond the specified period. The data processing will then be based on your consent in accordance with point (a) of Article 6(1) GDPR. The data will be deleted after twelve months, at the latest. Your online application After entry and transmission, your data are transferred directly via an encrypted connection to the server of our external service provider, rexx systems GmbH, Süderstraße 75-79, 20097 Hamburg, Germany. This is our processor within the meaning of Article 28 GDPR and is contractually bound to compliance with GDPR. All data are encrypted using the TLS method. Job Alert If you wish, we will inform you about suitable job offers. We process the information provided by you (location, career level, area of responsibility, e-mail address) to inform you by e-mail once a new job opening matching your search criteria has become available. For this, we use our external service provider, rexx systems GmbH, Süderstraße 75-79, 20097 Hamburg, Germany. This is our processor within the meaning of Article 28 GDPR and is contractually bound to compliance with GDPR. All data are encrypted using the TLS method. The data processing will be based on your consent in accordance with point (a) of Article 6(1) GDPR. The data will be deleted after twelve months, at the latest. Data security Our employees as well as our processor are obliged by both their contractual obligations and also data protection rules to treat your personal data confidentially. To protect your collected data against accidental or intentional manipulation, loss, destruction or access by unauthorized persons, technical and organizational measures are used, which are continuously improved in line with technological development. i) Contacting as a dealer If you contact us via one of our "Become a dealer" contact form or by e-mail to become a dealer, your data will be processed exclusively for the purpose of processing and handling your request. Data concerned are: firm, last and first name, e-mail address, phone number, company address, website domain, subject and content of your message. Processing and handling your request is not possible without processing these data. The legal basis for this data processing is point (b) of Article 6(1) GDPR. j) Job Bike Leasing If you contact us via our contact form Job Bike Leasing, by e-mail or by phone, to inform yourself about a Job Bike Leasing, your data will be processed exclusively for the purpose of processing and handling your request and for preparing an offer for the Job Bike you have requested. The data concerned are: Company name, last and first name, e-mail address, telephone number (in case of contact by telephone or callback request), employer, employer ID, Job Bike configuration data, subject and content of your message. Transmission of your data to third parties We transmit the aforementioned personal data and the offer we have prepared to the Job Bike provider with whom your employer cooperates. You can find the Job Bike provider currently cooperating with us here. If your employer accepts the offer, we will forward the aforementioned personal data to the dealer responsible for you. This dealer will carry out the final assembly for you and hand over the Job Bike to you. Without the processing of this data the consultation, the processing and handling of your request, the preparation of an offer and the final assembly and the handover of the Job Bike by the dealer is not possible. The legal basis for this data processing is point (b) of Article 6(1) GDPR. k) Disclosure of personal data to processors and other third parties In accordance with the applicable data protection regulations, we may disclose your personal data to external processors (Article 28 GDPR) acting on our behalf and providing services in connection with our website, the contact forms, the application process and our digital offerings (e.g. host providers, IT service providers). Data are transmitted based on processing agreements. Our processors may process your personal data only to the extent necessary to perform their specific tasks. They are contractually obliged to process your personal data only on our behalf and pursuant to our instructions. Any processors domiciled outside the European Union or the European Economic Area are either based in third countries for which an adequacy decision has been issued by the European Commission or an adequate level of protection is ensured by standard data protection clauses issued by the European Commission which we have concluded with the external processor. In addition to the processors designated elsewhere in this Privacy Policy, your personal data will be disclosed to the following third party processors, including, without limitation: - Secion GmbH, Member of Allgeier CORE Group GmbH, Paul-Dessau-Straße 8, 22761 Hamburg, Germany, for IT security checks; - CTM-COM GmbH, In den Leppsteinwiesen 14, 64380 Roßdorf, Germany, for IT systems maintenance and care; - Stiftung Nieder-Ramstädter Diakonie, Stiftungsverein, Bodelschwinghweg 5, 64367 Mühltal, Germany, for the disposal of data carriers; - Kühne + Nagel (AG & Co.) KG, Wilhelm-Kaisen-Brücke 1, 28195 Bremen, Germany, for delivery of goods and other logistic services; - Druckerei Lokay e. K., Königsteiner Straße 3, 64354 Reinheim, Germany, for production and shipping of printed products; - Scholz & Volkmer GmbH, Schwalbacher Straße 72, 65183 Wiesbaden, Germany, for hosting, maintenance, further development and content creation for the website; - Spark 5 GmbH, Rheinstraße 97, 64295 Darmstadt, Germany, for network analysis and penetration testing; - Code Piraten UG, Am Ruhmbach 44, 45149 Essen, Germany, for further development of the website; - Hanbuch Packaging, Obergasse 85, 64319 Pfungstadt, Germany, for various print jobs and shipping; - Podigee GmbH, Schlesische Str. 20, 10997 Berlin, Germany, for podcast hosting. - Wolters Kluwer Service und Vertriebs GmbH, Hindenburgstraße 46, 71638 Ludwigsburg for supplying the software “Addison OneClick”, Support Digital Data Solutions B.V. (CookieFirst), Plantage Middenlaan 42a, 1018DH, Amsterdam for the provision of the Cookie Consent Management Use of cookies on the website You may adjust your cookie settings on our website individually at any time . a) General information To make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. Cookies are small text files that are stored on your end device. Some of the cookies we use are deleted again after the end of the browser session, i.e. once you have closed your browser (so-called session cookies). Other cookies remain on your device and enable us or our partner companies to recognize your browser on your next visit (persistent cookies). You can change your browser settings to generally block cookies or to inform you when cookies are sent to your device. There are several ways of dealing with cookies. Please use your browser instructions or help menu to learn more about how to adjust your browser settings. In this case, you may have to adjust some settings manually each time you visit a page and accept that some functions may be impaired. Specifically, we use the following types of cookies. Unless the user deletes the cookie or revokes his/her consent to the use of cookies, the cookie will be stored for the duration of its use for this purpose. It will be deleted automatically immediately afterwards. b) Required cookies and security cookies - On our website, we use required and security-relevant cookies. These are cookies that are used to make use of the website and navigate it faster or more safely and that guarantee special functions that are absolutely required for a normal visit to the website and for navigating it. For example, your cookie settings are saved by such cookies so our cookie notice will be displayed only once. They allow for sending forms securely via our website to prevent our systems from being attacked by a CSRF (cross-site request forgery), or ensure that a user is assigned to the services they have booked, his/her digital shopping cart, My Bike area or language and country settings. Data processing is based on point (b) of Article 6(1) GDPR. The use of these cookies is technically required to make the website available to you in a legally compliant manner, to be able to store your cookie settings on the website or to enable a purchase or paid services via our website. Storage duration: session or 1 year - The website also uses the security cookie "__cfduid" from Cloudflare, Inc, 101 Townsend St., San Francisco, California 94107, USA ("Cloudflare"). The cookie is used to identify visitors when using a shared IP address and to confirm that the visit is coming from a known device, even if you access our website from a potentially insecure network (e.g. in public places). In this way, security settings can be applied for each individual user. We have concluded a processing agreement under Article 28 GDPR with Cloudflare. An reasonable level of data protection is guaranteed with the conclusion of the EU standard contract clauses. Storage duration: 1 month c) Cookies for an optimal user experience: dealer search and detailed dealer view With your consent, we use various cookies to optimize the user experience on our website: - So that we can help you quickly with your dealer search, we store your zip code or other location data (in the form of IP addresses) via the cookies to show you the nearest dealers in your town or city and surroundings. Storage duration: 1 year - We use a cookie to store the last bike you viewed. In this way, we can show you the last bike you viewed when you access the site next time. Storage duration: 1 year The legal basis for setting cookies for an optimal user experience is your consent in accordance with point (a) of Article 6(1) GDPR. You may withdraw your consent at any time by unchecking the box "For an optimal user experience" in "Cookie settings". However, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. d) Cookies for our statistics and further development We collect data for statistics and analysis to continuously and further improve our product range and our website. To do so, we use cookies to determine, for example, the number of visitors and the effect of certain pages on our website and to optimize our content. Google Analytics This website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google Ireland"). Google Analytics uses cookies that enable an analysis of your use of the website. The information generated by the cookie about your use of this website may be transmitted to and stored on a server of Google LLC, 1600 Amphitheatre Parkway, Mountain View, California, USA ("Google") in the USA. However, if IP-anonymization is enabled on this website, your IP-address will be first shortened within European Union Member States or in other EEA states. The complete IP address will be in transmitted to a Google server in the USA and shortened there in exceptional cases. Google Ireland will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The IP address transmitted by your browser in the context of Google Analytics will not be combined with any other data from Google Ireland or Google. Please note that this website uses Google Analytics with the extension "_anonymizeIp()". As a result, IP addresses are stored in anonymized form only, a direct personal reference in connection with the stored data therefore is excluded. We have concluded a processing agreement under Article 28 GDPR with Google Ireland. Data transmission therefore is privileged under Article 28 GDPR. For exceptional cases where personal data are transmitted to the USA, a reasonable level of data protection is guaranteed by the conclusion of the EU standard contractual clauses. The legal basis for our use of Google Analytics is your consent in accordance with point (a) of Article 6(1) GDPR. You may withdraw your consent at any time by unchecking the box "For our statistics and further development" in "Cookie settings". However, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You may also prevent the collection of data generated by the cookie related to your use of the website (including your IP address) as well as the processing of such data by Google, by downloading and installing the browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=de. to disable Google Analytics for your current Internet browser. You may also prevent detection by Google Analytics, by clicking on the following link. An opt-out cookie is set to prevent future collection of your information when you visit this website: Disable Google Analytics Storage duration: 2 years On our jobsite we use Matomo Analytics, a web analytics service provided by InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand („Matomo Analytics“). Matomo Analytics uses cookies with which we collect and store data for marketing and optimization purposes and create pseudonymous usage profiles. The usage data is transmitted directly to and stored on the server of our external service provider, rexx systems GmbH, Süderstraße 75-79, 20097 Hamburg. A transmission to InnoCraft Ltd. does not take place. The information generated by Matomo Analytics in the pseudonymous user profile is not used to personally identify the visitor of this website and is not merged with personal data about the bearer of the pseudonym. We store the following data about you: • two bytes of the IP address of the user's accessing system (e.g. 192.168.xxx.xxx); the IP address is not stored in full, so it is not possible to assign the stored, shortened IP address to the user • a unique ID of the user, which logs how the visitor uses the website • a unique session or visitor ID during the website visit • the website visited • the website from which the user accessed the website (referrer) • the subsites accessed from the accessed website • the time spent on the website • the frequency of access to the website. The legal basis for our use of Matomo Analytics is your consent in accordance with point (a) of Article 6(1) GDPR. You may withdraw your consent at any time by clicking on the cookie icon “Change Cookies” and by then clicking on “Refuse” in the cookie banner to deactivate the tracking. However, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You may also prevent the collection of data generated by the cookie related to your use of the jobsite as well as the processing of such data by us, by clicking on the following link. An opt-out cookie is set to prevent future collection of your information when you visit our jobsite: Storage duration: Up to 13 months e) Google Maps For certain functionalities of our website, such as dealer search and to display geographical information, we use the online map service Google Maps from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4 D04 E5W5, Ireland ("Google"). For this purpose, Google will obtain e.g. your IP address, device ID and the location of your terminal. Google also uses the data collected by it for market research and advertising purposes, i.e., in particular to analyze your behavior in order to create user profiles and to provide personalized advertising (including on behalf of third parties). We have no influence on this. You may "opt-out" of this function and have a say as to which advertising will be displayed to you in future as a user of Google services: https://adssettings.google.de/authenticated For further information on Google Maps and on data processing by Google visit: https://policies.google.com/privacy?hl=de&gl=de. Please note that according to the Google Privacy Policy user data may also be transmitted to the United States or to other countries outside the European Economic Area. According to Google, in such cases Google uses either the standard contractual clauses approved by the European Commission or bases such data transmission on the adequacy decisions issued by the European Commission regarding certain countries. The legal basis for our use of Google Maps is your consent in accordance with point (a) of Article 6(1) GDPR. You may withdraw your consent at any time by unchecking the box "Google Maps" in "Cookie settings". However, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Storage duration: up to 1 year f) YouTube API services You may watch the latest videos on the website, which are embedded by using a YouTube plugin (YouTube API services are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; "YouTube"). The "extended privacy mode" for YouTube videos is enabled on the website. According to YouTube, in this mode, no information about visitors to the site is stored, unless you are watching an embedded video. The data listed in the next paragraph will be transmitted only if you actively click and play the video. We do not collect or use the data mentioned in the next paragraph and also do not have any influence on the transmission of this data. When you visit the website, cookies set by YouTube will notify YouTube that you have visited the relevant subpage of the website. Moreover, the data collected during the informative visit of the website will be transmitted. This is done regardless of whether you have a YouTube user account and are logged in or you do not have such an account. If you are logged in to YouTube, your information is directly associated with your YouTube account. If you do not wish to have data assigned to your YouTube profile, you must log out before watching the video on the website. In addition, YouTube may also collect data about your GPS location when you access the site from a mobile device. YouTube stores your data as user profiles and uses them for purposes of advertising, market research and/or the needs-based design of YouTube's website. Such analysis is performed in particular (including for non-registered users) to display demand-oriented advertising and to inform other YouTube users about your activities on the website. You have a right to object to the creation of such user profiles, but you must contact YouTube to exercise this right. By incorporating YouTube videos in the website, a connection to the Google DoubleClick network is automatically established when visiting the website. This does not involve any setting of cookies in the browser. However, if DoubleClick cookies are stored already in your browser, they will be transmitted together with the request. According to the information provided by YouTube, data are transmitted only once you play the video. For further information on the purpose and scope of data collection and processing by YouTube, please see the YouTube Privacy Policy. There you will also receive more detailed information on your rights and the settings options for protecting your privacy: https://www.google.de/intl/de/policies/privacy. When you watch a YouTube video through the YouTube API Services, the YouTube Terms of Use apply (https://www.youtube.com/t/terms). Data processing when using the Riese & Müller RX Connect App When you use our Riese & Müller RX Connect App ("RX Connect App"), we process certain personal data. Which data they are, the purpose of such processing, the third parties that obtain your data and on what underlying legal basis are explained below in this section D. a) Information on the device used by you In order to connect the device on which you use the RX Connect App with our servers or other connected services (listed individually below), we may collect and process technical data related to your device, such as MAC address, IP address, serial number or other alphanumeric codes assigned to your end device. We process such data to establish the connection between your end device and our servers and enable you to use the RX Connect App. The legal basis for the aforementioned processing is the provision of the services requested by you (point (b) of Article 6(1) GDPR). b) Querying of location data (Google services) ou can use the location function in the RX Connect App to locate yourself on the map, to find dealers and/or to help you locate your bike. Transmission of your data to Google and to third countries For your selected location features, we use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4 D04 E5W5, Ireland ("Google"). For this purpose, Google will obtain e.g. your IP address, device ID and the location of your end device. Google also uses the data collected by it for market research and advertising purposes, i.e., in particular to analyze your behavior in order to create user profiles and to provide personalized advertising (including on behalf of third parties). We have no influence on this. You may "opt-out" of this function and have a say as to which advertising will be displayed to you in future as a user of Google services: https://adssettings.google.de/authenticated For further information on Google Maps and on data processing by Google visit: https://policies.google.com/privacy?hl=de&gl=de. Please note that according to the Google Privacy Policy user data may also be transmitted to the United States or to other countries outside the European Economic Area. According to Google, in such cases Google uses either the standard contractual clauses approved by the European Commission or bases such data transmission on the adequacy decisions issued by the European Commission regarding certain countries. Legal basis The legal basis for the aforementioned processing is your consent under point (a) of Article 6(1) GDPR. c) Push messages You may subscribe to receive so-called push messages. You will receive push messages with information about the status of your bike. For one, we use the services of Pusher, which is operated by Pusher Ltd. (07489873) 6 New Street Square, New Fetter Lane, London, England, EC4A 3AQ. Pusher Ltd. is our processor within the meaning of Article 28 GDPR and is contractually bound to compliance with GDPR. If you use an Android device, we also use the Firebase Cloud Messaging Service (“Firebase”) operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4 D04 E5W5, Ireland (“Google”). Google is our processor within the meaning of Article 28 GDPR and is contractually bound to comply with the GDPR. Please note that Google may also transfer data to the USA or other countries outside the European Economic Area. In such cases, a reasonable level of data protection is guaranteed by conclusion of the EU standard contractual clauses. No other Firebase services, such as tracking, are used. To sign up for push messages you must agree to receive push messages in the RX Connect App. This process will be documented and stored. Login time and a push token or device ID are stored. In case of an Android device, a Firebase installation ID is generated from the device ID and is also stored. This enables Firebase to determine which devices push messages should be sent to. These data serve the purpose of sending you push messages and also are proof of your registration. We statistically analyze push messages and thus are able to see if and when push messages are displayed and clicked on. This enables us to determine which push messages are of interest to recipients so as to match future messages to the presumed interests of all recipients and hence to increase the interest in our offering. Legal basis The legal basis for the aforementioned processing is your consent under point (a) of Article 6(1) GDPR. You may withdraw your consent at any time with effect for the future. Your withdrawal does not affect the legality of any previous processing. To exercise this right, you may withdraw your consent under "messages" in the system settings. d) Error analysis We are continuously working to keep our RX Connect App up-to-date, secure and error-free. We analyze possible software errors (so-called bugs) in order to fix them. To analyze bugs we use the Bug Tracking Tool by Functional Software, Inc. (business name: Sentry), 132 Hawthorne Street, San Francisco, CA 94107, USA ("Sentry"). Sentry is our processor within the meaning of Article 28 GDPR and is contractually bound to compliance with GDPR. Legal basis The legal basis for this data processing is our legitimate interest according to point (f) of Article 6(1) GDPR. We have a legitimate interest in keeping our RX Connect App error-free and functional and in particular in analyzing and closing any security loopholes. e) Link with your My Bike Account and use of RX Services You can link the RX Connect App to your My Bike Account. Your My Bike login information must be processed to link the RX Connect App. The legal basis for this is the provision of the services requested by you (point (b) of Article 6(1) GDPR). If you wish to use booked RX Services in our RX Connect App, you first must establish a link to your My Bike Account. The Supplement to the Privacy Policy (Riese & Müller RX Services) applies to the processing of your data in connection with your booked RX Services used via the RX Connect App, including the processing of movement, location data and trip statistics. f) Web Views Functionalities of our RX Connect App (such as registration, service booking, My Bike Account, imprint, privacy, contact) are displayed in so-called web views. This means that parts of our website will be displayed in our RX Connect App. Our privacy policy applies to the website in this regard, including the use of cookies as described there, see sections B and C. g) Processors used In accordance with the applicable data protection regulations, we may disclose your personal data to external processors (Article 28 GDPR) acting on our behalf and providing services in connection with our RX Connected App (e.g. host IT service providers). Data are transmitted based on processing contracts. Our processors may process your personal data only to the extent necessary to perform their specific tasks. They are contractually obliged to process your personal data only on our behalf and pursuant to our instructions. Any processors domiciled outside the European Union or the European Economic Area are either based in third countries for which an adequacy decision has been issued by the European Commission or an adequate level of protection is ensured by standard data protection clauses issued by the European Commission which we have concluded with the external processor. Your personal data will be disclosed for the aforementioned purposes to the following third parties as processors: - DATO SRL, via Botticini 13, Florence, Italy (CMS provider); - Sentry for bug analysis and fixing; - Pusher for using push messages; - Netlify, Inc., 2325 3rd St #215, San Francisco, CA 94107, USA (content delivery network provider). - Google for sending push messages to Android devices via Firebase. Your rights as a data subject Access You have the right to request information at any time as to whether we are processing your personal data and if so, to request access to such personal data. To exercise this right, you may contact us at any time using the contact information provided under clause 6. Rectification, erasure, restriction of processing (blocking) When we process your personal data, we take reasonable steps to ensure that your personal data are accurate and up-to-date for the purposes they were collected for. In the event that your personal data are inaccurate or incomplete, you may request rectification of such data. You may have the right to request erasure of your personal data or restriction of its processing. To exercise these rights, you may contact us at any time using the contact information provided under clause 6. Right to data portability You may have the right to receive from us the personal data concerning you which you have provided us with in a structured, commonly used and machine-readable format or to transmit such data to another controller. To exercise this right, you may contact us at any time using the contact information provided under clause 6. Right to object You have the right to object to the processing of your personal data at any time if we process your personal data for the purposes of direct marketing or if we process your personal data to pursue our legitimate interests and if there are reasons arising from your particular situation. To exercise this right, you may contact us at any time using the contact information provided under clause 6 or exercise you right to object as specified in this Privacy Policy. Withdrawal of consent with effect for the future You may withdraw your consent at any time with effect for the future. Data for billing and accounting purposes will not be affected by a termination / withdrawal or erasure. Your withdrawal does not affect the legality of any previous processing. To exercise this right, you may contact us at any time using the contact information provided under section D or exercise your right to object as specified in this Privacy Policy . Exercising your rights as a data subject If you have any questions about the processing of your personal data, or would like to request access to information, rectification, or blocking, in case of objection or erasure of data or if you would like to transmit the data to another company, please contactRiese & Müller GmbH Am Alten Graben 2 64367 Mühltal, Germany e-mail: [email protected] Our data protection officer Our company's data protection officer is: CTM-COM GmbH, Mr. Moritz Görmann In den Leppsteinswiesen 14 64380 Roßdorf, Germany e-mail: [email protected] Right to lodge a complaint You also have the right to lodge a complaint with the competent supervisory authority: Der Hessische Datenschutzbeauftragte (Data Commissioner for the State of Hesse) Gustav-Stresemann-Ring 1 65189 Wiesbaden, Germany e-mail: [email protected] Storage duration Unless this Privacy Policy stipulates specific deadlines, the following applies: Personal data which we collect in the context of our digital offerings are stored only until the purpose for which they were originally collected has been fulfilled. Where retention periods under commercial and tax law are to be observed, the storage period for certain data may be up to 10 years. Security We protect the transmission of your personal data with a secure connection, using modern cryptographic standards (TLS, e.g. with AES). TLS (transport layer security) is a security technology that ensures that your personal data are transferred securely online and cannot be viewed by third parties. Privacy Notice for the Facebook fan page https://www.facebook.com/rieseundmueller/ und Instagram page https://www.instagram.com/riesemuller/?hl=de As you may know, the European Court of Justice ("ECJ") has recently ruled that under data protection law, Facebook and a Facebook page operator are jointly responsible for data processing (ECJ, judgment of 5 June 2018); for further details visit: http://curia.europa.eu/juris/document/document.jsf?text=&docid=202543&pageIndex=0&doclang=DE&mode=req&dir=&occ=first&part=1&cid=298398. With this Privacy Notice, we therefore inform you - to the extent possible - about the processing of personal data when using our Facebook page https://www.facebook.com/rieseundmueller/ ("Fan Page") and our Instagram page https://www.instagram.com/riesemuller/?hl=de ("Instagram Page"). Both Instagram and Facebook are part of Facebook Inc. Controller, data protection officer Joint controllers within the meaning of the General Data Protection Regulation ("GDPR") for data processing when operating the Fan Page and Instagram Page, respectively, are: Facebook Ireland Ltd. 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland e-mail: [email protected] ("Facebook") and Riese & Müller GmbH Am Alten Graben 2 64367 Mühltal, Germany e-mail: [email protected] ("Riese & Müller GmbH" or "we") Contacting the data protection officers Contact details for the Facebook data protection officers: https://www.facebook.com/help/contact/540977946302970 The contact details of the data protection officer of Riese & Müller GmbH are: CTM-COM GmbH, Mr. Moritz Görmann In den Leppsteinswiesen 14 64380 Roßdorf, Germany e-mail: [email protected] Data processing when using our Fan Page and Instagram Page Users can send us messages via our Fan Page using Facebook Messenger, or can share, comment on or "Like" our posts. We process profile data (in particular the user's name) as well as the respective interaction (e.g. the content of the message or comment) in order to enable us to process user inquiries and answer their requests. As operators of the Fan Page, we use the "Facebook Insights" function provided by Facebook. Facebook Insights provides us with statistical data from Facebook (e.g. total number of page views, information on "Likes", page activity, etc.) Such statistical data is transmitted to us only in anonymized form, i.e. we cannot attribute such data to any particular visitor to our site. We also do not have access to the underlying data of the statistics. Users can send us messages via our Instagram Page via Instagram Direct or our feed, or can share, comment on or "Like" our posts. We process profile data (in particular the user's name) as well as the respective interaction (e.g. the content of the message or comment) in order to enable us to process user inquiries and answer their requests. As operators of the Instagram Page, we use the "Instagram Insights" function provided by Facebook. Instagram Insights provides us with statistical information from Facebook (e.g., total number of page views, user interactions such as postings or Likes, demographic information such as age, location, language or gender, page activity, referrals, etc.). Such statistical data is transmitted to us only in anonymized form, i.e. we cannot attribute such data to any particular visitor to our site. We also do not have access to the underlying data of the statistics. Facebook and we are joint controllers of the processing of Facebook and Instagram Insights data and have concluded an agreement within the meaning of Article 26 GDPR. To view this agreement, go to: https://de-de.facebook.com/legal/terms/page_controller_addendum. For further information on Facebook Insights and Instagram Insights, visit: https://de-de.facebook.com/legal/terms/information_about_page_insights_data. Processing purpose We maintain our Fan Page and Instagram Page to promote our products and to communicate with you. We also use the data provided by the Facebook Insights and Instagram Insights features. This help us to better understand your interests and to reach our target group. In this way, we are able to place targeted interest-based ads and to provide more relevant content on our fan page. For further information about us and our products visit https://www.r-m.de/de/; for our privacy policy go to: https://www.r-m.de/de/datenschutz/ . Facebook also uses the data collected by Facebook via our Fan Page or Instagram Page for market research and advertising purposes, i.e., in particular to analyze your behavior in order to create user profiles and to provide personalized advertising (including on behalf of third parties). You may "opt-out" of this function and have a say as to which advertising will be displayed to you in future as a Facebook or Instagram user: For Facebook: https://www.facebook.com/settings?tab=ads and https://www.youronlinechoices.com/de/praferenzmanagement/. You can adjust further settings here: https://www.facebook.com/help/contact/367438723733209 For Instagram: https://help.instagram.com/478880589321969/?helpref=hc_fnav&bc[0]=Instagram-Hilfebereich&bc[1]=Dein%20Konto%20verwalten Legal basis Personal data is processed on the basis of our legitimate interests pursuant to point (f) of the first sentence of Article 6(1) GDPR in effective communication and interaction with users as well as optimal presentation of our products and services, from which you as a user benefit as well. You are entitled to object to this type of data processing that is based on our legitimate interests at any time for reasons relating to your particular situation. To exercise this right, you may contact us at any time using the contact information provided under A. and B. above. Processing of your data by Facebook With every visit to our Fan Page or Instagram Page, personal data is processed by Facebook. As far as we are aware, Facebook also uses cookies (small text files stored on the various user terminals). These cookies are active for a period of up to two years, unless you delete them earlier. If the user is registered with Facebook or Instagram, Facebook will associate the collected data with the user's personal Facebook or Instagram profile. This enables Facebook to track user behavior (including across different end devices) and create user profiles. Facebook also processes the data to display personalized advertising on the Facebook or Instagram platform or on third-party sites. We have no influence on this data processing. The purpose and scope of data processing by Facebook as well as the relevant rights and setting options to protect the privacy of users are set forth in Facebook's Privacy Policy at https://de-de.facebook.com/privacy/explanation (Facebook) / https://de-de.facebook.com/help/instagram/519522125107875 (Instagram) as well as Facebook's Cookie Policy at https://de-de.facebook.com/policies/cookies/ or the Instagram Cookie Policy at https://help.instagram.com/1896641480634370. To manage your options to object, visit: https://de-de.facebook.com/settings?tab=ads (Facebook) and https://help.instagram.com/196883487377501/?helpref=hc_fnav&bc[0]=Instagram%20Help&bc[1]=Managing%20Your%20Account (Instagram). Please note that according to the Privacy Policy of Facebook, both Facebook and Instagram user data may also be transmitted to the United States or to other countries outside the European Economic Area. According to Facebook, in such cases Facebook uses either the standard contractual clauses approved by the European Commission or bases such data transmission on the adequacy decisions issued by the European Commission regarding certain countries. Storage of your personal data We will store your personal data only for as long as this is necessary to fulfill the purpose for which it was originally collected or - if applicable - longer, if required or justified by law. Your rights Information requests and the assertion of further rights of data subjects should be made sensibly and most effectively directly to Facebook as the platform provider. This also follows from our agreement with Facebook and from the fact that only Facebook has the direct information and the database from which the statistics provided to us are compiled. You may contact us at any time using the contact details set forth above under A. and B if our support is required. You have the following rights: (a) Right of access You have the right to obtain from us, at any time upon request, information on your personal data processed by us within the scope of Article 15 GDPR. To do so, you may submit a request by post or e-mail to the contact data set forth above under A. and B. (b) Right to rectification of inaccurate data You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. To do so, use the contact data set forth above under A. and B. (c) Right to erasure Under the conditions described in Article 17 GDPR, you have the right to ask us to undertake the erasure of personal data concerning you. In particular, these conditions provide for a right of erasure if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, an objection or if personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject. To assert your right to erasure, use the contact data set forth above under A. and B. (d) Right to restriction of processing You have the right to obtain from us restriction of processing according to Article 18 GDPR. This right exists, in particular, if the accuracy of the personal data is contested between the user and us, for a period required to enable us to verify the accuracy of the personal data; if processing is unlawful and the user opposes the erasure of the personal data and requests the restriction of their use instead; furthermore if the personal data are no longer required for the purposes of our processing, but they are required by the user for the establishment, exercise or defense of legal claims; and also, if the successful exercise of an objection is still disputed between us and the user. To assert your right to restrict processing, use the contact data set forth above under A. and B. (e) Right to data portability You have the right to receive from us the personal data concerning you which you have provided us with in a structured, commonly used and machine-readable format in accordance with Article 20 GDPR. To assert your right to data portability, use the contact data set forth above under A. and B. (f) Right to object You have the right to object in accordance with Article 21 GDPR, on grounds relating to your particular situation, at any time to processing of personal data concerning your which is based inter alia on point (e) or (f) of Article 6(1) GDPR. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. To exercise this right, you may contact us at any time using the contact information provided under A. and B. above. (g) Right to withdraw consent You have the right to withdraw your consent at any time pursuant to Article 7(3) GDPR with effect for the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To exercise this right, you may contact us at any time using the contact information provided under A. and B. above. (h) Right to lodge a complaint You furthermore have the right to lodge a complaint with a supervisory authority. Changes to this Privacy Policy We reserve the right to change this Privacy Policy as our Fan Page or Instagram Page is updated. Please visit this Fan Page or Instagram Page, respectively, regularly and check the respective current Privacy Policy. This Privacy Policy was last updated on 13 January 2021. Privacy Notice for YouTube Channelhttps://www.youtube.com/channel/UC7IPIhyMOUzKIDrRv1XpMJA With this privacy notice we inform you - to the extent possible - about the processing of personal data when using our YouTube Channel https://www.youtube.com/channel/UC7IPIhyMOUzKIDrRv1XpMJA ("YouTube Channel"). The YouTube platform is part of Google LLC. Controller Controller within the meaning of the General Data Protection Regulation ("GDPR") for data processing when operating the YouTube Channel is: Riese & Müller GmbH Am Alten Graben 2 64367 Mühltal, Germany e-mail: [email protected] (Riese & Müller GmbH" or "we") Contacting the data protection officer The contact details of the data protection officer of Riese & Müller GmbH are: CTM-COM GmbH, Mr. Moritz Görmann In den Leppsteinswiesen 14 64380 Roßdorf, Germany e-mail: [email protected] Data processing when using our YouTube Channel Users can use our YouTube Channel to share and comment on our videos or to "Like" or "Dislike" them. We process profile data (especially the user's name) as well as the respective interaction (e.g. the content of the comment) in order to enable us to process user inquiries and answer their requests. As operators of the YouTube Channel, we use the "YouTube Analytics" function provided to us by YouTube. YouTube Analytics provides us with statistical data from YouTube (e.g. top videos, reach, types of access sources, playing time, target audience information (age, gender, origin and time of online activity as well as subtitles used), information on "Likes" or "Dislikes"). Such statistical data is transmitted to us only in anonymized form, i.e. we cannot attribute such data to any particular visitor to our site. We also do not have access to the underlying data of the statistics. For further information on Youtube Analytics visit: https://policies.google.com/privacy?hl=de&gl=de. Processing purpose We maintain our YouTube Channel to promote our products and to communicate with you. To do so, we also use the data provided by YouTube Analytics. This help us to better understand your interests and to reach our target group. In this way, we are able to place targeted interest-based ads and to provide more relevant content on our fan page. For further information about us and our products visit https://www.r-m.de/de/; for our privacy policy go to: https://www.r-m.de/de/datenschutz/ . YouTube also uses the data collected by YouTube via our YouTube channel for market research and advertising purposes, i.e. in particular to analyze your behavior in order to create user profiles and to provide personalized advertising (including on behalf of third parties). You may "opt-out" of this function and have a say as to which advertisement will be displayed to you in future as a YouTube user: https://adssettings.google.de/authenticated Legal basis Personal data is processed on the basis of our legitimate interests pursuant to point (f) of the first sentence of Article 6(1) GDPR in effective communication and interaction with users as well as optimal presentation of our products and services, from which you as a user benefit as well. You are entitled to object to this type of data processing that is based on our legitimate interests at any time for reasons relating to your particular situation. To exercise this right, you may contact us at any time using the contact information provided under A. and B. above. Processing of your data by YouTube With every visit to our YouTube Channel, personal data is processed by YouTube. As far as we are aware, YouTube also uses cookies (small text files stored on the various user terminals). These cookies are active for a period of up to ten years, unless you delete them earlier. If the user is registered with YouTube, YouTube will associate the collected data with the user's personal YouTube profile. This enables YouTube to track user behavior (including across different end devices) and create user profiles. YouTube also processes the data to display personalized advertising on the YouTube platform or on third-party sites. We have no influence on this data processing. The purpose and scope of data processing by YouTube as well as the relevant rights and setting options to protect the privacy of users are set forth in YouTube's Privacy Policy at https://policies.google.com/privacy?hl=de&gl=de, in YouTube's Cookies Policy at https://policies.google.com/technologies/ads?hl=de and also in the Policy on the use of data by YouTube when you use websites or apps from YouTube partners at https://policies.google.com/technologies/partner-sites?hl=de. Please note that according to the YouTube Privacy Policy, YouTube user data may also be transmitted to the United States or to other countries outside the European Economic Area. Storage of your personal data We will store your personal data only for as long as this is necessary to fulfill the purpose for which it was originally collected or – if applicable – longer, if required or justified by law. Your rights You can send requests for information or assert further data subject rights at any time by using our contact data set forth above under A. and B. You have the following rights: (a) Right of access You have the right to obtain from us, at any time upon request, information on your personal data processed by us within the scope of Article 15 GDPR. To do so, you may submit a request by post or e-mail to the contact data set forth above under A. and B. (b) Right to rectification of inaccurate data You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. To do so, use the contact data set forth above under A. and B. (c) Right to erasure Under the conditions described in Article 17 GDPR, you have the right to ask us to undertake the erasure of personal data concerning you. In particular, these conditions provide for a right of erasure if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, an objection or if personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject. To assert your right to erasure, use the contact data set forth above under A. and B. (d) Right to restriction of processing You have the right to obtain from us restriction of processing according to Article 18 GDPR. This right exists, in particular, if the accuracy of the personal data is contested between the user and us, for a period required to enable us to verify the accuracy of the personal data; if processing is unlawful and the user opposes the erasure of the personal data and requests the restriction of their use instead; furthermore if the personal data are no longer required for the purposes of our processing, but they are required by the user for the establishment, exercise or defense of legal claims; and also, if the successful exercise of an objection is still disputed between us and the user. To assert your right to restrict processing, use the contact data set forth above under A. and B. (e) Right to data portability You have the right to receive from us the personal data concerning you which you have provided us with in a structured, commonly used and machine-readable format in accordance with Article 20 GDPR. To assert your right to data portability use the contact data set forth above under A. and B. (f) Right to object You have the right to object in accordance with Article 21 GDPR, on grounds relating to your particular situation, at any time to processing of personal data concerning your which is based on point (e) or (f) of Article 6(1) GDPR. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. To exercise this right, you may contact us at any time using the contact information provided under A. and B. above. (g) Right to withdraw consent You have the right to withdraw your consent at any time pursuant to Article 7(3) GDPR with effect for the future. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To exercise this right, you may contact us at any time using the contact information provided under A. and B. above. (h) Right to lodge a complaint You furthermore have the right to lodge a complaint with a supervisory authority. Changes to this Privacy Policy We reserve the right to change this Privacy Policy as our YouTube channel is updated. Please visit our YouTube channel regularly and check the respective current Privacy Policy. This Privacy Policy was last updated on 25 January 2021. Privacy notice for the Twitter profile witter.com/riesemuller @riesemuller By means of this privacy notice, we inform you – as far as we are able to – about the processing of personal data when using our Twitter profile twitter.com/riesemuller/@riesemuller. The Twitter platform is part of Twitter Inc. Data processor Within the meaning of the General Data Protection Regulation ("GDPR"), the data processor in the operation of Twitter profiles is: Riese & Müller GmbH Am Alten Graben 264367 Mühltal, Germany E-mail: [email protected] (hereafter "Riese & Müller GmbH" or "we") Contact details of the data protection officer The contact details of the data protection officer at Riese & Müller GmbH are: CTM-COM GmbH, Mr Moritz Görmann In den Leppsteinswiesen 14 64380 Rossdorf, Germany E-mail: [email protected] Data processing when using our Twitter profile Via our Twitter profile, users have the option to send us messages, share, retweet, reply to, or "like" our posts. In doing so, profile data (in particular the name of the user) as well as the respective interaction (e.g. the content of the message) are processed by us so that we can deal with the users' enquiries and respond to their requests. As the operator of the Twitter profile, we use the "Twitter Analytics" function provided to us by Twitter. Through Twitter Analytics, we receive statistical data from Twitter (including but not limited to tweet activity and information about our followers, such as origins and interests). This statistical data is transmitted to us only in anonymised form, i.e. we cannot assign this data to any specific visitor to our site. In addition, we have no access to the data on which the statistics are based. Further information on data processing by Twitter can be found via the following link: https://twitter.com/en/privacy. Purposes of processing We maintain our Twitter profile to promote our products and to be able to communicate with you. We also use the data provided by the Twitter Analytics function for this purpose. This data helps us to better understand your interests and to reach our target group more effectively. In turn, this allows us to target interest-based advertising and provide more relevant content on our Twitter profile. You can find more information about us and our products on the following website https://www.r-m.de/en-gb/; our privacy policy can be found here: https://www.r-m.de/en-gb/privacy-policy/. Twitter also uses the data which it collects via our Twitter profile for market research and advertising purposes, i.e. in particular to analyse your behaviour, to create user profiles and to provide personalised advertising (also on behalf of third-party companies). You can make use of an "opt-out" option here and influence the advertising displayed to you in future as a user of the Twitter service. For more information and links, please see Section 2.10 of the Twitter privacy policy: https://twitter.com/en/privacy or at: https://help.twitter.com/en/personalization-data-settings Legal basis The processing of personal data takes place on the basis of our legitimate interests pursuant to Art. 6 section 1 p. 1 (f) GDPR in effective communication and interaction with users, as well as to provide optimised presentation of our products and services, from which you as a user also benefit. At any time, you have the right to refuse this type of data processing, which is based on our legitimate interest, on grounds relating to your particular situation. To exercise this right, you can contact us at any time using the contact details provided in A. and B. above. Processing of your data by Twitter Twitter processes your personal data each time you visit our Twitter profile. To the best of our knowledge, Twitter also uses cookies (small text files that are stored on the various end devices of the users). If the user is registered with Twitter, Twitter will assign the collected data to the user's personal Twitter profile; this enables Twitter to track user behaviour (also across different end devices) and to create user profiles. In addition, Twitter processes the data in order to display personalised advertising on the Twitter platform or on third-party sites. We have no influence on this data processing. The purpose and scope of data processing by Twitter, as well as the relevant rights and setting options for protecting the privacy of users, can be found in Twitter's privacy policy at https://twitter.com/en/privacy, in Twitter's cookie policy at https://help.twitter.com/en/rules-and-policies/twitter-cookies#more-privacy, and in the policy on data use by Twitter when you use websites or apps of Twitter partners at https://help.twitter.com/en/rules-and-policies/twitter-services-and-corporate-affiliates. Please note that, according to Twitter's privacy policy, Twitter user data may also be transferred to the USA or other countries outside the European Economic Area. Storage of your personal data We will only retain your personal data for as long as is necessary to fulfil the purpose for which it was originally collected or, where applicable, for as long as more extended retention is required or justified by law. Your rights At any time, you can send us requests for information and assert further rights as an affected person, by using the contact details given above under A. and B. You have the following rights: (a) Right to information Upon request, you have the right to obtain information from us at any time about the personal data processed by us that affects you within the scope of Art. 15 GDPR. To do this, you can submit a request by post or e-mail to the contact details provided in A. and B. above. (b) Right to correction of inaccurate data You have the right to request that we correct personal data relating to you without delay if it is inaccurate. For this purpose, please use the contact details provided under A. and B. above. (c) Right to deletion Under the conditions described in Art. 17 GDPR, you have the right to demand that we delete the personal data affecting you. These conditions provide in particular for a right of deletion if the personal data is no longer necessary for the purposes for which it was collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection or the existence of an obligation to delete under European Union law or the Member State law to which we are subject. To exercise your right to deletion, please use the contact details provided in A. and B. above. (d) Right to restriction of processing You have the right to demand that we restrict processing in accordance with Art. 18 GDPR. Particularly if there is a dispute between the user and us about the accuracy of the personal data, and also if the user requests restricted processing instead of deletion in the case of an existing right to deletion, then this right exists for the duration required to verify the accuracy. Furthermore, this right also exists if the data is no longer necessary for the purposes pursued by us, but the user requires it for the assertion, exercise, or defence of legal claims, and also if the successful exercise of an objection is still disputed between us and the user. To exercise your right to restrict processing, please use the contact details provided in A. and B. above. (e) Right to data portability You have the right to obtain from us the personal data concerning you that you have provided to us. It shall be made available to you in a structured, commonly used, and machine-readable format, in accordance with Art. 20 GDPR. To exercise your right to data portability, please use the contact details provided in A. and B. above. (f) Right of objection In accordance with Article 21 GDPR, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out, inter alia, on the basis of Article 6 section 1 (e) or (f) GDPR. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or if the processing is for the establishment, exercise, or defence of legal claims. To exercise this right, you can contact us at any time using the contact details provided in A. and B. above. (g) Right of withdrawal (when consent has previously been granted) You have the right to revoke consent granted in accordance with Art. 7 section 3 GDPR with effect for the future. The revocation of consent will not affect the legality of the processing carried out on the basis of the consent given before revocation. To exercise this right, you can contact us at any time using the contact details provided in A. and B. above. (h) Right of appeal You also have the right to contact the supervisory authorities in the event of complaints. Amendment of this privacy policy We reserve the right to amend this privacy policy in accordance with the updating of our Twitter profile. Please visit our Twitter profile on a regular basis and check the current privacy policy. This privacy policy was last updated on 01 April 2022
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Ova politika privatnosti definira kako Beliva koristi i štiti sve osobne podatke koje vi dajete na uvid Belivi. Beliva (u nastavku „Mi“) obrađuje osobne podatke koje su mu pružili njegovi newsletter pretplatnici, klijenti i partneri. U ovoj izjavi o Politici privatnosti se objašnjava kako i zašto obrađujemo Vaše osobne podatke. Naša Politika privatnosti odnose se na komunikaciju i usluge koje nudi Beliva prema newsletter pretplatnicima, klijentima i partnerima. Beliva zadržava pravo periodičke izmjene ove Politike privatnosti. Svaka izmjena ili nadopuna Politike privatnosti šalje se na vašu email adresu i stavlja na web stranicu. Trebali biste povremeno provjeriti ovu stranicu kako biste se uvjerili da su sve izmjene u skladu s Vašim željama. Ova Politika privatnosti stupa na snagu s danom njene objave na ovim internet stranicama. Tko smo mi? Beliva, vlasnik Iva Belé Success Concepta pruža usluge s područja edukacija, organizacije evenata i poslovnog savjetovanja. Sjedište Beliva je u Zagrebu, Hrvatska. Što skupljamo Na našim prijavama na newsletter, prijavama na naša događanja i prijavama za poslovno savjetovanja prikupljamo osobne podatke i podatke o kompanijama. Pod osobnim podacima misli se na osobne informacije koje ste dobrovoljno ostavili putem formi na našem webu, društvenim mrežama ili kroz formu za korisnički profil unutar našeg newslettera, a koje su potrebne za ispunjenje svrhe pružanja usluge ili uspostavljanja poslovnog odnosa, i u slučaju newsletter prijave za slanje marketinških poruka. Za potrebe pružanja usluga (odgovor na upit, prijava na treninge, kreiranje ponuda, uspostavljanje poslovnog kontakta), obrađujemo sljedeće podatke: - ime - prezime - e-mail adresa - broj mobitela - grad - fizička ili pravna osoba Za potrebe slanja newslettera obrađujemo slijedeće podatke: - e-mail adresa - ime - prezime Što radimo s prikupljenim informacijama Osobne podatke prikupljamo preko forme za prijavu na newsletter i obrađujemo da bismo slali (personalizirane) newslettere u kojima naši pretplatnici dobivaju Dnevnu dozu positive i informacije U svakom trenutku možete odjaviti naš Newsletter putem linka za odjavu koji se nalazi u svakom našem newsletteru. Isto tako, osobne podatke prikupljamo i obrađujemo preko kontakt forme na našoj web stranici kako bismo našim potencijalnim klijentima slali ponude i uspostavili poslovni kontakt. Podaci su dostupni djelatnicima kojima su nužni za obavljanje posla. Razdoblje u kojem će osobni podaci biti pohranjeni Vaše podatke čuvamo toliko dugo dok postoji svrha za čuvanje i obradu. • ugovori i dokumentacija: 11 godina • podaci o newsletter pretplatnicima: za vrijeme trajanja privole na newsletter Prava ispitanika Vezano na prikupljanje i obradu Vaših osobnih podataka, imate sljedeća prava koja smo Vam dužni osigurati: Pravo na pristup Pravo na ispravak Pravo na brisanje Pravo na ograničenje obrade Prenosivost podataka Pravo na prigovor Podnošenje pritužbe nadzornom tijelu Pravo na pristup Imate pravo dobiti od nas potvrdu obrađuju li se Vaši osobni podaci te ako se obrađuju, pristup osobnim podacima i sljedećim informacijama: svrsi obrade, kategorijama osobnih podataka o kojima je riječ, primateljima osobnih podataka te ostala prava koja su gore navedena. Ako se podaci prenose i obrađuju izvan EU, imate pravo na informaciju o posebnim zaštitnim mjerama. Kada je to moguće, možete dobiti kopiju osobnih podataka koji se obrađuju. Pravo na ispravak Imate pravo ishoditi od nas ispravak, bez nepotrebnog odgađanja, netočnih osobnih podataka koji se na Vas odnose. Uzimajući u obzir svrhe obrade, imate pravo dopuniti nepotpune osobne podatke, među ostalim i davanjem dodatne izjave Pravo na brisanje i povlačenje privole Imate pravo zatražiti brisanje I povlačenje privole pohranjenih osobnih podataka. Da biste to učinili, pošaljite svoj zahtjev na: info@ivabele.com. U slučaju otkazivanja pretplate ne newsletter i povlačenja privole, jednostavno kliknite na hipervezu u newsletteru za otkazivanje pretplate i prestat ćemo slati email-ove. Pravo na ograničenje obrade U posebnim okolnostima, imate pravo ograničiti obradu vaših osobnih podataka. Da biste zatražili ograničenje, molimo Vas da nas kontaktirate na: info@ivabele.com Pravo na prenosivost podataka Imate pravo primati svoje osobne podatke (koji se tiču samo vas) u strukturiranom, uobičajenom obliku i strojno čitljivom formatu (“prenosivost podataka”) i imate pravo prenijeti ove podatke drugom kontroloru podataka. Da biste zatražili prenosivost podataka, molimo Vas da nas kontaktirate na: info@ivabele.com Pravo na prigovor Ako se obrada osobnih podataka zasniva na ostvarenju naših legitimnih interesa, imate pravo na temelju svoje posebne situacije u svakom trenutku uložiti prigovor na obradu osobnih podataka koji se odnose na Vas. Ako uložite takav prigovor, nećemo više obrađivati Vaše osobne podatke, osim ako dokažemo da postoje uvjerljivi legitimni razlozi za obradu koji nadilaze interese, prava i slobode ispitanika ili radi postavljanja, ostvarivanja ili obrane pravnih zahtjeva. Podnošenje pritužbe nadzornom tijelu U slučaju potrebe za zaštitom prava možete obratiti Agenciji za zaštitu osobnih podataka (AZOP). Upravljanje vašim osobnim podacima Nećemo prodavati, distribuirati ili iznajmljivati vaše osobne podatke bilo kojim trećim stranama osim ukoliko budemo obvezni zakonom to učiniti. Možemo koristiti Vaše osobne podatke kako bi vam poslali promotivne ponude ili informacije koje su unutar vašeg područja interesa a povezane su uz naše usluge i proizvode. Ukoliko mislite da vaši podaci koji se nalaze kod nas nisu točni ili želite da ih uklonimo iz naše baze podataka, molimo kontaktirajte nas putem e-maila info@ivabele.com, kontakt obrasca ili putem telefona. Kontakt informacije radi ostvarenja Vaših prava: Molimo kontaktirajte nas na adresi: info@ivabele.com ili na broj telefona +385 91 37 37 737. Vaše upite i zahtjeve obradit ćemo bez nepotrebnog odgađanja i u skladu s zakonskim obvezama te ćemo Vas informirati o mjerama koje smo poduzeli. Kolačići – što su? Kako bi održavali web stranicu i osigurali da njezine funkcionalnosti budu na očekivanoj razini ivabele.com koristi tehnologiju poznatu kao “kolačići”. Kolačić (eng. Cookie) je podatak male veličine koji web stranica pohranjuje u računalo ili mobilni uređaj posjetitelja. Kolačić dozvoljava web stranici da „zapamti“ akcije posjetitelja iz prethodnih posjeta. Većina preglednika dozvoljava upotrebu kolačića, ali korisnik ih u svakom trenutku može obrisati ili u pregledniku postaviti zabranu pohrane istih. Najčešći razlozi korištenja kolačića su: identifikacija posjetitelja, pamćenje specifičnih preferencija korisnika, pomoć pri unosu informacija koje su već unesene prilikom prethodnih posjeta, skupljanje podataka za analize te promotivne kampanje. Kakvi sve kolačići postoje? Kolačići se mogu klasificirati: - po trajanju: Privremeni kolačići – pohranjuju se na računalu , te se automatski brišu nakon zatvaranja web-preglednika. Omogućuju internetskoj stranici da dobije privremene podatke, poput komentara ili stanja košarice za kupnju. Trajni kolačići – ostaju u vašem web pregledniku i nakon zatvaranja i obično imaju rok isteka. Pohranjuju podatke kao što su korisničko ime i lozinka, što omogućuje da koristite funkcionalnost „zapamti me“ prilikom prijave, kako ne biste morali upisivati korisničko ime i lozinku svaki puta kada koristite internet stranicu. - po pravnoj osobi od koje dolaze: Kolačići prve strane – oni dolaze s web stranice koju ste posjetili, a mogu biti privremeni ili stalni. Omogućavaju Internet stranicama da spreme podatke koji se koriste kada korisnik ponovno posjeti Internet stranicu. Kolačić treće strane – postoji nekoliko vanjskih servisa koji korisniku spremaju limitirane kolačiće (Facebook, Instagram, Google Analytics i AdWords). - po svrsi: Neophodni kolačići – ključni su za upotrebu Internet stranice i bez istih stranica nema svoju punu funkcionalnost. Funkcionalni kolačići mogu uključivati kolačiće koji pružaju uslugu koju je korisnik zatražio. Kolačići za praćenje i analitiku – Prikupljaju se anonimno, ne mogu pratiti aktivnosti korisnika na drugim Internet stranicama i služe za praćenje ponašanja korisnika te u svrhu mjerenja ponašanja publike i sastavljanja izvješća za poboljšanja Internet stranice. Marketinški kolačići – za personalizaciju ponude te ciljanje i oglašavanje. Upotrebljavaju se za prikazivanje oglasa relevantnih za korisnika i njegove interese. Ovi kolačići također se mogu upotrebljavati za mjerenje učinkovitosti kampanje s kojom je korisnik bio u kontaktu tijekom posjeta Internet stranice. Mjerenje posjećenosti Google Analytics Internet stranica ivabele.com koristi sustav Google Analytics za praćenje broja posjetitelja i njihovog kretanja internet stranicom. Ti se podaci ne mogu koristiti za identifikaciju pojedinih korisnika i na serveru se čuvaju 26 mjeseci, nakon čega se trajno uklanjaju. Internet stranica ivabele.com ne koristi značajke sustava Google Analytics koje povezuju podatke iz Analyticsa s osobnim Google računima korisnika. Ukoliko želite onemogućiti spremanje kolačića od strane alata, slijedite ovu poveznicu – https://tools.google.com/dlpage/gaoptout. Facebook Pixel ivabele.com koristi Facebook-Pixel društvene mreže Facebook Inc. (“Facebook”). Korištenjem acebook-Pixela moguće je pratiti ponašanje korisnika nakon što on klikne na neki oglas na mrežnoj stranici Facebooka. Pomoću Facebook-Pixela možemo pratiti prihvaćenost naših marketinških aktivnosti na Facebooku i optimizirati ih ako je potrebno. Prikupljeni podaci su anonimizirani i ne omogućuju identifikaciju korisnika. Facebook pohranjuje i obrađuje podatke za vlastite marketinške svrhe. Daljnje informacije o Facebookovim pravilima o privatnosti možete dobiti: https://www.facebook.com/about/privacy/ Ako želite onemogućiti servis Facebook-Pixel možete to učiniti isključivanjem kolačića u postavkama vašeg web preglednika. Kako onemogućiti kolačiće? Isključivanjem kolačića odlučujete da li hoćete dopustiti pohranjivanje kolačića na vašem računalu. Postavke vezano za kolačiće mogu se kontrolirati i konfigurirati u vašem web pregledniku. Za informacije o postavkama kolačića, odaberite web-preglednik koji koristite. Chrome: https://support.google.com/chrome/answer/2392709 Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US Microsoft Internet Explorer: https://support.microsoft.com/hr-hr/topic/upravljanje-kola%C4%8Di%C4%87ima-i-njihovo-brisanje-168dab11-0753-043d-7c16-ede5947fc64 Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/view-and-delete-browser-history-in-microsoft-edge-00cf7943-a9e1-975a-a33d-ac10ce454ca4 Opera: https://help.opera.com/en/latest/web-preferences/ Safari iOS/Mac: https://support.apple.com/en-us/HT201265 Dodatne informacije oko isključivanja kolačića Trenutno postoji nekoliko web stranica za isključivanje pohranjivanja kolačića za različite servise. Više se možete informirati na sljedećim linkovima: https://www.allaboutcookies.org https://www.youronlinechoices.eu https://www.aboutads.info/choices Hvala na povjerenju!