Name/Fa. CCG Cool Chain Group PL SP.Z.O.O
Road No .: ul. Kamienna 10
Postcode, City, Country: PL- 31-403, Krakow, Poland
Commercial Register / No .: KRS 0000363584
Managing Director: Björn Gersch, Krzysztof Biel
Telephone number: +48 (012) 422 23 29
E-mail address: email@example.com
Data protection officer:
E-mail address: firstname.lastname@example.org
Types of processed data:
- Inventory data
- contact information
- content data
- Usage data
- Meta / communication data
Processing of special categories of data (Article 9 (1) GDPR):
- No special categories of data are processed.
Categories of data subjects:
- Customers / prospects.
- Visitors and users of the online offer.
In the following, we also refer to the persons concerned as „users“.
Purpose of processing:
- Providing the online offer, its contents and functions.
- Provision of contractual services, service and customer care.
- Answering contact requests and communicating with users.
- Marketing, Advertising and Market Research.
- security measures.
1. Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) 1 lit. a. and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of (pre-) contractual measures as well as the answer to inquiries is Art. 6 (1) 1 lit. b. GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) 1 lit. c. GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) 1 lit. f. GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) 1 lit. d. GDPR as legal basis.
3. Safety measures
We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk. Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. In addition we have set up procedures to ensure the perception of affected rights, data erasure and reaction to endangerment of data. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection by technology design and by privacy-friendly default settings taken into account (Article 25 GDPR).
4. Collaboration with contract processors and third parties
We are part of the METRO Group. In order to achieve the above-mentioned purposes, we use service providers as processors in accordance with Art. 28 GDPR, for example as IT service providers, for the dispatch of goods ordered by you, as well as for post, e-mails and SMS or for establishing contact via telephone. These can be external service providers as well as companies from the METRO Group, such as service centers used by various METRO Group companies (shared services centers). These service providers may be located both inside and outside the European Union or the European Economic Area. We use contractual agreements (so-called “Data Processing Agreement”) with the service providers to ensure that they process personal data in accordance with the requirements of the GDPR, even if the data processing takes place outside the European Union or the European Economic Area in countries in which otherwise, an adequate level of data protection is not guaranteed and there is no adequacy decision by the European Commission, as explained in point 5 below. For more information on the existence of an adequacy decision by the European Commission and appropriate safeguards and to obtain a copy of these guarantees, you can contact our Privacy Officer at email@example.com. In addition, we only transfer data to third parties if there is a legal obligation to do so. In this case, the transfer is based on Art. 6 (1) 1 lit. c GDPR.
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit the data to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) 1 lit. b. GDPR to fulfill the contract), you have given your written consent, a legal obligation obliges it or based on our legitimate interests (e.g. the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called „data processing contract“, this is done on the basis of Art. 28 GDPR.
5. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. The data processing is performed on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called „standard contractual clauses“).
6. Rights of the data subject
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
According to Art. 16 GDPR you have the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.
According to Art. 77 GDPR you have the right to file a complaint with the competent supervisory authority.
In addition, you have the right to be informed in accordance with Art. 19 GDPR.
7. Right to withdraw
You have the right to withdraw your consent in accordance with. Art. 7 (3) GDPR with effect for the future at any time.
8. Right to object
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
9. Cookies and Right to object Direct Mail
10. Deletion of data
According to legal requirements, the date will be stored for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant to taxation, etc.).
We process inventory data (e.g. names and addresses as well as contact information of users), contract data (e.g. services used, names of contacts, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. Art. 6 (1) 1 lit b. GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.
As part of the registration, the mandatory data protection information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention for commercial or tax law reasons according to Art. 6 (1) 1 lit. c. GDPR. It is the responsibility of the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 (1) 1 lit. c. GDPR.
The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); Information in the customer account remains until its deletion.
When contacting us (via contact form or e-mail), the information provided by the user to process the contact request is processed according to Art. 6 (1) 1 lit. b. GDPR.
User information can be stored in our Customer Relationship Management System („CRM System“) or similar system.
We use the Helpdesk CRM system, Help Scout Inc., 131 Tremont St, Boston, MA 02111-1338, USA, based on our legitimate interests (efficient and fast processing of user requests). For this purpose, we have concluded a contract with Help Scout with so-called standard contractual clauses in which Help Scout commits itself to processing the user data only in accordance with our instructions and compliance with the EU data protection standard. Help Scout is also certified under the Privacy Shield Agreement, providing an additional guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000KzX1AAK&status=Active).
We delete the contact requests, if they are no longer required. We check the necessity every two years; Inquiries from customers who have a customer account, we store permanently and refer to the deletion on the details of the customer account. In the case of legal archiving obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
13 Comments and posts
If users leave comments or other contributions, their IP addresses are stored based on our legitimate interests within the meaning of Art. 6 (1) 1 lit. f. GDPR for 7 days.
The storage is for our own safety, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc. In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
14. Collection of access data and log files
Based on our legitimate interests within the meaning of Art. 6 (1) 1 lit. f. GDPR Data we survey every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of seven days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
15. Online presence in social media
We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
16. Cookies & Range Measurement
Cookies are information transmitted from our web server or third-party web servers to users‘ web browsers and stored there for later retrieval. Cookies can be small files or other types of information storage.
We use „session cookies“ that are only stored for the duration of the current visit to our online presence (for example, to enable the storage of your login status or the shopping cart function and thus the use of our online offer at all). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the retention period. These cookies can not save any other data. Session cookies will be deleted if you have finished using our online offer and you have e.g. log out or close the browser.
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
17. Google Analytics
Your IP address will be shortend by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internat usage to the website operator. The provided IP address provided by Google Analytics will not be merged with other Google information.
You can prevent the storage of cookies by setting your browser software accordingly. You may also prevent the collection by Google of the data generated by the cookies and related to your use of the website (including your IP adress) and the processing of this data by Google by downloading the browser plug-in available at the following link and install: https://tools.google.com/dlpage/gaoptout?hl=en.
We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services, only those users who have shown an interest in our online offering or who have certain characteristics (eg interests in specific topics or products visited by them) Web pages) that we submit to Google (so-called „remarketing“ or „Google Analytics audiences“). With Remarketing Audiences, we also want to make sure that our ads are in line with the potential interest of users and are not annoying.
We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) 1 lit. f. GDPR) we use the marketing and remarketing services („Google Marketing Services „), LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (“ Google „).
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. If a user e.g. showing ads for products he’s been interested in on other websites is called remarketing. For these purposes, when Google and our other websites accessing Google Marketing Services are directly accessed by Google, a code will be executed by Google and so-called (re) marketing tags (invisible graphics or code, also called „Web Beacons“) incorporated into the website. With their help, the user is provided with an individual cookie, i.e. a small file is saved (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file is noted which web pages the user visited, for what content he is interested and what offers he has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer. The IP address of the users is also recorded.The above information may also be linked by Google with such information from other sources. If the user then visits other websites, they can be displayed according to his interests, the ads tailored to him.
The data of the users are pseudonym processed in the context of the Google marketing services. That Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google’s servers in the United States.
Among the Google marketing services we use is u.a. the online advertising program „Google AdWords“. In the case of Google AdWords, each advertiser receives a different „conversion cookie“. Cookies can not be tracked through AdWords advertisers‘ websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
Also we can use the service „Google Optimizer“. Google Optimizer allows us to understand how various changes to a website (such as changes to the input fields, the design, etc.) can take place in so-called „A / B testings“. Cookies are stored on users‘ devices for these purposes. Only pseudonymous data of the users are processed.
In addition, we may use the „Google Tag Manager“ to integrate and manage the Google Analytics and Marketing Services on our website.
If you wish to opt-out of interest-based advertising through Google Marketing Services, you can take advantage of Google’s recruitment and opt-out options: https://adssettings.google.com/authenticated.
19. Facebook, Custom Audiences and Facebook Marketing Services
Within our online offer is used due to our legitimate interests in analysis, optimization and economic operation of our online offer and for these purposes, the so-called „Facebook pixel“ of the social network Facebook, by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025 , USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland („Facebook“).
Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
With the help of the Facebook pixel, it is on the one hand possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called „Facebook ads“). Accordingly, we use the Facebook Pixel to display the Facebook Ads we have been sent only to those Facebook users who have shown an interest in our online offer or who have certain features (e.g. interests in certain topics or products visited by them), which we transmit to Facebook (so-called „Custom Audiences“). With the help of the Facebook pixel, we also want to make sure that our Facebook ads are in line with the potential interest of users and are not annoying. With the help of the Facebook pixel we can also understand the effectiveness of the Facebook ads for statistical and market research purposes, in which we see whether users were redirected to our website after clicking on a Facebook ad (so-called „conversion“).
The processing of the data by Facebook is part of Facebook’s data usage policy. Accordingly, general notes on how to display Facebook Ads, in Facebook’s Data Usage Policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook Pixel and how it works, visit the help section of Facebook: https://www.facebook.com/business/help/651294705016616.
You may object to the capture by the Facebook Pixel and use of your data to display Facebook Ads. To set which types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions for the usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform independent, i. they are adopted for all devices, such as desktop computers or mobile devices.
To prevent the collection of your data by means of the Facebook pixel on our website, please click the following link: Facebook opt-out Note: If you click the link, an „opt-out“ cookie will be saved on your device. If you delete the cookies in this browser, then you have to click the link again. Furthermore, the opt-out only applies within the browser you use and only within our webdomain on which the link was clicked.
You can also use the Cookies for distance measurement and promotional purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and in addition the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
20. Facebook social plugins
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) 1 f. GDPR) we use social plugins („plugins“) of the social network facebook.com, which operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland („Facebook“). The plugins can represent interaction elements or content (eg videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white „f“ on blue tile, the terms „Like“, „Like“ or a „thumbs up“ sign) or are marked with the addition „Facebook Social Plugin“. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user invokes a feature of this online offering that includes such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the device of the user and incorporated by him into the online offer. In the process, user profiles can be created from the processed data. We therefore have no influence on the amount of data that Facebook collects with the help of this plugin and therefore inform the users according to our knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example, press the Like button or leave a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymous IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Other settings and inconsistencies regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American site http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.
21. Integration of services and content of third parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) 1 lit. f. GDPR), we make use of content or services offered by third-party providers in order to provide their content and services, such as Include videos or fonts (collectively referred to as „content“). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as „web beacons“) for statistical or marketing purposes. The „pixel tags“ can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web sites, visit time, and other information regarding the use of our online offer.
The following presentation provides an overview of third-party providers as well as their contents, as well as links to their data protection statements, which contain further information on the processing of data and, for already mentioned here, contradictory possibilities (so-called opt-out) contain:
– If our customers use the payment services of third parties (for example, PayPal or Sofortüberweisung), the terms and conditions and the privacy notices of the respective third party, which are available within the respective websites, or transactional applications.