Data Protection Provisions Applicable To Newsletter Marketing
Information on data protection pursuant to Articles 13, 14 and 21 of the General Data Protection Regulation (GDPR)
We take data protection extremely seriously, particularly where the personal information of our newsletter subscribers and press release recipients is concerned (“data”). We are writing to inform you about how we process your data and which claims and rights you are entitled to.
1. Data controller
The controller is:
Lena Hoschek GmbH
2. Categories of data relevant to newsletter marketing and press releases:
– e-mail address as contact details for the delivery of the newsletter.
– e-mail address as contact details for the delivery of press releases.
3. Purpose of the processing
a) The purpose of the processing is to distribute the newsletter you subscribed to; the collected data is used solely for the purpose of sending an advertising newsletter containing information about Lena Hoschek GmbH, news, special offers, discounts, events etc. based on your personal interests and activity to the e-mail address you provided.
b) In addition, we may also use your personal data for the following purposes:
- measures designed to further develop services and products;
- reporting to verify the success of the measures employed over time;
- reviewing and optimising procedures for market analysis, benchmarking;
- providing personal data in the course of a due diligence procedure;
- enhancing our data (e.g. using/researching publicly available data);
- use for systems development/development of test systems;
- asserting legal claims and defence in legal disputes;
- further developing existing systems and processes;
- internal and external audits, security checks;
c) Press releases: the collected data is used solely in order to send press releases concerning our products, events and/or company news to the e-mail address provided by you.
4. Legal basis
The newsletter is distributed in accordance with the foregoing clauses 3 a) and c) based on your consent pursuant to Art. 6(1) lit. f GDPR.
The additional processing in clause 3 b) is carried out based on overriding interests of Lena Hoschek GmbH. We evaluate the efficiency and attractiveness of our newsletter from a technical perspective, in order in future only to send you those product recommendations that are of interest to you. Since no sensitive personal information is used to this end and, as a rule, evaluations are carried out solely on an aggregated, not on a personal level, the data processing constitutes a legitimate interest.
5. Recipients or categories of recipients of your data
– Lena Hoschek GmbH has access to your data only insofar as this is necessary for the attainment of purposes in accordance with the internal allocation of tasks. Within the company, only those departments and employees as require such access will be granted access to your data.
– Service providers: we engage service providers who have access to your data as order processors and process this information for specific purposes as stipulated by us. These are processes can providers of marketing service, website hosting services, IT support services or website analysis services.
– Other third parties: under certain circumstances, we share your data with authorities, external advisers, business partners or courts, where necessary.
– International data transfer: while all recipients are based within the EU/EEA, you can expect that in future, recipients may be located in a country outside the EU/EEA which does not provide a level of data comparable to that in Europe. In particular, service providers may in future be located in the USA. In this case, Lena Hoschek GmbH will either select service providers certified under the US-EU Privacy Shield Program (Art. 45(1) GDPR) or which have agreed with Lena Hoschek GmbH the EU standard data protection clauses adopted by the EU Commission (Art. 46 (2) (c) or (d) GDPR).
We will not otherwise share your data with third parties unless we notify you separately. If we commission service providers in the course of order processing, your data will there be subject to the safety standards stipulated by us, in order to ensure appropriate protection of your data.
6. Duration of data storage
We will process and store your data until such time as you withdraw consent.
7. Processing of your data in a third country or by an international organisation
Your personal data is not processed in a third country or by any international organisation. Should such processing be intended in future, you will be notified accordingly.
8. Your rights
Under certain circumstances, you can assert the following data protection rights:
- You have the right to obtain information on which data we store and process, and to have that information corrected or deleted in accordance with Art. 15, 16, 17 GDPR; Data can be deleted provided no other statutory provisions (e.g. statutory storage requirements) or overriding legitimate interests on our part (e.g. in defence of our rights and claims) do not preclude such deletion;
- Right to restriction of data processing pursuant to Art. 18 GDPR,
- Right to object pursuant to Art. 21 GDPR,
- Right to data portability pursuant to Art. 20 GDPR.
Furthermore, you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). However, we recommend that you bring your complaint to us first to allow us to resolve your issue more quickly.
Wherever possible, your requests to exercise your rights should be submitted, in writing, to the address stated above.
9. Scope of your obligation to provide your data
You are not under any legal obligation to provide your data to Lena Hoschek GmbH. However, if you do not provide your e-mail address and consent, we will be unable to send you our newsletter. The provision of your data is entirely voluntary. You will not suffer any legal disadvantage as a result of not submitting your data.
10. Automated individual decision-making (including profiling)
We do not use any automated decision-making procedures pursuant to Art. 22 GDPR. As required by law, we will notify you separately if we intend in future to use such procedures in individual cases.
Information on your right to object pursuant to Art. 21 GDPR
You have the right at any time to object to the processing of your personal information on the basis of Art. 6 (1) f GDPR (data processing based legitimate interests) or Art. 6 (1) e GDPR (data processing in the public interest). However, in order to be able to lodge an objection, there must be grounds for your objection relating to your particular situation. This also applies for profiling based on this provision as defined in Art. 4 No. 4 GDPR.
If you object, we will no longer process your personal information unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the establishment, exercise or defence of legal claims.
We will no longer process your data for the purposes of newsletter advertising and press releases if you object to data processing for these purposes.
You can submit an objection at any time to the address stated above firstname.lastname@example.org.