Data Privacy Statement
We appreciate your interest in our company. Data protection is of particular importance to the management of Einkaufsbüro Deutscher Eisenhändler GmbH (Purchasing and Marketing Association, E/D/E). The Internet pages of E/D/E can generally be used without providing any personal data. However, if a data subject wishes to use specific services of our company through our website, personal data processing may be required. If the processing of personal data is required and there is no legal basis for such processing, we generally seek the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address or telephone number of the data subject, always takes place in accordance with the General Data Protection Regulation and in accordance with the country-specific data protection provisions applicable to E/D/E. Through these data Protection Statement, our company seeks to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of these data Protection Statement.
E/D/E has implemented numerous technical and organisational measures as the controller in order to ensure the most complete protection possible for personal data processed via this website. Nevertheless, Internet-based data transmissions may generally have security gaps so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us in alternative ways, for example by telephone.
1. Name and address of the controller
The controller as defined by the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
2. Name and address of the Data Protection Officer
The controller’s Data Protection Officer for the processing is:
Every data subject may contact our Data Protection Officer at any time with any questions or suggestions regarding data protection.
By using cookies, E/D/E can provide users of this website with more user-friendly services that would not be possible without setting the cookie.
The data subject may prevent the setting of cookies through our website at any time by means of a corresponding setting of the Internet browser used and thus permanently prevent the setting of cookies. Furthermore, already set cookies can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
4. Collection of general data and information
The website of E/D/E collects a series of general data and information every time the website is accessed by a data subject or an automated system. This general data and information is stored in the log files of the server. The collection may include (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the Website from which an accessing system accesses our website (so-called referrers), (4) the sub-websites which can be accessed via (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used in the event of attacks on our information technology systems.
When using this general data and information, E/D/E does not draw conclusions about the data subject. Rather, this information is required to (1) correctly deliver the contents of our website, (2) to optimise the content of our website and the advertising for it, (3) to ensure the continued functioning of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information are therefore analysed statistically and evaluated further by E/D/E with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection 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.
The data subject has the opportunity to register on the website of the controller by providing personal data. The personal data to be transmitted to the controller is derived from the specific input mask used for the registration. The personal data entered by the data subject will be collected and stored solely for internal use by the controller and for his own purposes. The controller may arrange for the transfer to one or more processors, such as a package service provider, which also uses the personal data only for internal use attributable to the controller.
By registering on the website of the controller, the IP address of the data subject assigned by the Internet service provider (ISP) and the date and time of registration are also stored. The storage of these data takes place against the backdrop that this is the only way to prevent misuse of our services, and, in case of need, these data make it possible to investigate committed offenses. In this respect, the storage of these data is required to safeguard the controller. A disclosure of these data to third parties does not occur, unless there is a legal obligation to disclose or the disclosure is used for prosecution.
The registration of the data subject who is voluntarily providing personal data is used by the controller to provide the data subject with content or services that, due to the nature of the matter, can only be offered to registered users. Registered persons are free to modify the personal data given at registration at any time or to delete it completely from the database of the controller.
At any time upon request, the controller provides information to each data subject as to which personal data about the data subject are stored. Furthermore, the controller corrects or deletes personal data upon the request or reference of the data subject, provided this does not conflict with any statutory storage requirements. All of the controller’s employees, who are responsible for data in this context are available to the data subject as a contact person.
6. Subscription to our Newsletter
On the website of E/D/E, users are given the opportunity to subscribe to the newsletter of our company. The personal data transmitted to the controller when the newsletter is ordered are found in the input mask used for this purpose.
E/D/E informs its customers and business partners at regular intervals by way of a newsletter about company offers. The newsletter of our company can only be received by the data subject, if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter. For legal reasons, a confirmation e-mail using the double opt-in procedure will be sent initially to the e-mail address entered by a data subject for sending the newsletter. This confirmation e-mail is used to check whether the owner of the e-mail address is the data subject and has authorised receipt of the newsletter.
Furthermore, when subscribing to the newsletter, we also store the IP address of the data subject assigned by the Internet Service Provider (ISP) used by the computer system at the time of registration, as well as the date and time of registration. The collection of these data is necessary in order to determine the (possible) misuse of a data subject’s e-mail address at a later date and therefore serves as a legal safeguard for the controller.
The personal data collected in the context of registering for the newsletter shall be used exclusively for sending our newsletter. Subscribers to the newsletter may also be notified by e-mail if this is necessary for the operation of the newsletter service or registration, which may the case in the event of changes to the newsletter or technical conditions. There is no disclosure to third parties of the personal data collected as part of the newsletter service. The data subject may terminate the subscription to our newsletter at any time. The consent to the storage of personal data that the data subject has given us for the sending of the newsletter may be revoked at any time. There is a corresponding link in each newsletter for the purpose of revoking consent. It is also possible to unsubscribe from the newsletter at any time directly on the controller's website, or to inform the controller in a different way.
7. Processing of operational contact data in the EDE CRM system
EDE GmbH processes the general operational costumer contact information in a customer contact data tool („Customer Relationship Management System“), designed exclusively for communication purposes within the framework of the business relationship. Data processing within this system is used exclusively for the management of contact information, and no additional functions are foreseen. The data processing is carried out in the legitimate interest of the company, respectively for the purpose of contract implementation under the terms of Art. 6 lit. b, lit. f.
8. Newsletter tracking
The newsletters of E/D/E contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in such e-mails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. On the basis of the embedded tracking pixel, E/D/E can detect if and when the e-mail was opened by a data subject and which links in the e-mail were visited by the data subject.
Such personal data collected via the tracking pixels contained in the newsletters will be stored and evaluated by the controller in order to optimise the delivery of newsletters and to better adapt the content of future newsletters to the interests of the data subject. These personal data will not be disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent made via the double opt-in procedure. After revocation, the controller will delete this personal data. For E/D/E, cancellation of the receipt of the newsletter is considered an automatic cancellation of the newsletter.
9. Contact possibilities via the website
Due to legal regulations, the website of E/D/E contains information that enables us to contact our company quickly and to communicate directly with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or through a contact form, the personal data provided by the data subject will be automatically stored. Such personal data, voluntarily transmitted by an individual to the controller, is stored for the purpose of processing or contacting the data subject. There is no disclosure of these personal data to third parties.
10. Comment function in the website blog
E/D/E offers users the opportunity to leave direct comments about individual posts on a blog located on the website of the controller. A blog is a web-based, usually public-accessible portal in which one or more people, who are called bloggers or web bloggers, are able to post articles or write down thoughts in so-called blog posts. As a rule, third parties may make comments in blog posts.
If a data subject leaves a comment in a blog published on this website, not only the comments left by the data subject but also information on the time of the comment input and the username (pseudonym) chosen by the data subject are saved and published. Furthermore, the IP address assigned by the Internet Service Provider (ISP) of the data subject is also logged. This storage of the IP address is made for security reasons in the event the data subject violates the rights of third parties or posts illegal contents by submitting a comment. The storage of such personal data is therefore in the controller’s own interest so that he could exculpate himself in case of an infringement. There is no disclosure of these personal data to third parties, provided such disclosure is not required by law or is used for the legal defence of the controller.
11. Subscribing to comments in the website blog
Generally, third parties may subscribe to the comments made in the blog of E/D/E. In particular, a commentator has the opportunity to subscribe to comments following comments on a particular blog post.
If a data subject chooses the option to comment, the controller will send an automatic confirmation e-mail to check using the double opt-in procedure whether the owner of the e-mail address provided for that person has actually chosen this option. The option to subscribe to comments may be terminated at any time.
12. Routine deletions and blocking of personal data
The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of the storage or, as the case may be, by the European regulators or by any other legislator of laws or regulations to which the controller is subject.
If the purpose of the storage is omitted or if a storage period prescribed by the European regulators or any other competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
13. Rights of the data subject
a) Right to confirmation
As granted by the European regulators, each data subject has the right to ask the controller to confirm whether personal data that concerns him is being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may contact an employee of the controller at any time.
b) Right to access/ information
Any data subject affected by the processing of personal data has the right granted by the European regulators to obtain information from the controller free of charge on the personal data stored about him and a copy of that information at any time. Furthermore, the European regulators have provided the data subject with the following information:
the processing purposes;
the categories of personal data being processed;
the recipients or categories of recipients to whom the personal data have been disclosed or are yet to be disclosed, in particular to recipients in third countries or at international organisations;
if possible, the planned duration for which the personal data will be stored or, if that is not possible, the criteria for determining that duration;
the existence of a right to correction or deletion of the personal data concerning him or a restriction of the processing by the controller or of a right to object to such processing;
the existence of a right to complain to a supervisory authority;
if the personal data are not collected from the data subject: All available information on the source of the data;
the existence of automated decision-making including profiling under Art. 22 (1) and (4) of the GDPR and - at least in these cases - meaningful information on 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 as to whether personal data has been transmitted to a third country or to an international organisation. If that is the case, then the data subject has the right to obtain information about the appropriate guarantees in connection with the transfer.
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 regulators to demand the immediate rectification of inaccurate personal data concerning him. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.
If a data subject wishes to exercise the right of rectification, he/she may contact an employee of the controller at any time.
d) Right to erasure (right to be forgotten)
Any data subject affected by the processing of personal data shall have the right granted by the regulators to ask the controller to immediately erase the personal data concerning him/her, provided that one of the following reasons applies and the processing is not required:
The personal data was collected for such purposes or otherwise processed for purposes that are no longer necessary.
The data subject revokes his/her consent on which the processing was based pursuant to Art. 6 (1) (a) of the GDPR or Art. 9 (2) (a) of the GDPR and lacks any other legal basis for the processing.
The data subject objects to the processing pursuant to Art. 21 (1) of the GDPR, and there are no legitimate reasons for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) of the GDPR.
The personal data was processed unlawfully.
The deletion of personal data is necessary to fulfil a legal obligation under European Union or national laws to which the controller is subject.
The personal data was collected with regard to information society services offered pursuant to Art. 8, para. 1 of the GDPR.
If one of the above reasons applies and a data subject wishes to arrange for the deletion of the personal data stored with E/D/E, he/she may contact an employee of the controller at any time. The employee of E/D/E shall arrange for the deletion request to be fulfilled immediately.
If the personal data has been made public by E/D/E and if our company as the controller is responsible for the erasure of personal data in accordance with Art. 17, para. 1 of the GDPR, E/D/E will take appropriate measures considering the available technology and the implementation costs, including technical means, and inform other controllers who processed the published personal data that the data subject has requested that these other controllers delete all links to these personal data or copies or replications of these personal data, if the processing is not necessary. The employee of E/D/E shall arrange what is necessary in the individual case.
e) Right to restriction of processing
Any data subject affected by the processing of personal data has the right, as granted by the European regulators, to request that the controller restrict the processing if one of the following preconditions exists:
The data subject contests the accuracy of the personal data for a period of time that allows the controller to check the accuracy of the personal data.
The processing is unlawful and the data subject refuses to delete the personal data but instead requests the restriction of the use of the personal data.
The controller no longer needs the personal data for the purposes of processing, but the data subject requires them to assert, exercise or defend legal claims.
The data subject has lodged an objection to the processing pursuant to Art. 21, para. 1 of the GDPR, and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.
If one of the above preconditions is met and a data subject wishes to request the restriction of personal data stored with E/D/E, he/she may contact an employee of the controller at any time. The employee of E/D/E shall initiate the restriction of the processing.
f) Right to data portability
Any data subject affected by the processing of personal data has the right granted by the European regulators to obtain the personal data the data subject provided to a controller in a structured, conventional and machine-readable format. The data subject also has the right to transfer these data to another controller without hindrance by the controller to whom the personal data was provided, provided that the processing is based on the consent pursuant to Art. 6 (1) (a) of the GDPR or Art. 9 (1) (b) 2 (a) of the GDPR or on a contract pursuant to Art. 6 (1) (b) of the GDPR and processing takes place by means of an automated process, unless the processing is necessary for the performance of a task in the public interest or in the exercise of public authority, which has been assigned to the controller.
Furthermore, by exercising his/her right to data portability under Art. 20 (1) of the GDPR, the data subject has the right to see that the personal data are transmitted directly from one controller to another controller, provided this is technically feasible and this does not affect the rights and freedoms of other persons.
In order to assert the right to data portability, the data subject can contact an employee of E/D/E at any time.
g) Right to objection
Any data subject affected by the processing of personal data shall have the right granted by the European regulators to lodge an objection to the processing of personal data at any time, for reasons arising from her particular situation, pursuant to Art. 6 (1) (e) or f of the GDPR. This also applies to profiling based on these provisions.
E/D/E will no longer process personal data in the event of an objection, unless we can prove that there are compelling legitimate reasons for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves the purpose of assertion, exercise or defence of legal claims.
If E/D/E processes personal data for direct marketing, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling, to the extent it is associated with such direct marketing. If the data subject objects to E/D/E’s processing for direct marketing purposes, E/D/E will no longer process the personal data for these purposes.
In addition, the data subject has the right, for reasons arising from his/her particular situation, to lodge an objection to the processing of personal data for scientific or historical research purposes or for statistical purposes pursuant to Art. 89, para. 1 of the GDPR, unless such processing is necessary to fulfil a task in the public interest.
To exercise the right of objection, the data subject may directly contact any employee of the Einkaufsbüro Deutscher Eisenhändler GmbH or another employee. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58 / EC, to exercise the right of objection regarding automated procedures using technical specifications.
h) Automated decisions in individual cases including profiling
Any data subject affected by the processing of personal data shall have the right granted by the European regulators, not to be subject to a decision based solely on automated processing, including profiling, which has a legal impact on her or, in a similar manner, is significantly affected by it; unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is permitted by Union or Member State regulations to which the controller is subject, and these regulations provides for appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject ; or (3) occurs with the express consent of the data subject.
If the decision (1) is required for the conclusion or fulfilment of a contract between the data subject and the controller or (2) it takes place with the explicit consent of the data subject, E/D/E shall take appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, including at least the right to obtain the intervention of a person by the controller to express her own opinion and to contest the decision.
If the data subject wishes to assert rights with regard to automated decision-making, he/she can contact an employee of the controller at any time.
i) Right to revoke a data protection consent
Any data subject affected by the processing of personal data has the right, as granted by the European regulators, to revoke consent to the processing of personal data at any time.
If the data subject wishes to assert the right to revoke consent, he/she may contact an employee of the controller at any time.
14. Data protection for job applications and during the application process
The controller collects and processes the personal data of applicants for the purpose of processing the application process. The processing can also be done electronically. This is particularly the case if an applicant submits corresponding application documents to the controller by electronic means, for example by e-mail or via a web form available on the website. If the controller concludes an employment contract with an applicant, the data transmitted shall be stored for the purposes of the employment relationship in accordance with the law. If no employment contract is concluded with the candidate by the controller, the application documents shall be automatically deleted two months after the announcement of the rejection decision, unless no other legitimate interests of the controller oppose the deletion. Other legitimate interest in this sense, for example, is a burden of proof in a proceeding under the General Equal Treatment Act (AGG).
15. Data protection provisions for application and use of etracker
The controller has integrated components of the company etracker on this website. Etracker is a web analysis service. Web analysis is the collection, gathering and analysis of data about the behaviour of visitors to websites. Among other things, a web analysis service collects data on website from which a data subject has accessed a website (so-called referrers), which subpages of the website were accessed or how often and for which length of stay a sub-website was viewed. A web analysis is mainly used to optimise a website and to do a cost-benefit analysis of Internet advertising.
The operating company of etracker is etracker GmbH, Erste Brunnenstrasse 1, 20459 Hamburg, Germany.
etracker sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. Each time one of the individual pages on this website is visited, which is operated by the controller and into which an etracker component has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective etracker component to transfer data for marketing and optimisation purposes to etracker. In the context of this technical procedure, etracker obtains information about data that subsequently will be used to create pseudonymous usage profiles. The usage profiles obtained in this way are used to analyse the behaviour of the data subject who has accessed the website of the controller and are evaluated with the aim of improving and optimising the website. The data collected via the etracker component will not be used to identify the data subject without first obtaining the specific and explicit consent of the data subject. These data are not combined with personal data or other data containing the same pseudonym.
The data subject can prevent the setting of cookies through our website, as shown above, at any time by means of a corresponding setting of the Internet browser used and thus permanently oppose the setting of cookies. Such a setting of the Internet browser used would also prevent etracker setting a cookie on the information technology system of the data subject. In addition, cookies already set by etracker can be deleted at any time via the Internet browser or other software programs.
Furthermore, the data subject has the option to object to collection of the data generated by the etracker cookie, to use of data procured by this website and to prevent the processing of these data by etracker, and to prevent such. In this case, the data subject must press the cookie-set button at the link: www.etracker.de/privacy, which sets an opt-out cookie. The opt-out cookie set with the objection shall be placed on the information technology system used by the data subject. If the cookies on the data subject's system are deleted after an objection, the data subject must revisit the link and set a new opt-out cookie.
By setting the opt-out cookie, however, it is possible that the data subject can no longer use the controller’s website to the full extent.
The applicable data protection regulations of etracker can be found at: www.etracker.com/de/datenschutz.html.
16. Legal basis of processing
Art. 6, I lit. a of the GDPR provides our company with the legal basis for processing operations, during which we obtain consent for a particular processing purpose. If the processing of personal data is necessary to fulfil a contract to which the data subject is a party, as is the case, for example, in processing operations necessary for the delivery of goods or the provision of any other service or consideration, processing shall be based on Art. 6, I lit. b of the GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of enquiries regarding our products or services. If our company is subject to a legal obligation, which requires the processing of personal data, such as the fulfilment of tax obligations, the processing is based on Art. 6, I lit. c of the GDPR. In rare cases, the processing of personal data may be required 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 premises were injured and his or her name, age, health insurance or other vital information would have to be passed on to a doctor, hospital or another third party. Then the processing would be based on Art. 6, I lit. d of the GDPR. Ultimately, processing operations could be based on Art. 6, I lit. f, DS-GMO. On this legal basis, processing operations that are not covered by any of the above legal foundations are required if processing is necessary to safeguard the legitimate interests of our company or a third party, unless the interests, fundamental rights and fundamental freedoms of the data subject prevail. Such processing operations are particularly allowed us because they have been specifically mentioned by the European regulators. In that regard, a legitimate interest is assumed to exist if the data subject is a customer of the controller (recital 47, second sentence of the GDPR).
17. Legitimate interest in the processing pursued by the controlled or a third party
If the processing of personal data is based on Art. 6, I lit. f of the GDPR, our legitimate interest is carrying out our business for the benefit of all of our employees and our shareholders.
18. Duration for the storage of personal data
The criterion for the duration of the storage of personal data is the respective statutory retention period. After its expiry, the corresponding data will be routinely deleted, if is no longer required to fulfil the contract or to initiate a contract.
19. Legal or contractual regulations for the provision of personal data; necessity for the conclusion of the contract; obligations of the data subject to provide the personal data; possible consequences for non-provision
We inform you that the provision of personal information is partly required by law (such as tax regulations) or may result from contractual arrangements (such as information about the contractual partner). Occasionally it may be necessary for a contract to be concluded in which a data subject provides us with personal data, which subsequently must be processed by us. For example, the data subject is required to provide us with personal information when our company enters into a contract with her. Failure to provide the personal data would mean that the contract with the data subject could not be finalised. Prior to any personal data being provided by the data subject, the data subject must contact one of our employees. Our employee will inform the individual on a case-by-case basis whether the provision of the personal data is required by law or contract or is required for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
20. Existence of automated decision-making
As a responsible company, we forego automatic decision-making or profiling.
This Data Privacy Statement has been created by E/D/E.