Data Protection Notice for the website www.einhell.bg
Einhell Bulgaria OOD (hereinafter referred to as „the company‟) thanks you for visiting our website and for your interest in our company. Protecting your data is important to us. You provide your data on a voluntary basis. The company processes this information in accordance with the provisions of the European General Data Protection Regulation.
1. Responsible Entity
The entity responsible for processing your data is Einhell Germany AG. Exceptions in this regard are described in this data protection notice.
Our contact information is as follows:
Einhell Bulgaria OOD
Blvd."Tzar Osvoboditel" No.331
9000 Varna, Bulgaria
E-Mail: [email protected]
Contact information for the Data Protection Office is available under No. 22 below.
2. Personal Data
Personal data is specific information relating to the personal or factual circumstances of a particular or identifiable person. This includes information such as your IP address and browser settings, form of salutation, correct name, address, email address, phone number, date of birth and information about your Einhell products. In addition, as part of our services we also provide you with access protected by user name and password. As part of this process, we store your user name and password, and where necessary your sex. Personal information that cannot be directly associated with your true identity -- such as, for example, your favourite websites or the number of users on a site -- is not considered personal information.
Additionally we process the connection and identifing data for your web browser to present the appropriate content to you.
3. Processing Personal Information
We process and store various types of temporary data any time you visit the company's website. This includes connection data from the computer accessing the website, the webpage(s)/file(s) you select as well as the data and length of time you visit the website. We also ascertain identification data for the browser and the operating system you use as well as the website used to visit us. Personal information such as salutation, your name, address, where applicable your company, your date of birth, phone number or email address and information about your Einhell products are only collected if you provide it voluntarily as part of registration, a survey, a contest, in concluding a contract or when requesting information.
4. Specified use and dissemination of personal data
The company uses the personal data you provide for the purpose of the technical administration of the website, in providing services, for customer management, to make improvements to the website, for product-related surveys and for marketing purposes only to the extent required for each repective purpose.
5. Legal basis for data processing
he legal basis for the processing of your personal data depends on the purpose underlying the processing.
5.1 Technical administration of the website
The legal basis for the processing of personal data for the purpose specified above is Art. 6(1) lit. b of the General Data Protection Regulation (GDPR), provided a contractual relationship exists with you. Where no contractual relationship exists between the company and you, the legal basis for data processing is Art. 6(1) lit. f GDPR. A transfer of personal data (see figure 2) is necessary in order to establish a connection to the website and to display website content.
5.2 Provision of services
The legal basis for the processing of personal data for the purpose specified above is Art. 6(1) lit. b GDPR. We provide our services as part of fulfilling contractual obligations. We are unable to fufil or perform the contract with you if we are unable to process personal data.
The following services are available on our website www.einhell.bg (June 2016) for which we store personal data:
- Customer Login
- product warranty on Einhell products
- battery warranty
- brushless warranty
- Questions & Answers (by Bazaarvoice Inc.; see figgure 5.10)
- Product reviews (by Bazaarvoice Inc.; see figgure 5.10)
5.3 Google Analytics
The legal basis for processing personal information when using Google Analytics is Art. 6(1) lit. f GDPR. We require statistical information on the use of our website in order to make it more user friendly, to conduct audience measurements and to carry out market research.
This website uses Google Analytics, a web analysis service of Google Inc. (hereinafter: Google). Google Analytics employs so-called "cookies", text files, which are stored to your computer and which facilitate analysis of your use of the website. The information generated by the cookie on your use of this website is usually transmitted to a Google server in the US, where it is stored. Due to the activation of IP anonymisation on this website, Google truncates your IP address within the member states of the European Union and other signatories to the Agreement on the European Economic Area. Only by way of exception is a complete IP address first transmitted to a Google server in the US and truncated there. Google uses this information on behalf of the operator of this website in order to evaluate your use of the site, to compile reports on website activities and to provide the website operator with other services relating to website and internet use. The IP address transmitted by your browser to Google Analytics is not merged with other Google data.
You can prevent cookies from being stored to your computer by selecting the appropriate settings on your browser software; please be aware, however, that by doing so you may not be able to make full use of all the features on this website. Moreover, you can also prevent the data generated by the cookie relating to your use of the website(incl. your IP address) from being collected and processed by Google by downloading and installing the browser plug-in available at the following link: Browser add-on for deactivating Google Analytics. Browser-Add-on to deacivate Google Analytics.
In addition or as a supplement to the browser add-on, you can disable tracking by Google Analytics on our website by clicking on this link. This will install an opt-out cookie on your device. It will prevent Google Analytics from collecting information for this website and for this browser for as long as the cookie is installed on your computer.
5.4 Facebook pixel and Facebook remarketing
Owing to our legitimate interest in the analysis, optimisation and economic operation of our webite, the site employs the so-called "Facebook pixel“ from the social network Facebook, operated by Facebook Inc. (1601 S. California Ave - Palo Alto - CA 94304 - USA) or, in the event your are resident in the EU, Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland) (“Facebook”).
With the aid of the Facebook pixel, Facebook is able to identify visitors to our website as a target group for presentation of ads, so-called "Facebook ads". We use Facebook pixel accordingly in order to show the Facebook-delivered ads only to those users who have demonstated an interest in our internet services or who exhibit the speicific characteristics that we communicate to Facebook (also referred to as "pixel events" and which contain, for example, user email addresses). In other words, by using the Facebook pixel, we seek to ensure that our Facebook ads reflect the potential interests of our users and are not simply an annoyance. With the aid of the Facebook pixel we are also better able to track the effectiveness of Facebook advertisements for statistical and marketing purposes by seeing whether users were directed to our website after clicking on a Facebook ad.
Facebook immediately incorporates the Facebook pixel when our website is accessed and can store a cookie, i.e. a small file, on your device. If you then log into Facebook or visit Facebook while logged in, your visit to our website is noted in your profile. The data collected on you remains anonymous to us, it therefore provide us no indication as to the identity of the user. However, the data is stored and processed by Facebook, so that it is possible to make a connection to the respective user profile. Insofar as we transmit data to Facebook for cross-checking purposes, this data is encrypted locally on your browser and only then sent to Facebook via a secured https connection. This occurs solely for the purpose of reconciling data likewise encrypted by Facebook.
Insofar as we transmit data to Facebook for cross-checking purposes, this data is encrypted locally on your browser and only then sent to Facebook via a secured https connection. This occurs solely for the purpose of reconciling data likewise encrypted by Facebook.
The processing of data by Facebook occurs within the scope of Facebook's data utilisation guidelines. General information on the display of Facebook ads can be found in Facebook's data utilisation guidelines: www.facebook.com/policy.php. You can find special information and details on Facebook pixel and how it operates in Facebook's Help section: www.facebook.com/business/help/651294705016616.
You can object to collection of data by Facebook pixel and its use in presenting Facebook ads. To do so, refer to the followng webpage created by Facebook and follow the directions there regarding the preferences for user-based advertisement: www.facebook.com/settings, or declare your objection via the US webpage: www.aboutads.com/choices or the EU webpage: www.youronlinechoices.com/uk/your-ad-choices/ erklären. The preferences are platform-independent, meaning, they are adopted by all devices, whether desktop computer or mobile devices.
We embed YouTube videos on some of our websites. The provider of the corresponsing plug-ins is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit a site with the YouTube plug-in, a connection to the servers at YouTube is established. YouTube is thereby notified of which sites you visit. If you are logged into your YouTube account, YouTube can associate your surfing history to you personally. You can prevent this by logging out of your YouTube account.
If you have deactivated the storage of cookies for the Google ad program, then you need not be concerned about this type of cookie when viewing YouTube videos. However, YouTube also collects non-personal user information in other cookies. If you wish to prevent this, you must block cookies from being saved to your browser.
You can find additional information on data privacy at "Youtube“ in the provider's data protection notice at: www.google.de/intl/de/policies/privacy/
5.6 Google AdWords
Our website uses Google conversion tracking. If you link to our website via an ad delivered by Google, Google Adwords places a cookie on your computer. The cookie for conversion tracking is placed on your computer when a user clicks on an ad delivered by Google. These cookies expire at the end of 30 days and do not serve to identify you personally. If the user visits certain pages on our website and the cookie has not yet expired, we and Google can detect that the user clicked on the ad and was routed to this site. Each Google Adwords customer receives a different cookie. Cookies therefore cannot be tracked via websites of Adwords customers. The information obtained with the aid of conversion cookies serves to compile conversion statistics for Adwords customers that have opted into conversion tracking. These customers learn the total number of users that clicked on their ad and that were routed to a page with a conversion tracking tag. However, they do not obtain any information that can be used to identify users personally.
If you do not want to participate in tracking, you can decline to allow the cookie from being placed on your computer -- using, for example, browser settings that deactivate the automatic placement of cookies or set your browser so that it blocks cookies from the domain "googleleadservices.com“.
Please note that you should not delete opt-out cookies if you do not wish to have measurement data recorded. If you have deleted all the cookies in your browser, you will need to set the opt-out cookie again.
5.7 Use of Google Remarketing
This website uses the remarketing feature from Google Inc. ("Google"). This feature serves to present interest-related advertisements to website visitors in the Google ad network. A cookie is saved to the website visitor's browser that makes it possible to recognize the visitor when he/she accesses websites that belong to Google's ad network. Visitors to these websites can be presented with advertisements relating to content that the visitor accessed previously on websites that use Google's remarketing feature.
5.8 Google Maps
This website uses Google Maps API in order to visually display geographic information. When using Google Maps, Google collects, processes and utilises data on use of the map function by users. You can obtain further information on data processing by Google in Google's data protection notice. There you can also make changes to your personal data privacy settings in the data protection centre.
5.9 Use of script libraries (Google webfonts)
We use script libraries and font libraries on this website, such as, for example, Google Webfonts, in order to display our content correctly and in a graphically appealing manner on all browsers (https://www.google.com/webfonts/). Google Webfonts are used to avoid repeat downloads to your browser's cache. If the browser does not support Google Webfonts or blocks access, the content will be displayed in standard font.
Accessing script libraries or font libraries automatically establishes a connection to the provider of the library. It is theoretically possible -- though it is currently unclear whether and for what purpose -- providers collect data on these libraries..
You can find the data privacy guielines for the library provider Google here: www.google.com/policies/privacy/
The IT-partner Bazaarvoice provides the functionalities for questions & answers and product reviews on the Einhell website.
When using the Q&A services of our technical customer support, your personal data is provided to and processed by the IT service provider, Bazaarvoice. The company provides the technical and administrative support of our technical specialists so that we can respond to your questions as quickly as possible.
The services around the topic of product evaluations (reviews and ratings) are also looked after in the system by the company, Bazaarvoice. In addition, customer-specific emails are sent when the Service 2 + 1 warranty extension is used or when the Bazaarvoice interface is used. Therefore we ask for your expicit agreement before sending this one-time eMails to you. In case you accepted this we submit the following information to Bazaarvoice:
- UserID (generated hash value)
- registered Product
- Timestamp of registration
- language settings for mailing (de/en)
The Bazaarvoice data protection guidelines can be found at http://www.bazaarvoice.com/de/privacy-policy/
If the Do-Not-Track feature is activated in the browser, no external Issuu plug-ins will be loaded without approval, only the reference to this option will be displayed.
Our pages use features from Cloudflare. The provider is Cloudflare, Inc. 665 3rd St. #200, San Francisco, CA 94107, USA.
Cloudflare provides a globally distributed content delivery network with DNS. The technical transfer of information between your browser and our website is routed via the Cloudflare network. Cloudflare is thus able to analyse the data traffic between users and our websites; for example, to speed up the loading time of our pages or to detect and ward off attacks on our services.
In addition, Cloudflare may store cookies on your computer for optimisation and analysis. This safeguards our legitimate interests in the security, performance and reliability of our advertising offer in accordance with Art. 6(1)(f) GDPR. We have concluded a corresponding contract processing agreement with Cloudflare on the basis of the GDPR. The data is generally processed in Germany or other states in the European Union. Insofar as processing is carried out in third countries in certain cases, processing is only carried out if the adequacy of the level of data protection in the third country has been asserted by the EU Commission in accordance with Article 45 GDPR, on the basis of the EU standard contractual clauses or if an adequate level of data protection is ensured by the data recipient in another way. Cloudflare collects statistical data about your visit to this website. Access data includes:
- IP address
- Date and time of the request
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser, operating system and its interface, language and version of the browser software
Cloudflare uses the log data for statistical evaluations for the purpose of operation, security and optimisation of the offer. You can find information about the data collected there and about security and data protection at Cloudflare here.
6. Transfer of data
Your personal data is not transferred to third parties, unless required for the purpose of concluding a contract or you have explicitly given your consent. When providing services, it may, for example, be necessary for us to forward your address and order information to your wholesale partner, service partner. If we use external service providers, they are carefully selected and are obligated to comply with all data protection provisions as per Art. 28 GDPR (see figure 5).
Using the links below, you can find out how to manage cookies (or deactivate them, among other things) in major browsers:
- Chrome Browser: https://support.google.com/accounts/answer/61416?hl=en
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Processing is carried out on the basis of § 15 (3) TMG (Telemedia Act) as well as art. 6 (1) lit. f GDPR due to our justified interest in the purposes above. The data collected in this way is pseudonymised using technological measures. It is therefore not possible to connect the data to your person. The data will not be stored together with other personal data pertaining to you.
You can adjust your cookie settings at any time and revoke any previously conceded consents.
You can see a list of the external cookies used when visiting the website in section 5.
8. Contact form
When you contact us by email or contact form, the information you provide is stored for the purpose of processing your query as well as for potential follow-up questions.
If you choose to receive the newsletter offered through the website, we ask that you provide us an email address as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter (double opt-out procedure). In order to personalise the newsletter, we store personal data, such as salutation, first name, last name and email address. We then use this data in sending the requested information and to document your consent. The consent granted to store data, email address and to use it in sending the newsletter may be withdrawn with future effect at any time, either via the link in the newsletter, your Einhell user account or by submitting it in writing to Einhell Germany AG, Wiesenweg 22, 94435 Landau / Isar, Germany, [email protected]. In managing and distributing our newsletter we employ the services of CleverReach GmbH & Co. KG (Muehlenstr. 43 - 26180 Rastede - Germany). To be able to do the newsletter service properly we submit the stated personal data to CleverReach.
10. Statistical Analysis
We require statistical information on the use of our website in order to make the site more user friendly, to conduct audience measurements and to carry out market research. For this purpose, we employ the web analysis tools described in this section.
10.1 Google Analytics
Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). This analysis software is configured in conformity with data protection requirements. More specifically, we use Google Analytics in conjuction with the accessory feature provided by Google for anonymising IP addresses. This tool generally truncates an IP address within the EU and only in exceptional circumstances after it has been transmitted to the US.
You can prevent this tool from collecting and analysing your data by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout
11. Data Security
Our employees and service providers we employ are obligated to maintain confidentiality and to abide by the provisions of applicable data privacy law. The company undertakes appropriate technical and organisational security measures to protect your personal data from loss, alteration, destruction and against access by unauthorised persons and unauthorised dissemination. Our security measures are updated in accordance with technical advancements.
To protect the security of your data during transmission, we use current state-of-the-art encryption processes.
12. Data Retention Period
We generally retain your data for as long as it is needed to provide for use of our website and the services associated with it or for as long as we have a legitimate interest in its continued retention (e.g. following fulfilment of contract, we may still have a legitimate interest in marketing by post). Deletion of data occurs following expiry of statutory or contractual retention periods (e.g. retention periods specified by tax and commercial law). Data not subject to retention periods are deleted once they are no longer needed to fulfill the specified purpose.
13. User Rights
As website user, you are entitled to certain rights. To exercise your rights, please refer to the information in the section on contacts. Please make sure, however, that we are able to clearly identify who you are.
14. Right to obtain information, make corrections and delete data
Pursuant to the General Data Protection Regulation, you may at any time upon request and at no cost receive written information on which data we have stored about you (e.g. name, address). Furthermore, you have the right to correct or delete this data, if statutory requirements have been met. Exempted from this right to delete are, for example, data on business processes that are subject to statutory retention periods.
15. Right to restrict data processing
You have the right to restrict the processing of your personal data.
16. Right to Object
In addition, you have the right to object to the processing of data by us. We will then cease processing your data, except where -- pursuant to statutory provisions -- we can demonstrate compelling legimate grounds for continued procesing that outweight your rights.
17. Right to Data Transferability
Furthermore, upon request we pledge to provide for the transferability of personal data you provide by making this data available in a commonplace and machine-readable data format.
18. Withdrawal of Consent
You may at any time and with future effect withdraw consent to the processing of personal data that you granted us for one or more specific purposes. This does not affect the lawfulness of processing that occured prior to your withdrawal of consent.
19. Automated processing of personal data
Processing of your personal data soley by automated means occurs only if necessary for concluding or fulfilling a contract and if it does not involve any legal or like effect on you.
20. Modification of our data protection provisions
We retain the right to periodically modify this data protection notice so that it meets current legal requirements or in order to implement changes to our services in the data protection notice (e.g. when introducing new services). This data protection notice will then apply to any subsequent visit to the website.
21. Lodging complaints with regulatory authorities
You have the right to direct any complaints about the processing of your personal data to the relevant regulatory authority. You may contact either the data privacy office with jurisdiction at your place of residence or state or the data privacy office with jurisdiction over us. This is the:
Landesamt für Datenschutzaufsicht (State Office for Data Protection Monitoring)
Email: [email protected]
Any suggestions, complaints or questions you may have as regards the processing of your personal data may be directed to our data protection officer. We recommend you send confidential information only via postal mail.
Data Protection Officer Einhell Bulgaria OOD
Einhell Bulgaria OOD
Blvd."Tzar Osvoboditel" No.331
Email: [email protected]
Telefon: +35 952 739 038