We are very pleased that you are interested in Creanon. Data protection is particularly important to us. The Creanon website can generally be used without providing any personal data. However, if a data subject wants to use special company services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Creanon. By means of this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of the rights to which they are entitled by means of this data protection declaration.
As the controller responsible for processing, Creanon has implemented numerous technical and organizational measures to ensure the most complete possible protection of personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us in alternative ways, for example by telephone.
Creanon’s data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
We use the following terms, among others, in this data protection declaration:
a) personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). A natural person is considered to be identifiable if, directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or to one or more special features, the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person can be identified.
b) data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the data controller.
Processing is any process carried out with or without the help of automated procedures or any such series of processes in connection with personal data such as collecting, recording, organizing, arranging, storing, adapting or changing, reading out, querying, using, disclosure by transmission, distribution or any other form of making available, matching or linking, restriction, deletion or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.
Profiling is any type of automated processing of personal data, which consists in using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict that natural person’s preferences, interests, reliability, behavior, whereabouts or relocation.
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data not assigned to an identified or identifiable natural person.
g) Controller or data controller
Verantwortlicher oder für die Verarbeitung Verantwortlicher ist die natürliche oder juristische Person, Behörde, Einrichtung oder andere Stelle, die allein oder gemeinsam mit anderen über die Zwecke und Mittel der Verarbeitung von personenbezogenen Daten entscheidet. If the purposes and means of this processing are specified by Union law or the law of the Member States, the person responsible or the specific criteria for his naming can be provided for by Union law or the law of the Member States.
Processor is a natural or legal person, public authority, institution or other body that processes personal data on behalf of the person responsible.
Recipient is a natural or legal person, public authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law are not considered recipients.
j) third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or the processor, are authorized to process the personal data.
Consent is any expression of will voluntarily given by the data subject in an informed manner and unequivocally for the specific case in the form of a declaration or other clear confirmatory action with which the data subject indicates that they consent to the processing of their personal data is.
2. Name and address of the person responsible for processing
The company responsible within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is:
By means of a cookie, the information and offers on our website can be optimized for the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the online shop uses a cookie to remember the items that a customer has placed in the virtual shopping cart, without having to log in or register.
The person concerned can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
4. Collection of general data and information
The Creanon website collects a series of general data and information each time the website is accessed by an affected person or an automated system. This general data and information is stored in the log files of the server. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites, which are accessed via an accessing system on our website can be controlled, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used to avert threats in the event of attacks on our information technology systems.
When using these general data and information, the Company does not draw any conclusions about the data subject. Rather, this information is required to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website and ( 4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack. Creanon therefore analyzes this anonymously collected data and information statistically, with the aim of increasing data protection and data security in our company, and ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by an affected person.
5. Registration on our website
The data subject has the option of registering on the website of the controller by providing personal data. Which personal data is transmitted to the person responsible for processing results from the respective input mask used for registration. The personal data entered by the person concerned are collected and stored exclusively for internal use by the person responsible for processing and for their own purposes. The person responsible for processing can arrange for the data to be passed on to one or more processors, for example a parcel service provider, who also uses the personal data exclusively for internal use attributable to the person responsible for processing.
By registering on the website of the person responsible for processing, the IP address assigned to the person concerned by the Internet service provider (ISP), the date and time of registration are also stored. This data is stored against the background that this is the only way to prevent misuse of our services and, if necessary, to enable criminal offenses that have been committed to be investigated. In this respect, the storage of this data is necessary to protect the person responsible for processing. In principle, this data will not be passed on to third parties unless there is a legal obligation to pass it on or the passing on is for criminal prosecution.
The registration of the data subject, with the voluntary provision of personal data, enables the data controller to offer the data subject content or services that, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the database of the person responsible for processing.
The person responsible for processing shall provide any data subject with information at any time upon request as to which personal data is stored about the data subject. Furthermore, the person responsible for processing corrects or deletes personal data at the request or notice of the person concerned, provided that there are no legal storage obligations to the contrary.
6. Subscription to our newsletter
On the Creanon website, users are given the opportunity to subscribe to our enterprise’s newsletter. Which personal data is transmitted to the person responsible for processing when ordering the newsletter results from the input mask used for this purpose.
The company Creanon informs its customers and business partners at irregular intervals by means of a newsletter about company offers. The newsletter of our company can only be received by the person concerned if (1) the person concerned has a valid e-mail address and (2) the person concerned registers for the newsletter dispatch. For legal reasons, a confirmation e-mail will be sent to the e-mail address entered by a data subject for the first time for the newsletter dispatch using the double opt-in procedure. This confirmation e-mail is used to check whether the owner of the e-mail address, as the person concerned, has authorized receipt of the newsletter.
When registering for the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP) of the computer system used by the person concerned at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of the e-mail address of a person concerned at a later point in time and therefore serves to provide legal protection for the person responsible for processing.
The personal data collected as part of registering for the newsletter will only be used to send our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or for registration in this regard, as could be the case in the event of changes to the newsletter offer or changes in the technical conditions. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be canceled by the data subject at any time. The consent to the storage of personal data that the person concerned has given us for sending the newsletter can be revoked at any time. There is a corresponding link in every newsletter for the purpose of revoking consent. It is also possible to unsubscribe from the newsletter at any time directly on the website of the person responsible for processing or to inform the person responsible for processing of this in another way.
7. Newsletter tracking
Creanon’s newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, Creanon can see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the person responsible for processing in order to optimize the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the person concerned. This personal data will not be passed on to third parties. Affected persons are entitled at any time to revoke the relevant separate declaration of consent given via the double opt-in procedure. After a revocation, this personal data will be deleted by the person responsible for processing. The company Creanon automatically regards a withdrawal from the receipt of the newsletter as a revocation.
8. Contact option via the website
Due to legal regulations, the Creanon website contains information that enables quick electronic contact to our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a person concerned contacts the person responsible for processing by e-mail or via a contact form, the personal data transmitted by the person concerned will be automatically saved. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. This personal data will not be passed on to third parties.
9. Routine Deletion and Blocking of Personal Data
The person responsible for processing processes and stores the personal data of the person concerned only for the period of time necessary to achieve the purpose of storage or if this is required by the European directive and regulation giver or another legislator in laws or regulations which the person responsible for processing subject, was provided.
If the purpose of storage no longer applies or if a storage period stipulated by the European legislator for directives and regulations or another competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.
10. Rights of the data subject
a) Right to Confirmation
Every data subject has the right, granted by the European directive and regulation giver, to request confirmation from the data controller as to whether personal data relating to them are being processed. If an affected person wishes to make use of this right of confirmation, they can contact the person responsible for processing or any other employee at any time.
b) Right to information
Every person affected by the processing of personal data has the right, granted by the European directive and regulation giver, to receive free information about the personal data stored about him and a copy of this information from the person responsible for processing at any time. Furthermore, the European legislator for directives and regulations has granted the data subject access to the following information:
- the processing purposes
- the categories of personal data being processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria used to determine that duration
- the existence of a right to correction or deletion of the personal data concerning you or to restriction of processing by the person responsible or a right to object to this processing
- the existence of a right of appeal to a supervisory authority
- if the personal data is not collected from the data subject: all available information about the origin of the data
- the existence of automated decision-making including profiling in accordance with Article 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject
Furthermore, the data subject has a right to information as to whether personal data has been transmitted to a third country or to an international organization. If this is the case, the person concerned has the right to receive information about the appropriate guarantees in connection with the transmission.
If an affected person wishes to exercise this right to information, they can contact the person responsible for processing or any other employee at any time.
c) Right to rectification
Every person affected by the processing of personal data has the right granted by the European directive and regulation giver to demand the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to request the completion of incomplete personal data – also by means of a supplementary declaration.
If a data subject wishes to exercise this right to rectification, they can contact the data controller or any other employee at any time.
d) Right to erasure (right to be forgotten)
Every person affected by the processing of personal data has the right granted by the European directive and regulation giver to demand that the person responsible delete the personal data concerning them immediately if one of the following reasons applies and if the processing is not necessary:
- The personal data were collected for such purposes or otherwise processed for which they are no longer necessary.
- The data subject revokes their consent on which the processing is based in accordance with Art. 6 para. 1 letter a DS-GVO or Art. 9 para. 2 letter a DS-GVO and there is no other legal basis for the processing.
- In accordance with Art. 21 para. 1 DS-GVO objection to the processing, and there are no overriding legitimate reasons for the processing, or the data subject submits an objection pursuant to Art. 21 para. 2 DS-GVO objection to the processing.
- The personal data have been unlawfully processed.
- Erasure of the personal data is necessary to fulfill a legal obligation in Union or Member State law to which the controller is subject.
- The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 DS-GVO.
If one of the above reasons applies and a person concerned wishes to have personal data stored at Creanon deleted, he or she can contact the person responsible for processing or any other employee at any time. This person will arrange for the request for deletion to be complied with immediately.
If the personal data was made public by Creanon and our company is responsible according to Art. 17 Para. 1 DS-GVO, Creanon shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other persons responsible for data processing who process the published personal data that the data subject has requested the deletion of all links to this personal data or of copies or replications of this personal data from these other persons responsible for data processing, insofar as the processing is not necessary. The person responsible for processing at Creanon or another employee will arrange the necessary measures in individual cases.
e) Right to restriction of processing
Any person affected by the processing of personal data has the right, granted by the European directive and regulation giver, to demand that the person responsible restrict the processing if one of the following conditions is met:
- The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data.
- The person responsible no longer needs the personal data for the purposes of processing, but the data subject needs them to assert, exercise or defend legal claims.
- The data subject has objected to the processing pursuant to Art. Art. 21 para. 1 DS-GVO and it is not yet clear whether the legitimate reasons of the person responsible outweigh those of the person concerned.
If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored at Creanon, they can contact the data controller or any other employee at any time. This person will arrange for the restriction of processing.
f) Right to data portability
Every person affected by the processing of personal data has the right, granted by the European directive and regulation giver, to receive the personal data relating to them, which the person concerned has provided to a person responsible, in a structured, common and machine-readable format. You also have the right to transfer this data to another person responsible without hindrance by the person responsible to whom the personal data was provided, provided that the processing is based on the consent in accordance with Art. 6 para. 1 letter a DS-GVO or Art. 9 para. 2 letter a DS-GVO or on a contract according to Art. 6 para. 1 letter b DS-GVO and the processing is carried out using automated procedures, unless the processing is necessary for the performance of a task that is in the public interest or in the exercise of official authority that has been transferred to the person responsible.
Furthermore, when exercising their right to data portability in accordance with Art. 20 para. 1 DS-GVO, you have the right to have the personal data transmitted directly from one person responsible to another person responsible, insofar as this is technically feasible and provided that this does not affect the rights and freedoms of other persons.
g) Right to object
Every person affected by the processing of personal data has the right granted by the European directive and regulation giver, for reasons that arise from their particular situation, at any time against the processing of personal data concerning them, which is based on Art. 6 para. 1 letters e or f DS-GVO to file an objection.
Creanon no longer processes the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend of legal claims.
If Creanon processes personal data in order to operate direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. If the data subject objects to Creanon to the processing for direct marketing purposes, Creanon will no longer process the personal data for these purposes.
In order to exercise the right to object, the person concerned can contact the person responsible for processing or any other employee of Creanon directly. In connection with the use of information society services, the data subject is also free, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.
h) Right to withdraw consent under data protection law
Every person affected by the processing of personal data has the right granted by the European directive and regulation giver to revoke consent to the processing of personal data at any time.
If the data subject wishes to assert their right to revoke consent, they can contact the person responsible for processing or any other employee of Creanon at any time.
11. Payment method: Data protection regulations for PayPal as a payment method
The person responsible for processing has integrated PayPal components on this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal also offers the option of processing virtual payments via credit cards if a user does not have a PayPal account. A PayPal account is managed via an email address, which is why there is no classic account number. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also assumes trustee functions and offers buyer protection services.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.
If the data subject selects “PayPal” as the payment option during the ordering process in our online shop, the data of the data subject is automatically transmitted to PayPal. By selecting this payment option, the data subject agrees to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number or other data required for payment processing. Personal data related to the respective order are also required to process the purchase contract.
The transmission of the data is intended for payment processing and fraud prevention. The person responsible for processing will transmit personal data to PayPal in particular if there is a legitimate interest in the transmission. The personal data exchanged between PayPal and the person responsible for processing may be transmitted by PayPal to credit agencies. The purpose of this transmission is to check identity and creditworthiness.
PayPal may pass on the personal data to affiliated companies and service providers or subcontractors insofar as this is necessary to fulfill the contractual obligations or the data is to be processed in the order.
The data subject has the option of withdrawing their consent to the handling of personal data from PayPal at any time. A revocation does not affect personal data that must be processed, used or transmitted for (contractual) payment processing.
PayPal’s applicable data protection regulations can be found at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
12. Legal Basis for Processing
Art. 6 I lit. a DS-GVO serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary to fulfill a contract to which the data subject is party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b DS-GVO. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in the case of inquiries about our products or services. Is our company subject to a legal obligation which requires the processing of personal data, such as the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data could become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GVO. Ultimately, processing operations could be based on Art. 6 I lit. f DS-GVO. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the person concerned do not prevail. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, he took the view that a legitimate interest could be assumed if the data subject is a customer of the person responsible (recital 47 sentence 2 DS-GVO).
13. Legitimate interests in processing pursued by the controller or a third party
Is the processing of personal data based on Article 6 I lit. f DS-GVO is our legitimate interest in conducting our business for the benefit of Creanon.
14. Duration for which the personal data will be stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the deadline, the corresponding data will be routinely deleted, provided they are no longer required to fulfill the contract or to initiate a contract.
15. Statutory or contractual requirements for providing the personal data; Necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a person concerned makes personal data available to us, which must then be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject can contact the person responsible for processing. This clarifies for the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.
16. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
This sample data protection declaration was created by the data protection declaration generator of the DGD Deutsche Gesellschaft für Datenschutz GmbH, the Datenschutzaudit carried out in cooperation with the Medienrechtskanzlei WILDE BEUGER SOLMECKE made.