Privacy Policy of Bethge Treuleben GmbH


The provisions of the EU General Data Protection Regulation (hereinafter “GDPR”) apply throughout Europe. We would like to inform you about the processing of personal data carried out by our company in accordance with this Regulation (see Articles 13 and 14 GDPR). If you have any questions or comments regarding this privacy policy, you may address them at any time to the email address stated under Section 2 or 3.

Table of contents:

I. Overview
   1. Scope
   2. Controller
   3. Data Protection Officer

II. The data processing operations in detail
   1. General information on data processing
   2. Accessing the website/application
   3. Newsletter
   4. Email advertising to existing customers
   5. Job application
   6. Customer support
   7. Catalogue request
   8. Collection, processing and use of personal data for acquiring new customers
   9. Tracking
   10. Social media plugins
   11. Order
   12. Credit check
   13. Shipping companies

III. Rights of data subjects
   1. Right to object
   2. Right of access
   3. Right to rectification
   4. Right to erasure (“right to be forgotten”)
   5. Right to restriction of processing
   6. Right to data portability
   7. Right of withdrawal of consent
   8. Right to lodge a complaint

IV. Glossary

I. Overview

In this section of the privacy policy you will find information on the scope, the controller responsible for the data processing, its data protection officer and on data security.

1. Scope

Data processing by Bethge Treuleben GmbH can essentially be divided into two categories:

-   For the purpose of contract performance, all data required for the performance of a contract with Bethge Treuleben GmbH are processed. If external service providers are also involved in the performance of the contract, e.g. logistics companies or payment service providers, your data will be passed on to them to the extent required in each case.

-   When accessing the website/application of Bethge Treuleben GmbH, various information is exchanged between your device and our server. This may also include personal data. The information collected in this way is used, among other things, to optimise our website or to display advertising in your device’s browser.

This privacy policy applies to the following offerings:

- our online offering available at www.bethge.store;

- whenever any of our other offerings (e.g. websites, subdomains, mobile applications, web services or integrations into third-party pages) refer to this privacy policy, regardless of the way in which you access or use it.

All of these offerings are also collectively referred to as “Services”.

2. Controller

The controller for data processing – i.e. the party that decides on the purposes and means of processing personal data – in connection with the Services is

Bethge Treuleben GmbH
Max Stöcker
Hohe Bleichen 21
20354 Hamburg
Germany

Tel.: +49 (0)40 / 307057-0
Email: m.stoecker@bethge.store

3. Data Protection Officer

You can contact our Data Protection Officer as follows:

BullProtect, a brand of NetBull GmbH
Patrick Vaillant
Birkenweg 48
D-35435 Wettenberg

Email: datenschutz@bethge.store

II. The data processing operations in detail

In this section of the privacy policy, we inform you in detail about the processing of personal data within the scope of our Services. For better clarity, we structure this information according to certain functionalities of our Services. During normal use of the Services, various functionalities and thus also various processing operations may occur successively or simultaneously.

1. General information on data processing

The following applies to all processing operations described below, unless otherwise stated:

a. No obligation to provide data

There is neither a contractual nor a statutory obligation to provide personal data. You are not obliged to provide data.

b. Consequences of non-provision

For required data (data marked as mandatory when entered), non-provision means that the relevant service cannot be provided. Otherwise, non-provision may mean that our services cannot be provided in the same form and quality.

c. Consent

In various cases, you have the option, in connection with the processing operations described below, to give us your consent to further processing (possibly for some of the data). In this case, we will inform you separately, in connection with submitting the respective declaration of consent, about all modalities and the scope of the consent and about the purposes we pursue with such processing operations.

d. Transfer of personal data to third countries

If we transfer data to third countries, i.e. countries outside the European Union, the transfer will take place exclusively in compliance with the statutory requirements for permissibility.

The requirements for permissibility are governed by Articles 44–49 GDPR.

e. Hosting by external service providers

Our data processing is carried out to a large extent with the involvement of so-called hosting service providers, who provide us with storage space and processing capacities in their data centres and, on our instructions, also process personal data on our behalf. These service providers process data either exclusively in the EU, or we have ensured an adequate level of data protection with the help of the EU standard contractual clauses.

f. Transfer to public authorities

We transfer personal data to public authorities (including law enforcement authorities) if this is necessary to fulfil a legal obligation to which we are subject (legal basis: Art. 6(1)(c) GDPR) or if it is necessary for the assertion, exercise or defence of legal claims (legal basis: Art. 6(1)(f) GDPR).

g. Retention period

We do not store your data longer than we need them for the respective processing purposes. If the data are no longer required for the fulfilment of contractual or legal obligations, they are regularly deleted, unless their temporary retention is still necessary. Reasons for this may include, for example:

  • Compliance with retention obligations under commercial and tax law

  • Preservation of evidence for legal disputes within the scope of statutory limitation periods

We may also continue to store your data if you have expressly given your consent to this.

h. Data categories

  • Account data:
    Login/user ID and password
  • Master data:
    Title, form of address/gender, first name, last name, date of birth
  • Address data:
    Street, house number, if applicable address additions, postcode, city, country
  • Contact data:
    Telephone number(s), fax number(s), email address(es)
  • Registration data:
    Information about the service via which you registered; times and technical information regarding registration, confirmation and deregistration; data provided by you during registration
  • Order data:
    Products ordered, prices, payment and delivery information
  • Payment data:
    Account data, credit card data, data regarding other payment services such as PayPal
  • Access data:
    Date and time of the visit to our service; the page from which the accessing system came to our page; pages accessed during use; data for session identification (session ID); and the following information about the accessing computer system: Internet Protocol address (IP address) used, browser type and version, device type, operating system and similar technical information.
  • Application data:
    CV, references, proofs, work samples, certificates, images
  • Data pursuant to Art. 9 GDPR:
    Data revealing racial and ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the unique identification of a natural person, health data or data concerning a natural person’s sex life or sexual orientation.

2. Accessing the website/application

This section describes how we process your personal data when you access our Services. We specifically point out that the transmission of access data to external content providers (see under b.) is unavoidable due to the technical functioning of information transmission on the Internet.
 

a. Information on processing

Data category

Purpose

Legal basis

Where applicable, legitimate interest

Retention period

 

Access data

Establishing the connection, displaying the content of the Service, detecting attacks on our page based on unusual activities, error diagnosis

Art. 6(1)(f) GDPR

Proper functioning of the Services, security of data and business processes, prevention of misuse, prevention of damage caused by interference with information systems

7 days

 

b. Recipients of the personal data

Category of recipients

Data concerned

Legal basis for the transfer

Where applicable, legitimate interest

External content providers that provide content (e.g. images, videos, embedded posts from social networks, advertising banners, fonts, update information) required to display the Service

Access data

Processing on behalf (Art. 28 GDPR)

Proper functioning of the Services, (accelerated) display of content

IT security service providers

Access data

Processing on behalf (Art. 28 GDPR)

Prevention of attacks by exploiting security gaps/vulnerabilities

 

3. Newsletter

We describe here what happens to your personal data in connection with a subscription to our newsletter:

a. Information on processing

Data category

Purpose

Legal basis

Where applicable, legitimate interest

Retention period

Email address

Verification of registration (double opt-in procedure), sending the newsletter

Art. 6(1)(a) GDPR

 

until withdrawal of consent

Master data

Personalisation of the newsletter

Art. 6(1)(a) GDPR

 

until withdrawal of consent

Registration data

Traceability of newsletter registration/confirmation/unsubscription

Art. 6(1)(c) GDPR

Proof of newsletter registration/confirmation/unsubscription

until withdrawal of consent

Newsletter usage profile data

Interest-based design of the newsletter

Art. 6(1)(a) GDPR

Improvement of our service, advertising purposes

until withdrawal of consent

 

b. Recipients of the personal data

Category of recipients

Data concerned

Transfer to third countries?

Newsletter dispatch service provider

all data listed under a.

No

 

4. Email advertising to existing customers

We send mailings to our existing customers in accordance with the requirements of Section 7(3) UWG and use personal data for this purpose as follows:

a. Information on processing

Data category

Purpose

Legal basis

Where applicable, legitimate interest

Retention period

Email address

Sending the mailing

Art. 6(1)(f) GDPR

Direct advertising while observing the requirements of Section 7(3) UWG

until receipt of an objection to advertising

Master data

Personalisation of the mailing

Art. 6(1)(f) GDPR

Direct advertising while observing the requirements of Section 7(3) UWG

until receipt of an objection to advertising

 

b. Recipients of the personal data

Category of recipients

Data concerned

Transfer to third countries?

Newsletter dispatch service provider

all data listed under a.

No

 

5. Job application

During an ongoing application process, we process your personal data as follows:

a. Information on processing

Data category

Purpose

Legal basis

Where applicable, legitimate interest

Retention period

Address data, contact data

Identification, contacting, communication for the initiation of a contract

Art. 6(1)(b) GDPR

 

6 months

Master data

Identification, contacting, age verification

Art. 6(1)(b) GDPR

 

6 months

Application data

Applicant selection

Art. 6(1)(b) GDPR

 

6 months

 

b. Recipients of personal data

Category of recipients

Data concerned

Legal basis for the transfer

Where applicable, legitimate interest

Where applicable, service providers / tools

     

 

6. Customer support

You can find out here how we process your personal data when you contact our customer service:

a. Information on processing

Data category

Purpose

Legal basis

Where applicable, legitimate interest

Retention period

Master data, contact data, content of enquiries/complaints

Handling customer enquiries and user complaints

Art. 6(1)(b), (f)

Customer retention, improvement of our service

Processing of the enquiry

 

b. Recipients of personal data

Category of recipients

Data concerned

Legal basis for the transfer

Where applicable, legitimate interest

       

 

7. Catalogue request

The following information describes how your personal data are processed when you request a catalogue from Bethge Treuleben GmbH and receive it by post.

a. Information on processing

Data category

Purpose

Legal basis

Where applicable, legitimate interest

Retention period

Address data, contact data Identification, contacting, sending advertising materials Art. 6(1)(a) GDPR   6 months

 

b. Recipients of the personal data

Category of recipients

Data concerned

Legal basis for the transfer

Where applicable, legitimate interest

       

 

8. Collection, processing and use of personal data for acquiring new customers

Furthermore, Bethge Treuleben GmbH uses your data for advertising purposes and may transmit address data compiled in list form for its own marketing purposes as well as for the marketing purposes of partner companies. However, this does not apply to your email address.

 

a. Information on processing

Data category

Purpose

Legal basis

Where applicable, legitimate interest

Retention period

Address data, contact data Identification, contacting, sending advertising materials Art. 6(1)(a) GDPR   6 months

 

b. Recipients of the personal data

Category of recipients

Data concerned

Legal basis f