Privacy Policy
We very much appreciate your interest in our company. Data privacy is of particular importance to the management of Sankosha Europe by Ziermann GmbH. In principle, it is possible to use of the websites of Sankosha Europe by Ziermann GmbH without providing any personal data. However, if a data subject would like to make use of the special services of our company via our website, it may become necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain the consent of the data subject.
Personal data, for example the name, address, email address or telephone number of a data subject is always processed in accordance with the General Data Protection Regulation and in line with the country-specific data protection provisions applicable to Sankosha Europe by Ziermann GmbH. By means of this privacy statement, our company wishes to inform the public about the type, scope and purpose of the personal data used and processed by us. Furthermore, data subjects are informed of their legal rights by means of this privacy statement.
As the data controller, Sankosha Europe by Ziermann GmbH has implemented numerous technical and organisational measures to ensure the most complete protection of the personal data collected via this website. Nevertheless, internet-based data transmission can always have security gaps, which means that absolute protection cannot be guaranteed. For this reason, each data subject is free to transmit personal data to us by alternative means, such as by telephone.
1. Definition of terms
The privacy statement of Sankosha Europe by Ziermann GmbH is based on the terminology used by the European directive and regulatory authority in the General Data Protection Regulation (GDPR). Our privacy statement should be easy to read and understand for both the public and our customers and business partners. In order to ensure this, we would like to explain some of the terminology used.
We use, among others, the following terms in this privacy statement:
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a) Personal data
Personal data refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, especially 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.
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b) Data subject
Data subject refers to every identified or identifiable person whose personal data are processed by the party responsible for processing.
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c) Restriction of processing
Processing refers to any operation or set of operations which is performed on personal data or on sets of personal data, with or without the use of automated processes, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
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d) Einschränkung der Verarbeitung
Einschränkung der Verarbeitung ist die Markierung gespeicherter personenbezogener Daten mit dem Ziel, ihre künftige Verarbeitung einzuschränken.
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e) Profiling
Profiling refers to any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal factors relating to a natural person, in particular to analyse or predict factors concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
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f) Pseudonymisation
Pseudonymisation refers to the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without reference to additional information, provided that such additional information is stored separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
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g) Controller or data controller
Controller or data controller refers to 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 the laws of the Union or member state, the controller or the specific criteria for their nomination may be provided by Union or member state law.
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h) Processor
Processor refers to a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
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i) Receiver
Recipient refers to 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 within the framework of a particular enquiry in accordance with Union or member state law shall not be regarded as recipients.
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j) Third party
Third party refers to 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 authorised to process personal data.
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k) Consent
Consent refers to 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.
2. Name and address of the data controller
The controller, according to the General Data Protection Regulation, other data protection laws in the member states of the European Union and other provisions relating to data protection, refers to:
Sankosha Europe by
Ziermann GmbH
Lochmatt 1A
77880 Sasbach
Germany
Phone: +49 (0)7841 / 6002 – 100
E-mail: info@sankosha-europe.com
Website: https://sankosha-europe.com
3. Cookies
The websites of Sankosha Europe by Ziermann GmbH use cookies. Cookies are text files that are filed and saved by an internet browser on a computer system.
Cookies cannot execute programs or transfer viruses to your computer. They are used to make the Internet offer as a whole more user-friendly and effective.
Some cookies are “session cookies.” Such cookies will be deleted automatically after the end of your browser session. On the other hand, other cookies will remain on your terminal device until you delete them yourself. Such cookies help us to recognise you when you return to our website.
With a modern web browser, you can monitor, restrict or prevent the setting of cookies. A lot of web browsers can be configured in such a way that cookies are deleted automatically when the programme is closed. The deactivation of cookies can result in a restricted functionality of our website.
The setting of cookies, which are necessary in order to carry out electronic communication processes or to provide certain functions requested by you (e.g. shopping basket) shall be carried out based on Article 6(1)(f) of the GDPR. As the operator of this website we have a legitimate interest in the storage of cookies for the technically fault-free and smooth provision of our services. If other cookies are set (e.g. for analysis functions) these will be treated separately in this privacy statement.
4. Collection of general data and information
The website of Sankosha Europe by Ziermann GmbH collects a series of general data and information when a data subject or automated system accesses the website. This general data and information is stored in the server log files. This data and information includes:
- the browser types and versions used
- the operating system used by the accessing system
- the time zone difference to Greenwich Mean Time (GMT)
- the referrer URL
- the internet service provider of the accessing system
- the date and time of access to the website
- the internet protocol address (IP address)
When using this general data and information, Sankosha Europe by Ziermann GmbH does not draw any conclusions about the data subject. In fact, this information is required to (1) deliver the contents of our website correctly, to (2) optimise the contents of our website as well as its advertisement, to (3) guarantee the long-term viability of our information technology systems and the technology of our website and to (4) provide law enforcement authorities with the information required for criminal prosecution in case of a cyber attack. This anonymously collected data and information is therefore, on the one hand, statistically, and, on the other hand, assessed by Sankosha Europe by Ziermann GmbH with the objective of increasing data protection and data security in our company in order to ultimately guarantee an optimal level of security for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
5. Registration on our website
In order to use certain functions, you can register on our website. The transmitted data exclusively serve the purpose of using the respective offer or service. Mandatory details requested during the registration are to be entered in full. Otherwise we will refuse the registration.
In the event of important changes, for example for technical reasons, we will inform you by e-mail. The e-mail will be sent to the address, which was entered during registration.
The processing of the data entered with the registration shall be carried out based on your consent (Article 6(1)(a) of the GDPR). A revocation of your already granted consent is possible at all times. An informal notification by e-mail is sufficient for the revocation. The lawfulness of the already carried out data processing shall remain unaffected by the revocation.
We shall store the data entered with the registration during the period of time, in which you are registered on our website. Your data will be deleted if you should revoke your registration. Statutory storage deadlines shall remain unaffected.
6. Contact opportunity via the website
In accordance with statutory provisions, the website of Sankosha Europe by Ziermann GmbH contains information that allows you to make quick electronic contact with our company as well communicate directly with us, which also includes a general electronic mail address (e-mail address). If a data subject contacts the data controller via email or a contact form, the personal data submitted by the data subject are saved automatically. These personal data submitted voluntarily by a data subject to the data controller are saved for the purposes of processing or for establishing contact with the data subject. These personal data will not be forwarded to third parties.
7. Inquires by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, your enquiry including all personal data (name, enquiry) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.
This data is processed on the basis of Article 6(1)(b) of the GDPR, insofar as your request is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on your consent (Article 6(1)(a) of the GDPR) and/or on our legitimate interests (Article 6(1)(f) of the GDPR), as we have a legitimate interest in the effective processing of the requests addressed to us.
The data sent to us by you via contact inquiries remains with us until you request us to delete it, revoke your consent to its storage or the purpose for which it was stored ceases to apply (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
8. Data transfer upon conclusion of the contract for the purchase and dispatch of goods
Personal data will only be transmitted to third parties if it is necessary in the context of the execution of the contract. Third parties may be, for example, payment service providers or logistics companies. Further transmission of data does not take place or only if you have expressly agreed to it.
The basis for data processing is Article 6(1)(b) of the GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.
9. SSL or TLS encryption
For security reasons and for the protection of the transmission of contractual contents, which you send us as the site operator, our website uses an SSL or TLS encryption. Data, which you transmit via this website, can therefore not also be read by third parties. You can recognise an encrypted connection by the “https://” address line of your browser and by the lock symbol in the browser line.
10. Rights of the data subject
a) Right to confirmation
Every data subject has the right, as granted by the European directive and regulatory authority, to request confirmation of the processing of personal data of the data subject from the controller. If a data subject wishes to exercise this right to confirmation, then he or she may contact an employee of the data controller at any time.
b) Right to information
Every data subject affected by the processing of personal data has the right, protected by the European directive and regulatory authority, to receive information about the personal data stored about him or her at any time and for free and to receive a copy of this information from the data controller. Furthermore, the European regulator has granted the data subject the following information:
- the processing purposes
- the categories of personal data being processed
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
- if possible, the planned period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
- the existence of a right to rectification or erasure of the personal data concerning the data subject or a restriction of the processing by the controller or of a right to object to such processing
- the existence of the right of appeal to a supervisory authority
- if the personal data are not collected from the data subject: any available information about the origin of the data
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and — at least in these cases — meaningful information about the logic involved and the scope and intended impact of such processing on the data subject
Furthermore, the data subject has a right to information on whether their personal data has been transmitted to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information about the appropriate guarantees related to the transmission of personal data.
If a data subject wishes to exercise this right to information, they may contact an employee of the controller at any time.
c) Right to rectification
Any data subject affected by the processing of personal data has the right granted by the European directive and regulatory authority to request an immediate correction of inaccurate personal data concerning him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of providing a supplementary statement, taking into account the purposes of the processing.
If a data subject wishes to exercise this right to correction, they may contact an employee of the controller at any time.
d) Right to erasure (right to be forgotten)
Every person affected by the processing of personal data has the right protected by the European directive and regulatory authority to obtain from the controller the deletion of personal data concerning him or her without undue delay where one of the following grounds applies and the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the above reasons applies and a data subject wishes to have the personal data that is stored at Sankosha Europe by Ziermann GmbH erased, they may contact an employee of the data controller. The employee of Sankosha Europe by Ziermann GmbH ensures that the request for erasure is complied with immediately.
If the personal data has been made public by Sankosha Europe by Ziermann GmbH and if our company is obliged to erase the personal data in accordance with Article 17(1) of the GDPR, then Sankosha Europe by Ziermann GmbH is thereby obliged, taking into consideration the available technology and the implementation costs, to take appropriate measures – including technical measures – to inform other controllers which are processing the published personal data that the data subject has requested these controllers erase all links to the personal data, as well as copies or replications of the personal data, insofar as the processing is not necessary. The employee of Sankosha Europe by Ziermann GmbH will perform the necessary measures in individual cases.
e) Right to restriction of processing
Every person affected by the processing of personal data has the right protected by the European directive and regulatory authority to obtain from the controller restriction of processing where one of the following 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 their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the above conditions are met and a data subject desires to have the personal data that is stored at Sankosha Europe by Ziermann GmbH restricted, they may contact an employee of the data controller. The employee of Sankosha Europe by Ziermann GmbH ensures that the processing thereof is restricted.
f) Right to data portability
Every data subject affected by the processing of personal data has the right granted by the European directive and regulatory authority to receive the personal data affecting the data subject provided by the data subject to a controller in a structured, commonly used and machine-readable format. The data subject also has the right to transmit this data to another controller without hindrance from the controller to which the data was provided as long as the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing occurs automatically if processing is not necessary for the perception of a task that is in the public interest or is performed as an exercise of public power assigned to the controller.
Furthermore, the data subject can, when exercising their right to data portability according to Article 20(1) of the GDPR, request that the personal data be transmitted directly from one controller to another insofar as this is technically possible and the rights and freedoms of other persons are not thereby affected.
If the data subject wishes to exercise their Right to data portability, they may contact an employee of Sankosha Europe by Ziermann GmbH at any time.
g) Right to object
Each data subject affected by the processing of personal data has the right granted by the European directive and regulatory authority to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point of Article 6(1)(e) or (f) of the GDPR. This also applies for profiling based on these provisions.
In case of an objection, Sankosha Europe by Ziermann GmbH will no longer process personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
If Sankosha Europe by Ziermann GmbH is processing personal data for direct marketing purposes, the data subject shall then have the right to object at any time to processing of personal data concerning him or her for such marketing. This includes profiling to the extent that it is related to such direct marketing. If the data subject objects to Sankosha Europe by Ziermann GmbH to the processing for direct marketing purposes, then Ziermann GmbH will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her by Sankosha Europe by Ziermann GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact an employee of Sankosha Europe by Ziermann GmbH or another employee directly. Furthermore, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European directive and regulatory authority not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a controller, or (2) is not 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 (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a controller, or (2) it is based on the data subject’s explicit consent, then Sankosha Europe by Ziermann GmbH 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 contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, then he or she may at any time directly contact an employee of the data controller.
i) Right to withdraw consent to data privacy
Each data subject shall have the right granted by the European directive and regulatory authority to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, then he or she may contact an employee of the data controller directly at any time.
11. Data privacy for applications and application procedures
The data controller shall collect and process the personal data of applicants for the purpose of executing the application procedure. Processing may also be carried out electronically. This is especially the case if an applicant submits corresponding application documents to the data controller by email or by means of an online form on the website. If the data controller concludes an employment contract with an applicant, the submitted data will then be stored for the purpose of executing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the data controller, the application documents shall be automatically erased two months after notification of rejection, provided that no other legitimate interests of the data controller are in opposition to the erasure. Other legitimate interests in this sense include, for example, a burden of proof in a procedure under the General Equal Treatment Act (AGG).
12. Privacy policy on the use and application of Google Analytics (with anonymisation function)
The data controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, recording and evaluation of data on the behaviour of visitors to websites. Among other things, a web analysis service collects data about the website from which a data subject came to a website (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is mainly used to optimise a website and for cost-benefit analysis of internet advertising.
The operating company of Google Analytics is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Analytics is to analyse the flow of visitors to our website. Among other things, Google uses the data and information obtained to evaluate the use of our website in order to compile online reports for us which show the activities on our website and to provide further services in connection with the use of our website.
Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of our website is called up operated by the data controller and on which a Google Analytics component has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject.
The data subject can prevent the setting of cookies by our website, as described above, at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.
13. Privacy policy on the use and application of YouTube
Our website uses plugins of YouTube for the integration and presentation of video contents. The provider of the video portal is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
If a site with integrated YouTube plugin is called, a connection will be established to the servers of YouTube. YouTube hereby finds out which of our sites you have called.
YouTube can allocate your surfing behaviour directly to your personal profile should you be logged into your YouTube account. By logging out beforehand you have the possibility to prevent this.
The use of YouTube shall be carried out in the interest of an attractive presentation of our online offers. This represents a legitimate interest within the meaning of Article 6(1)(f) of the GDPR.
You can find details relating to the handling of user data in the privacy statement of YouTube under: https://www.google.de/intl/en/policies/privacy.
14. Legal basis for processing
Article 6(1)(a) of the GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case when processing operations are necessary for the supply of goods or to provide any other service, for example, then processing is based on Article 6(1)(b) of the GDPR. The same applies to those processing operations necessary for performing pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfillment of tax obligations, processing is based on Article 6(1)(c) of the GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our company were to suffer injuries and his/her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. In this case, processing would be based on Article 6(1)(d) of the GDPR. Lastly, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are outweighed by the interests or fundamental rights and freedoms of the data subject requiring protection of personal data. We are permitted to perform such processing operations in particular as they have been mentioned specifically by the European legislator. The legislator advocates that a legitimate interest could be assumed in the case that the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).
15. Period for which the personal data is stored
The criteria used to determine the period of storage of personal data is the relevant statutory retention period. After the period has expired, the corresponding data is routinely deleted insofar as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
16. Statutory or contractual requirements relating to the provision of personal data; Necessity for conclusion of a contract; Obligation of the data subject to provide the personal data; Possible consequences of failure to provide such data
We hereby inform you that the provision of personal data is partly required by law (e.g. tax regulations) and can also result from contractual provisions (e.g. information about the contractual partner). It may occasionally be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would mean that contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject 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 of the consequences of non-provision of the personal data.
17. Existence of automated decision-making
As a socially responsible company, we do not use automatic decision-making or profiling.