Privacy Policy

PRIVACY POLICY FOR THE LEDVANCE WEBSITE

As of July 2022

Preamble

At LEDVANCE, data privacy is our top priority. The careful handling of your personal data is important to us. That is why we handle your data confidentially, in strict compliance with the applicable data protection provisions.

Below, we would like to explain to you which data we use, at what point in time and for what purpose. Our objective is to make you aware of our website’s functionality and how we ensure the protection of your personal data, which is of utmost importance to us. We will not use your personal data unless we have your consent or legal permission.

I. NAME AND ADDRESS OF THE DATA CONTROLLER

The data controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States, and other data protection law provisions, is as follows:

LEDVANCE GmbH
Parkring 1-5
85748 Garching near Munich
Germany
+49 89 780673-100
contact@ledvance.com
www.ledvance.de
(hereinafter referred to as ‘LEDVANCE’ or ‘we’).

II. CONTACT DETAILS OF THE DATA PROTECTION OFFICER

The controller’s data protection officer is as follows:

Mr. Matthias Lindner
bDSB LEDVANCE
c/o intersoft consulting services AG
Beim Strohhause 17
20097 Hamburg
Germany
Phone: +49 40 790235 – 0
Fax: +49 40 790235 – 170
E-Mail: privacy@ledvance.com

III. AVAILABILITY OF THE WEBSITE AND CREATION OF LOG FILES

1. Description and scope of data processing

Every time you visit our website, our system will automatically collect data and information from the computer system of the accessing device.

The following data are collected in this process:

Information about the device type and browser type, and the version used
The user’s operating system
The user’s internet service provider
The user’s IP address
Date and time of access
Websites from which the user’s system was referred to our website
Websites that are accessed by the user’s system via our website
These data is stored in the log files in our system. These data will not be stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s device For this purpose, the user’s IP address must remain stored for the duration of the session.

Storage in log files takes place in order to ensure the functionality of the website. The data also enables us to optimise our website and ensure the security of our information technology systems. No analysis of the data for marketing purposes takes place in this regard.

This also constitutes our legitimate interest in data processing as per Art. 6(1)(1)(f) GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of the data and the log files is Art. 6(1)(1)(f) GDPR.

4. Duration of storage

The data will be erased once it is no longer necessary to achieve the purpose for which it was collected. In the case of data collection for the provision of the website, this will be the case when the respective session has ended.

In the case of data storage in log files, this will be the case after seven days at the latest. It may, however, be retained for a longer period of time. In this case, the IP addresses of the users will be erased or masked to ensure that the accessing device can no longer be traced back.

5. Right to object

The collection of the data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. The user is therefore not entitled to object to this.

IV. USE OF COOKIES

1. Description and scope of data processing

Our website uses cookies. Cookies are text files which are stored in the web browser or by the web browser on the user’s computer system. When a user accesses a webpage, a cookie may be stored on the user’s operating system. This cookie contains a distinctive character string that enables unique identification of the browser when the website is accessed again.

We use cookies to make our website more user-friendly. Some of our website’s elements require that the calling browser remains identifiable even after a page change.

The cookies store and transmit the following data:
Language settings
Login data
In addition, this website uses cookies that allow us to analyse the user’s surfing behaviour.

This allows the following data to be transmitted:

Search terms used
Frequency of page views
Utilisation of website functions
The user data collected in this way will be pseudonymised by means of technical precautions. It is therefore no longer possible to assign the data to the accessing user.

When accessing our website, the user will be informed about the use of cookies for analytical purposes, and their consent to the processing of the personal data used in this regard will be obtained. In this regard, reference will also be made to this privacy policy.

2. Purpose of data processing

The purpose of implementing technically necessary cookies is to make it easier for users to use the websites. Some of our website features may be unavailable without the use of cookies. It must be possible to recognise the browser even after the user goes to a new page on the site.

We require cookies for the following applications:

Configuring language settings
Remembering search terms
The user data collected by technically necessary cookies will not be used to create user profiles.

Analysis cookies are used to improve the quality of our website and its content. The analysis cookies tell us how the website is being used, which allows us to continuously improve our offerings.

LEDVANCE collects data about how you use the website, for example which pages you visit the most and which errors occur. This analytical profiling helps us to measure how effective the website offerings are, and how the website performance could be improved.

This also constitutes our legitimate interest in personal data processing as per Art. 6(1)(1)(f) GDPR.

3. Legal basis for data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6(1)(1)(f) GDPR.

The legal basis for the processing of personal data using cookies for analytical and other purposes with the relevant user's consent is Art. 6(1)(1)(a) GDPR.

4. Storage duration / Right to objection and erasure

Cookies are stored on the user’s device, and transferred to our site by this device. Therefore, you as the user also have full control over the use of cookies. By changing the settings in your web browser or any other apps on your device, you can deactivate or restrict the transfer of cookies. Previously saved cookies can be erased at any time. This can also be done automatically. If cookies are deactivated for our website, you may not be able to use all of the website’s features to their fullest extent.

If you are using a Safari browser (version 12.1 and above), cookies will be automatically erased after seven days. This also applies to opt-out cookies which are placed to prevent tracking measures.

V. NEWSLETTER

1. General Information

You can register for our newsletter on our LEDVANCE corporate website. With the LEDVANCE newsletter you will receive the latest information about our, products, offers, events and lighting tips from the fascinating world of modern lighting. You will usually receive weekly e-mails from us. For email marketing, we use the marketing software service Klaviyo, a company of Klaviyo Inc. 125 Summer St. Boston, MA 02110, USA.

The legal basis for sending the respective newsletter is your consent according to Art. 6 para. 1 p. 1 lit. a DSGVO in conjunction with. § Art. 7 para. 2 no. 2 UWG.

Art. 7 (3) UWG forms the legal basis for existing customer advertising by e-mail, in the context of the sale of goods or services, provided that the legal requirements for this are met.

For the registration to our newsletters we use the so-called double-opt-in procedure. This means that after you have registered for the newsletter, we will send you an electronic message to the e-mail address you have provided by clicking on "Send", in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm that you wish to receive the newsletter, you will be excluded from the newsletter service.

In order to send you the newsletter, we need your e-mail address as well as the form of address, your last name and the country you live in. This information is used to address you personally and to send you a newsletter tailored to your interests. The further specification of the last name is voluntary.

After your confirmation, we store the data you provide for the purpose of sending the newsletter until revoked. We also store when you register, the time of your registration and confirmation, in order to prove your registration in case of doubt and, if necessary, to clarify any misuse of your personal data. The legal basis for logging the registration is our legitimate interest according to Art. 6 para. 1 p.1 lit. f DSGVO in proving a formerly given consent, see also Art. 7 para. 1 DSGVO.

You can revoke your consent to the sending of the newsletter at any time without giving a reason with effect for the future and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided at the end of each newsletter email.

2. Newsletter Tracking

We would like to point out that registration for the newsletter is also associated with tracking. We also use the Klaviyo marketing software service for this purpose. When you register for the newsletter, you also agree at the same time that we perform analyses by individually measuring, storing and evaluating opening and click rates in recipient profiles for the purpose of designing future newsletters. I.e. we evaluate your user behavior when sending the newsletter to determine whether and when the newsletter was opened. For this evaluation, the emails sent contain so-called web beacons or tracking pixels that are stored on our server and loaded when the newsletter is opened. The following information is transmitted in this process:

IP address
Device type
Information about the operating system
Date and time of the visit
Search terms
Usage data
Cookie information
URL

We use the collected data to create a user profile in order to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletter, which links you click on in them and infer personal interests from this. We link this data to actions you have taken on our website. The legal basis for this data processing is your consent given when registering for the newsletter, Art. 6 para. 1 p.1 lit. a DSGVO.

You can revoke your consent to tracking at any time with effect for the future by unsubscribing from the newsletter. In this case, the revocation includes the entire newsletter, as a separate revocation of the tracking is unfortunately not technically possible. To do this, simply unsubscribe from the newsletter using the unsubscribe link provided at the end of each newsletter. The revocation of the tracking is therefore unfortunately always connected with an unsubscription from the newsletter.

The described tracking is also not possible if you have deactivated the display of images by default in your e-mail program. In this case, the newsletter will not be displayed in full and you may not be able to use all the functions. If you display the images manually, the above tracking will take place.

The information from the tracking is only stored for as long as it is required for the purposes we have described. Data that has been stored by us for other purposes remains unaffected by this.

The data you provide for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted after you unsubscribe from the newsletter. Data that has been stored by us for other purposes remains unaffected by this.

3. Use of Klaviyo

For our newsletter management described in V. 1.) and 2.) and the associated tracking, we use the e-mail marketing service Klaviyo, of the American company Klaviyo Inc. 125 Summer St. Boston, MA 02110, based in the USA.

Consequently, in the case of the data processing listed within the scope of the newsletter, it cannot be ruled out that data will also be transferred to the third country USA or that there will be a possibility of access from the third country for support purposes. We would like to point out that, in the opinion of the European Court of Justice, there is not yet an adequate level of data protection in the USA that complies with EU requirements.

We have concluded an order processing agreement with Klaviyo in accordance with Art. 28 DSGVO, according to which Klaviyo undertakes to ensure the necessary protection of your data and to process it in accordance with the applicable data protection regulations exclusively on our behalf and in accordance with our instructions. A corresponding safeguard of the third country transfer is ensured in the sense of Art. 44 ff DSGVO by the use of appropriate guarantees in the form of the EU standard contractual clauses according to Art. 46 DSGVO. Further information can be found at https://www.klaviyo.com/legal/data-processing-agreement and in the Klaviyo privacy policy.

VI. EMAIL CONTACT

1. Description and scope of data processing

You can use our website to contact us using the email address provided. In that case, the user’s personal data sent along with the email will be stored.

The data will be used exclusively to process your inquiry. For this purpose, contract processors such as Microsoft365 are used, with which the corresponding contracts have been concluded.

2. Purpose of data processing

If we do contact you by email, this also constitutes the necessary interest in the processing of the data.

3. Legal basis for data processing

The legal basis of the processing of the data is, with the relevant user’s consent, Art. 6(1)(a) GDPR.

The legal basis for the processing of the data transferred while sending an email is Art. 6(1)(f) GDPR.

If the purpose of making contact by e-mail is for the conclusion of a contract, then Art. 6(1)(b) GDPR shall constitute an additional legal basis for the processing.

4. Duration of storage

The data will be erased once it is no longer necessary to achieve the purpose for which it was collected. For the personal data that is sent via email, this will be the case when the respective conversation with the user has been terminated. The conversation will be deemed terminated when it can be inferred from the circumstances that the facts in question have been finally clarified.

The additional personal data collected during the sending process will be erased after a seven-day period at the latest.

5. Right to objection and erasure

The user may withdraw their consent to the processing of personal data at any time. A user who has contacted us by email can object at any time to the storage of his or her personal data. If this right is exercised, it will not be possible to continue the conversation.

contact@ledvance.com

All personal data stored within the course of establishing contact will be erased in that case.

contact@ledvance.com

VII. COMPANY PROFILES IN SOCIAL MEDIA

1) Instagram:

Instagram, part of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Our company website provides information and offers Instagram users the opportunity to communicate. If you perform an action on our Instagram company account (e.g., comments, posts, likes etc.), it is possible that by doing so, you will make personal data (e.g., real name or photograph of your user profile) public. However, as we generally or to a great extent have no influence on the processing of your personal data by Instagram, which is also responsible for the LEDVANCE GmbH company profile, we cannot provide any authoritative details about the purpose and extent of the processing of your data.

Our company profiles in social media are used for communication and information exchange with (potential) customers. In particular, we will use the company profiles for the following purposes:

Products

The publications via the company profiles may contain the following content:

Information about products
Information about services
Contests
Customer contact
Service and support
All users are free to publish personal data by means of activities.

The legal basis for the processing of personal data is, with the voluntary consent of the user in this regard, Art. 6(1)(1)(a) GDPR.

We will store your activities and personal data published via our company’s Instagram profile until the consent is withdrawn. In addition, we comply with the statutory retention periods.

We may further process data from our company’s Instagram profile in our systems, for example in the event of a customer complaint via Instagram. We will then erase the data after the expiry of the retention period.

To ensure appropriate guarantees to protect the transmission and processing of personal data outside the EU, the data transfer to and data processing by Instagram take place on the basis of appropriate guarantees in accordance with Art. 46 et seqq. GDPR, in particular by the conclusion of so-called standard data protection clauses in accordance with Art. 46(2)(c) GDPR.

You can object at any time to the processing of your personal data, which we collect while you use our company’s Instagram profile, and assert your data subject rights set forth in part IV of this Privacy Policy. In order to do so, please send us a plain email to contact@ledvance.com . You will find more information about how Instagram processes your personal data and the respective options to object here:

Instagram: https://help.instagram.com/519522125107875

2) Pinterest:

Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland

Our company website provides information and offers Pinterest users the opportunity to communicate. If you perform an action on our company’s Pinterest profile (e.g., comments, posts, likes etc.), it is possible that by doing so, you will make personal data (e.g., real name or photograph of your user profile) public. However, as we generally or to a great extent have no influence on the processing of your personal data by Pinterest, which is also responsible for the LEDVANCE GmbH company profile, we cannot provide any authoritative details about the purpose and extent of the processing of your data.

Our company profiles in social media are used for communication and information exchange with (potential) customers. In particular, we will use the company profiles for the following purposes:

Products

The publications via the company profiles may contain the following content:

Information about products
Information about services
Contests
Customer contact
Service and support
All users are free to publish personal data by means of activities.

The legal basis for the processing of personal data is, with the voluntary consent of the user in this regard, Art. 6(1)(1)(a) GDPR.

We will store your activities and personal data published via our company’s Pinterest profile until the consent is withdrawn. In addition, we comply with the statutory retention periods.

We may further process data from our company profile in our systems and erase them after the end of the respective retention periods, for example those specified in the German Commercial Code (Handelsgesetzbuch, HGB).

To ensure appropriate guarantees to protect the transfer and processing of personal data outside the EU, the data transfer to and data processing by Pinterest take place on the basis of appropriate guarantees in accordance with Art. 46 et seqq. GDPR, in particular by the conclusion of so-called standard data protection clauses in accordance with Art. 46(2)(c) GDPR.

You can object at any time to the processing of your personal data, which we collect while you use our Pinterest company account, and assert your data subject rights set forth in part IV of this Privacy Policy. In order to do so, please send us a plain email to contact@ledvance.com . You will find more information about how Pinterest processes your personal data and the respective options to object here:

Pinterest: https://policy.pinterest.com/de/privacy-policy

3) Twitter:

Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland

Our company website provides information and offers Twitter users the opportunity to communicate. If you perform an action on our company’s Twitter profile (e.g., comments, posts, likes etc.), it is possible that by doing so, you will make personal data (e.g., real name or photograph of your user profile) public. However, as we generally or to a great extent have no influence on the processing of your personal data by Twitter, which is also responsible for the LEDVANCE GmbH company profile, we cannot provide any authoritative details about the purpose and extent of the processing of your data.

Our company profiles in social media are used for communication and information exchange with (potential) customers. In particular, we will use the company profiles for the following purposes:

Products

The publications via the company profiles may contain the following content:

Information about products
Information about services
Contests
Customer contact
Service and support
All users are free to publish personal data by means of activities.

The legal basis for the processing of personal data is, with the voluntary consent of the user in this regard, Art. 6(1)(1)(a) GDPR.

We will store your activities and personal data published via our Twitter company account until the consent is withdrawn. In addition, we comply with the statutory retention periods.

In some cases, we will continue to process data from our company profile in our systems. These data will be stored for as long as there is a purpose for doing so or a retention period, for example if necessary in potential legal disputes for the purposes of legal defence.

To ensure appropriate guarantees to protect the transfer and processing of personal data outside the EU, the data transfer to and data processing by Twitter take place on the basis of appropriate guarantees in accordance with Art. 46 et seqq. GDPR, in particular by the conclusion of so-called standard data protection clauses in accordance with Art. 46(2)(c) GDPR.

You can object at any time to the processing of your personal data, which we collect while you use our company’s Twitter profile, and assert your data subject rights set forth in part IV of this Privacy Policy. In order to do so, please send us a plain email to contact@ledvance.com. You will find more information about how Twitter processes your personal data and the respective options to object here:

Twitter: https://twitter.com/de/privacy

4) YouTube:

YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States

Our company website provides information and offers YouTube users the opportunity to communicate. If you perform an action on our company’s YouTube account (e.g., comments, posts, likes etc.), it is possible that by doing so, you will make personal data (e.g., real name or photograph of your user profile) public. However, as we generally or to a great extent have no influence on the processing of your personal data by YouTube, which is also responsible for the LEDVANCE GmbH company account, we cannot provide any authoritative details about the purpose and extent of the processing of your data.

Our company profiles in social media are used for communication and information exchange with (potential) customers. In particular, we will use the company profiles for the following purposes:

Products

The publications via the company profiles may contain the following content:

Information about products
Information about services
Contests
Customer contact
Service and support
All users are free to publish personal data by means of activities.

The legal basis for the processing of personal data is, with the voluntary consent of the user in this regard, Art. 6(1)(1)(a) GDPR.

We will store your activities and personal data published via our company’s YouTube account until the consent is withdrawn. In addition, we comply with the statutory retention periods.

In some cases, we will continue to process data from our company profile in our systems. These data will be stored for as long as there is a purpose for doing so or a retention period, for example if necessary in potential legal disputes for the purposes of legal defence.

To ensure appropriate guarantees to protect the transfer and processing of personal data outside the EU, the data transfer to and data processing by YouTube take place on the basis of appropriate guarantees in accordance with Art. 46 et seqq. GDPR, in particular by the conclusion of so-called standard data protection clauses in accordance with Art. 46(2)(c) GDPR.

You can object at any time to the processing of your personal data, which we collect while you use our company’s YouTube account, and assert your data subject rights set forth in part IV of this Privacy Policy. In order to do so, please send us a plain email to contact@ledvance.com . You will find more information about how YouTube processes your personal data and the respective options to object here:

YouTube: https://policies.google.com/privacy?gl=DE&hl=de

VIII. USE OF COMPANY PROFILES IN PROFESSIONAL NETWORKS

1. Scope of data processing

We use company profiles in professional networks. We have company profiles in the following professional networks:

LinkedIn:

LinkedIn, Unlimited Company, Wilton Place, Dublin 2, Ireland

XING:

XING SE, Dammtorstraße 30, 20354 Hamburg, Deutschland

Our company website provides information and offers users the opportunity to communicate.

The company accounts are used for applications, information/PR and active sourcing.

We are not able to provide details about the processing of your personal data by the companies which are also responsible for the company accounts. You will find further information in the privacy policies of the following companies:

LinkedIn:

https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

XING:

https://privacy.xing.com/de/datenschutzerklaerung

If you perform an action on our company account (e.g., comments, posts, likes etc.), it is possible that by doing so, you will make personal data (e.g., real name or photograph of your user profile) public.

2. Legal basis for data processing

The legal basis for the processing of your data in connection with the use of our company account is Art. 6(1)(1)(f) GDPR.

3. Purpose of data processing

Our company profile serves to inform users about our services. All users are free to publish personal data by means of activities.

4. Duration of storage

We will store your activities and personal data published via our company profiles until the consent is withdrawn. In addition, we comply with the statutory retention periods.

5. Right to objection and erasure

You can object at any time to the processing of your personal data, which we collect while you use our company profiles, and assert your data subject rights set forth in part IV of this Privacy Policy. To do so, please send us a plain email to the email address specified in this Privacy Policy.

To ensure appropriate guarantees to protect the transfer and processing of personal data outside the EU, the data transfer to and data processing by LinkedIn take place on the basis of appropriate guarantees in accordance with Art. 46 et seqq. GDPR, in particular by the conclusion of so-called standard data protection clauses in accordance with Art. 46(2)(c) GDPR.

You will find further information about the objection and erasure options here:

LinkedIn:

https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

XING:

https://privacy.xing.com/de/datenschutzerklaerung

IX. HOSTING

The website is hosted on servers by a service provider appointed by us.
Our service provider is:

SpaceNet AG

Joseph-Dollinger-Bogen 14

D-80807 Munich

The servers automatically collect and store information in so-called server log files, which your browser automatically sends when you visit the website. The following information is stored:

Browser type and browser version
Device type and operating system used
Referrer URL
Host name of the accessing computer
Date and time of the server query
IP address

These data will not be merged with other data sources. This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically correct display and the optimisation of its website; the server log files must be stored for this purpose.

The website’s server is located in Germany.

X. PLUGINS USED

1) Use of Google Analytics 4

1. Scope of processing of personal data
This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which can be utilized to analyze the use of websites.

2. How the tracking works
In order to utilize Google Analytics 4, we use so-called "server-side tracking". If you give your consent in accordance with Art. 6 (1) lit. a GDPR via the cookie banner, we will assign you a unique tracking ID. We store this ID together with other data transmitted to us when you visit the website on one of our own servers with hosting location within the EU. The following data is hereby transmitted:

IP address
referrer ID
timestamps
browser type
user agent
if applicable, mobile identifiers such as IDFA, UDID, Android ID or Google Advertising ID, Windows Advertising ID or other Windows IDs, IMEI or IMSI, MSISDN.

In order to ensure that Google Analytics does not receive any personal data, the tracking ID we create is detached from any personal as well as device data listed above so that the ID is an anonymized record. Once this has been ensured, we will solely transmit your anonymized ID to Google Analytics 4. This may also result in the transmission of this information to the servers of the company Google LLC, which is based in the USA, and further processing of the information there.

Google Analytics 4 also enables the creation of statistics with statements about age, gender and interests of website users on the basis of an evaluation of interest-based advertising and with the involvement of third-party information via a special function, the so-called "demographic characteristics". This makes it possible to determine and distinguish between groups of website users for the purpose of targeted marketing measures. However, data collected via the "demographic characteristics" cannot be assigned to a specific person and thus not to you personally. This data collected via the "demographic characteristics" function is retained for 2 months and then deleted.

As an extension of Google Analytics 4, the "UserIDs" function is also used for this website. By assigning individual UserIDs, we can have Google create cross-device reports (so-called "cross-device tracking"). This means that your usage behavior can also be analyzed across devices if you have given your corresponding consent to the use of Google Analytics 4 in accordance with Art. 6 (1) lit. a GDPR, if you have set up a personal account by registering on this website and are logged into your personal account on different end devices with your relevant login data. The data collected in this way shows, among other things, which end device was used to click on an ad for the first time and which end device was used for conversion.

3. Purpose of data processing
The purpose of the processing is the evaluation of the use of the website, the compilation of reports (reports) on website activities or usage behavior and to provide us with further services related to website and internet usage.

4. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (a) GDPR.

5. Duration of storage
The data collected in the context of the use of Google Analytics 4 will be retained for 14 months and then deleted. Beyond the aforementioned storage period, the data is only used for analysis purposes in aggregated and anonymized form, i.e. without the possibility of identifying individuals.

6. Additional measures
We have concluded a so-called data processing agreement with Google for our use of Google Analytics 4, by which Google is obliged to protect the data of our website users and not to pass it on to third parties.
To ensure a higher level of data protection, we have agreed standard data protection clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavor to obtain additional regulations and commitments from the recipient in the USA.

7. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

2)   Use of Google Tag Manager

1. Scope of processing of personal data
This website uses the Google Tag Manager of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") to collect information about user behavior and manage tags.

2. How the tagging works
To utilize the Google Tag Manager, we use so-called "server-side tagging". With the assistance of a tag, your IP-address is being collected and sent to our own server with hosting location within the EU , where the Google Tag Manager is implemented and receives the IP-address. Here, still on our own server, the IP-address is anonymized and only then sent to further services connected to the Tag Manager. This means that we only process your personal data on our own server and a connection to Google servers is technically excluded.

3. Purpose of data processing
The purpose of the processing lies in the collected and clear administration as well as an efficient integration of the services of third parties through tags. Tags are small code elements on an online presence that are used, among other things, to measure visitor numbers and behavior, capture the impact of online advertising and social channels, use remarketing and targeting, and test and optimize online presences. When a user visits the online presence, the current tag configuration is sent to the user's browser. It contains statements about which tags are to be triggered.

4. Legal basis for the processing of personal data
The legal basis for the processing of personal data is Art. 6 (1) (1) (f) GDPR. The website operator has a legitimate interest in a technically error-free provision of the website and therefore a clear administration as well as an efficient integration of the services of third parties through tags.

5. Duration of storage
The data collected in the context of the use of the Google Tag Manager will be retained for 14 days and then deleted.[A3] Beyond the aforementioned storage period, the data is only used for analysis purposes in aggregated and anonymized form, i.e. without the possibility of identifying individuals

6. Additional measures
We have concluded a so-called data processing agreement with Google for our use of Google Analytics 4, by which Google is obliged to protect the data of our website users and not to pass it on to third parties.

To ensure a higher level of data protection, we have agreed standard data protection clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavor to obtain additional regulations and commitments from the recipient in the USA. [A4]

7. Objection and removal
The collection of data for the provision of the website as well as the storage is essential for the operation of the website. Therefore, the user may not object to the aforementioned processes.

3)   Use of Google Maps

1. Scope of personal data processing

We use the Google Maps online map service by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the European Union, Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (hereinafter referred to as ‘Google’). We use the Google Maps plugin to visually present geographical data and embed them into our website. When using Google Maps on our website, information about the use of our website, your IP address, and addresses entered in the route planning feature will be sent to a Google server in the USA, where it will be stored.

To ensure appropriate guarantees to protect the transfer and processing of personal data outside the EU, the data transfer to and data processing by Google take place on the basis of appropriate guarantees in accordance with Art. 46 et seqq. GDPR, in particular by the conclusion of so-called standard data protection clauses in accordance with Art. 46(2)(c) GDPR.

You will find further information about the processing of data by Google here:

https://policies.google.com/privacy?gl=DE&hl=de

2. Purpose of data processing

The use of the Google Maps plugin serves to improve the user-friendliness and ensure the appealing presentation of our website.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is, with the voluntary consent of the user in this regard, Art. 6(1)(1)(a) GDPR.

4. Duration of storage

Your personal data will be stored for as long as it is necessary in order to achieve the objectives described in this Privacy Policy or as prescribed by law.

5. Right to objection and erasure

You can prevent the collection and processing of your personal data by Google by stopping the storage of third-party cookies on your computer, using the ‘Do Not Track’ feature of a supporting browser, deactivating the execution of script code in your browser, or installing a script blocker such as NoScript (https://noscript.net/ ) or Ghostery (https://www.ghostery.com ) in your browser.

You can use the following link to deactivate the use of your personal data by Google:

https://adssettings.google.de

You will find further information about the objection and erasure options at Google here:

https://policies.google.com/privacy?gl=DE&hl=de

4)   Use of Microsoft Clarity

We use the “Microsoft Clarity” tool on our website, a tool from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft Clarity helps us to understand usage behavior and interactions on our website and thus improve our website and supports us in error analysis.

In addition, your personal data will be processed for the following purposes:

Tracking (e.g. interest/behavioral profiling, use of cookies),
Remarketing and conversion measurement (measuring the effectiveness of marketing measures),
Interest-based and behavioral marketing,
Profiling (creating user profiles),
Reach measurement (e.g. access statistics, recognition of returning users) and
Cross-device tracking (processing of user data across devices for marketing purposes).

Click data (e.g. Internet presentations visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical position of a device or a person), movement data (mouse movements, scrolling). movements) in pseudonymized form and incorrect interactions with buttons (dead clicks). Behavior patterns, heatmaps and session recordings are created from the data. We cannot trace these records back to an individual person. Click data is stored for up to 13 months.

The legal basis for the processing of your personal data for the stated purposes is your consent, in accordance with Art. 6 Para. 1 lit a GDPR and Section 25 Para. 1 TTDSG. You can revoke your consent at any time with future effect using the consent tool.

The data is also transmitted to Microsoft. Microsoft may further process the data for its own purposes, e.g. to improve products and for advertising purposes. We have no knowledge of which data is processed for which specific purposes. We have no influence on this. Further information about the information collected can be accessed via the following website: https://learn.microsoft.com/en-us/clarity/setup-and-installation/clarity-data. Data processing is carried out by Microsoft Corporation, based in the USA. Microsoft Corporation is certified according to the Data Privacy Framework, so that an adequacy decision by the European Commission within the meaning of Art. 45 GDPR exists for data transfers to Microsoft Corporation. The status of the certification can be accessed via the following website: https://www.dataprivacyframework.gov/s/. Further information on data processing at Microsoft can be found in the Microsoft data protection regulations.

XI. Use of analytics data for aggregated evaluations and customer insights

In order to get the best insights from tools used on this website, we transfer data that is collected through various tools into our customer resource management (CRM) system and to our specific service providers, with whom we can aggregate data from analytics and tracking services. These providers act as our data processors and we have concluded data processing agreements accordingly.

In our CRM system, we process information gathered from our analytics and tracking tools about your website behavior (e.g. when you visited, from which location you visited or how many times you visited our website). Depending on the permissions you gave us through the cookie banner for the usage of specific analytics and tracking tools, the according analytics and tracking data will be combined with data from the CRM system.

Analytics data from our website as well as data from our CRM system will be used in aggregated form, meaning that any personal reference will have been removed. We analyze the aggregated data insights to improve our marketing strategy and tailor our services to our clientele.

XiI. USE OF ONLINE CATALOGUE TOOLS

Online catalogue flipaio
You can view some of our catalogues online. For this we use flipaio, a system from the provider apollon GmbH & Co. KG, Maximilanstraße 104, 75172 Pforzheim ("flipaio"). When you open an online catalogue, flipaio processes your IP address and your operating system in order to enable technically flawless retrieval of the catalogue. The IP address is also recorded for security purposes. For anonymised statistical evaluation of the use of the online catalogue, flipaio records access to the online catalogues. When you open the catalogue, use the search field, download the catalogue or click on a link, this access is counted. Your IP address is not stored as part of the statistical analysis, nor are other tracking methods used. The legal basis is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the provision, improvement and functionality of our online catalogues. The data is not passed on or used in any other way.

When using the online catalogue, you can also contact us via a contact form. If we request information via the contact form that is not required for contacting us, we have always labelled this as optional. We use this information to specify your enquiry and to improve the processing of your request. This information is provided expressly on a voluntary basis and with your consent, Art. 6 para. 1 lit. a) GDPR. If this involves information on communication channels (e.g. email address, telephone number), you also consent to us contacting you via this communication channel in order to respond to your enquiry. You can of course revoke this consent at any time for the future. If you have not given us your consent, the legal basis is Art. 6 para. 1 lit. f GDPR, whereby our legitimate interest lies in responding to your request. The information you provide in the contact form will be recorded by flipaio and forwarded to us immediately for processing. Your data will not be stored permanently by flipaio. We delete the data collected in connection with your contact once storage is no longer necessary, or restrict processing if there are statutory retention obligations.

The privacy policy of the provider of flipaio (apollon GmbH & Co. KG) can be found at https://apollon.de/datenschutz/.

XIII. USE OF WEB CONFERENCE PROVIDERS

We use the web conference provider WebinarJam, a service of GENESIS DIGITAL LLC, 4730 S. Fort Apache Rd. Suite 300, Las Vegas, NV, 89147-7947, USA ("WebinarJam"). If you register for a webinar via the registration form and participate in the webinar, your personal data will be processed by WebinarJam. This includes in particular your IP address, your name, your e-mail address and any other content that you enter yourself on WebinarJam (e.g. chat messages). The legal basis for data processing is Art. 6 para. 1 lit. b GDPR (contract fulfilment) and Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest lies in the customer-oriented and professional organisation of the webinars.
WebinarJam processes your data in the USA, among other places. The USA is considered a generally unsafe third country under the GDPR. WebinarJam is not currently certified under the Data Privacy Framework (DPF) programme. This means that WebinarJam has not publicly committed to complying with the DPF obligations and any data transfer to the USA cannot take place without additional measures due to the current adequacy decision of the European Commission of 10 July 2023. WebinarJam uses standard contractual clauses approved by the EU Commission (= Art. 46 para. 2 and 3 GDPR) as the basis for data processing for recipients based in third countries (outside the European Union) or for data transfer there. These clauses oblige WebinarJam to comply with the EU level of data protection when processing personal data outside the EU. The clauses are based on an implementing decision of the EU Commission.
You can find WebinarJam's privacy policy at https://home.webinarjam.com/privacypolicy.

XiV. RIGHTS OF THE DATA SUBJECT

In accordance with the applicable data protection legislation, you have the following rights, particularly in accordance with the statutory requirements:

1)   Right to information, rectification, erasure and restriction

You have the right to request information at any time about your personal data stored by us.

When we process or use your personal data, we will endeavour to ensure, by implementing appropriate measures, that your personal data are accurate and up-to-date for the purposes for which they were collected.

In the event that your personal data are incorrect or incomplete, you can request these data be rectified.

You may also have the right to request the erasure or restriction of processing of your personal data if, for example, such processing no longer fulfils a legitimate business purpose in accordance with this Privacy Policy or applicable law, and statutory retention periods do not require its further storage.

2)   Right to data portability

You may also have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, or transmit these data to another controller.

3)   Right to withdraw your granted consent

If you have agreed to the collection, processing and use of your personal data, you can withdraw your consent at any time with future effect, but the legitimacy of the processing carried out on the basis of the consent until withdrawal will not be affected.

4)   Right to object

You have the right to object, on grounds related to your particular situation, at any time to processing of your personal data which is based on Art. 6(1)(e) or (f) GDPR. We will not process your personal data after an objection, unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or the processing is intended to assert, exercise, or defend legal claims (see Art. 21[1] GDPR, so-called ‘restricted right to object’). In that case, you must demonstrate reasons for the objection which are based on your particular situation.

In addition, you also have the right at any time to object to the processing of your personal data for the purposes of direct marketing, without stating reasons.

5)   Exercise

To exercise your data privacy rights, you can contact us at any time using the contact details provided above. In that case, please state the name of the website concerned, and attach an according identification of yourself.

6)   Right to lodge a complaint

You also have the right to lodge a complaint with the competent supervisory authority, if you believe that the processing of your personal data is not lawful.

PRIVACY POLICY FOR THE LEDVANCE WEBSITE

Preamble

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