Name and contact information of the controller according to Article 4 (7) GDPR
FRIMO Group GmbH
Data protection officer
Security and protection of your personal data
We consider it our primary responsibility to protect the confidentiality of the personal information you provide and protect it from unauthorized access. That is why we use the utmost care and state-of-the-art security standards to ensure the maximum protection of your personal data.
As a private company, we are subject to the provisions of the European Data Protection Regulation (GDPR) and the regulations of the German Federal Data Protection Act (BDSG). We have taken technical and organizational measures to ensure that the data protection rules are respected both by us and by our external service providers.
Legislation requires that personal data be processed lawfully, fairly, and in a transparent manner in relation to the data subject (“lawfulness, fairness, transparency”). To ensure this, we inform you about the individual legal definitions that are also used in this privacy statement:
- Personal data
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Restriction of processing
“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- Filing system
“Filing system” means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- Third party
“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Lawfulness of processing
The processing of personal data is only lawful if there is a legal basis for processing. Pursuant to Article 6 (1) a - f GDPR, the legal basis for the processing may include,
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which the controller is subject;
- processing is necessary in order to protect the vital interests of the data subject or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Information about the collection of personal data
(1) We inform about the personal data being collected when you use our website below. Personal data includes, for example, name, address, email addresses, user behavior.
(2) When you contact us by email or using a contact form, we will store the information you have provided to answer your questions. We delete the data collected in this context after storage of it is no longer required or the processing is restricted if legal storage obligations exist.
Collection of personal data when visiting our website
In the case of merely informative use of the website, in other words, if you do not register or otherwise provide us with information, we will only collect the personal data that your browser transmits to our server. When you view our website, we collect the following data which is technically necessary for us to display our website to you and to ensure its stability and security (legal basis is Article 6 (1) sentence 1 f GDPR):
- IP address
- Date and time of the request
- Time zone difference to Greenwich mean time (GMT)
- Content of the request (specific page)
- Access status / HTTP status code
- Amount of transmitted data
- Website from which the request originated
- Operating system and its interface
- Language and version of the browser software.
(1) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive, assigned to the browser you are using, and provide certain information to the entity that set the cookie. Cookies cannot run programs or transmit viruses to your computer. They serve to make the Internet offer more user-friendly and effective overall.
(2) This website uses the following types of cookies, the scope and operation of which are explained below:
- transient cookies (see a.)
- persistent cookies (see b.).
- Transient cookies are automatically deleted when you close the browser. They include in particular session cookies. These store a session ID, with which various requests from your browser can be assigned to the common session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.
- Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie. You can delete these cookies with the security settings of your browser at any time.
- You can configure your browser setting according to your wishes and,
for example, decline the acceptance of third-party cookies or all cookies. “Third Party Cookies” are cookies that have been installed by a third party and therefore not by the actual website which you are currently visiting. Please note that disabling cookies may restrict your use of all the features on this website.
- The Flash cookies used are not detected by your browser but by your Flash plug-in. Furthermore, we use HTML5 storage objects, which are stored on your device. These objects store the required data regardless of your browser and do not have an automatic expiration date. If you do not want processing of Flash cookies, you will need to install an add-on such as “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash killer cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. In addition, we recommend that you regularly delete your cookies and the browser history manually.
More features and offers of our website
(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you will generally need to provide additional personal data that we use to provide the service and to which the aforementioned data processing principles apply.
(2) We partly use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions, and are regularly inspected.
(3) Moreover, we may disclose your personal data to third parties, if promotional action participations, competitions, contracts or similar services are offered by us together with partners. You will receive more information concerning this when you provide your personal data or below in the description of the products and services.
(4) Insofar as our service providers or partners have their seat in a country outside the European Economic Area (EEA), we will inform you about the consequences of this circumstance in the description of the offer.
(1) With your consent, you can subscribe to our newsletter, which will inform you about any current interesting offers. The advertised goods and services are named in the declaration of consent.
(2) To register for our newsletter, we use the double opt-in procedure. This means that after you have registered, we will send you an email to the email address specified in which we ask you to confirm that you wish to receive the newsletter. In addition, we store the IPaddresses you used and the time of registration and confirmation. The purpose of this is to provide evidence of your registration and, where applicable, to be able to clarify any potential misuse of your personal data.
(3) The only data that is absolutely necessary for sending you our newsletter is your email address. The provision of other separately marked data is voluntary, and it will be used to contact you directly. After receiving your confirmation, we will store your email address for the purpose of sending you the newsletter. The legal basis for this is Art.6(1)(1)(a) GDPR.
(4) You may withdraw your consent to the receipt of the newsletter at any time and unsubscribe from it. You can withdraw your consent by clicking on the link provided in each newsletter email , by sending an email firstname.lastname@example.org or by contacting us using the contact details stated in the legal notice.
(5) Please note that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails we send contain so-called web beacons or tracking pixels, which depict single-pixel image files that are stored on our website. For the purposes of evaluation, we link the data specified in Section 3 above and the web beacons with your email address and an individual ID. The data is collected in pseudonymized form only, which means that the IDs are not linked with any other personal data relating to you; this prevents any direct links being made to a particular individual. You can object to this tracking at any time by clicking on the separate link that is provided in every email or by contacting us through another channel. The information shall be stored until such time as you unsubscribe from the newsletter. After cancellation of the newsletter subscription, we store the data in a purely statistical and anonymous form.
Our website is intended for the use of adults only. Persons under the age of 18 should not send any personal data to us without the approval of their parents or legal guardians.
Rights of the data subject
(1) Withdrawal of consent
Where personal data is processed on the basis of consent given by you, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of any processing for which consent was given and which was carried out prior to the withdrawal thereof.
To exercise your right to withdraw your consent, you may contact us at any time.
(2) Right to confirmation
You have the right to obtain from the controller confirmation as to whether or not personal data relating to you is being processed by us. You may request this confirmation at any time using the contact details stated above.
(3) Right to information
Where personal data is processed, you may request information about this personal data and about the following details at any time:
- the purposes of the processing;
- the categories of personal data processed;
- the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to rectification or erasure of the personal data relating to you, or the right to restriction of processing of personal data by the controller, or the right to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data is not collected from the data subject, all available information as to the origin of said data;
- the existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and, at least in these cases, detailed information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data is transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer of said data. We shall provide a copy of the personal data undergoing processing. Where the request is submitted electronically, the information shall be provided in a commonly used electronic format, unless otherwise requested. The right to obtain a copy according to paragraph 3 must not adversely affect the rights and freedoms of others.
(4) Right to rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data relating to you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
(5) Right to erasure (‘right to be forgotten’)
You have the right to obtain from the controller the erasure of personal data relating to you without undue delay and we shall be obligated to erase personal data without undue delay where one of the following grounds applies:
- The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
- The data subject withdraws the consent on which the processing was based pursuant to Art. 6(1)(a), or Art. 9(2)(a) GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
- The personal data has been processed unlawfully.
- The erasure of the personal data is necessary for compliance with a legal obligation under the Union or Member State law to which the controller is subject.
- The personal data has been collected in relation to the offer of information society services pursuant to Article 8(1) GDPR.
Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, said personal data.
The right to erasure (‘right to be forgotten’) shall not apply where processing is necessary:
- for exercising the right to freedom of expression and information;
- for compliance with a legal obligation which requires processing under the Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with Art. 9(2)(h) and (i) GDPR as well as Art. 9(3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defense of legal claims.
(6) Right to restriction of processing
You have the right to obtain from us restriction of processing of your personal data where one of the following conditions applies:
- 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 and the data subject opposes the erasure of the personal data and requests the restriction of use thereof instead;
- the controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defense of legal claims, or
- the data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where processing has been restricted according to the aforementioned conditions, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
In order to exercise the right to restriction of processing, the data subject may contact us at any time using the contact details provided above.
(7) Right to data portability
You have the right to receive the personal data relating to you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where:
- the processing is based on consent pursuant to 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and
- the processing is carried out by automated means.
In exercising your right to data portability pursuant to paragraph 1, you have the right to have the personal data transmitted directly from one controller to another, where technically feasible. Exercising the right to data portability shall not affect the right to erasure (‘right to be forgotten’). That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
(8) Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data relating to you that is based on Art. 6(1)(e) or (f) GDPR; this shall also apply for profiling based on these provisions. The controller shall no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or where processing is necessary for the establishment, exercise or defense of legal claims.
Where personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data relating to you for such marketing; this shall also include profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
You have the right, on grounds relating to your particular situation, to object to the processing of personal data relating to you for scientific or historical research purposes or statistical purposes pursuant to Article89 (1), the data subject, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You may exercise your right to object at any time by contacting the responsible controller.
(9) Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This shall not apply if the decision:
- is necessary for entering into, or performance of, a contract between the data subject and a data controller;
- is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
- is based on the data subject's explicit consent.
The data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
The data subject may exercise this right at any time by contacting the responsible controller.
(10) Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement where the data subject is of the opinion that the processing of the personal data relating to them is in breach of this Regulation.
(11) Right to an effective judicial remedy
Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR, you have the right to an effective judicial remedy where you are of the opinion that your rights under this Regulation have been breached as a result of the processing of your personal data in non-compliance with this Regulation.
Use of Google Analytics
(1) This website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, which are text files that are stored on your computer and enable an analysis of how you use the website. The information generated by the cookie about your use of this website is normally sent to a Google server in the US and stored there. If IP anonymisation has been enabled on this website, however, your IP address will first be truncated by Google within the member states of the European Union or in other countries that are party to the Agreement on the European Economic Area. Only in exceptional situations will the full IP address be sent to a Google server in the US and truncated there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports about website activity and to provide the website operator with other services relating to website activity and Internet usage.
(2) The IP address transmitted by your browser as part of Google Analytics shall not be combined with other Google data.
(3) You can prevent the installation of cookies by adjusting your browser settings accordingly; in this case, however, we must point out that not all functions of this website may be available to you in their full capacity. You may also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) for Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
(4) This website uses Google Analytics with the extension “_anonymizeIp()”. This allows further processing of the truncated IP addresses, thereby preventing any direct connection from being made to a particular individual. Where a connection is made between you and the personal data relating to you, this shall be directly excluded and the personal data immediately deleted.
(5) We use Google Analytics in order to analyze and regularly optimize our website. The statistics enable us to optimize our website and make it more interesting for you as the user. With regard to the exceptional cases in which personal data is transmitted to the US, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. Art. 6 (1) f) GDPR provides the legal basis for the use of Google Analytics.
(6) Third-party provider details: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, fax: +353 (1) 436 1001. Terms and Conditions of Use:
(7) This website also uses Google Analytics for a cross-device analysis of visitor numbers performed by way of a user ID. You can disable the cross-device analysis of your use of the website in the “my data” section of your customer account.
Use of social media plug-ins
(2) We have no influence over the data collected or the manner in which such is processed, nor are we aware of the full scope of data collection, the purpose of processing or the storage periods. Nor do we have any information on the deletion of the collected data by the plug-in provider.
(3) The plug-in provider stores the collected data relating to you in the form of user profiles and uses these for the purpose of advertising, market research and/or the customization of its website. The data is evaluated particularly (including for users who are not logged in) to display appropriate ads and in order to inform other social network users of your activities on our website. You have the right to object to the creation of such user profiles, however you will have to contact the respective plug-in provider to exercise this right. The plug-in allows you to interact with the social networks and other users so that we can optimize our website and make it more interesting for you as the user. Art. 6 (1) f) GDPR provides the legal basis for the use of plug-ins.
(4) The data is forwarded regardless of whether or not you have an account with the plug-in provider and are logged in to it. If you are logged in with the plug-in provider, the data collected by us relating to you will be directly allocated to your account with the plug-in provider. If you press the activated button and, for example, link the page, the plug-in provider stores this information in your user account and makes it visible to your contacts. We recommend logging out of a social network when you have finished using it, particularly before activating the button, so as to prevent this data being allocated to your profile with the plug-in provider.
(5) Further information on the purpose and scope of data collection and the processing of such by the plug-in provider is available in the following Data Privacy Policies of these providers. You can also find further information on your rights with regard to the above and settings to protect your privacy in these Policies.
(6) Addresses of the respective plug-in providers and URL including their Data Privacy Policies:
- Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Irland; https://www.facebook.com/about/privacy; further information on data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo. Facebook has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; https://policies.google.com/privacy. Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
- Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. Twitter has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
- Xing AG, Gänsemarkt 43, 20354 Hamburg, Germany; http://www.xing.com/privacy.
- T3N, yeebase media GmbH, Kriegerstr. 40, 30161 Hannover, Germany; https://t3n.de/store/page/datenschutz.
- LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy. LinkedIn has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
- Flattr Network Ltd. located on 2 nd Floor, White bear yard 114A, Clerkenwell Road, London, Middlesex, England, EC1R 5DF, Great Britain; https://flattr. com/privacy.]
Integration of Google Maps
(1) We use Google Maps on this website. This enables us to display interactive maps directly on the website, making it convenient for you to use the map function.
(2) When you visit the website, Google receives the information that you have accessed the respective sub-page of our website. The data specified in Section 3 of this Policy is also transmitted. This occurs regardless of whether or not you have a user account with Google and are logged into it. If you are logged into Google, your data will be directly allocated to your account. If you are not comfortable with this data being allocated to your Google account, you should log out before activating the button. Google stores the data relating to you in the form of user profiles and uses these for the purpose of advertising, market research and/or the customization of its website. The data is evaluated particularly (including for users who are not logged in) to display appropriate ads and in order to inform other social network users of your activities on our website. You have the right to object to the creation of such user profiles; however, you will have to contact Google to exercise this right.
Use of Google Fonts
Analysis by wiredminds
Our website uses a counting pixel technology provided by wiredminds GmbH
(www.wiredminds.de) to analyze visitor behavior. If necessary, data is collected, processed
and stored, from which user profiles are created under a pseudonym. Wherever possible and
reasonable, these usage profiles are completely anonymized. Cookies can be used for this
purpose. Cookies are small text files that are stored in the visitor's Internet browser and
serve to recognize the Internet browser. The collected data, which may also contain personal
data, will be transmitted to wiredminds or collected directly by wiredminds. wiredminds may
use information that is left by visiting the websites to create anonymized usage profiles. The
data obtained without explicit consent of the affected person will not be used to personally
identify the visitor of this website and will not be merged with personal data of the bearer of
the pseudonym. Whenever IP addresses are recorded, their immediate anonymization takes
place by deleting the last number block.
Exclude from tracking.
We employ the services of external service providers (processors), e.g. for dispatching goods, sending newsletters or for payment processing. A separate order data processing contract has been concluded with the service provider to ensure the protection of your personal data.
We cooperate with the following service providers:
KIWI. Werbeagentur GmbH
Bramscher Straße 14