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Privacy Policy

Privacy Policy in accordance with the General Data Protection Regulation (GDPR)

(1) Information about the collection of personal data and contact details of the controller

1.1. We are pleased that you are visiting our website and thank you for your interest. Below, we inform you about how your personal data is handled when using our website. Personal data is any information that can be used to personally identify you.

1.2. The controller responsible for data processing on this website according to the General Data Protection Regulation (GDPR) is:

Varodem S.A.
Rue d’Arlon 45
6747 Saint-Léger, België
Tel.: +32 (0)63239624
Fax: +32(0)63239653
E-mail: info@varodem.nl

The controller responsible for the processing of personal data is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

1.3. The controller has appointed a data protection officer for this website.

1.4. This website uses SSL and TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries you send to the controller). You can recognize an encrypted connection by the character string “https://” and the lock icon in your browser’s address bar.

(2) Data collection when visiting our website

When you use our website for informational purposes only, meaning you do not register or otherwise provide us with information, we collect only the data your browser transmits to our server (so-called server logs). When you visit our website, we collect the following data, which is technically necessary to display our website to you:

  • Which website of ours you visit
  • Date and time of the visit
  • Data volume sent in bytes
  • From which internet page you arrived at the website
  • Browser used
  • Operating system used
  • IP address used (possibly anonymized)

Processing is carried out in accordance with Article 6, paragraph 1, point (f), GDPR, based on our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used for other purposes. However, we reserve the right to subsequently review the server log files should there be any concrete indications of illegal use.(3) Cookies

Cookies

To make visiting our website attractive and enable the use of certain functions, we use cookies on various pages. These are small text files that are stored on your computer system. Some of the cookies we use are deleted after the end of your browser session, i.e., after you close your browser (so-called session cookies). Other cookies remain on your computer and allow us or our partner companies (third-party cookies) to recognize your browser on subsequent visits (persistent cookies). When cookies are placed, they collect and process personal user information, such as browser and location data, and IP addresses. Persistent cookies are automatically deleted after a specified period. This period may vary depending on the cookie.

Cookies are sometimes used to simplify the ordering process by saving settings (e.g., by remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is also processed via specific cookies, this is done in accordance with Article 6(1)(b) GDPR for the performance of the contract or in accordance with Article 6(1)(f) GDPR to protect our legitimate interests in the optimal functioning of the website and creating a customer-friendly and effective website experience.

We collaborate with advertising partners who help us make our online offering as interesting as possible for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). You will be informed individually and separately about the use of such cookies and the scope of the information collected in the sections below.

Please note that you can configure your browser to inform you about the setting of cookies and to decide individually whether to accept cookies or to reject them for certain cases or generally. Each browser manages cookie settings differently. This is described in the Help menu of each browser, which explains how to change your cookie settings. You can find this information for the respective browser via the following links:

Edge
Firefox
Google Chrome
Safari
Opera

Please note that certain functions of our website may only be usable to a limited extent if the placing of cookies is refused.

(4) Contact

When you contact us (for example, via a contact form or email), personal data is collected. The data collected when using a contact form is determined by the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and the associated technical administration. The legal basis for processing data is our legitimate interest in responding to your request in accordance with Article 6(1)(f) GDPR. If you contact us to conclude a contract, the additional legal basis for processing is Article 6(1)(b) GDPR. Your data will be deleted after your request has been processed. This is the case if it can be inferred from the circumstances that the matter in question has been finally resolved and provided that no legal storage obligations apply.

(5) Use of social media

5.1. Facebook plugins with Shariff solution
Our website uses so-called social plugins (“plugins”) from the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). To increase the protection of your personal data when you visit our website, these buttons are not integrated as complete plugins, but only as HTML links. This type of integration ensures that no connection to the Facebook servers is established when you visit a page on our website that contains such a button. When you click the button, a new browser window opens and the Facebook website is accessed, where you can interact with the plugins there (if necessary, after entering your login information).
Facebook Inc., headquartered in the US, is certified under the EU-US Privacy Shield, which guarantees compliance with the required EU data protection level. More information can be found
here
. Information on the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your relevant rights and settings options for protecting your privacy, can be found in
Facebook’s privacy policy
.

5.2 LinkedIn Plugin as Shariff Solution
Our website uses so-called social plugins (“plugins”) from the online service LinkedIn. LinkedIn is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). To better protect your data when you visit our website, these buttons are not fully integrated as plugins, but can only be accessed via an HTML link on the page. This integration method ensures that we do not establish a connection to LinkedIn’s servers when you visit a page on our website that contains such buttons. When you click the button, a new browser window opens and you access the LinkedIn page, where you can interact with the plugins (possibly after entering your login details). LinkedIn Corporation, headquartered in the United States, is certified for the Privacy Shield agreement for the US and Europe, which guarantees compliance with the data protection level applicable in Europe. More information can be found here. The purpose and scope of this storage and the further processing and use of this data by LinkedIn, as well as your rights and settings regarding the protection of your privacy, can be found in
LinkedIn’s privacy policy.

5.3 WhatsApp Plugins with Shariff Solution
Our website uses social plugins (“plugins”) from the WhatsApp messenger service. WhatsApp is operated by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“WhatsApp”). To increase the protection of your data when you visit our website, these buttons are not fully integrated as plugins, but are only integrated into the page via an HTML link. This integration ensures that when you access a page on our website containing such buttons, no connection is established with Facebook’s servers. When you click the button, a new browser window opens and you access the WhatsApp page, where you can interact with the plugins present there (possibly after entering your login details).
WhatsApp Ireland Limited, based in Ireland, is certified for the US-European data protection agreement “Privacy Shield,” which guarantees compliance with the data protection level applicable in the EU. More information can be found
here
. You can read about the purpose and scope of data collection and further processing and use of the data by WhatsApp, as well as your rights and settings options for protecting your privacy, in
WhatsApp’s
privacy policy.

(6) Use of YouTube videos

This website uses the YouTube embedding function to display and play videos from the provider “YouTube,” which is part of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). In this context, the “extended data protection mode” is used, which, according to the provider, only triggers the storage of user information when the video(s) are played. When playback of embedded YouTube videos is started, the provider “YouTube” sets cookies to collect information about user behavior. According to information from “YouTube,” these cookies serve, among other things, to compile video statistics, improve user-friendliness, and prevent unauthorized activities. If you are logged in to Google, your information will be directly associated with your account when you click on a video. If you want to prevent your profile from being associated with YouTube, you must log out before activating the button. Google stores your data (even if you are not logged in) as usage profiles and analyzes them. Such analysis is carried out in particular pursuant to Article 6(1)(f) GDPR based on Google’s legitimate interests in displaying personalized advertising, conducting market research, and/or tailoring its website to needs. You have the right to object to this usage profiling; to exercise this right, you must contact YouTube.

Regardless of whether embedded videos are played, a connection to the Google network “DoubleClick” is established each time you visit this website. This may lead to further data processing beyond our control. Google LLC, headquartered in the US, is certified under the EU-US Privacy Shield Framework, which guarantees compliance with the required EU data protection level. More information can be found
here
. Further information about data protection at YouTube can be found in the provider’s
privacy policy
.

(7) Web analysis services

7.1. Google Universal Analytics
This website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies. These are text files stored on your computer that allow analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

This website uses Google Analytics exclusively with the “_anonymizeIp()” extension, which anonymizes the IP address by shortening it before processing, thus preventing direct personal identification. With this extension, Google shortens your IP address within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the US and shortened there. In these exceptional cases, this processing takes place in accordance with Article 6(1)(f) of the GDPR based on our legitimate interest in the statistical analysis of user behavior for marketing and optimization purposes.
Google uses this information on our behalf to analyze your use of the website, compile reports on your website activity, and provide us with other services relating to the use of this website and the internet. The IP address transmitted by your browser within the framework of Google Analytics will not be associated with other data held by Google.

You can prevent the storage of cookies by selecting the appropriate settings in your browser software; however, please be aware that you may not be able to fully utilize all functions of this website. You can also prevent Google from collecting and processing the data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available at the following link.

As an alternative to the browser plug-in or within browsers on mobile devices, you can click the following link to set an opt-out cookie that will prevent Google Analytics from collecting data on this website in the future (this opt-out cookie only works in this browser and only for this domain. If you delete your cookies in this browser, you will need to click this link again):

7.2. Disabling Google Analytics
Google LLC, headquartered in the US, is certified under the EU-US Privacy Shield, which guarantees compliance with the required EU data protection level. More information can be found here.. This website also uses Google Analytics for cross-device analysis of visitor flows. A user ID forms the basis for this. You can disable the cross-device analysis of your website use in your customer account under “My Data” – More information can be found in the privacy policy of Google.

(8) Other

8.1. Google Maps
On our website, we use Google Maps (API) from Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Maps is a web service for displaying interactive (land) maps to visually represent geographic information. By using this service, you can view our location and make it easier to plan your route to our location.

When you access subpages that include the Google Maps map, information about your use of our website (e.g., your IP address) is transmitted to and stored by Google servers in the US. This happens regardless of whether Google provides a user account you are logged in to or whether no user account exists. If you are logged in to Google, your data is directly associated with your account. If you do not want your data to be associated with your profile on Google, you must log out before activating the button. Google stores and analyzes your data (even for users who are not logged in) as usage profiles. Such analysis is carried out in accordance with Art. 6(1)(f) GDPR on the basis of Google’s legitimate interests in personalized advertising, market research, and/or the effective design of its website. You have the right to object to the creation of these user profiles; you must contact Google to exercise your objection.

Google LLC, based in the US, is certified under the EU-US Privacy Shield, which guarantees compliance with the applicable data protection level in the EU. More information can be found
here
.

If you do not agree to the future transfer of your data to Google when using Google Maps, you can disable the Google Maps service completely. You can do this by disabling JavaScript in your browser. Google Maps, and therefore the map display on this website, will then be unavailable.

Google’s Terms of Use can be viewed on this
website
. You can find the additional Terms of Use for Google Maps
here
.

Detailed information about data protection relating to the use of Google Maps can be found on the Google website (“Google Privacy Policy”).

8.2. Google reCAPTCHA
On this website, we also use the reCAPTCHA function of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). This function is intended to distinguish whether an input is made by a natural person or by abusive machine or automated means. The service includes the transmission of the IP address and any other data required by Google for the reCAPTCHA service to Google and is carried out in accordance with Article 6(1)(f) GDPR, based on our legitimate interest in determining individual freedom of action online and preventing abuse and spam. Google LLC, based in the US, is certified under the European data protection agreement “Privacy Shield,” which guarantees compliance with the data protection standards applicable in the EU. More information can be found here. More information about Google reCAPTCHA and Google’s privacy policy can be found here.

(9) Rights of the data subject

9.1. Under applicable data protection law, you, as a data subject, have extensive data protection rights (rights of information and intervention) vis-à-vis the controller processing your personal data, about which we inform you below:

  • Right of access pursuant to Article 15 GDPR;
  • Right to rectification pursuant to Article 16 GDPR;
  • Right to erasure pursuant to Article 17 GDPR;
  • Right to restriction of processing pursuant to Article 18 GDPR;
  • Right to notification pursuant to Article 19 GDPR;
  • Right to data portability pursuant to Article 20 GDPR;
  • Right to withdraw consent pursuant to Article 7, paragraph 3, GDPR;
  • Right to lodge a complaint pursuant to Article 77 GDPR.

9.2. Right to object
If, within the framework of a balancing of interests, we process your personal data based on our overriding legitimate interest, you have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data with future effect.

If you exercise your right to object, we will stop processing the data in question. However, we reserve the right to continue processing data if we can demonstrate compelling legitimate grounds for processing that override the interests, fundamental rights, and freedoms of the data subject, or if the processing is for the establishment, exercise, or defense of legal claims.

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing. You can exercise your right to object as described above. If you exercise your right to object, we will cease processing the data in question for these purposes.

It goes without saying that you can object to the processing of your personal data for advertising and data analysis purposes at any time. You can inform us of your objection to advertising using the following contact details:

Varodem S.A.
Rue d’Arlon 45
6747 Saint-Léger, Belgium
Tel.: +32 (0)63239624
Fax: +32(0)63239653
E-mail: info@varodem.nl

Management: Jürgen Gold, Bernd Mangold

(10) Duration of storage of personal data

The duration of personal data retention is determined by the respective statutory retention period (e.g., tax and commercial law retention periods). After this period expires, the relevant data will be systematically deleted if it is no longer required for the performance or preparation of a contract and we have no legitimate interest in further retention.

(11) Data processing for the processing of an order

11.1. To process your order, we work with the service provider(s) listed below, who support us, either wholly or partially, in fulfilling our agreements. Certain personal data is shared with these service providers in accordance with the following information.

The personal data we collect will be passed on to the transport company commissioned with the delivery as part of contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment information to the credit institution commissioned with the payment as part of payment processing, insofar as this is necessary for payment processing. If payment service providers are used, we will inform you explicitly below. The legal basis for this data transfer is Art. 6(1)(b) GDPR.

11.2. Execution of credit checks

  • Creditreform Augsburg
    If we grant a concession in advance (e.g., delivery on account), we reserve the right to conduct a credit check based on mathematical-statistical methods to maintain our legitimate interest in determining our customers’ solvency. We provide the personal data required for a credit check to the following service provider in accordance with Art. 6 (1) (f) GDPR: Creditreform Augsburg Frühschutz & Wipperling KG Beethovenstrasse 4, 86150 Augsburg. The credit information may contain probability values ​​(so-called score values). If score values ​​appear in the result of the credit information, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of the score values ​​includes, but is not limited to, address data. We use the result of the credit check regarding the statistical probability of default for the purpose of deciding whether to establish, execute, or terminate a contractual relationship. You can object to this processing of your data at any time by sending a message to the data controller or to the aforementioned information agency. We may also retain the right to process your personal data if this is necessary for contractual payment processing. Creditreform Augsburg’s data protection declaration: https://www.creditreform-augsburg.de/navigations/content-footer/datenschutzerklaerung.html
  • IHD Gesellschaft für Kredit und Forderungsmanagement mbH
    In the event of a credit risk, we will transfer your data (name, address, email address, company information, and possibly contractual and receivables information) for the purpose of credit checks, verifying receipt at the specified address, and processing debt collections to IHD Gesellschaft für Kredit und Forderungsmanagement mbH, Augustinusstr. 11 B, 50226 Frechen, and, if applicable, to other cooperating credit agencies. The legal basis for this transfer is Article 6(1)(b) GDPR and Article 6(1)(f) GDPR. Data transfers based on Article 6(1)(f) GDPR may only take place if this is necessary to safeguard the legitimate interests of our company and if the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, do not outweigh the interests. For the purpose of deciding on the establishment, execution, or termination of the contractual relationship, we also collect or use automatically generated probability values, which may also use address data for calculation purposes. Detailed information about our contractual partner IHD, as defined in Article 14 GDPR, including its business purpose, the purpose of data storage there, the legal basis, IHD’s data recipients, the right of access, deletion, and correction, as well as profiling, can be found
    here
    . Information about our contracting partners in the area of ​​intelligence agencies can be found
    here
    .

Created: 17-12-2018