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Cup Concept

Privacy statement

Cup Concept Mehrwegbechersysteme GmbH

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as ‘data’) within our online service and the related websites, features and content, as well as external websites such as our social media profiles (collectively referred to as ‘online service’). With regard to the terminology used, such as ‘personal data’ or its ‘processing’, please refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller:
Name/company: Cup Concept Mehrwegsysteme GmbH
Street/no.: Elzstraße 3
Post code, town, country: 79350 Sexau
Commercial register/no.: HRB 261380
Email address: info@cupconcept.de

Data protection officer:
Name: Sebastian Müller
Street/no.: Blutenburgstr. 59
Post code, town, country: 80636 München
Email address: s.mueller@ifduc.de

Categories of processed data:
- Stock data (such as names, addresses).
- Contact data (such as email addresses, phone numbers).
- Content data (such as text entries, photographs, videos).
- Usage data (such as websites visited, interest in content, access times).
- Meta/communication data (such as device information, IP addresses).

Processing of special categories of data (Article 9 (1) of the GDPR):
- No special categories of data are processed.

Categories of data subjects affected by processing:
- customers / prospective customers / suppliers.
- visitors to and users of the online service.

Purpose of processing:
- Provision of the online service, its content and its features.
- Performance of contractual services, service and customer care.
- Responding to inquiries and communication with users.
- Marketing, advertising and market research.
- Security measures.

Updated: 25/05/2018

 

1. Relevant legal bases
In accordance with Article 13 of the GDPR, we would like to inform you about the legal bases of our data processing. Unless the legal basis is stated in the Privacy Policy, the following applies: The legal basis for obtaining consent is Article 6 (1) (1) and Article 7 of the GDPR; the legal basis for processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Article 6 (1) (b) of the GDPR; the legal basis for processing in order to fulfil our legal obligations is Article 6 (1) (c) of the GDPR; and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) (f) of the GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 (1) (d) of the GDPR serves as the legal basis.

2. Changes and updates to the Privacy Policy
We ask you to inform yourself regularly about the content of our Privacy Policy. We will adjust the Privacy Policy as soon as the changes to our data processing require us to do so. We will notify you as soon as the changes require any action on your part (e.g. consent) or any other individual notification.

3. Security measures
3.1. In accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk. The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as related access, input, disclosure, availability and separation. In addition, we have established procedures that ensure the enjoyment of data subject rights, data deletion and response to data vulnerability. Furthermore, we consider the protection of personal data as early as the development or selection of hardware, software and procedures, according to the principle of data protection by technology design and by way of privacy-friendly default settings (Article 25 GDPR).

4. Collaboration with processors and third parties
4.1. If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them or otherwise grant access to the data, this is only done on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is required to fulfil the contract, in accordance with Article 6 (1) (b) GDPR), if you have consented, if a legal stipulates it, or on the basis of our legitimate interests (e.g. the use of agents, web hosts etc.).

4.2. If we commission third parties to process data on the basis of a so-called ‘processing contract’, this is done on the basis of Article 28 of the GDPR.

5. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third-party services, or if data is disclosed or transferred to third parties, this will only be done if it is to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special conditions under Article 44 et seq. of the GDPR are met. This means that the processing is carried out, for example, on the basis of specific guarantees, such as the official recognition of a level of data protection corresponding to that of the EU (e.g. the ‘Privacy Shield’ for the United States) or compliance with officially recognised special contractual obligations (so-called ‘standard contractual clauses’).

6. Rights of data subjects
6.1. You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Article 15 of the GDPR.
6.2. In accordance with Article 16 of the GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
6.3. In accordance with Article 17 of the GDPR, you have the right to request that affected data be deleted immediately; or, alternatively, in accordance with Article 18 of the GDPR, you have the right to request the restriction of processing of that data.
6.4. In accordance with Article 20 of the GDPR, you have the right to obtain the data concerning you that you have provided to us, and request its transfer to other controllers. 
6.5. In accordance with Article 77 of the GDPR, you have the right to file a complaint with the responsible supervisory authority.

7. Right of withdrawal
You have the right to withdraw granted consent with future effect in accordance with Article 7 (3) of the GDPR.

8. Right of objection
You may object to the future processing of your data at any time in accordance with Article 21 of the GDPR. The objection may, in particular, be made against processing for direct marketing purposes.

9. Cookies and right of objection for direct marketing
We use temporary and permanent cookies, i.e. small files that are stored on users’ devices (for explanation of the term and function, see last section of this Privacy Policy). In part, the cookies are used for security or to operate our online service (e.g. to display the website) or to save the user’s decision when confirming the cookie banner. In addition, we or our technology partners use cookies for audience measurement and marketing purposes. Users are informed about this in the Privacy Policy.
A general objection to the use of cookies for online marketing purposes can be made for a variety of services, especially in the case of tracking, via the US site www.aboutads.info/choices/ or the EU site www.youronlinechoices.com. Furthermore, the storage of cookies can be blocked by switching them off in the browser settings. Please note that this may result in some features of this online service becoming unusable.

10. Deletion of data
10.1. The data processed by us is deleted or limited in its processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this Privacy Policy, the data stored by us is deleted as soon as it is no longer required for its purpose and the deletion does not conflict with any statutory retention requirements. Insofar as the data is not deleted because it is required for other legitimate purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
10.2. According to statutory requirements, retention is mandated, in particular, for 6 years under § 257 (1) HGB (trading books, inventories, opening balance sheets, annual accounts, commercial letters, accounting documents etc.) and for 10 years under § 147 (1) AO (books, records, management reports , accounting receipts, commercial and business letters, documents relevant to taxation etc.).

11. Provision of contractual services
We process stock data (such as names, addresses and contact information of users), contract data (such as services used, names of contacts, payment information) for the purpose of performing our contractual obligations and services in accordance with Article 6 (1) (b) of the GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.

12. Contact
12.1. When contacting us (via the contact form or email), the information provided by the user is processed in accordance with Article 6 (1) (b) of the GDPR in order to process the contact inquiry.
12.2. User information may be stored in our customer relationship management system (“CRM system”) or similar inquiry organisation system.
12.3. We delete the inquiries if they are no longer required. We check if they are required every two years; we store inquiries from customers who have a customer account permanently. For the deletion of such inquiries, please refer to the information concerning customer accounts. In the case of statutory retention requirements, the deletion takes place after their expiry (after expiry of commercial law (6 years) and tax law (10 years) retention requirements).

13. Collection of access data and log files
13.1. Based on our legitimate interests within the meaning of Article 6 (1) (f) of the GDPR, we collect data on all access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved website, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
13.2. Log file information is stored for security purposes (e.g. to investigate abusive or fraudulent activities) for a maximum of seven days and subsequently deleted. Data whose further retention is required for evidential purposes is exempted from deletion until final clarification of the incident.

14. Online presence on social media
14.1. We maintain an online presence on social networks and platforms in order to communicate with customers, prospective customers and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply. 
14.2. Unless otherwise stated in our Privacy Policy, we process users’ data if they communicate with us on social networks and platforms, e.g. if they write posts on our online presences or send us messages.

15. Cookies & audience measurement
15.1. Cookies are information transmitted from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Cookies can be small files or other types of information storage. 
15.2. We use ‘session cookies’ which are only stored for the duration of the current visit to our website (e.g. to enable the storage of your login status or the offer feature and thus the use of our online service). In session cookies, a randomly generated unique identification number is stored, a so-called session ID. In addition, cookies contains information about their origin and storage period. These cookies cannot store any other data. Session cookies are deleted once you finish using our online service and log out or close the browser, for instance.
15.3. This Privacy Policy provides users with information about the use of cookies for pseudonymous audience measurement.
15.4. If you as a user do not want cookies stored on you computer, please disable the option in your browser’s settings. Saved cookies can be deleted in your browser’s settings. Disabling cookies can lead to functional limitations of this online service.
15.5. You may object to the use of cookies for audience measurement and advertising purposes through the Network Advertising Initiative’s opt-out page (http://optout.networkadvertising.org/) as well as the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

16. Google Analytics
16.1. Based on our legitimate interests (i.e. interest in the analysis, optimisation, and economic operation of our online service within the meaning of Article 6 (1) (f) of the GDPR), we use Google Analytics, a web analytics service provided by Google LLC (‘Google’). Google uses cookies. The information generated by the cookie about the users’ use of the online service is usually transmitted to a Google server in the US and stored there.
16.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
16.3. Google will use this information on our behalf to evaluate the use of our online service by users, to compile reports on the activities within this online service and to provide us with further services related to the use of this online service and internet usage. In this case, pseudonymous user usage profiles may be created from the processed data.
16.4. We only use Google Analytics with activated IP anonymisation. This means that the users’ IP addresses will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
16.5. The IP address submitted by the user’s browser will not be merged with other Google data provided. Users can prevent the storage of cookies by setting their browser software accordingly; users may also prevent Google’s collection and processing of the data generated by the cookie and related to their use of the online service by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout
16.6. For more information about data usage by Google, settings and objections, visit Google’s websites: www.google.com/intl/en/policies/privacy/partners (‘How Google uses information from sites or apps that use our services’), policies.google.com/technologies/ads (‘Advertising’), adssettings.google.com/authenticated (‘Manage information Google uses to show you ads’).

17. Newsletter
17.1. We would like to inform you about the contents of our Newsletter as well as the registration, dispatch and statistical evaluation procedures and your right of objection. By registering for our Newsletter, you agree to receive it and to the procedures described.
17.2. Content of the Newsletter: We send newsletters, emails and other electronic notifications with advertising information (hereinafter ‘Newsletter’) only with the consent of the recipient or with legal permission. Insofar as the contents are specifically outlined during registration for the Newsletter, such contents are authoritative for the users’ consent. In addition, our Newsletters contain information about our products, offers, promotions and our company.
17.3. Double opt-in and logging: Registration for our Newsletter takes place via a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that nobody can register with an email address not belonging to them. The registration for the Newsletter is logged in order to provide evidence of the registration process in accordance with legal requirements. This includes storing the times of registration and confirmation, as well as the IP address. Likewise, changes to your data stored with the Dispatch Provider are also logged.
17.4. Dispatch Provider: The newsletter is dispatched by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as ‘Dispatch Provider’. You can view the Dispatch Provider’s privacy policy here: www.cleverreach.com/de/datenschutz/. Furthermore, the Dispatch Provider may, according to its own information, use this data in pseudonymous form, i.e. without assigning it to a user, in order to optimise or improve its own services, e.g. for the technical optimisation of dispatch and presentation of the Newsletters or for statistical purposes, to determine which countries the recipients are from. However, the Dispatch Provider does not use the data of our newsletter recipients to write to them itself, nor does it pass them on to third parties.
17.5. Registration data: To register for the Newsletter, it is sufficient to enter your email address. Optionally, we ask you to provide a name that we can use to address you in the Newsletter.
17.6. Measuring success – The Newsletters contain a so-called ‘web beacon’, i.e. pixel-sized file that is retrieved from the Dispatch Provider’s server when the Newsletter is opened. During this retrieval, technical information is initially collected, such as information about your browser and system, as well as your IP address and time of retrieval. This information is used to improve the technical performance of services based on the technical data, or the target audience and their reading habits based on their access locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the Newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual Newsletter recipients. However, neither we not the Dispatch Provider endeavours to observe individual users. Instead, the evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to their interests.

18. Integration of services and third-party content
18.1. Based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Article 6 (1) (f) of the GDPR), we make use of content or services offered by third-party providers in order to include their content and services, such as videos or fonts (hereinafter collectively referred to as ‘Content’). This always presupposes that the third-party providers of this Content can see the users’ IP addresses, since they would not be able to send the content to their browsers without an IP address. The IP address is therefore required for the presentation of this Content. We endeavour to use only Content whose respective providers use IP addresses solely for the delivery of the Content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as ‘web beacons’) for statistical or marketing purposes. The ‘pixel tags’ can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring websites, visit time, and other information regarding the use of our online offer; it may also be linked to such information from other sources.
• Maps by the service ‘Google Maps’ by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. Privacy Policy: www.google.com/policies/privacy/, opt-out: www.google.com/settings/ads/.
• Videos by the platform ‘YouTube’ of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. Privacy Policy: policies.google.com/privacy, opt-out: adssettings.google.com/authenticated.
• Features of the service Instagram are integrated into our online service. These features are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, United States. If you are logged in to your Instagram account, you can link the contents of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to our pages with your user account. Please note that the provider of the pages, we do not receive knowledge of the content of the data transferred and its use by Instagram. Privacy Policy: instagram.com/about/legal/privacy/.

19. Google (re)marketing services
19.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Article 6 (1) (f) of the GDPR) we use the marketing and remarketing services (‘Google Marketing Services’) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, (‘Google’).
19.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
19.3. Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. For example, when a user is shown ads for products that they were interested in on other websites, this is referred to as remarketing. For these purposes, when our website and other websites using Google Marketing Services are accessed, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as ‘web beacons’) are incorporated into the website. With their help, the user is provided with an individual cookie, i.e. a small file is saved (in lieu of cookies, similar technologies may also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file contains notes on which websites the user has visited, what content they are interested in and what offers they have clicked on. Furthermore, it contains technical information about the browser and operating system, referring websites, visit time and other information on the use of the online service. Users’ IP addresses are also recorded, whereby in the context of Google Analytics, IP addresses are shortened within member states of the European Union or other parties to the Agreement on the European Economic Area and only in exceptional cases are they transferred to a Google server in the US and shortened there. The IP addresses will not be merged with user data within other Google services. The above information may also be linked by Google with such information from other sources. If the user goes on to visit other websites, they can be displayed according to the user’s interests with tailored ads.
19.4. The data of the users is processed in the form of pseudonyms for Google Marketing Services. This means that for instance, Google does not store and process users’ names or email addresses, but rather processes the relevant data in a cookie-related manner within pseudonymous user profiles. This means that from the perspective of Google, the ads are not managed and displayed for a specifically identified person, but rather for the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without pseudonymisation. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google’s servers in the US.

The Google Marketing Services we use include the online advertising programme ‘Google AdWords’. In the case of Google AdWords, each AdWords customer receives a different ‘conversion cookie’. Cookies cannot be tracked through AdWords customers’ websites. The information collected through the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers will see the total number of users who clicked on their ad and were redirected to a page provided with a conversion tracking tag. However, they do not receive information that can personally identify users.