RSP GmbH ("RSP", "we", "us") treats the protection of personal data as of paramount importance. In addition to the obvious compliance with the legal provisions on data protection, we would like to commit ourselves to the responsible handling of your data, based on these additional specifications.
1 Who is responsible for data processing and whom may I contact?
Responsible within the meaning of the General Data Protection Regulation (GDPR) is:
the RSP GmbH company
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You can reach our company data protection officer under the contact details above, as well as by e-mail at email@example.com
2 What do we understand by personal data?
Personal data is any information that relates to an identified or identifiable natural person. Identifiable means any natural person who can be directly or indirectly identified, in particular by association with an identifier such as a name, a customer number, a location data, an online identifier or other special features.
These include, for example, any information that you provide us with in order to be able to register and use your user account, such as your name, your telephone number and your address. Purely statistical data that we collect when visiting our websites are not included as we cannot associate them with your person.
3 Which data do we collect?
3.1 Data provided by you to us
3.1.1 when raising general inquiries.
For inquiries directed to us, we process your name, contact details (such as telephone number, e-mail address and postal address) as well as any other information that you voluntarily provide when filling in forms or other data fields on our website. This includes information you provide when:
- you submit a request for a particular product;
- you ask a question or give us feedback.
3.1.2 you use our spare parts catalogue
To use our online spare parts catalogue, you must register a user account with us or log in to your existing user account. When creating your user account and completing the order, we will process your name, address, e-mail address, if applicable, your telephone number, part number, name, quantity and other remarks that you provide to us.
3.1.3 you send online application documents
If applicants submit suitable application documents to us, electronically, for example by e-mail or via a web form on our website, we process the personal data of the applicant for the purpose of processing the application.
Within the RSP, only those persons whose job is to process the application will have access to your data. Our service providers may also receive data for these purposes if they maintain data secrecy and, among other things, comply with our written data protection policy.
3.2 General data we collect when using this website
When you visit our website, a number of general data are collected and stored in log files. These are the browser types and versions used, the operating system used by the accessing system, the website from which an accessing system accesses our website (so-called referrers), the resources you access, date and time of access to the website, an internet protocol address (IP address), the accessing system's Internet service provider and other comparable data and information that enable us to provide security in the event of attacks on our website.
When using this general data, we draw no conclusions about the person concerned. Rather, these data are needed to properly deliver the contents of our website, to optimise the presentation of the content of our website, to ensure the continued functioning of our website, and to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack.
We therefore evaluate these pseudonymised data on the one hand statistically and on the other hand with the aim of increasing data protection and data security in order to ensure a sufficient level of protection for the personal data we process. The pseudonymised data stored on the server log files are stored separately from all personal data provided by an concerned person.
3.3 Data we collect for website usage analysis and improvement through cookies or similar analysis tools
Many cookies contain a so-called cookie ID, a unique identifier. It consists of a string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows the visited websites to distinguish the individual browser of an affected person from other internet browsers that contain other cookies. Your anonymised IP address, details of your operating system used, Internet browser and other device details, such as the resolution used, will also be collected. The purpose of this recognition is to provide the users of this site more user-friendly services that would not be possible without the cookie setting. For example, your shopping cart is kept available via a cookie.
By means of a cookie, the information and offers on our website can be optimised for the benefit of the user and it also make it easier for users to use our website.
The setting of cookies through our website can be prevented at any time by means of a corresponding setting in the Internet browser used and thus its use can be at any time permanently rejected. For this, please follow the instructions in the help section of your internet browser. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the user deactivates the playing of cookies in the Internet browser used, not all functions of our website may be fully usable.
3.4 Use of Google Analytics
For the purpose of demand-oriented design and continuous optimisation of our website, we use Google Analytics, a web analysis service of the Google Ireland Ltd. (“Google“). In this context, pseudonymised usage profiles are created and cookies are also used. The information generated by the cookie about your use of this website, such as browser type / version, operating system used, referrer URL (the previously visited page), hostname of the accessing computer (IP address), time of server request, are sent to a Google server based in the US and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to the website activity and internet usage for the purposes of market research and tailor-made website design. This information may also be transferred to third parties if required by law or if third parties process such data in an order. Under no circumstances will your IP address be merged with any other data provided by Google. The IP addresses are anonymised, so that an assignment is not possible (so-called IP masking).
You can prevent the installation of cookies by a corresponding setting of the browser software; however, we point out that in this case not all the features of this website may be fully exploited. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing this Browser Add-on. As an alternative to the browser add-on, especially for browsers on mobile devices, you can prevent the collection by Google Analytics by clicking on this link. An opt-out cookie will be set which prevents the future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website, and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again. For more information about privacy in connection with Google Analytics, visit the website of Google Analytics.
4 Is personal information transmitted to a third country?
With the use of this website, also a data transfer to countries outside the European Economic Area ("EEA") in the context of in no. 3.4 data processing occurs, if the opt-out option was not selected. For this area, there is no adequacy decision of the EU Commission, as there is no data policy comparable with the EU data protection rules (the so-called third countries).
The company stated in no. 3.4 is certified under the EU-US Privacy Shield and guarantees the persons concerned an appropriate data privacy level, in particular legally binding and enforceable rights.
The rest of the data processing takes place exclusively in the EU, using contracted service providers acting on our behalf.
A data transfer to countries outside of the EEA takes place, as far as
- this is required to process your requests;
- in the context of an order processing according to Art. 28 GDPR.
If service providers are used in the third country, they are obliged to comply with EU data protection standards in addition to the written instructions under the agreement by the EU Commission's standard contractual clauses.
5 Integration of services and contents of third parties
Within our website we use contents and service offers of third-party providers in order to integrate their contents and services, in particular videos or fonts (referred to collectively in the following as “contents”). This always requires that third-party providers of these contents perceive the IP addresses of the users, because without the IP addresses they cannot send contents to their browsers. The IP address is thus required for the representation of these contents. We will make efforts to use only such contents whose relevant providers use the IP address only for delivering the contents. Furthermore, third-party providers can use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. By means of the “pixel tags”, information about how the visitor traffic is on the pages of this website can be evaluated. Moreover, the pseudonym information can be saved in the form of cookies on the device of the user and, among other things, contain technical information about the browser and operating system, referring websites, visiting time as well as further information about the use of our online offer and be linked to such information from other sources.
The following representation offers an overview of third-party providers as well as their contents along with links to their privacy statements, containing further notes on the processing of data and, partly stated herein, possibilities of appeal (so-called opt-out):
External fonts from Monotype Imaging Holdings Inc., a Delaware corporation at 600 Unicorn Park Drive, Woburn, Massachusetts 01801 USA. Integration of MyFonts takes place by a service call-up at myfonts.com (normally in the USA). Privacy statement:
Videos of the platform “YouTube” of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy statement: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
6 How long do we save your data?
The RSP processes and stores personal data of the data subject only as long as this is necessary for the fulfilment of the purpose or as required by law.
If the RSP concludes a contract of employment with the applicant, the transmitted data will be stored at the RSP in compliance with legal requirements, otherwise the application documents will be deleted no later than five months after the announcement of the rejection decision, unless deletion exceeds any other legitimate interests of the data controller. Another legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (GETA).
Also, commercial and tax retention periods may preclude deletion. The deadlines for storage and documentation specified there are up to ten years. If the purpose of the storage is omitted or if a legally prescribed retention period expires, the personal data will be routinely and in accordance with the statutory provisions restricted or deleted unless they are used as evidence.
7 On which legal basis do we process your data?
We process the aforementioned personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Federal Data Protection Act (FDPA):
7.1 on the decision on the establishment of an employment relationship (Article 6 (1) (b) GDPR i.V.m. § 26 FDPA)
We process the data that you have sent us in connection with your application in order to examine your suitability for the position (or possibly other open positions in our company) and to carry out the application process in accordance with § 26 FDPA.
7.2 In the context of the balance of interests (Article 6 (1) (f) GDPR)
If necessary, we process your data for the protection of legitimate interests of us or third parties, as far as you have not objected to the use of your data, for
- statistical analysis of the use of our website, for the interest-oriented design of the website and to ensure that the content of our website is displayed in the most optimal way for you and your computer (also under recourse to the order processor Google Ireland Ltd.)
- asserting legal claims and defence in legal disputes;
- ensuring IT security, data protection control and data security;
- prosecution of criminal offences;
- the provision of information about our products, services, offers or technical developments (direct marketing) to you, which you request from us as our customer or which we believe may interest you, to the extent permitted by law;
- integration of videos or fonts of third-parties for an economic operation of our website;
- the processing of inquiries via the contact form;
- passing on your personal data within the group of companies, insofar as this is legally permissible, for internal administration purposes, including the processing of personal data of customers and employees;
- to store some of your personal information if you use our services or have indicated a preference for marketing communications or other correspondence, e.g. to be able to process the follow-up requests, to improve our service;
7.3 On the basis of your consent (Article 6 (1) a of GDPR)
Provided that you have agreed to process your personal data for particular purposes (e.g. our newsletter dispatch), the legality of this processing is given on the basis of your consent.
For sending the newsletter, we use the so-called double opt-in procedure, which means that we will only send you a newsletter by e-mail if you have previously explicitly confirmed to us that you wish to receive our newsletter. You will then receive a notification e-mail from us requesting you to confirm that you wish to receive our newsletter by clicking on the link in the e-mail. You can unsubscribe from the newsletter at any time. A textual message to the contact details referred to in point 1 (e.g. e-mail, fax, letter) is sufficient. Of course, you can also use the unsubscribe link available in every newsletter.
We may also use your personal information for direct marketing purposes or for soliciting your opinion on our products and services, which may be used for marketing, research and analysis purposes, provided that you have consented to them for such purposes.
8 Is the use of automated decision making or profiling processes carried out?
In principle, we do not use a fully automated decision-making pursuant to Article 22 GDPR. If we use these procedures in individual cases, we will inform you about this separately, if this is required by law.
9 Is the provision of personal data required by law or contract?
You are not obligated to provide us with the aforementioned personal data via the website.
10 Other receivers of the data?
In addition to service providers acting on behalf of us and previously named recipients, we may also disclose your personal information to third parties when we are required to disclose or further transmit your personal information in order to comply with a legal obligation or the rights, property or security of RSP to protect our customers or others.
In order to process your data for the purposes described here, it may be necessary to disclose (or otherwise process) your personal information to a company in our group or to third parties.
11 Your rights as a concerned person
Any person affected by our personal data processing has the right to information under Article 15 GDPR, the right to rectification under Article 16 GDPR, the right to cancellation under Article 17 GDPR, the right to restriction of processing under Article 18 GDPR, the right to object under Article 21 GDPR and the right to data portability under Article 20 GDPR. With regard to the right to information and the right to erase, the restrictions under §§ 34 and 35 FDPA apply. In addition, there is a right of appeal to a data protection supervisory authority pursuant to Article 77 GDPR in the sense of § 19 FDPA.
11.1 Information about your right of objection under Article 21 GDPR
11.1.1 Case-specific right of objection
You have the right, for reasons of your own particular situation, to object at any time to the processing of personal data relating to you pursuant to Article 6 (1) of the GDPR (data processing based on a balance of interests); this also applies, as far as given, to a profiling based on this provision within the meaning of Article 4 (4) GDPR.
In individual cases, we also process your personal data in order to operate direct mail. You also have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct mail.
If you object, we will no longer process your personal information unless we can establish compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purposes of asserting, exercising or defending legal claims.
If you object to the processing for the purposes of direct advertising, we will not process your personal data for these purposes any more without incurring any costs other than the transmission costs in accordance with the basic tariffs.
Please contact the data protection officer directly regarding your data protection rights.
11.2 Revocation of granted consent
The data subject can revoke any consent given to us at any time. This also applies to the revocation of declarations of consent that were given to us before the validity of the EU General Data Protection Regulation, i.e. before 25 May 2018. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.[FN1]
11.2.1 Perception of contradiction or revocation of a granted consent
The objection can be form-free and can be addressed to us by telephone:
- by using our contact form in contact section, expressing your objection;
- by written communication to:
- by phone: +49 36 71 57 21 0
- by fax: +49 36 71 57 21 21
- by e-mail: firstname.lastname@example.org
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Links to third party websites
Notification of changes
We encourage all parents and guardians to instruct their children in the safe and responsible use of personal information available on the Internet. Children should not submit personal information to our website without the consent of a parent or guardian. We hereby affirm that we do not knowingly collect, use, or mislabel any of your children's personal information.