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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: Einkaufsbüro Deutscher Eisenhändler GmbH

EDE Platz 1

42389 Wuppertal

Germany

Phone: +49 (0)202 6096-0

E-mail: webkontakt@ede.de

Website: www.ede.de

 

2. data protection officer

 

Purchasing Office German Ironmonger GmbH

For the attention of the data protection officer 

 

EDE 1st place

42389 Wuppertal

Germany

 

e-mail: datenschutz@ede.de

Website: www.ede.de

 

Every data subject may contact our Data Protection Officer at any time with any questions or suggestions regarding data protection.

 

3. Cookies

 

The websites of the E/D/E use cookies. Cookies are text files that are filed and stored on a computer system via an Internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual's browser from other Internet browsers that contain other cookies. A particular web browser can be recognised and identified by the unique cookie ID. 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. By means of a cookie the information and offers on our website can be optimised in terms of the user. Cookies allow us, as already mentioned, to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies need not re-enter their access data each time they visit the website, as this is done by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping basket in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a 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.

 

5. registration on our website

 

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. ZR-Online


ZR-Online is operated by E/D/E GmbH and is a technical platform through which suppliers and members (hereinafter referred to as "users") of E/D/E GmbH and users who have a direct billing relationship with ETRIS Bank GmbH, as a subsidiary of E/D/E GmbH, can, among other things Among other things, they can view lists (so-called "OP lists") of settled and unsettled documents of a specific accounting period, recognize the document status and create payment advice notes as well as process documents for checking purposes (e.g. by marking them), download them and process complaints.

When using the service, the following personal data is transmitted to ZR-Online:

•    First name

•    Surname

•    e-mail address

The data is processed for the purpose of authenticating users, managing user accounts, sending notification emails and processing user inquiries.

Authentication takes place via a hashed session ID, which is transferred from the extranet to ZR-Online. This session ID is deleted at the end of the session.

Access to the personal data is granted to E/D/E and ETRIS BANK employees as well as employees of the service provider commissioned by E/D/E to operate the application by way of order processing. Furthermore, the data is transferred to the Microsoft Azure cloud instance of E/D/E, which is hosted in European data centers.

All data in the application is encrypted both in transit and at rest.

The processing of personal data for invoicing is based on the fulfillment of a contract in accordance with Art. 6 (1) lit. b) GDPR. The processing of personal data in the form described above is based on E/D/E's legitimate interest in a user-friendly, fast, cost-effective and efficient provision of documents for its members and suppliers in accordance with Art. 6 (1) lit. f) GDPR.

 

9. 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.

 

10. 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.

 

11. 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.

 

12. 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.

 

13. 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.

 

14. 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.

 

15. 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).

 

16. 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.  

 

17. 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).

 

18. 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.

 

19. 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.

 

20. 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. 

 

21. Existence of automated decision-making

 

As a responsible company, we forego automatic decision-making or profiling.

 

22. Google Analytics

 

Our online offer integrates functions of the web analysis service Google Analytics of the provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and in the European Union GoogleIreland Ltd. with its headquarters in Gordon House, Barrow Street, Dublin 4, Ireland.

 

Google Analytics uses so-called "cookies", i.e. text files which are stored on your computer and which enable an analysis of website use. The information generated by the cookie about the use of this website is usually transferred to a server of Google Inc. in the USA and stored there. Google has joined the Privacy Shield, so that Google Inc. guarantees compliance with EU data protection standards.

 

Further information on the handling of user data in connection with Google Analytics can be found under the following link. Privacy policy of Google.

 

The storage of cookies is based on Art. 6 Para. 1 lit. f of the GDPR (“DSG-VO”). There is a legitimate interest in the analysis of user behaviour in order to optimise both the website and advertising.

 

Data collection by Google Analytics can be prevented by following the link below (deactivate Google Analytics). An opt-out cookie will be set which will prevent the collection of your data during future visits to the website. 

 

Furthermore, the storage of cookies can be prevented by adjusting your browser software. However, this may mean that not all functions of this website can be used to their full extent. It is also possible to prevent the collection of the data generated by the cookie and related to your use of the website (including IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the link.

 

23. Real User Monitoring

 

The website of Einkaufsbüro Deutscher Eisenhändler GmbH uses Uptrends Real User Monitoring to measure performance as experienced by the website visitor. Uptrends does not use cookies to collect data or track visitors to our website. Instead, Uptrends uses a small script file on our site that sends performance data for visitors to our website to Uptrends' servers. The information collected from each visitor includes IP addresses, device types, operating systems and browsers used. Uptrends' servers aggregate the performance data of all of our site visitors and provide us with information that allows us to improve the user experience on the site based on the above information. Uptrends uses the IP addresses of our website visitors to obtain information about the visitor's state or country, but nothing else. In addition, Uptrends does not store IP addresses on a long-term basis and Uptrends does not track or share information about individual users with third parties.

 

The Uptrends privacy policy: https://www.uptrends.de/datenschutzrichtlinie

 

This Data Privacy Statement has been created by E/D/E.

 

Data protection information for social media channels

 

Last update: 01.2024

 

1 Data protection notices

 

We are very delighted that you have visited one of our social media channels and are interested in our company. Data protection is of a particularly high priority for the management of Einkaufsbüro Deutscher Eisenhändler GmbH (hereinafter referred to as "E/D/E GmbH", "we", "us" or "responsible party"). With this data protection notice, we are informing you about how personal data is processed in connection with visits to or interactions with our social media channels or their content.

 

Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). The legal basis for data protection can be found in the General Data Protection Regulation.

 

E/D/E GmbH is present on the following social media platforms:

 

  • Facebook
  • Instagram
  • YouTube
  • Vimeo
  • X
  • LinkedIn
  • Xing

 

2 Name and address of the controller

 

The controller within the meaning of 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 the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data. In the case of our social media channels, this is a joint responsibility of Einkaufsbüro Deutscher Eisenhändler GmbH and the respective platform operators.

 

If you transmit personal data to us via our social media channels and we alone decide on the purposes and means of processing, the

 

Einkaufsbüro Deutscher Eisenhändler GmbH

EDE Platz 1

42389 Wuppertal

 

Germany

 

Tel.: +49 202 6096-0

E-mail: webkontakt(at)ede.de

Website: www.ede.de

 

Controller for the processing.

 

Please refer to the following sections for information on any joint responsibilities regarding the respective social media channels.

 

3 Contact details of the data protection officer

 

Einkaufsbüro Deutscher Eisenhändler GmbH

FAO Data Protection Officer 

 

EDE Platz 1

42389 Wuppertal

 

Germany

 

E-mail: datenschutz(at)ede.de

Website: www.ede.de 

 

You can contact our data protection officers directly at any time in case of any questions or suggestions pertaining to data protection.

 

Please refer to the following sections for contact details of the data protection officers of the respective platform operators.

 

4. Wonderlink

 

We use Wonderlink technology from Seyffert mit Himmelspach GmbH, Boppstrasse 10, 10967 Berlin, Germany, to create the link tree that leads users of our social media channels to our privacy policy, among other things. The Wonderlink link tree does not use cookies or other technologies to create user profiles or analyze user data in any way.

 

The use of this service is in our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR in a legally compliant use of social media platforms.

 

You can contact Seyffert mit Himmelspach GmbH regarding data protection issues via the e-mail address support@wonderlink.de.

 

Here you will find further information on Wonderlink and the Seyffert mit Himmelspach GmbH privacy policy.

 

5 Facebook

 

The operating company of Facebook is Meta Platforms, Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the USA or Canada, the controller for the processing of personal data is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

 

You can contact the data protection officer of Meta Platforms Ireland Ltd. via the Meta Platforms Ireland Ltd. contact form.

 

The data policy published by Facebook provides information about the collection, processing, and use of personal data by Facebook. It also explains what settings options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress the transmission of data to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

 

a) Purpose and scope of the processing of personal data

 

We use the Facebook Insights statistics service to optimize our Facebook fan page. We and Meta Platforms Ireland share responsibility for the processing of personal data via this service. Further information on joint responsibility can be found here. When you visit our site, Facebook Insights records your activities and provides us with the data via anonymized statistics. You can find information about Facebook Insights here.

 

If you contact us via Facebook, share or comment on our posts, we will receive further data, such as your Facebook account name, the date and time of your post or contact. The other data records or information provided by you depend on the content of the comments or the purpose of your contact.

 

b) Legal basis for processing personal data

 

We process the data provided by you in connection with your interaction with our site or your contacting us and which may be accessible to us in order to safeguard our legitimate interests in contacting and communicating with our interested parties, which predominate in the context of a balancing of interests. This also includes our legitimate interests in data processing in accordance with Art. 6 (1) lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

 

c) Duration of storage and deletion of data

 

The storage period of the data that you transmit to us essentially depends on the reason for your contacting us. If the respective purpose for data processing no longer applies, we delete or block the data concerned.

 

You can find information on the storage period on Facebook here.

 

d) Transfer of data

 

We do not pass on data that we have received from you via our Facebook page to third parties.

 

Facebook may transfer data to the USA or other countries outside the European Union. Information on how you can restrict this can be found here.

 

6 Instagram

 

Instagram is an online service of Meta Platforms, Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the USA or Canada, the controller for the processing of personal data is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

 

You can contact the data protection officer of Meta Platforms Ireland Ltd. via the Meta Platforms Ireland Ltd. contact form.

 

a) Information on data processing by Meta Platforms Ireland

 

The Instagram Privacy Policy specifies the categories of personal data that are processed when using Meta Platforms products (see I.), describes in general terms the purposes for which this data is used (see II.) and specifies the categories of recipients to whom this data may be disclosed (see III., IV.). You can also find information on the legal basis for the processing of this data (see V.) and information on how you can withdraw your consent to the processing of personal data under the link to the privacy policy.

 

Further information on the respective legal basis can be found here. In the Privacy Policy you will find information on how you can exercise your rights of access, rectification, portability, and erasure against Meta Platforms Ireland (see VI.). Under this point you will also find information about your right to object to certain processing of personal data.

 

You can find more information about your control options in this help article. In the Privacy Policy you will also find information about the duration for which personal data is stored and information about the criteria for determining this duration and the possibility of blocking or deleting Instagram accounts (see VII.). The Privacy Policy refers to Meta Platforms Ireland's intention to transfer data to third countries based on adequacy decisions or standard contractual clauses issued by the European Commission (see IX.).

 

We have set up our Instagram page as a business profile and use anonymized page statistics ("Instagram Insights") provided by Meta Platforms Ireland, which provide us with insights about visitors to our Instagram page and their interactions with our Instagram page and its content. We do not contribute to the decision on the means and purposes of processing event data used to generate page statistics. The statistics include the following information:

 

  • Reach, page views, time spent on video posts
  • Interactions such as marking a post with "Like", commenting on or sharing posts
  • Demographic information on age, gender, and location

 

We use this data to identify trends. It is not possible for us to link back to the people who triggered these events.

 

b) Information on the use of cookies by Meta Platforms Ireland

 

If you visit our Instagram page and your browser allows cookies to be stored, Meta Platforms Ireland stores information in the form of small text files in your browser's memory (hereinafter "cookies") and can access this information when you visit the Facebook platform or a website that integrates Facebook technologies. For more information on the purpose of the cookies used, the integration of these cookies by other websites and your control options in this regard, please refer to the information on Instagram cookies.

 

We would like to point out that Meta Platforms Ireland is able to track your user behavior (across devices for logged-in users) on other websites beyond the Instagram platform by means of the cookies used. This applies both to persons registered with the Instagram platform and to persons not registered there.

 

We would also like to point out that we have no influence on the data processing carried out by Meta Platforms Ireland in connection with cookies. It is also possible to visit our Instagram page if you configure your browser so that no cookies are stored by the Facebook platform. Information on how to adjust the settings for cookies in your browser can usually be found in the help section of the browser you are using.

 

If you are registered or logged in to the Instagram or Facebook platform and want to prevent Meta Platforms Ireland from linking your visit to our Facebook page to your Instagram or Facebook user account, you should log out of Facebook or deactivate the "stay logged in" function, delete the cookies on your device and close and restart your browser.

 

c) Data processing of interactions on our Instagram page

 

Our Instagram page offers you the opportunity to react to our posts, comment on them and send us private messages. Please check carefully what personal data you share with us via our Instagram page. If you wish to avoid Meta Platforms Ireland processing any personal data you submit to us, please contact us by other means.

 

In addition to the content you submit, information about your profile, likes and posts will be visible to us depending on your privacy settings. You can find out how to change your privacy settings in this help article.

 

We process your data when you contact us or interact with our site, or its content based on Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest lies in responding to your request. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

 

We process the data provided by you in this context and which may be accessible to us to safeguard our legitimate interests in contacting and communicating with our interested parties, which predominate in the context of a balancing of interests. This also includes our legitimate interests in data processing in accordance with Art. 6 (1) lit. f GDPR.

 

As far as possible, your data will be deleted when we cease to operate our Instagram page. Any further storage of this data by Meta Platforms Ireland is governed exclusively by the provisions of the Instagram Privacy Policy and Instagram Terms of Use.

 

7 YouTube

 

YouTube is an online service of YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, is responsible for the data processing of persons living outside the United States.

 

You can contact Google's data protection department using this contact form.

 

a) Purpose and scope of the processing of personal data

 

YouTube collects and processes your personal data as the sole controller when you access our YouTube channel. This includes, for example, your IP address and other information that can usually be assigned to your device via cookies.

 

Further information on the purpose and scope of data collection and its processing by YouTube can be found in the privacy policy.

 

b) Legal basis for processing personal data

 

We process the data provided by you in connection with your interaction with our YouTube channel or your contacting us and which may be accessible to us in order to safeguard our legitimate interests in contacting and communicating with our interested parties, which predominate in the context of a balancing of interests. This also includes our legitimate interests in data processing in accordance with Art. 6 (1) lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

 

c) Duration of storage and deletion of data

 

The storage period of the data that you transmit to us essentially depends on the reason for your contacting us. If the respective purpose for data processing no longer applies, we delete or block the data concerned.

 

Information on the storage duration of data by YouTube or Google can be found here.

 

Information on opt-out options can be found here.

 

d) Transfer of data

 

We do not pass on data that we have received from you via our YouTube channel to third parties.

 

YouTube or Google may transfer data to the USA or other countries outside the European Union. Information on how you can restrict this can be found here.

 

8 Vimeo

 

Vimeo is an online service of Vimeo LLC, 555 West 18th Street, New York, New York 10011, USA.

 

You can contact Vimeo's data protection department at the e-mail address privacy@vimeo.com.

 

a) Purpose and scope of the processing of personal data

 

Vimeo collects and processes your personal data as the sole controller when you access our Vimeo channel. This includes, for example, your IP address and other information that can usually be assigned to your device via cookies.

 

Further information on the purpose and scope of data collection and its processing by Vimeo can be found in the privacy policy and the cookie policy.

 

b) Legal basis for processing personal data

 

We process the data provided by you in connection with your interaction with our Vimeo channel or your contacting us and which may be accessible to us in order to safeguard our legitimate interests in contacting and communicating with our interested parties, which predominate in the context of a balancing of interests. This also includes our legitimate interests in data processing in accordance with Art. 6  (1) sentence 1 lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6  (1) sentence 1 lit. b GDPR.

 

c) Duration of storage and deletion of data

 

The storage period of the data that you transmit to us essentially depends on the reason for your contacting us. If the respective purpose for data processing no longer applies, we delete or block the data concerned.

 

Information on how long Vimeo stores data can be found here.

 

Information on opt-out options can be found here.

 

d) Transfer of data

 

We do not pass on data that we have received from you via our Vimeo channel to third parties.

 

Vimeo may transfer data to the USA or other countries outside the European Union. Information on how you can restrict this can be found here.

 

9 X

 

X is an online service of X Corp, 1355 Market Street, Suite 900, San Francisco, CA 94103 USA. X International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, is responsible for the data processing of persons living outside the United States.

 

You can contact X's Data Protection Officer via this contact form or by post at X International Company, Attn: Data Protection Officer, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland.

 

We would like to point out that you use the X short messaging service offered here and its functions at your own risk. This applies to the use of the interactive functions (e.g., sharing, rating).

 

a) Purpose and scope of the processing of personal data

 

The data collected about you when you use the service is processed by X Inc. This includes your IP address, the application used, information about the device you are using (including device ID and application ID), information about websites accessed, your location and your mobile phone provider.

 

This data is assigned to the data of your X account or your X profile. We have no influence on the type and scope of the data processed by X, the type of processing and use or the disclosure of this data to third parties. Information about which data is processed by X and for what purposes it is used can be found in X's privacy policy and via the option to view your own data at X. You also have the option of requesting information via the X data protection form or the archive requests.

 

Via X buttons or widgets integrated into websites and the use of cookies, X is able to record your visits to these websites and assign them to your X profile. This data can be used to tailor content or advertising to you. Information on this and the available settings options can be found on X support pages here and here.

 

Finally, X also receives information when you view content, for example, even if you have not created an account. This so-called "log data" may include the IP address, the browser type, the operating system, information about the previously accessed website and the pages you accessed, your location, your mobile phone provider, the end device you use (including device ID and application ID), the search terms you used and cookie information.

 

You have the option of restricting the processing of your data in the general settings of your X account and under "Privacy and security". On mobile devices (smartphones, tablet computers), you can also restrict X's access to contact and calendar data, photos, location data, etc. in the settings options there. However, this depends on the operating system used. Further information on these points can be found on this X support page.

 

The data you enter on X, in particular your username and the content published under your account, will be processed by us to the extent that we may retweet or reply to your tweets or post tweets from us that refer to your account. The data freely published and disseminated by you on X is thus included by Einkaufsbüro Deutscher Eisenhändler GmbH in our offer and made accessible to our followers.

 

The data is processed by us for customer loyalty and advertising purposes.

 

b) Legal basis for processing personal data

 

We process the data provided by you in connection with your interaction with our X-channel or your contacting us and which may be accessible to us in order to safeguard our legitimate interests in contacting and communicating with our interested parties, which predominate in the context of a balancing of interests. This also includes our legitimate interests in data processing in accordance with Art. 6 (1) lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

 

c) Duration of storage and deletion of data

 

The storage period of the data that you transmit to us essentially depends on the reason for your contacting us. If the respective purpose for data processing no longer applies, we delete or block the data concerned.

 

Information on the storage period of data by X can be found here.

 

d) Transfer of data

 

We do not pass on data that we have received from you via our X account to third parties.

 

X may transfer data to the USA or other countries outside the European Union. Information on how you can restrict this can be found here.

 

10 LinkedIn

 

LinkedIn is an online service of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

 

You can contact LinkedIn's data protection officer using this contact form.

 

a) Purpose and scope of the processing of personal data

 

We use LinkedIn to communicate with you and other interested parties and to inform you about Einkaufsbüro Deutscher Eisenhändler GmbH, among other things. As a rule, cookies are stored on your computers in which the usage behavior is stored. This user data is anonymized and aggregated by LinkedIn and made available to us for analysis. In addition, we only process the data records that you make available to us via LinkedIn. When processing personal data via LinkedIn, there is joint responsibility between us and LinkedIn Ireland Unlimited Company. Further information on joint responsibility can be found here.

 

Further information on the purpose and scope of data collection and its processing by LinkedIn can be found in the privacy policy.

 

b) Legal basis for processing personal data

 

We process the data provided by you in connection with your interaction with our LinkedIn account or your contacting us and which may be accessible to us in order to safeguard our legitimate interests in contacting and communicating with our interested parties, which predominate in the context of a balancing of interests. This also includes our legitimate interests in data processing in accordance with Art. 6 (1) lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

 

c) Duration of storage and deletion of data

 

The storage period of the data that you transmit to us essentially depends on the reason for your contacting us. If the respective purpose for data processing no longer applies, we delete or block the data concerned.

 

Information on how long LinkedIn stores data can be found here.

 

d) Transfer of data

 

We do not pass on data that we have received from you via our LinkedIn account to third parties.

 

LinkedIn may transfer data to the USA or other countries outside the European Union. You can find information about this here.

 

11 Xing

 

Xing is an online service of New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany.

 

You can find the contact details of Xing's data protection officer here.

 

a) Purpose and scope of the processing of personal data

 

We use Xing to communicate with you and other interested parties and to inform you about Einkaufsbüro Deutscher Eisenhändler GmbH, among other things. As a rule, cookies are stored on your computer in which the usage behavior is stored. This user data is anonymized and aggregated by Xing and made available to us for analysis. In addition, we only process the data records that you make available to us via Xing.

 

Further information on the purpose and scope of data collection and its processing by LinkedIn can be found in the privacy policy.

 

b) Legal basis for processing personal data

 

We process the data provided by you in connection with your interaction with our Xing account or your contacting us and which may be accessible to us in order to safeguard our legitimate interests in contacting and communicating with our interested parties, which predominate in the context of a balancing of interests. This also includes our legitimate interests in data processing in accordance with Art. 6 (1) lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

 

c) Duration of storage and deletion of data

 

The storage period of the data that you transmit to us essentially depends on the reason for your contacting us. If the respective purpose for data processing no longer applies, we delete or block the data concerned.

 

You can find information on the storage period of data by Xing here.

 

d) Transfer of data

 

We do not pass on data that we have received from you via our Xing account to third parties.

 

You can find information on the forwarding of data by Xing here.

 

12 Your rights

 

You have the right to request confirmation at any time as to whether we are processing personal data about you and, if this is the case, to receive information about this data and the information referred to in Art. 15 GDPR. Furthermore, you have the right to rectification pursuant to Art. 16 GDPR, the right to erasure pursuant to Art. 17 GDPR, the right to restriction of processing pursuant to Art. 18 GDPR and the right to data portability pursuant to Art. 20 GDPR, provided that the respective applicable legal requirements are met.

 

You have the right in accordance with Art. 21 GDPR to object at any time to the processing of personal data relating to you on grounds relating to your situation.

 

If the processing of your personal data was based on your consent pursuant to Art. 6 (1) lit. a) GDPR, you have the right pursuant to Art. 7 (3) GDPR to revoke your consent at any time with effect for the future.

 

To exercise your rights, you can contact us at any time using the contact details above.

 

13 Existence of automated decision-making

 

As a responsible company, we do not use automatic decision-making or profiling.

 

14 Right to appeal to a supervisory authority according to Art. 77 (1) GDPR

 

If you suspect that your data is being processed illegally on our site, you can contact a supervisory authority. You have the right to appeal in the EU Member State of your place of residence, place of work and/or place of the alleged infringement, i.e., you can choose the supervisory authority you contact in the places mentioned above. The supervisory authority to which the appeal was lodged will then inform you of the status and outcome of your submission, including the possibility of a judicial remedy under Art. 78 GDPR.