Privacy statement

Thank you very much for your interest in our company. Data protection has a particularly high priority for the management of Primas. Using the Internet pages of Primas is basically possible without giving any personal data. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the Basic Data Protection Regulation and the country-specific data protection rules applicable to Primas. By means of this privacy policy, our company wishes 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 this data protection declaration.

As the data controller, Primas has implemented numerous technical and organizational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, such as telephone.

1.Definitions

The data protection declaration of Primas is based on the terms used by the European directive and regulation giver in the adoption of the data protection basic regulation (DS-GVO). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. In order to guarantee this, we would like to explain the terms used in advance.

We use the following terms in this privacy statement, among others:

  • a) Personal data

    Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). A natural person shall be considered identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an on-line identifier or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

  • b) Data subject

    Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

  • c) Processing

    ‘Processing’ means any operation or set of operations which is carried out with or without the aid of automated processes and which relates to personal data, such as collection, recording, organization, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, qualification, erasure or destruction.

  • d) Limitation of processing

    Limitation of processing is the marking of stored personal data with the aim of limiting their future processing.

  • e) Profiling

    Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movement of that natural person.

  • f) Pseudonymization

    Pseudonymization means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

  • g) Controller or data controller

    The controller or data controller is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the controller or controllers may be designated in accordance with Union law or with the law of the Member States on the basis of certain criteria.

  • h) Processors under contract

    Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  • i) Recipient

    The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not that person is a third party. However, authorities which may receive personal data in the context of a specific investigation mandate under Union law or the law of the Member States shall not be considered as recipients.

  • j) Third parties

    Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or processor.

  • k) Consent

    Consent shall mean any voluntary, informed and unambiguous expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, indicating that he or she consents to the processing of his or her personal data.

2.The name and address of the controller

The person responsible within the meaning of the Basic 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 Data Protection Commissioner:

Primas GbR

Kladower Damm 316 c-d

14089 Berlin

Germany (German)

Phone: +49 (0)30 3462 4311

E-Mail: support@primas-software.de

Website: https://www.primas-software.de

3. Collection of general data and information

The Primas website collects a series of general data and information each time a data subject or an automated system accesses the website. This general data and information is stored in the log files of the server. The (1) browser types and versions used can be recorded, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-sites which are accessed via an accessing system on our website, (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 to avert dangers in the event of attacks on our information technology systems.

When using this general data and information, Primas does not draw any conclusions about the data subject. This information is needed (1) to correctly deliver the content of our website, (2) to optimize the content and advertising of our website, (3) to ensure the long-term functionality of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Primas both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimum 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 the person concerned.

4. Registration on our website

The data subject shall have the possibility to register on the website of the controller by providing personal data. The personal data transmitted to the data controller is determined by the respective input mask used for registration. The personal data entered by the data subject shall be collected and stored exclusively for internal use by the data controller and for its own purposes. The controller may arrange for the data to be disclosed to one or more processors, such as a parcel service provider, who will also use the personal data solely for internal purposes attributable to the controller.

By registering on the website of the data controller, the IP address assigned to the data subject by the Internet service provider (ISP) and the date and time of registration are also stored. The storage of these data takes place so any abuse of our services can be prevented, and these data may thus be necessary for investigating possible infringements. In this respect, the storage of this data is necessary to safeguard the data controller. This data will not be passed on to third parties unless there is a legal obligation to do so or unless the data is used for criminal prosecution.

The registration of the data subject by voluntarily providing personal data serves the purpose of the data controller in terms of offering the data subject contents or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have them completely deleted from the database of the data controller.

The data controller shall provide any data subject at any time upon request with information regarding personal data stored relating to the data subject. Furthermore, the data controller shall correct or delete personal data at the request or upon notice of the data subject, provided that this does not conflict with any statutory storage obligations. The entire staff of the controller shall be available to the data subject as contact persons in this context.

5. Possibility of contact via the website

Due to legal regulations, the Primas website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject shall be automatically stored. Such personal data transmitted voluntarily by a data subject to the controller are stored for the purposes of processing or contacting the data subject. This personal data will not be passed on to third parties.

6. Routine deletion and blocking of personal data

The controller shall process and store the personal data of the data subject only for the period of time necessary to achieve the storage purpose or where provided for by the European directive and regulation maker or another legislator in laws or regulations to which the controller is subject.

If the storage purpose no longer applies or if a storage period prescribed by the European directive and regulation giver or another competent legislator expires, the personal data shall be blocked or deleted routinely and in accordance with the statutory provisions.

7. Rights of the data subject

  • a) Right to confirmation

    Every data subject shall have the right, granted by the European directive and regulation maker, to obtain from the controller confirmation as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.

  • b) Right of access

    Any person concerned by the processing of personal data has the right, granted by the European directive and regulation maker, to obtain at any time, free of charge, from the controller, information on the personal data relating to him which have been stored and a copy of that information. In addition, the European legislator has provided the data subject with the following information:

    • the processing purposes
    • the categories of personal data processed
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
    • 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 the rectification or erasure of personal data concerning him or her or to the limitation of the processing carried out by the controller or of a right to object to such processing
    • the existence of a right of appeal to a supervisory authority
    • if the personal data are not collected from the data subject: all available information on the origin of the data
    • the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the DS Block Exemption Regulation and, at least in these cases, meaningful information on the logic involved, the scope and the intended effects of such processing on the data subject

    The data subject also has the right to know whether personal data have been transferred to a third country or to an international organization. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.

    If a data subject wishes to exercise this right of access, he or she may at any time contact an employee of the controller.

  • c) Right to rectification

    Any person concerned by the processing of personal data has the right, granted by the European directive and regulation maker, to request the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject shall have the right, having regard to the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary statement.

    If a data subject wishes to exercise this right of rectification, he or she may at any time contact an employee of the controller.

  • d) Right to cancellation (right to be forgotten)

    Any person subject to the processing of personal data shall have the right, granted by the European directive and regulation, to require the controller to erase without delay personal data concerning him or her which are subject to one of the following conditions and to the extent that the processing is not necessary:

    • The personal data have been collected for such purposes or processed in any other way for which they are no longer necessary.
    • The data subject withdraws his or her consent on which the processing was based pursuant to Article 6(1)(a) DS Block Exemption Regulation or Article 9(2)(a) DS Block Exemption Regulation, and there is no other legal basis for the processing.
    • The data subject objects to the processing under Article 21(1) DS Block Exemption Regulation, and there are no overriding legitimate reasons for the processing or the data subject objects to the processing under Article 21(2) DS Block Exemption Regulation.
    • Personal data have been processed unlawfully.
    • The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject.
    • The personal data were collected in relation to information society services offered pursuant to Art. 8 para. 1 DS-GVO.

    If one of the above reasons applies and a data subject wishes to have personal data stored by Primas deleted, he may at any time contact an employee of the data controller. The employee of Primas will arrange for the request for deletion to be complied with immediately.

    If the personal data have been made public by Primas and if our company is obliged to delete the personal data as responsible party according to Art. 17 para. 1 DS-GVO, Primas shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other persons responsible for data processing who process the published personal data that the person concerned has requested the deletion of all links to these personal data or copies or replications of these personal data from these other persons responsible for data processing, insofar as the processing is not necessary. The Primas employee will take the necessary steps in individual cases.

  • e) Right to limitation of processing

    Any person subject to the processing of personal data has the right, granted by the European directive and regulation, to request the controller to limit the processing if one of the following conditions is met:

    • The accuracy of the personal data is contested by the data subject for a period of time which allows the data controller to verify the accuracy of the personal data.
    • The processing is unlawful, the data subject refuses the deletion of the personal data and 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 needs them for the assertion, exercise or defense of legal claims.
    • The data subject has lodged an objection against the processing pursuant to Art. 21 para. 1 DS-GVO, and it is not yet clear whether the legitimate reasons of the data controller outweigh those of the data subject.

    If one of the above conditions is met and a data subject wishes to request the limitation of personal data stored by Primas, he or she can contact an employee of the data controller at any time. The employee of Primas will cause the processing to be restricted.

  • f) Right to data transferability

    Any data subject involved in the processing of personal data has the right, granted by the European directive and regulation, to obtain personal data concerning him or her which have been provided by the data subject to a controller in a structured, common and machine-readable format. It shall also have the right to communicate such data to another controller without interference from the controller to whom the personal data have been provided, provided that the processing is based on the consent referred to in Article 6(1)(a) DS Block Exemption Regulation or Article 9(2)(a) DS Block Exemption Regulation or on a contract referred to in Article 6(1)(b) DS Block Exemption Regulation and that the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

    Furthermore, when exercising his or her right to data transferability pursuant to Art. 20 (1) DS-GVO, the data subject shall have the right to request that the personal data be transferred directly from one responsible person to another responsible person, insofar as this is technically feasible and insofar as this does not impair the rights and freedoms of other persons.

    In order to assert the right to data transferability, the person concerned may contact a Primas employee at any time.

  • g) Right of appeal

    Any person subject to the processing of personal data has the right, granted by the European directive and regulation maker, to object at any time, for reasons related to his/her particular situation, to the processing of personal data concerning him/her on the basis of Article 6(1)(e) or (f) of the DS Block Exemption Regulation. This also applies to profiling based on these provisions.

    In the event of objection, Primas will no longer process the personal data unless we can prove compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the person concerned, or the processing serves to assert, exercise or defend legal claims.

    Where Primas processes personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to the processing of the personal data for the purpose of such advertising. This also applies to profiling in so far as it is related to such direct marketing. If the data subject objects to the data being processed for the purposes of direct marketing, Primas will no longer process the personal data for those purposes.

    In addition, the data subject has the right to object to the processing of personal data concerning him or her by Primas for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the DS Block Exemption Regulation for reasons arising from his or her particular situation, unless such processing is necessary for the performance of a task in the public interest.

    To exercise the right to appeal, the person concerned may directly contact any Primas employee or any other employee. The data subject shall also be free to exercise his or her right of objection in relation to the use of information gathering services, notwithstanding Directive 2002/58/EC, subject to automated procedures using technical specifications.

  • h) Automated case-by-case decisions including profiling

    Any person subject to the processing of personal data has the right under the European Directive and Regulation not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects upon him or her or significantly affects him or her in a similar manner, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the data controller, or (2) is authorized by union or national law or by the member states to which the data controller is subject and which provides for adequate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, or (3) is taken with the express consent of the data subject.

    If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the data controller or (2) is taken with the express consent of the data subject, Primas shall take appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, including at least the right to have the data controller intervene, to present his or her point of view and to contest the decision.

    If the data subject wishes to exercise rights relating to automated decisions, he or she may at any time do so by contacting an employee of the controller.

  • i) Right to revoke consent under data protection law

    Every person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to revoke their consent to the processing of personal data at any time.

    If the person concerned wishes to assert their right to withdraw consent, they can contact an employee of the person responsible for processing at any time.

8. Payment Method : Data protection provisions on Klarna as a method of payment

The data controller has integrated Klarna components into this website. Klarna is an online payment service provider that enables you to purchase on account or make flexible installment payments. Klarna also offers other services such as buyer protection and identity and credit checks.

Klarna is operated by Klarna AB, Sveavägen 46, 111 34 Stockholm, Sweden.

If the person concerned selects either “purchase on account” or “hire purchase” as payment options during the ordering process in our online shop, the data of the person concerned is automatically transmitted to Klarna. By selecting one of these payment options, the person concerned consents to the transmission of personal data required for the processing of the invoice or instalment purchase or for identity and credit checks.

The personal data transmitted to Klarna is usually first name, surname, address, date of birth, gender, email address, IP address, telephone number, mobile phone number as well as other data necessary for the processing of an invoice or installment purchase. Personal data related to the respective order are also necessary for the processing of the purchase contract. In particular, there may be mutual exchange of payment information such as bank details, card number, expiry date and CVC code, number of articles, article number, data on goods and services, prices and tax charges, information on previous purchasing behavior or other information on the financial situation of the person concerned.

The transmission of data is intended in particular for identity verification, payment administration and fraud prevention purposes. The data controller will transfer personal data to Klarna in particular if there is a legitimate interest in the transfer. The personal data exchanged between Klarna and the controller are transmitted by Klarna to credit agencies. The purpose of this transmission is to check identity and creditworthiness.

Klarna also passes on the personal data to affiliated companies (Klarna Group) and service providers or subcontractors insofar as this is necessary to fulfil contractual obligations or the data are to be processed on behalf of Klarna.

Klarna collects and uses data and information about the previous payment behavior of the person concerned as well as probability values for their behavior in the future (so-called scoring) in order to decide on the establishment, implementation or termination of a contractual relationship. The scoring is calculated on the basis of scientifically recognized mathematical-statistical methods.

The data subject has the possibility to revoke his/her consent to Klarna to handle personal data at any time. A revocation does not affect personal data which must be processed, used or transmitted for (contractual) payment processing.

Klarna’s current data protection regulations can be found at https://cdn.klarna.com/1.0/shared/content/policy/data/de_en/data_protection.pdf.

9. Payment Method : Data protection provisions for Sofortüberweisung as a method of payment

The data controller has integrated Sofortüberweisung components on this website. Sofortüberweisung is a payment service that enables cashless payment of products and services on the Internet. Sofortüberweisung represents a technical procedure through which the online merchant immediately receives a payment confirmation. This enables a retailer to deliver goods, services or downloads to the customer immediately after the order has been placed.

The operating company of Sofortüberweisung is SOFORT GmbH, Fussbergstrasse 1, 82131 Gauting, Germany.

If the person concerned selects “Sofortüberweisung” as a payment option during the ordering process in our online shop, the data of the person concerned is automatically transferred to Sofortüberweisung. By selecting this payment option, the data subject consents to the transfer of personal data necessary for the processing of the payment.

In the case of purchase processing via Sofortüberweisung, the buyer transmits the PIN and the TAN to Sofort GmbH. After a technical check of the account balance and retrieval of further data, Sofortüberweisung then makes a transfer to the online merchant to check the account coverage. The execution of the financial transaction is then automatically notified to the online merchant.

The personal data exchanged with Sofortüberweisung is first name, surname, address, email address, IP address, telephone number, mobile phone number or other data necessary for payment processing. The purpose of data transmission is to process payments and prevent fraud. The data controller will transfer other personal data to Sofortüberweisung even if there is a legitimate interest in the transfer. Personal data exchanged between Sofortüberweisung and the controller may be transferred to credit agencies by Sofortüberweisung. The purpose of this transmission is to check identity and creditworthiness.

Sofortüberweisung may pass on the personal data to affiliated companies and service providers or subcontractors if this is necessary to fulfil the contractual obligations or if the data are to be processed on behalf of the customer.

The person concerned has the possibility to revoke his/her consent to the handling of personal data at any time against Sofortüberweisung. A revocation does not affect personal data which must be processed, used or transmitted for (contractual) payment processing.

The applicable data protection provisions of Sofortüberweisung can be found at https://www.sofort.com/ger-DE/datenschutzerklaerung-sofort-gmbh/ .

10. Legal basis for processing

Art. 6 I lit. a DS-GVO serves our company as a legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, such as in cases of inquiries about our products or services. If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data may become necessary 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 business was injured and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GVO.

Ultimately, processing operations could be based on Art. 6 I lit. f DS-GVO. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject do not predominate. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the person concerned is a customer of the person responsible (recital 47 sentence 2 DS Block Exemption Regulation).

11. Legitimate interests in the processing pursued by the controller or by a third party

If the processing of personal data is based on Article 6 I lit. f DS-GVO, our legitimate interest is the conduct of our business for the benefit of all our employees and shareholders.

12. The duration for which the personal data will be stored

The criterion for the duration of the storage of personal data is the respective legal retention period. After expiry of this period, the corresponding data will be routinely deleted unless they are no longer required for the fulfillment or initiation of the contract.

13. Statutory or contractual provisions for the provision of personal data; Necessity for the conclusion of the contract; Obligation of the data subject to provide the personal data; possible consequences of non-provision

We explain to you that the provision of personal data is in part required by law (e.g. tax regulations) or can also result from contractual regulations (e.g. information on the contractual partner).
Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data that we subsequently have to process. For example, the data subject is obliged to provide us with personal data when our company concludes a contract with them. Failure to provide personal data would mean that the contract could not be concluded with the person concerned.
Before the person concerned provides personal data, the person concerned must contact one of our employees. Our employee explains to the person concerned on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the failure to provide the personal data would have.

14. Existence of automated decision-making

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

This data protection declaration was created by the data protection declaration generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as data protection officer, in cooperation with the data protection lawyers of the law firm WILDE BEUGER SOLMECKE | Lawyers created.    

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