DATA PROTECTION

Privacy Policy

1. Introduction

This website is provided by TA Triumph-Adler. Please find below information about how your personal data is processed when you access and use our website, as required under Article 13 of the General Data Protection Regulation (GDPR).

2. Controller

Names and contact details for the controller can be found in our Legal Notice.

3.  Data protection officer 

You can contact our data protection officer in writing at the address shown in the Legal Notice. Please mark the envelope ‘FAO Data Protection Officer’. Alternatively, please use the e-mail address datenschutz@triumph-adler.net.

4. Processing of personal data

4.1. General overview of processing activities

We offer various services on our web pages, which are listed below:

  • Operation of the website and log files

Processing of certain personal data in order to provide our website. 

  • Use of cookies

List of cookies used in order to provide our services.

  • E-mail newsletter

Sign up with your e-mail address if you would like to be informed about news from TA Triumph-Adler, such as product launches, events and articles from the TA blog ‘TAlking-Future’. 

  • Contact forms

Fill in the form so that we can contact you.

  • White papers, executive briefs and infographics

Fill in the form to sign up for white papers, executive briefs or infographics. 

  • Events and webinars

Fill in the form to sign up for our events or webinars. We will send you confirmation of your participation and information about the event/webinar.

  • Job applications

You can apply for jobs with us online. Data is processed only for application purposes.

  • Map display and geolocation

In order to optimise support in your region, we have integrated the Google Maps service to help you find your local point of contact.

  • Tracking, retargeting and online advertising

We use various technologies to optimise the design of our website, to measure the success of our advertising and to be able to show you suitable advertising.

  • Customer satisfaction surveys

To improve our quality of service and to better tailor our services to your needs, we use online customer satisfaction surveys. You can participate in these by clicking the link on our website or in the e-mail we send you.

  • Social media fanpages and Custom Audiences

On our social media fanpages in Facebook and LinkedIn, we provide further information about our services. Using Custom Audiences technology, we can make social media advertising more effective by showing posts only to visitors of our website, for example. 

To be able to offer these processing activities and to continuously optimise our website, we use the services of other service providers on our website. In this respect, data, including personal data, is sent to the following service providers and used by them. 

We select these service providers carefully and obligate them under contract to comply with statutory requirements, for example in their capacity as ‘processor’ in accordance with Article 28 GDPR. If these providers process your data outside the European Union or the European Economic Area, we make sure that they are bound by EU Standard Contractual Clauses or, in the case of processing in the US, that they are certified under the US-EU Privacy Shield. As a result, these providers guarantee an appropriate level of data protection.

4.2. Operation of the website and use of log files

4.2.1. Nature and extent of personal data processing

The following information, which your browser automatically transmits to us, is processed when you visit our website:

  • Browser type/version
  • Operating system used
  • Name of the previously visited website
  • IP address/host name of your device
  • Date and time of the server request

External fonts provided by Google are used on our website. These fonts (fonts.googleapis.com, googleusercontent.com, fonts.gstatic.com.) are integrated by accessing a server, typically a Google server in the US. Which of our websites you have visited will therefore be transmitted to the server. Google also processes the IP address of the browser used on the website visitor’s device. When you view a page, your browser loads the fonts you need to display text in a consistent format.

4.2.2. Purposes and legal basis of personal data processing

Your personal data is processed in accordance with point (b) of Article 6(1) GDPR to enable use of the website and to display journalistic content on the subject of digitalisation.

We process your personal data on the basis of our legitimate interest within the meaning of point (f) of Article 6(1) GDPR in order to

  • ensure the proper operation of the website,
  • fulfil legal obligations and ensure security of processing, e.g., to defend against and investigate cyber-attacks, and
  • to optimally display our website quickly using a uniform typeface. 

4.2.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

Our website is hosted by DOM Digital Online Media GmbH, Bismarck Str. 60, 50672 Cologne, Germany. A data processing agreement in accordance with Article 28 GDPR has been entered into with the processor.

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Republic of Ireland is the controller in respect of the personal data processing for displaying the fonts. When the website is accessed, your personal information is transferred to a third country, namely to the parent organisation Google LLC, 1600 Amphitheater Parkway Mountain View, CA 94043, USA. The European Commission decided in its Adequacy Decision (EU) 2016/1250 of 12 July 2016 (EU-US Privacy Shield) that there is an adequate level of data protection in the USA. The corresponding certificate can be found here here.

Your personal data is shared with state institutions, public authorities or legal counsel only within the framework of mandatory national legislation or if this is necessary to establish, exercise or defend our or third-party legal claims.

4.2.4. Duration of storage

Personal data is deleted automatically 14 months after the connection was made, unless statutory retention periods require otherwise. We do not know whether and for how long Google processes your data.

4.2.5. Right to erasure, objection and rectification

Data needs to be collected in order to provide the website and needs to be stored in log files for the website to operate. The user therefore has no erasure, objection or rectification options when it comes to operation of the website.

You can prevent data processing for the displaying of Google fonts by disabling the JavaScript technology in your browser on your computer. A standard font from your device will then be displayed. If you do so, however, not all the functions of the website will be available to you.

4.2.6. Other

You can find more information about the service provider Google

4.3. Use of Cookies

4.3.1. Nature and extent of personal data processing

Disable TA Cookies

4.3.2. Purposes and legal basis of personal data processing

 The processing of necessary cookies on your device is based on our legitimate interest within the meaning of point (f) of Article 6(1) GDPR to save the settings you have made for current and future use of our website.

The processing of all other cookies is based on your consent under point (a) of Article 6(1) GDPR in conjunction with Article 7 GDPR.

4.3.3. Duration of processing, ability to object and to disable cookies 

Cookies are stored on your computer and transmitted by your computer to our site. As a user, you therefore have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Already saved cookies can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may not be possible to use all the functions of the website in full.

4.4. E-mail newsletter

4.4.1. Extent of personal data 

Our website allows you to receive free e-mail newsletters on a regular basis to inform you about our latest interesting offers and news. When you sign up for the e-mail newsletter, the following data is sent to us.

  • E-mail address (required)
  • Personal data such as title, first name, last name (optional)
  • IP address of the computer you are using
  • Date and time of sign-up and confirmation
  • Opening and click rate through pixel technology within the e-mail

We use double opt-in for the sign-up procedure. In other words, we will only send you e-mail newsletters if you confirm you wish to sign up after you have provided your e-mail address, using the e-mail we send you and the link contained therein.

Sign-up and confirmation are logged. This is to ensure that only you yourself can sign up for the newsletter service as the user of the specified e-mail address. Your confirmation must be made promptly, otherwise your sign-up and e-mail address will not be transmitted to TA Triumph-Adler. Until you have provided confirmation, our newsletter service will not accept any further sign-ups using this e-mail address.

4.4.2. Purposes and legal basis of processing 

The user’s e-mail address is collected in order to deliver the e-mail newsletter to the correct target group. The legal basis of data processing after you have signed up for the newsletter is point (b) of Article 6(1) GDPR. 

Sign-up and confirmation are logged in order to prove you have signed up and, if necessary, to be able to investigate any misuse of your personal data. We also have a legitimate interest in doing so in accordance with point (f) of Article 6(1) GDPR. No overriding legitimate interest on your part is apparent that would prevent us from processing this data. The logging is also in your interest, as it prevents unauthorised third parties signing up as you.

We also analyse, in accordance with point (f) of Article 6(1) GDPR, whether you have opened and read the e-mail newsletters and, if so, whether you clicked any links. This enables us to

  • maintain our mailing lists and delete non-interested readers from our lists.
  • determine which of our articles were particularly interesting in order to optimise our journalistic offering.

No overriding legitimate interest on your part is apparent that would prevent us from processing this data. By collecting statistical data, we ensure that we can offer you articles that are continuously optimised for your interests.

4.4.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

For sending out our e-mail newsletter, we use the service provider CleverReach® GmbH & Co. KG (Mühlenstrasse 43, 26180 Rastede, Germany) as well as the service provider Salesforce for other processing. If you sign up for our newsletter, the data provided during sign-up is collected by TA Triumph-Adler, provided you confirm the sign-up process (received e-mail with confirmation link). The data is transferred to CleverReach and Salesforce, where it is processed in order to create the mailing list and to send out the newsletter.

Your data is transmitted to Salesforce (Salesforce Germany GmbH, Erika-Mann-Strasse 31, 80636 Munich, Germany, a company of Salesforce.com EMEA Limited, village 9, floor 26 Salesforce Tower, 110 Bishopsgate, London, UK, EC2N 4AY as well salesforce.com Inc. The Landmark @ One Market, Suite 300, San Francisco, CA 94105, USA.) EU standard contract clauses have been concluded with the processor on the basis of point (c) of Article 46(2) GDPR.

4.4.4. Duration of storage

Your personal data is deleted at your request or when the service is discontinued. There is an unsubscribe link in every e-mail newsletter.  The contents of non-confirmed sign-ups for the e-mail newsletter are not transferred to TA Triumph-Adler. Transfer takes place only when the link in the received e-mail is confirmed, otherwise the contents are deleted.

4.4.5. Right to erasure, objection and rectification

You can unsubscribe from our e-mail newsletter at any time by clicking ‘Unsubscribe’ at the bottom of the e-mail newsletter or by sending a short e-mail to abmeldung@triumph-adler.net. After unsubscribing, you will no longer receive e-mail newsletters. If your e-mail address has to be processed by us for other reasons, your e-mail address will be blocked for the sending of e-mail newsletters.

4.4.6. Consequences of not providing data

Our e-mail newsletter is a voluntary service. We need an e-mail address in order to send out our e-mail newsletter.

4.4.7. Other information

CleverReach also uses the Google Analytics analytics tool (see point 4.11). More information about CleverReach and privacy at CleverReach can be found (in German) here: https://www.cleverreach.com/de/datenschutz/

More information about privacy at Salesforce can be found (in German) here: https://www.salesforce.com/de/campaign/gdpr/

4.5. Contact forms 

4.5.1. Nature and extent of personal data processing 

Through our website, you can use our contact form for the following topics that you can select: ‘Consultation, Events, Feedback, Career, Press Inquiry, Products, Arrange call-back, Service, Support, TA Cockpit, Environment, Company’. The following data is transmitted to us when you use the contact form.

  • First name, position, telephone number, customer number (optional)
  • Title, last name, company, e-mail, postcode, customer (yes/no) (required)
  • When ‘Arrange call-back’ is selected, the phone number is required and the e-mail is optional
  • When ‘Career’ is selected, the ‘company’ field is not available
  • Indication of consent to receive the newsletter
  • Date and time the contact enquiry is sent

For data processing, your consent is obtained as part of the contact form and reference is made to our Privacy Policy. We use the opt-in procedure for the contact form. In other words, we transmit your contact details and message, provided you have acknowledged the Privacy Policy. Your data is logged and, if a quote or consultation is involved, recorded in our CRM for our sales team. All other possible selection fields such as Events, Feedback, Career, Press, Call-back, Service, Support and TA Cockpit are forwarded to the appropriate department to answer your enquiry.

4.5.2. Purposes and legal basis of personal data processing

User data is collected so as to answer the enquiry satisfactorily and, if desired, to provide it to our sales team for further consultation. The legal basis of processing the data after the user has used the contact form is point (a) of Article 6(1) GDPR (consent).  The IP address, time of sign-up and the data you send to us by e-mail are processed on the basis of point (f) of Article 6(1) GDPR. If the purpose of the e-mail contact is to initiate or execute a contract, the legal basis of processing is point (b) of Article 6(1) GDPR.

4.5.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

Your data is transmitted to authorised employees within our company. In addition, processors, such as IT service providers are used, who are responsible for operation, support and maintenance. There is no transmission of your data to a third country or international organisations.

4.5.4. Duration of storage

Data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data from the contact form input screen and data sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the matter in question has been resolved. The additional personal data collected during the sending process is deleted no later than after a period of one year.

4.5.5. Right to erasure, objection and rectification

You are able to withdraw your consent to the processing of your personal data at any time. If you contact us by e-mail, you may object to your personal data being stored at any time. In such a case, the conversation cannot continue. All personal data stored in the course of contact will be deleted in this case.

4.5.6. Consequences of not providing data

Our contact form is a voluntary service that we offer to you on our website. To transmit your contact enquiry, the required information listed above (under 4.5.1) as well as acknowledgement of our Data Privacy are necessary.

4.6. White papers, executive briefs and infographics

4.6.1. Nature and extent of personal data processing

Our website allows you to be sent white papers, executive briefs and infographics. If you request these, the following data is sent to us:

  • Customer (yes/no), title, e-mail address, (required)
  • Title, first name, last name, company, position (optional)
  • Date, time the contact enquiry is sent
  • Information about the sending of other e-mail newsletters or product information

We use double opt-in for the sign-up procedure. In other words, we will only send you the requested content if you confirm you wish to sign up after you have provided your e-mail address, using the e-mail we send you and the link contained therein.

Your request and confirmation are logged. This is to ensure that only you yourself can sign up for the download as the user of the specified e-mail address. Your confirmation must be made promptly, otherwise your sign-up and e-mail address in the database of the service provider will not be transmitted to us and will be deleted. Until you confirm, we will not send anything to this e-mail address.

If you have given your consent in the download form to receive the newsletter or future white papers, you will also receive confirmation links for these services in the e-mail we send you.

4.6.2. Purposes and legal basis of processing

The legal basis of data processing is point (a) of Article 6(1) GDPR (consent). The logging of your request, the processing of the IP address, the respective information material and the time are used to facilitate and prove your sign-up and, if necessary, to investigate any misuse of your personal data. We also have a legitimate interest in doing so in accordance with point (f) of Article 6(1) GDPR.

4.6.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

For sending out the information materials, we use the service provider CleverReach® GmbH & Co. KG (Mühlenstrasse 43, 26180 Rastede, Germany) as well as the service provider Salesforce for other processing. If you sign up for our information material, the data provided is collected by TA Triumph-Adler, provided you confirm the sign-up process (received e-mail with confirmation link). The data is transferred to CleverReach and Salesforce, where it is processed in order to create the mailing list and to send out the information.

Your data is transmitted to Salesforce (Salesforce Germany GmbH, Erika-Mann-Strasse 31, 80636 Munich, Germany, a company of Salesforce.com EMEA Limited, village 9, floor 26 Salesforce Tower, 110 Bishopsgate, London, UK, EC2N 4AY as well salesforce.com Inc. The Landmark @ One Market, Suite 300, San Francisco, CA 94105, USA.) EU standard contract clauses have been concluded with the processor on the basis of point (c) of Article 46(2) GDPR.

4.6.4. Duration of storage

Your personal data is deleted if you withdraw your consent or when the service is discontinued. 

4.6.5. Right to erasure, objection and rectification

If you have given your consent in the download form to receive white papers on a regular basis, you can unsubscribe from the service at any time by clicking ‘Unsubscribe’ in the e-mail you receive or on the website, or by sending a short e-mail to abmeldung@triumph-adler.net. After unsubscribing, you will no longer receive white papers. If your e-mail address has to be processed by us for other reasons, your e-mail address will only be blocked for e-mail newsletters and/or download mailings.

4.6.6. Consequences of not providing data

The sending out of our information materials is a voluntary service. To transfer the content, the required information listed above and acknowledgement of the Privacy Policy are necessary.

4.6.7. Other

CleverReach also uses the Google Analytics analytics tool (see point 4.11). More information about CleverReach and privacy at CleverReach can be found (in German) using the following Link.

More information about Salesforce can be found (in German) using the following Link.

4.7. Events and webinars

4.7.1. Nature and extent of personal data processing

Our website allows you to sign up for our events or webinars. The following data is transmitted to us when you use the sign-up form.

  • Title, first name, last name, e-mail, company, postcode, customer (yes/no) (required)
  • Telephone number, position (optional)
  • Indication of consent to receive the e-mail newsletter
  • Date and time the sign-up is sent

We use the opt-in procedure for signing up. In other words, we transmit your contact details, provided you have acknowledged the Privacy Policy. Your data is logged. If your query is about a webinar, your sign-up details will be sent to our service provider ‘GoToWebinar’.

4.7.2. Purposes and legal basis of personal data processing

The legal basis of data processing during sign-up and participation in our events and webinars is point (b) of Article 6(1) GDPR. The respective conditions of participation apply.

The logging of your request, the processing of the IP address and the time are used to facilitate and prove that you have signed up and, if necessary, to investigate any misuse of your personal data. We also have a legitimate interest in doing so in accordance with point (f) of Article 6(1) GDPR.

4.7.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

Your personal information is processed by authorised personnel within our company for planning and running events and webinars. Other processors are used for the running of events and webinars.

In order to run webinars, your personal data (title, first name, last name, company, postcode, e-mail, customer yes/no) is shared with our service provider GoToWebinar (LogMeIn Ireland Limited, Bloodstone Building Block C, 70 Sir John Rogerson’s Quay, Dublin 2, Republic of Ireland – part of LogMeIn, Inc., 320 Summer Street, Boston, MA 02210, USA). The parent organisation LogMeIn Inc. is certified under the US-EU ‘Privacy Shield’ data protection agreement and is thus committed to comply with European data protection requirements. You can find the certificate for the service provider here. A data processing agreement (EU standard contract clauses) has been concluded with the processor on the basis of point (c) of Article 46(2) GDPR.

4.7.4. Duration of storage

We do not know whether or for how long LogMeIn stores the above data.

4.7.5. Right to erasure, objection and rectification

Your personal data is deleted if you request such deletion using the addresses specified in point 5 or when the service is discontinued.

4.7.6. Consequences of not providing data

Participation in our events is voluntary. Participation is not possible unless the data listed in 4.7.1 is provided.

4.7.7. Existence of automated decision-making or profiling

No automated decision-making or profiling takes place.

4.7.8. Other

More information about the service provider we use can be found here.

4.8. Job applications

4.8.1. Nature and extent of personal data processing

Our website allows you to submit online job applications. For online job applications, we use the service ‘Softgarden’. When using the form, the following data is sent to Softgarden and TA Triumph-Adler in encrypted form.

  • Personal master data (such as title, first and last name, date of birth, address)
  • Communication data (e-mail address and telephone number)
  • Application data (covering letter, CV, attachments, certificates and other information provided by you)
  • IP address, date and time the application is sent

We use the opt-in procedure when using the form. In other words, we transmit your contact details, provided you have acknowledged the Privacy Policy. Your details and confirmation are logged. You can also create a CV using the social media platforms Xing, LinkedIn or Softgarden. To do so, you have to log in to your user account with the respective provider.

4.8.2. Purposes and legal basis of personal data processing

We collect and process your personal data in order to initiate and potentially establish a contractual relationship. When initiating a working relationship, in particular an employment relationship, the legal basis of processing is Article 88 GDPR in conjunction with Section 26 Federal Data Protection Act (BDSG).

There may be a possibility that your personal data will be used to establish, exercise and defend legal claims, if you or we have or assert legal claims. In such a case, the legal basis would be point (f) of Article 6(1) GDPR. In accordance with said provision, the processing of personal data is lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, except where such interests of the controller or third party are overridden by your interests or rights in excluding such processing.

The legitimate interests of the controller or a third party then lie in the establishment, exercise or defence of legal claims. If legal bases are mentioned in this information, the versions thereof as amended apply to the processing of personal data.

4.8.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

Your application data is processed within the company, to the extent that this is necessary in order to establish the employment relationship. Furthermore, processors within the meaning of Article 28 GDPR are used, who are responsible for the operation and maintenance of our network, the devices and applications used. For online applications, we use the processor Softgarden (Softgarden e-recruiting GmbH, Tauentzienstrasse 14, 10789 Berlin, Germany). No transmission to third countries or international organisations takes place.

4.8.4. Duration of storage, right to erasure, objection and rectification

Data is stored until the application process is completed. Should we opt for another candidate, your data will be deleted after you have been rejected. In individual cases, data may be stored beyond the decision selecting another candidate for the position. This would be the case, for example, if there are indications that you might file claims against us. Data is then stored for as long as the processing of the data is necessary for the establishment, exercise or defence of legal claims. In this case, the criteria governing the storage period may include the time limits laid down in legislation such as Section 15(4) first sentence General Equal Treatment Act, Section 61b Labour Court Act, statutory limitation periods or statutory storage obligations.

In addition, data may be stored if this is provided for or mandated by the European or national legislator in EU Regulations, legislation or other rules to which the controller is subject.

4.8.5. Consequences of not providing data

For the application process, you are not required to provide us with personal data. However, we will not be able to complete the application process if we do not have the personal data that is necessary to assess your professional background, qualifications, availability and to get in touch. The use of our online application service is voluntary. As an alternative, you can also send us your application documents in writing.

4.9. Map display and geolocation

Our website uses Google Maps to show you where our offices are located and to make it easier for you to find us.  
4.9.1. Nature and extent of personal data processing
When accessing this website, personal data as referred to in point 4.2.1. is automatically transferred to the service provider.

4.9.2. Purposes and legal basis of processing
Your personal data is processed in order to display the TA locations (legitimate interest within the meaning of point (f) of Article 6(1) GDPR).

4.9.3. Recipients or categories of recipients, transmissions to a third country and presence of an adequacy decision
By accessing the corresponding webpage, Google (Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Republic of Ireland) receives the above information and thus information about which of our websites you have visited. If you are logged in as a member of Google LLC, Google Maps associates this information with your personal user account. The European Commission decided in its Adequacy Decision (EU) 2016/1250 of 12 July 2016 (EU-US Privacy Shield) that there is an adequate level of data protection in the USA. The corresponding certificate can be found here.

4.9.4. Storage duration and, if applicable, criteria for determining the storage duration
We do not know whether or for how long Google stores the above data.

4.9.5. Right to erasure, objection and rectification

It is technically possible that Google could use the data obtained to identify at least some users. We have no control over the processing by Google of personal data and personality profiles of website users for other purposes.

You can easily disable the Google Maps service and thus prevent data transfer to Google. To do so, disable JavaScript in your browser. We would point out, however, that you may not be able to use the map display in this case.

For more information, see the Google Maps Terms of Service and the Google Privacy Policy

4.10. Google reCAPTCHA

Our website uses Google reCAPTCHA to ensure that inputs are made by a natural person.

4.10.1. Nature and extent of personal data processing
When accessing this website, personal data as referred to in point 4.2.1. is automatically transferred to the service provider. 

4.10.2. Purposes and legal basis of processing
In order to ensure adequate data security when transmitting information, we use the Google reCAPTCHA service in some cases. This is mainly used to distinguish whether the input is made by a natural person or improperly by machine and automated processing. Your personal data is processed on the basis of our legitimate interest within the meaning of point (f) of Article 6(1) GDPR in ensuring the security of our website.

4.10.3. Recipients or categories of recipients, transmissions to a third country and presence of an adequacy decision
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Republic of Ireland is the controller in respect of the personal data processing for displaying the fonts. When the website is accessed, your personal information is transferred to a third country, namely to the parent organisation Google LLC, 1600 Amphitheater Parkway Mountain View, CA 94043, USA. The European Commission decided in its Adequacy Decision (EU) 2016/1250 of 12 July 2016 (EU-US Privacy Shield) that there is an adequate level of data protection in the USA. The corresponding certificate can be found here here.

4.10.4. Storage duration and, if applicable, criteria for determining the storage duration

We do not know whether or for how long Google stores the above data.

4.10.5. Other

It is technically possible that Google could use the data obtained to identify at least some users. We have no control over the processing by Google of personal data and personality profiles of website users for other purposes.

If you do not consent to data being transmitted to Google, then you should not visit subpages of our website where Google reCAPTCHA is integrated.

Google’s deviating data privacy regulations apply in this respect. More information can be found in the Google Privacy Policy.

Tracking, retargeting and online advertising

4.11. Google Analytics incl. Google Tag Manager

4.11.1. Nature and extent of personal data processing

This website uses Google Analytics, a web analytics service provided by Google. Google Analytics uses ‘cookies’, which are text files placed on your computer that enable analysis of your use of the website. The data referred to in point 4.2.1 is processed in this respect.

We also use Google Tag Manager. Through this service, website tags can be managed through a user interface. Google Tool Manager only implements tags. In other words, no cookies are used and no personal data is collected. Google Tool Manager triggers other tags, which may, in turn, collect data. However, Google Tag Manager does not access this data. If this service has been disabled at domain or cookie level, all tracking tags are disabled.

4.11.2. Purposes and legal basis of personal data processing

On our behalf, Google uses this information to evaluate your use of the website, to compile reports on website activity and to provide other services to us relating to website activity and Internet usage.  Data is processed on the basis of your consent within the meaning of point (a) of Article 6(1) GDPR in conjunction with Article 7 GDPR.

4.11.3. Recipients or categories of recipients, transmission of your data to a third country and presence of an adequacy decision

The operator of the Google Analytics component is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Republic of Ireland. We use the extension ‘gat.anonymizeIp’ for web analytics via Google Analytics. By means of this extension, Google truncates and anonymises the IP address of the data subject’s Internet connection if our websites are accessed from a Member State of the European Union or from another state party to the Agreement on the European Economic Area. Personal information is transferred to a third country, namely to the parent organisation Google LLC, 1600 Amphitheater Parkway Mountain View, CA 94043, USA. The European Commission decided in its Adequacy Decision (EU) 2016/1250 of 12 July 2016 (EU-US Privacy Shield) that there is an adequate level of data protection in the USA. The corresponding certificate can be found here here.

4.11.4. Duration of processing/Right to erasure, objection and rectification

When you visit our website for the first time, a cookie notice will be displayed. Unless you disable the setting of cookies, tracking is activated. However, this data is deleted by Google after 14 months. If you reject the cookie notice, you can visit our website without tracking. You can also prevent cookies being stored by setting your browser software accordingly.  Furthermore, you can prevent Google from collecting and processing data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available at Link.

As an alternative to the browser add-on, especially for browsers on mobile devices, you can prevent Google Analytics from collecting data by withdrawing your consent in Section 4.3.1 (Cookies). An opt-out cookie is set in this respect, which prevents your data from being collected when you visit this website in the future. The opt-out cookie is only valid for this browser and only for our website, and is stored on your device. If you delete cookies from this browser, you will have to set the opt-out cookie again.

4.11.5. Consequences of not providing data

If you disable tracking, we would point out that you may not be able to use all the features of our website in full.

4.11.6. Other information

More information about data privacy in relation to Google Analytics can be found in the Privacy Policy and in Google Analytics Help.

4.12. Google Ads and Google Ads Conversion

4.12.1. Nature and extent of personal data processing

We use Google’s online advertising tools ‘Google Ads’ and ‘Google Ads Conversion’ to promote our attractive offerings on external websites. These tools allow us to determine how successful individual advertising measures are. Our interest in this respect lies in showing you interesting advertisements and thus to achieve a fair calculation of advertising costs. When accessing this website, personal data as referred to in point 4.2.1. is automatically transferred to the service provider.

Because of the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no control over the extent of and further use of data collected by Google using this tool and the information provided here is to the best of our knowledge: Through the integration of Ads Conversion, Google is informed that you have accessed the relevant part of our website or have clicked one of our adverts. If you are registered with a service provided by Google, Google can associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may learn of and store your IP address.

4.12.2. Purposes and legal basis of personal data processing

When you click an advert placed by Google, a conversion tracking cookie is placed on your computer. The information gathered using the conversion cookie is used to generate conversion statistics for us. In this respect, we find out the total number of users who clicked our ads and were redirected to a page equipped with a conversion tracking tag. However, we do not receive any information that enables us to identify users in person. Your data is processed for the ‘Google Ads’ online advertising tool on the basis of your consent within the meaning of point (a) of Article 6(1) GDPR in conjunction with Article 7 GDPR.

4.12.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

The operator of the Google Analytics component is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Republic of Ireland. Personal data is transferred to a third country. The European Commission decided in its Adequacy Decision (EU) 2016/1250 of 12 July 2016 (EU-US Privacy Shield) that there is an adequate level of data protection in the USA. The corresponding certificate can be found here here.

4.12.4. Duration of storage/right to erasure, objection and rectification

The storage duration can be found in the table in point 4.3.1. If you do not want tracking to be used, you can object to it by setting your browser software accordingly to prevent the installation of third-party cookies. You will then not be included in the conversion tracking statistics.

You can prevent Google Analytics from collecting data by withdrawing your consent in Section 4.3.1 (Cookies). An opt-out cookie is set in this respect, which prevents your data from being collected when you visit this website in the future. The opt-out cookie is only valid for this browser and only for our website, and is stored on your device. If you delete cookies from this browser, you will have to set the opt-out cookie again.

Furthermore, you can prevent Google from collecting and processing data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available at Link.

We would point out, however, that you may not be able to use all the functions of this service in full in this case.

4.12.5. Other information 

More information on data privacy and functions is available from Google Ads and in the Google Privacy Policy.

4.13. Native advertising: Outbrain and Accado

4.13.1. Nature and extent of personal data processing 

The technology provided by Outbrain UK Ltd, 5 New Bridge Street, London, EC4V 6JA, UK (‘Outbrain’) and Accado - a unit of Performics-Newcast GmbH (‘Accado’) allows us to use cookies that are stored on your computer/device to refer you to further content on our website or on third-party websites that may be interesting for you. Recommendations integrated by Outbrain and Accado are determined on the basis of the content that you have previously read. In technical terms, the content is automatically controlled and delivered by Outbrain and Accado. Content is displayed on a pseudonymised basis. Personal data is not stored in this respect. To select appropriate content, the cookie uses information on the 

  • device source
  • browser type and 
  • your IP address, which has been completely anonymised by removing the last octet.

We also use the remarketing or ‘Custom Audience’ feature from Outbrain and Accado. This allows us to provide individualised, interest-based advertising for visitors to the TA website. Outbrain and Accado use cookies to analyse website use. As a result, website visitors and anonymous data about the use of the website are collected.

4.13.2. Purposes and legal basis of personal data processing

When you access our website, data is used for the Outbrain and Accado services on the basis of your consent within the meaning of point (a) of Article 6(1) GDPR in conjunction with Article 7 GDPR.

4.13.3. Recipients or categories of recipients, transmission of your data to a third country and presence of an adequacy decision

Your personal information is transmitted to Outbrain UK Ltd., 5 New Bridge Street, London, EC4V6JA, UK, a subsidiary of Outbrain Inc., 39 West 13th Street, New York, NY 10011, USA.

In the case of Accado, personal data is transmitted to AdSpirit GmbH, Niedstr. 40-41, 12159 Berlin, Germany.

To the extent that data is provided to Outbrain and is transferred to Outbrain Inc. or to any other recipient outside the EU/EEA, Outbrain ensures that the transfer is made in accordance with EU data protection rules by ensuring an adequate level of protection for such data and that adequate safeguards have been set up to protect the data.

4.13.4. Duration of storage/right to erasure, objection and rectification

Your personal data is deleted at your request or when the service is discontinued. You may opt out of tracking for the display of interest-based recommendations at any time by setting an opt-out cookie: 

Disable Outbrain

Disable Accado

Please note that you have to set the opt-out cookie separately in each device that you use to access our websites.

4.13.5. Consequences of not providing data 

After opting out, you will continue to be offered interesting additional content; however, this will no longer be based on how you have previously used our websites in the past.

4.13.6. Existence of automated decision-making incl. profiling

The recommendations made by Outbrain and Accado are based on: (i) your browsing history; (ii) similar surfing patterns of other users; (iii) recommendations that are popular with Outbrain’s addressees at any given time; (iv) a certain degree of randomness; and (v) target requirements provided or required by the controller.

4.13.7. Other information

More information about data privacy and Outbrain can be found at http://outbrain.com/legal/privacy.

More information about data privacy and Accado can be found at http://www.accado.de/kontakt/datenschutz

 

Social media fanpages and Custom Audiences

4.14. Facebook fanpages

On our fanpage provided by Facebook (Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Republic of Ireland) we provide further information about our services.

4.14.1. Nature and extent of personal data processing

We use your personal data, which you transmit to Facebook when using the fanpage, in order to analyse use of our fanpage and to tailor our services to the correct target group.

In this respect we use statistical reports such as the total number of page views, likes, devices used, page activity, post interactions and reach, user activity (comments, shared content, responses), origin (country and city), language, views and clicks in the shop, age group, gender, education, occupation, relationship status, clicks on phone numbers or Facebook groups linked to our site.

We use, for example, break-downs according to age and gender for a tailored approach, attractive design and the preferred visit times of users to optimise our posts in terms of time and content.

4.14.2. Purposes and legal basis of processing

For the information service provided, we adopt joint controllership within the meaning of Article 26 GDPR with Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Republic of Ireland. In accordance with point (f) of Article 6(1) GDPR, the legal basis of processing is our legitimate interest in attracting attention to our services and being able to contact you.

4.14.3. Right of access, right to rectification, objection and erasure

Since only Facebook has full access to user data, we recommend that you contact Facebook directly if you wish to assert your rights as described in point 5.

Alternatively, you can obtain support from us at the address referred to in point 3 to assert your rights against Facebook.

More information on Facebook fanpages can be found using the links on Page Insights and Privacy.

Facebook’s full data use policy provides an overview of all data processing by Facebook. The policy also provides information about ways to contact Facebook and ad settings.

 

Customer satisfaction surveys

4.15. Conducting customer satisfaction surveys

4.15.1. Nature and extent of personal data processing

You can either participate in our customer satisfaction surveys on our website or we will send the survey to you by e-mail. When provided by e-mail, the following personal data is sent to our service provider Netigate Deutschland GmbH:

  • Title, last name, first name, e-mail address

In addition, when you participate in customer satisfaction surveys provided on our website, the following personal data is collected and transmitted to Netigate and TA Triumph-Adler:

  • Title, last name, first name, e-mail address, telephone number (optional)

4.15.2. Purpose and legal basis of personal data processing

Your data is collected to enable us to provide you with feedback in specific cases of dissatisfaction. The logging of your participation in the satisfaction survey, the processing of the IP address, and the time are used to facilitate and prove your participation in the survey and, if necessary, to investigate any misuse of your personal data. We also have a legitimate interest in doing so in accordance with point (f) of Article 6(1) GDPR.

4.15.3. Recipients or categories of recipients, transmission of your data to a third country or international organisations and presence of an adequacy decision

For our customer satisfaction surveys, we use an input interface provided by Netigate Deutschland GmbH (Netigate Deutschland GmbH, Untermainkai 27–28, 60329 Frankfurt am Main, Germany). A data processing agreement in accordance with Article 28 GDPR has been entered into with the service provider. If you submit data as part of a customer satisfaction survey, this is collected by TA Triumph-Adler/Netigate. When customer satisfaction surveys are sent by e-mail and when preparing results, your data is transmitted to Netigate. There is no transmission of your data to a third country.

4.15.4. Duration of storage

Your personal data is deleted at your request or after a period of five years.

4.15.5. Right to erasure, objection and rectification

Furthermore, you can make use of your right to object at any time without stating reasons for doing so. You can modify or completely withdraw the consent you have given to take future effect. You can submit your objection to TA Triumph-Adler by e-mail (support@triumph-adler.net) or by fax ((+ 49-385) 6171-2587), stating your customer number.

4.15.6. Consequences of not providing data

You can participate in our customer satisfactions surveys on our website at any time, without providing any personal data. The provision of your personal information is voluntary and is not required to transmit the customer satisfaction survey through our website.

4.15.7. Other

More information about Netigate can be found here.

5. Data subject rights

Where the legal requirements are met, you have various rights when it comes to the handling of your personal data. If you have any questions regarding the assertion of your rights, please contact our data protection officer in writing. You can contact our data protection officer in writing at the address shown in the Legal Notice. Please mark the envelope ‘FAO Data Protection Officer’. Alternatively, please use the e-mail address datenschutz@triumph-adler.net.

  • Article 15 GDPR (Right of access by the data subject): You have the right to obtain information as to which data we process about you.
  • Article 16 GDPR (Right to rectification): If the data concerning you are inaccurate or incomplete, you can obtain rectification of inaccurate data or completion of incomplete data.
  • Article 17 GDPR (Right to erasure): Under the conditions set out in Article 17 GDPR, you can obtain erasure of your personal data. Your right to erasure depends, among other things, on whether we still need the data concerning you in order to meet our statutory obligations.
  • Article 18 GDPR (Right to restriction of processing): Under the conditions set out in Article 18 GDPR, you can obtain restriction of processing for personal data concerning you.
  • Article 20 GDPR (Right to data portability): You can receive the data you have provided in a structured, commonly used and machine-readable format and can have said data transmitted to another controller.
  • Article 21 GDPR (Right to object): On grounds relating to your particular situation, you can object at any time to processing of data concerning you. You can object in particular to the processing of your data for advertising purposes.
  • Article 7(3) GDPR (Right to withdraw consent): You have the right to withdraw your consent to the processing of your personal data at any time to take future effect. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.
  • Article 77 GDPR (Right to lodge a complaint with a supervisory authority): You have the right to lodge a complaint with a supervisory authority if you consider that our processing of your personal data infringes applicable data protection laws. The authority responsible for us is: Bavarian Data Protection Authority (BayLDA), Promenade 27 (Schloss), 91522 Ansbach, Germany, https://www.lda.bayern.de

6. Links to other websites

Our website contains links to other websites. We have no control over the data privacy policies of the operators of these sites. Despite having previously checked content carefully, we cannot accept any liability for external links to third-party content.

7. Validity and updating of the Privacy Policy

As a result of the development of our website or the implementation of new technologies, it may become necessary to change this Privacy Policy, so as to take future effect. We recommend that you always consult the current version of the Privacy Policy.

 

Nuremberg, Germany, 1 August 2019