Privacy Policy pursuant to the GDPR

We are very pleased that you have shown interest in our company. Data protection holds a particularly high priority for the management of TOWERPRO-Logistics GmbH. The use of the websites of TOWERPRO-Logistics GmbH is generally possible without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website, the processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we will generally obtain the consent of the data subject.

The processing of personal data – such as the name, address, email address or telephone number of a data subject – is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection provisions applicable to TOWERPRO-Logistics GmbH. By means of this Privacy Policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this Privacy Policy explains the rights to which data subjects are entitled.

As the controller responsible for processing, TOWERPRO-Logistics GmbH has implemented numerous technical and organisational measures to ensure the most comprehensive protection possible of the personal data processed through this website. Nevertheless, internet-based data transmission may generally involve security vulnerabilities, and therefore absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, for example by telephone.

1. Definitions

The Privacy Policy of TOWERPRO-Logistics GmbH is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understandable for both the public as well as our customers and business partners. To ensure this clarity, we would like to explain the terms used in advance.

In this Privacy Policy, we use, among others, the following definitions:

a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for processing.

c) Processing
Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting its future processing.

e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for processing
Controller or controller responsible for processing means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

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

i) Recipient
Recipient means a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes, by statement or by a clear affirmative action, by which the data subject signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the Data Controller

The controller, within the meaning of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union, and other provisions of a data protection nature, is:

TOWERPRO-Logistics GmbH

Am Weser-Terminal 10
28217 Bremen
Germany

Tel.: +49 421 566 333 66
Email: info@towerpro-logistics.com

Website: www.towerpro-logistics.com

3. Cookies

The websites of TOWERPRO-Logistics GmbH use cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.

Many websites and servers use cookies. Numerous cookies contain what is known as a cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character sequence that enables websites and servers to associate the specific Internet browser in which the cookie was stored with the corresponding user. This allows visited websites and servers to distinguish the individual browser of the data subject from other Internet browsers containing different cookies. A particular Internet browser can thus be recognised and identified by its unique cookie ID.

Through the use of cookies, TOWERPRO-Logistics GmbH can provide users of this website with more user-friendly services, which would not be possible without the placement of cookies.

Cookies enable us to optimise the information and offers on our website in the interest of the user. As already mentioned, cookies allow us to recognise users of our website. The purpose of this recognition is to make the use of our website easier for visitors. For example, users of a website that uses cookies do not have to re-enter their login information each time they visit, as this can be stored and retrieved by the website and the cookie placed on the user’s system. Another example is the cookie of an online shop’s shopping basket, which allows the shop to remember the items placed in the virtual cart.

The data subject may prevent the setting of cookies by our website at any time by adjusting the settings of the Internet browser used and may therefore permanently object to the placement of cookies. In addition, cookies that have already been set may be deleted at any time via an Internet browser or other software solutions. This is possible in all common Internet browsers. Should the data subject deactivate the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

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4. Collection of General Data and Information

Each time the website of TOWERPRO-Logistics GmbH is accessed by a data subject or by an automated system, the website collects a series of general data and information. These general data and information are stored in the server log files. The following may be recorded:
(1) the browser types and versions used,
(2) the operating system used by the accessing system,
(3) the website from which an accessing system reaches our website (so-called referrer),
(4) the sub-pages accessed on our website via an accessing system,
(5) the date and time of access to the website,
(6) an Internet Protocol address (IP address),
(7) the Internet service provider of the accessing system, and
(8) other similar data and information that serve to protect our information technology systems in the event of attacks.

When using these general data and information, TOWERPRO-Logistics GmbH does not draw any conclusions about the data subject. Rather, this information is required to
(1) correctly deliver the content of our website,
(2) optimise the content of our website as well as its advertising,
(3) ensure the long-term functionality of our information technology systems and website technology, and
(4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.

Therefore, TOWERPRO-Logistics GmbH evaluates these anonymously collected data and information statistically, and also with the aim of increasing data protection and data security within our company, in order to ensure an optimum level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Contact options via the Website

Due to statutory regulations, the website of TOWERPRO-Logistics GmbH contains information that enables a quick electronic contact with our company, as well as direct communication with us. This also includes a general address for electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject will be stored automatically.

Such personal data, transmitted on a voluntary basis by a data subject to the controller, is stored for the purpose of processing the enquiry or establishing contact with the data subject. No transfer of these personal data to third parties takes place.

6. Routine Erasure and Restriction of Personal Data

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is permitted by the European legislator or another competent legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely restricted or deleted in accordance with the statutory provisions.

7. Rights of the Data Subject

  • a) Right to Confirmation

    Every data subject has the right, granted by the European legislator, to obtain from the controller confirmation as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller at any time.

    b) Right of Access

    Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller, free of charge and at any time, information about the personal data stored concerning them and to receive a copy of such information. Furthermore, the European legislator has granted the data subject access to the following information:

    • the purposes of processing
    • the categories of personal data processed
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly recipients in third countries or international organisations
    • where possible, the planned duration for which the personal data will be stored or, if not possible, the criteria used to determine that duration
    • the existence of the right to rectification or erasure of the personal data concerning the data subject or restriction of processing by the controller or a right to object to such processing
    • the existence of a right to lodge a complaint with a supervisory authority
    • where the personal data is not collected from the data subject: any available information regarding the source of the data
    • the existence of automated decision-making including profiling under Article 22(1) and (4) GDPR, and — at least in those cases — meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for the data subject

    Furthermore, the data subject has the right to request information as to whether personal data have been transferred to a third country or an international organisation. Where this is the case, the data subject also has the right to be informed about the appropriate safeguards relating to such transfer.

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

    c) Right to Rectification

    Every data subject affected by the processing of personal data has the right, granted by the European legislator, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of processing, to request the completion of incomplete personal data — including by means of a supplementary statement.

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

    d) Right to Erasure ("Right to be Forgotten")

    Every data subject affected by the processing of personal data has the right, granted by the European legislator, to require the controller to erase personal data concerning them without undue delay, where one of the following grounds applies and insofar as processing is not required:

    • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
    • the data subject withdraws consent on which the processing was based pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal ground for processing
    • the data subject objects to processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for processing, or the data subject objects pursuant to Article 21(2) GDPR
    • the personal data have been unlawfully processed
    • erasure of the personal data is required for compliance with a legal obligation under Union or Member State law to which the controller is subject
    • the personal data have been collected in relation to services offered by the information society pursuant to Article 8(1) GDPR

    If one of the above grounds applies, and a data subject wishes to request erasure of personal data stored by TOWERPRO-Logistics GmbH, they may contact an employee of the controller at any time. The employee shall arrange for the erasure request to be complied with without delay.

    Where personal data have been made public by TOWERPRO-Logistics GmbH and our company, as controller, is obliged under Article 17(1) GDPR to erase the personal data, TOWERPRO-Logistics GmbH shall, taking into account available technology and implementation costs, take reasonable steps — including technical measures — to inform other controllers processing the published data that the data subject has requested erasure of all links to such personal data, or of copies or replications thereof, insofar as processing is not required. An employee of TOWERPRO-Logistics GmbH will take the necessary steps in individual cases.

    e) Right to Restriction of Processing

    Every data subject affected by processing of personal data has the right, granted by the European legislator, to request restriction of processing where one of the following conditions applies:

    • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data
    • processing is unlawful and the data subject opposes deletion of the personal data and requests restriction of use instead
    • the controller no longer requires the personal data for processing purposes, but the data subject requires them for the establishment, exercise or defence of legal claims
    • the data subject has objected to processing pursuant to Article 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject

    If one of the above conditions applies and a data subject wishes to request restriction of personal data stored by TOWERPRO-Logistics GmbH, they may contact an employee of the controller at any time. The employee of TOWERPRO-Logistics GmbH will arrange for restriction of processing.

    f) Right to Data Portability

    Every data subject affected by processing of personal data has the right, granted by the European legislator, to receive personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the data were provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR, and where processing is carried out by automated means, unless processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

    In exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject also has the right to have personal data transmitted directly from one controller to another, where technically feasible and provided this does not adversely affect the rights and freedoms of others.

    To exercise the right to data portability, the data subject may contact an employee of TOWERPRO-Logistics GmbH at any time.

    g) Right to Object

    Every data subject affected by the processing of personal data has the right, granted by the European legislator, to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

    TOWERPRO-Logistics GmbH shall no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for processing which override the interests, rights and freedoms of the data subject, or processing is for the establishment, exercise or defence of legal claims.

    Where TOWERPRO-Logistics GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data for such marketing. This also applies to profiling where it is related to direct marketing. If the data subject objects to TOWERPRO-Logistics GmbH regarding processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

    In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by TOWERPRO-Logistics GmbH for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

    To exercise the right to object, the data subject may contact any employee of TOWERPRO-Logistics GmbH directly. The data subject is further entitled, in the context of the use of information society services and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.

  • h) Automated Individual Decision-Making, Including Profiling

    Every data subject affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or for the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and that law also lays down suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the explicit consent of the data subject.

    If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) takes place with the explicit consent of the data subject, TOWERPRO-Logistics GmbH shall implement suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, which shall include at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.

    If a data subject wishes to exercise their rights concerning automated decision-making, they may contact an employee of the controller at any time.

  • i) Right to Withdraw Consent under Data Protection Law

    Every data subject affected by the processing of personal data has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time.

    If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.

8. Privacy Provisions on the Use of Google Analytics (with Anonymisation Function)

The controller has integrated the component Google Analytics (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data regarding the behaviour of visitors to websites. A web analytics service collects, among other things, data regarding the website from which a data subject accessed a website (so-called referrer), which subpages of the website were accessed, how often they were accessed and for what duration a subpage was viewed. Web analytics is predominantly used for the optimisation of a website and for cost-benefit analysis of online advertising.

The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The controller uses the addition "_gat._anonymizeIp" for web analytics via Google Analytics. By means of this addition, the IP address of the internet connection of the data subject is truncated and anonymised by Google when access to our website originates from a Member State of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is the analysis of visitor flows on our website. Google uses the collected data and information, among other things, to evaluate the use of our website, to compile online reports for us that show activities on our pages, and to provide other services related to the use of our website.

Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. With each visit to one of the individual pages of this website, which is operated by the controller and in which a Google Analytics component is integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. Within the scope of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which allows Google, among other things, to determine the origin of visitors and clicks, and subsequently to enable commission settlements.

Through the cookie, personal information such as access time, location from which access was made and the frequency of visits by the data subject to our website are stored. With each visit to our website, these personal data, including the IP address used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may transfer these personal data, obtained via the technical process, to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of an appropriate setting of the internet browser used, thereby permanently objecting to the placement of cookies. Such a setting of the internet browser used would likewise prevent Google from placing a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to and prevent the collection of data generated by Google Analytics relating to their use of this website, as well as the processing of such data by Google. To do this, the data subject must download and install a browser add-on via the link https://tools.google.com/dlpage/gaoptout
. This browser add-on informs Google Analytics via JavaScript that no data or information regarding visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is regarded by Google as an objection. If the information technology system of the data subject is subsequently deleted, reformatted or reinstalled, the data subject must reinstall the browser add-on to disable Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or by another person within their sphere of influence, reinstallation or reactivation of the browser add-on is possible.

Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/
and at http://www.google.com/analytics/terms/de.html

9. Legal Basis for Processing

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party — for example, when processing is required for the delivery of goods or the provision of another service or consideration — the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations necessary for carrying out pre-contractual measures, such as in cases of enquiries concerning our products or services.

If our company is subject to a legal obligation requiring the processing of personal data — such as compliance with tax obligations — the processing is based on Article 6(1)(c) GDPR.

In rare cases, processing of personal data may become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance data or other vital information had to be passed to a doctor, hospital or other third parties. In such a case, processing would be based on Article 6(1)(d) GDPR.

Ultimately, processing operations may be based on Article 6(1)(f) GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal grounds, where processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, provided that such interests are not overridden by the interests, fundamental rights and freedoms of the data subject. Such processing operations are particularly permitted because they were explicitly recognised by the European legislator. The legislator considered a legitimate interest to exist, for example, where the data subject is a customer of the controller (Recital 47, sentence 2 GDPR).

10. Legitimate Interests in Processing Pursued by the Controller or by a Third Party

If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit and well-being of all our employees and shareholders.

11. Duration for Which Personal Data is Stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of this period, the corresponding data are routinely deleted, provided that they are no longer required for the performance of a contract or the initiation of a contract.

12. Statutory or Contractual Requirements for Providing Personal Data; Necessity for Contract Conclusion; Obligation of the Data Subject to Provide Personal Data; Possible Consequences of Non-Provision

We hereby inform you that the provision of personal data may be partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information regarding the contracting party). In certain cases, it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with them. Failure to provide the personal data would result in the contract with the data subject not being concluded.

Before providing personal data, the data subject must contact one of our employees. Our employee will inform the data subject, on a case-by-case basis, whether the provision of personal data is legally or contractually required, or necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences resulting from failure to provide such personal data.

13. Existence of Automated Decision-Making

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

This Privacy Policy was created using the Privacy Policy Generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which operates as External Data Protection Officer in Landshut, in cooperation with lawyer Christian Solmecke, specialist in IT and data protection law.

Data Protection in Connection with Wipe Analytics

The controller has integrated components of the company Wipe Analytics on this website. Wipe Analytics is a web analytics service. Web analytics involves the collection, gathering and evaluation of data regarding the behaviour of visitors to websites. A web analytics service collects, among other things, data regarding the website from which a data subject accessed a website (so-called referrer), which subpages of the website were accessed, how often they were accessed, and for what duration a subpage was viewed. Web analytics is predominantly used for the optimisation of a website and for cost-benefit analysis of online advertising.

The operating company of Wipe Analytics is TENSQUARE GmbH, Wilhelminenstr. 29, 45881 Gelsenkirchen, Germany.

Wipe Analytics places a cookie on the information technology system of the data subject. What cookies are has been explained above. By accessing one of the individual pages of this website, which is operated by the controller and on which a Wipe Analytics component is integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Wipe Analytics component to transmit data to Wipe Analytics for marketing and optimisation purposes. Within the scope of this technical procedure, Wipe Analytics gains knowledge of data which is subsequently used to create pseudonymised usage profiles. The usage profiles created in this way serve to analyse the behaviour of the data subject who has accessed the controller’s website and are evaluated with the aim of improving and optimising the website. The data collected by the Wipe Analytics component will not be used to identify the data subject without obtaining separate and explicit consent from the data subject. Such data is not merged with personal data or with other data containing the same pseudonym.

The data subject may, at any time, prevent the setting of cookies by our website, as described above, by means of an appropriate setting of the internet browser used, thereby permanently objecting to the placement of cookies. Such a setting of the internet browser would also prevent Wipe Analytics from placing a cookie on the information technology system of the data subject. In addition, cookies already placed by Wipe Analytics can be deleted at any time via the internet browser or other software solutions.

Furthermore, the data subject has the possibility to object to and prevent the collection of data generated by the Wipe Analytics cookie relating to their use of this website, as well as the processing of such data by Wipe Analytics. To do so, the data subject must click the cookie-setting button via the link https://www.wipe-analytics.de/opt-out, which sets an opt-out cookie. The opt-out cookie set via this method will be stored on the information technology system used by the data subject. If the cookies on the system of the data subject are deleted after such an objection, the data subject must revisit the link and set a new opt-out cookie. The setting of the opt-out cookie may, however, result in certain functionalities of the controller's website no longer being fully usable by the data subject.

The applicable data protection provisions of Wipe Analytics may be accessed at https://www.wipe-analytics.de/privacy.