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Data protection notice
General
Data protection is an extremely important topic for Kulzer. We thus collect, process and use your personal data solely in accordance with legal provisions while respecting the appropriate technical and organizational data security measures.
This Privacy Policy describes the ways in which information about individual persons may be collected, used, disclosed, transferred and stored by Kulzer. The Privacy Policy applies to any interaction with Kulzer, including but not limited to Kulzer’s website and webshop, newsletter sign-up or the distribution of Kulzer products and services including software (“Services”).
What is personal data?
Personal data refers to details of personal or material circumstances of a particular or identifiable natural person. These include without being thereto your civil name, your mailing address, your telephone number or your date of birth.
Data controller and Data Protection Officer (DPO)
Data Controller of your personal data is
Kulzer GmbH
Leipziger Straße 2, 63450 Hanau
Germany
Our Data Protection Officer will be happy to answer any questions you may have regarding these matters:
Michael Adenau
Leipziger Straße 2, 63450 Hanau
Germany
Personal data Kulzer collects
When using Kulzer’s websites in general no personal data is collected, processed or used, unless represented otherwise in the following sections.
Prior to processing your personal data by Kulzer, you will be informed on the facts if and which personal data Kulzer collects. Furthermore you will be informed about this Privacy Policy and it will be stated whether the submission of your personal data is voluntary or necessary (eg. fulfilling a contract or receiving news).
Your personal data is collected in one or several of below cases:
- Use of our websites (IP-Address, Cookies)
- Use of social media
- Newsletter Sign-up (online and offline)
- Contacting us via our contact form, e-mail, telephone, facsimile, letter or personally
- Registering for our Services
- Entering into an agreement with Kulzer
Use of your personal data
Depending on the Services you make use of, different categories of personal data will be collected and used as follows:
Newsletter
On our website, you can subscribe to our newsletter that covers various subjects. We use the so-called double-opt-in procedure for registration. You will receive confirmation by e-mail at the e-mail address that you indicated upon registering, requesting that you confirm that you wish to receive the Newsletter. If you do not confirm within 100 days, your login will be automatically deleted. If you confirm your wish after receiving the Newsletter, we will store your e-mail addresses and other personal registration data until you unsubscribe from the Newsletter and request its deletion. The sole purpose of storage is to be able to send you the newsletter. Further detailed personal data obtained at registration is used for personalizing the Newsletter. Upon cancellation, this data is also completely blocked and not used further. You may withdraw your consent for the transmission of the newsletter at any time by clicking on the unsubscribe link contained in every Newsletter.
With the consent for tracking in our newsletters (so-called tracking permission), we can draw conclusions about the individual usage behaviour of our newsletter subscribers. The tracking permission can be withdrawn separately, i.e. without withdrawing the consent for the subscription of the newsletter itself. Without a tracking permission we cannot draw any conclusions about the usage behaviour of individual subscribers.
Contact
We also collect personal data when you notify us, for example when you contact us. We use and store this personal data exclusively for responding to your requests, for example for forwarding to the relevant internal department and communicating with you.
Communication of such personal data is made on an expressly voluntary basis and with your consent. We will use solely the communications channels you agreed on contacting you to answer your request.
Marketing and registration for services
If you have given us your consent to receive marketing information or legislation allows us to contact you without your prior consent, we will use your personal data for sending you marketing material, eg. our newsletter.
Performance of contracts
For performing contracts with you, we will use the personal data you provided us with. This personal data will be used to fulfil our contractual obligations as well as communicating with you to the extent necessary to perform the agreement.
Statistics
Kulzer keeps statistics about which areas of the site our users visit and which products the users prefer. This data does not contain personal data.
Where personal data (e.g. online identifiers, truncated IP addresses) is processed for these analyses, this is done solely on the basis of your consent; further details can be found in the sections relating to the respective services used. We process aggregated statistics that cannot be linked to specific individuals on the basis of our legitimate interest (Article 6(1)(f) of the GDPR).
Transmission of data to third parties
The collected personal data will be processed by Kulzer and/or affiliated companies under control of Kulzer. In any event the level of data privacy required by the European data protection laws is ensured and maintained at all times. Data Processing by Kulzer may include the transfer of personal data to a third-party including a third party based in a country where the EU GDPR may not apply as the case may be. Such third parties are service providers, suppliers and resellers appointed by Kulzer. In any such appointments Kulzer implemented all safeguards and provisions necessary to ensure the required level of data protection. Your personal data will apart from the above mentioned situations not be sold, shared or otherwise distributed to third parties without your consent, except where Kulzer is required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.
Deletion of your personal data
Kulzer will delete your personal data in the event Kulzer no longer needs to process them in relation to one or more of the purposes set out above, or you explicitly withdraw your consent insofar data processed relied on such consent. You can withdraw your consent at any time, effective as of the date of withdrawal. Data processing legitimized by consent prior to withdrawal remains unaffected by the withdrawal.
Security
We have implemented technical and organizational measures to keep your personal data safe from unauthorized access, loss or alteration. We ensure that our internal procedures meet our high IT and data security policy standards. Accordingly, we strive to protect the quality and integrity of your personal data.
All employees engaged in activities with personal data comply to procedures ensuring confidentiality, integrity and availability of all personal data.
Google Analytics 4 (server-side collection)
Where you have given your consent, this website uses Google Analytics 4 (GA4), a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland ("Google"). The controller for users in the EU/EEA is Google Ireland Limited.
Data is collected server-side (server-side tracking). The events triggered in your browser are first transmitted to a collection endpoint operated by us at the subdomain sst.kulzer.de and forwarded from there to Google. We do not currently apply any additional pseudonymization to the data before forwarding.
The server container used for this is operated by us on Google Cloud Platform in the europe-west1 region (Belgium).
The cookies used for user recognition and session measurement (_ga and ga<ID>) are set via the GA4 client in your browser; on the server side, only the event data is transmitted. Data processed includes, among other things, the truncated IP address, device and browser information, referrer URL, timestamp, pages visited and interaction events. IP truncation is enabled by default in GA4 and cannot be disabled.
Cookies used: "_ga" (visitor recognition) as well as "_ga_DS2TK5KPJ1" and "_ga_X1EZ9LV2QQ" (session/status information per data stream), each with a lifetime of up to 400 days, renewed on every visit.
The user-related data collected in GA4 is automatically deleted after 14 months.
Recipients / third-country transfer: The recipient is Google Ireland Limited; forwarding to Google LLC (USA) as a sub-processor may occur. Google LLC is certified under the EU-US Data Privacy Framework (DPF), so that an adequacy decision pursuant to Art. 45 GDPR exists for the transfer to the USA; in addition, standard contractual clauses pursuant to Art. 46 GDPR are in place. Access by US authorities cannot be entirely ruled out.
Data processing agreement: A data processing agreement pursuant to Art. 28 GDPR is in place with Google.
Legal basis: The processing is carried out exclusively on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. Your consent is managed via our consent management platform (consentmanager, consentmanager AB). You can withdraw your consent at any time with effect for the future via the consent tool.
Google Maps
This site uses the Google Maps map service via an API. It is operated by Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Irland.
To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.
Further information about handling user data, can be found in the data protection declaration of Google at https://policies.google.com/privacy?hl=en-US
Clarity
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
Microsoft Clarity is operated by Microsoft Corporation (USA); the controller in the EEA is Microsoft Ireland Operations Limited. Transfer to the USA may occur; Microsoft Corporation is certified under the EU-US Data Privacy Framework. The processing, including heatmaps and session replays, is carried out exclusively on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG, managed via our consent management platform. You can withdraw this consent at any time with effect for the future.
Meta Pixel and Meta Conversions API
1. Data controller
The data controller within the meaning of the GDPR is:
Kulzer GmbH Leipziger Straße 2 63450 Hanau Germany
2. Description of processing
We use the Meta Pixel and the Meta Conversions API from
Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Meta”) on our website and in our online shop.
These technologies enable us to track user behaviour after they have been redirected to our website by clicking on an advertisement, as well as to analyse interactions within the online shop.
a) Meta Pixel (client-side)
When you visit our website, the Meta Pixel establishes a direct connection to Meta’s servers. In doing so, events are recorded and transmitted to Meta.
b) Meta Conversions API (server-side)
In addition, we transmit event data directly from our web server to Meta on the server side. This allows us to process interactions that are not exclusively recorded via browser cookies.
3. Categories of data processed
The following data, in particular, may be processed during use:
Technical data
- IP address
- Browser type and version
- Device information
- Operating system
- Referrer URL
- Timestamp Usage data
- Pages visited
- Click behaviour
- Scroll behaviour
- Interactions with forms
- Time spent on site Webshop-Data
- Product views
- Shopping basket actions
- Order processes
- LogIn Action (No LogIn Details)
- Transaction ID
- Order value
- Currency
- Payment method (category, not full payment details)
- Customer data (only when Advanced Matching is enabled)
-
- Email address
- elephone number
- First name and surname
- Postcode
This data is cryptographically hashed (SHA-256) before transmission, provided it contains personally identifiable information.
Meta may link this data to existing Meta user accounts.
4. Purposes of processing
- Conversion-Tracking
- Analysis of purchasing behaviour in the online shop
- Measuring the success of advertising campaigns
- Target audience segmentation (Custom Audiences)
- Remarketing
- Advertisement optimisation
- Reducing wasted coverage
- Fraud prevention Cross-device recognition is possible.
5. Profiling
Through the processing of your data, Meta may create user profiles. These profiles may be used for personalised advertising.
We do not carry out any automated decision-making within the meaning of Article 22 of the GDPR.6. Legal basis
Processing takes place exclusively on the basis of your explicit consent in accordance with:
- Article 6(1)(a) of the GDPR
- Section 25(1) of the TDDDG
The Meta Pixel or the Conversions API will not be activated without your consent.
7. Consent management
Your consent is obtained and managed via: consentmanager (consentmanager AB, Schweden) https://app.consentmanager.net/
You may withdraw or amend your consent at any time with future effect.
8. Joint controllership (Article 26 of the GDPR) With regard to the collection and transmission of data via the Meta Pixel, we and Meta share joint responsibility in accordance with Article 26 of the GDPR.
In particular, Meta is responsible for:
- fulfilling information obligations
- ensuring that data subjects’ rights are upheld in relation to the data stored by Meta
The relevant agreement is available at: https://www.facebook.com/legal/controller_addendum
Meta is solely responsible for the further processing of the data. 9. Recipients of the data Recipient of the data is: Meta Platforms Ireland Ltd.
and, where applicable, Meta Platforms Inc., USA.
We do not disclose this information to any other third parties.
Use of third-party social media plugins and services
The following social media plugins are currently used on this website: Facebook, Xing, LinkedIn, X (formerly Twitter).
We use the so-called 2-click solution for them. First, when you visit our site, in principle, basically no personal data is transmitted to the providers of the plugins. You recognize the plugin provider by the marking on the shaded boxes by using the first letter. Data that may be personally correlated is only transmitted when you click on one of the plugins. By activating the plugins, data is automatically transmitted to the relevant plugin provider (by US providers in the USA) and stored. We have no influence on the data collected or data processing operations, nor do we know the full scope of the data collection, its purpose or time limits for storage. If the plugin provider collects data by using cookies, you can take the precaution of deleting all cookies by clicking on the shaded boxes in the security settings on your browser.
When you activate a plugin with the 2-click solution, the plugin provider receives the information that you have called up the corresponding page of our online offer. We do not know what additional data is collected from the plugin provider. According to the plugin provider in Germany, in the case of Facebook, only an anonymized IP is collected.
Additional videos are found on the website of third party provider YouTube stored on http://www.YouTube.com that can be played directly from our website. They are all linked in “extended data protection mode”, i.e. no data concerning you as a YouTube user is transmitted when you do not play the videos. Data is only transferred when you play the videos.
Data is collected by plugins or third party suppliers regardless of whether or not you have an account and/or are logged in. If you are logged in, this data is directly related to your account. When you activate the button using the 2-click solution and, for example, link to the page, the plugin provider also stores this information in your user account and publicly discloses this to your contact. Data collection begins for third party provider YouTube when you play the video. If you do not want your profile to be associated with the plugin or third party supplier, you must log out prior to activating the button.
The plugin provider stores this data as a user profile and generally uses it for advertising purposes, market research and/or the needs-based design of its website. Such an evaluation is conducted in particular (also for users that are not logged in) for displaying appropriate publicity and informing other social network users of your activities on our website. You have a right to object to the creation of this user profile, which you may exercise with regard to the plugin provider. Further information on the purpose and scope of the data collection and its processing by the plugin provider can be obtained in the following data privacy statements disclosed by the providers. They also contain information on your rights and settings options for protecting your privacy:
Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland;
http://www.facebook.com/policy.php;for further information on data collection: http://www.facebook.com/help/186325668085084
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; https://www.google.com/intl/en/policies/privacy/. https://www.google.com/policies/privacy
Cookies
Likewise, we use cookies for the purpose of enhancing our web content. Cookies are text information files that are stored on the web browser of your computer when you open one of our websites. We use this cookie technology to customize our websites according to preferred fields of interest and local settings. Should you wish to block the use of cookies, you may refuse cookies in your browser. For detailed operating instructions, refer to the manual issued by the manufacturer of your browser.
Your rights
If personal data is collected by Kulzer, Kulzer shall, to the extent permitted by law, guarantee your rights to information, rectification, deletion, limitation of processing and objection to processing. Also, the right to transfer the personal data to another data processor is granted. Upon request, Kulzer will provide you with a confirmation of the processing of personal information, as well as your rights. Furthermore, you may receive one (1) free copy of your personal data processed by Kulzer.
If you want us to update, amend or delete the personal data that we have recorded about you, or if you have any questions concerning Kulzer’s Privacy Policy, or if you wish to appeal against the processing of your personal data you may contact us.
Furthermore, you have the right to lodge a complaint to our DPO or your local data protection authority within your jurisdiction. The supervisory authority responsible for Kulzer is the Hessian Commissioner for Data Protection and Freedom of Information (HBDI) in Wiesbaden.
We reserve the right to amend this data privacy policy at any time in full compliance with the applicable rules on data protection.