Data Privacy Notice for belkagroups.com

Status: November 2022

1. General Information

1.1. Protecting your personal data is important to us. Via this Notice, we like to inform you about collecting and use of personal data in the event you visit our online shop.

1.2. Responsible party in line with art. 4 para. 7 EU – General Data Protection Regulation (GDPR) is:

Aventta Trading Industrial Investment GmbH Berlin, Germany. You can reach out to our data protection officer at  [email protected].

1.3. For the purpose of processing technically necessary personal data, in connection with a contract or upon your consent, cookies shall be stored on your computer if you use our online shop. Cookies are small text files, which are stored on your hard disc and are connected to the browser you use; via such text files, the owner of the cookie shall receive certain information. Cookies cannot execute programs or transfer viruses to your computer.

Irrespective of your consent you can configure your browser settings according to your purposes and e.g., reject the acceptance of certain or all cookies (see also clause 9). We have to point out, that you may not be able to use all functions of our online shop if you only accept technically necessary cookies.

1.4. Cookies are deleted after a certain period of time, which may vary depending on the type and function of the cookie. Collected personal data shall be deleted within the legally given period of time, which depends on the purpose of the use of such personal data.

1.5 Cookie Consent Manager

When you visit our online shop a cookie will be set to document your consent to various services. It is documented if and which service you consent to. You can change your selection at any time by clicking here and saving your new consent selection.

If you de-select a certain service and later, you activate this particular service during your visit to our online shop, this activation shall be documented as consent in the cookie consent manager.

This cookie for consent management is set and administered by us. These data shall be documented in the cookie:

• IP-address
• consent selection
• date and time of selection

If you delete all cookies at the end of your browser session, you will be asked for your consent selection anew when you visit our online shop again. In the event you do not delete the cookies, after six months you will be automatically asked, if your consent selection is still up to date.

Legal basis: legal obligation to proof consent given by the user, art. 6 para. 1 sent. 1 lit. a GDPR.

2. Your Rigths

2.1. You have these rights with regard to your personal data:

• Right of access (art. 15 GDPR),
• Right to rectification (art. 16 GDPR),
• Right to erasure (art. 17 GDPR),
• Right to restriction (art. 18 GDPR)
• Right to data portability (art. 20 GDPR),
• Right to object (art. 21 GDPR).

2.2. If you have given consent to processing your personal data, you can revoke your consent at any time in full or partially. Such revocation does only influence the validity of data processing as of the time you have made your revocation. You can reconfigure your consent here.

2.3. If we base processing of your personal data on our legitimate interest, you can object. Please inform us about your reasons why we should not process your personal data. Upon your reasoning we shall evaluate the facts and either we stop or adjust the data processing, or we will demonstrate compelling legitimate grounds for the processing.

2.4. Please turn your request to our data protection officer (see clause 1.2). In addition, you have the right to file an objection to our processing at any national data protection authority.

3. Collection of Personal Data during your visit to our online shop

3.1. Visit our online shop

Upon your visit to our online shop, we collect such personal data which is technically necessary to visualize our online shop in an appealing format and quality and to secure the stability and security of our online shop.

This data shall be recorded in a server log file:

• Landing page
• Time of the first visit to the website
• The volume of sent data in byte
• The website from which you referred to us
• used browser
• used operation system, language, and release no of your operation system
• your IP address (if so: in anonymized form)

legal basis: legitimate interest to necessary functionality of our online shop, art. 6 para. 1 sent. 1 lit. f GDPR.

3.2. Registration and Order

If you want to order in our online shop, it is necessary for the contract conclusion that you provide us with such personal data, which we need to process and execute your order. Obligatory information is marked. We process your data in order to execute your order. In order to prevent illegitimate access by third parties to your personal data (in particular financial data) the ordering process is encrypted by TLS-technique.

Legal basis: the processing is necessary for the performance of a contract to which the data subject is a party, art. 6 para. 1 sent. 1 lit. b GDPR.

1. This data is documented in a server log file for registration:

• email address
• password

1. This data is documented in a server log file for ordering:

• first and last name, email address
• if applicable: Company data
• invoice address, if deviating: delivery address
• order value

Due to commercial and tax legislation, we are obliged to store your address, payment details, and order data for a period of ten years. After two years we limit our processing in such a way, that your data is only used to comply with the aforementioned obligation.

3.3. Execution of Contract

For executing our contract, we pass on some of your personal data to third parties.

Legal basis: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, art. 6 para. 1 sent. 1 lit. b GDPR.

1. Payment Service Provider

Depending on your selection of payment service provider during the ordering process, we pass on (personal) data to the respective service provider which is necessary for executing the payment. The data protection notice of the respective payment service provider is applicable. We transfer this data to the payment service provider:

• first and last name, email address
• if applicable: company data
• invoice address
• order value

If you choose PayPal, you will be re-directed automatically to the website of PayPal (Europe) S.a.r.l. et Cie, S.C.A. (address: 22-24 Boulevard Royal, LU-2449 Luxembourg). Authorization and execution of payment is processed via the website of PayPal.

1. If necessary, for delivery, we pass on the following data to the shipment service provider:

• first and last name, email address
• delivery address

The shipment service provider may contact you prior to delivery in order to inform you about the delivery date and time or to agree on other details of delivery.

3.4. Communication

1. If you contact us via email or via our contact form the personal data you provide to us (mandatory data are marked with * in the contact form) will be stored in a log file to answer your questions.

Legal basis: the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, art. 6 para. 1 sent. 1 lit. b GDPR.

1. If you contact us via WhatsApp this personal data will be stored to answer your questions:

• account information
• profile name
• phone number

We use your data solely to answer your request. We herewith inform you that the use of WhatsApp is only unthe der control of WhatsApp Inc. By installing WhatsApp on your device, you have agreed to the terms of use of WhatsApp. We store your confirmation (i.e., your “yes” within the WhatsApp-chat), that you have read this Data Privacy Notice.

WhatsApp Inc. (address: 1601 Willow Road, Menlo Park, California 94025, USA) processes your personal data in the USA and shares this data with its affiliated company Facebook Inc. You can find WhatsApp’s data privacy information here: https://www.whatsapp.com/legal/business-policy/

Legal basis: processing of data upon your consent, art. 6 para. 1 sent. 1 lit. a GDPR.

If you do not wish for any data processing by WhatsApp, you may contact us via email or via phone.

c.This data is being erased when it is not necessary anymore, after 10 years at the latest.

4. Newsletter

4.1. We use double-opt-in process for our newsletter registration: after your subscription to our newsletter, we will send an email to the indicated email address with which we ask for your confirmation of newsletter subscription. Obligatory data is only your email address. Optional data is your first and last name and your date of birth. Optional data shall only be used to address you personally and to congratulate you to your birthday or to celebrate your jubilee.

If you do not confirm your subscription within 7 days, your data shall be blocked and deleted automatically after one month.

4.2. As verification of the date, time, and scope of your newsletter subscription (as well as un-subscription) we store the following data by setting a cookie:

• timestamp of subscription / un-subscription (date and time)
• IP-address
• newsletter content selection

4.3. Legal basis (newsletter): consent to the processing of his or her personal data for one or more specific purposes, art. 6 para. 1 sent. 1 lit. a GDPR. Legal basis (cookie): compliance with the legal obligation to prove consent, art. 6 para. 1 sent. 1 lit. c GDPR.

4.4. You may withdraw your consent to receiving the newsletter at any time by un-subscription. You can either unsubscribe (i) by clicking the unsubscribe link provided in each newsletter email, or (ii) by sending your withdrawal notice to [email protected].

4.5. We carry out statistical analysis regarding the click rate of our newsletter links. For this purpose, the links have UTM parameters, which are captured by Google Analytics as soon as the link has been activated. Upon this data, we can measure the rate between information in our newsletter and visit to the respective online shop campaign.

For this analysis, no complete IP address is collected. The analysis shows the data of the recipient with regard to opening the newsletter and clicking a campaign link in an anonymized form.

5. Google

5.1. We use the following Google services in our online shop:

Google Web Analytics is a service for recording the interaction of a user with our online shop, the products, and other contents of our online shop. This enables us (i) to ensure that our online shop is designed and continuously optimized to meet your needs; and (ii) to record and evaluate your usage statistically in order to optimize our offer for you.

For this analysis, cookies are stored on your computer, which collects the following information about your use of this online shop:

• browser type/version
• used operating system
• referrer URL (the previously visited page)
• IP address
• time of the server request
• user behavior (view, purchase activities)

We advertise this online shop via Google Adwords Conversion. When you click on an ad placed by Google, a cookie for conversion tracking is stored on your computer. These cookies have limited validity, do not contain any personal data, and are therefore not used for personal identification. If you visit certain pages of our website and the cookie has not yet expired, Google and we can recognize that you have clicked on the ad and have been redirected to this page. Each Google Adwords customer receives a different cookie. Thus, there is no way that cookies can be tracked across the websites of Google Adwords customers.

The information obtained with the help of the conversion cookie is used to create conversion statistics. This tells us the total number of users who clicked on one of our ads and were redirected to a page with a conversion tracking tag.

We use Google Remarketing to advertise our products by showing you our ads when you continue to use the internet after visiting our online shop. This means that the cookie is used to set a device identifier in order to display ads to you based on your previous usage behavior.

In order to present advertising tailored to your interests Cookies are stored on your computer, which records the following information about your surfing behavior:

• Visit the online shop
• Use of the online shop

Via Google Tag Manager, your IP address is only shortened by Google (so-called IP masking).

5.2. Google Web Analytics, Google Adwords Conversion, Google Remarketing, and Google Tag Manager are services of Google Inc. (address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). The responsible party and contact person in the EU is Google Ireland Limited (address: Gordon House, 4 Barrow Street, Dublin D04 E5W5, Ireland).

The information generated by the cookies is transferred to a Google server in the USA and stored there. Your anonymized, personal data may be used by Google for any of its own purposes, such as profiling, and may be linked to other data.

If you have a Google Account and have agreed to have your web and app browsing history linked to your Google Account by Google, information from your Google Account will be used to personalize ads. Your Google ID will be temporarily associated with your Google Analytics data in order to optimize your targeting. To disable this feature, please refer to the instructions provided by Google itself and in section 9.

More information on data protection and cookies at Google can be found in Google’s privacy policy: https://policies.google.com/privacy

5.3. We are a contractual partner of Google and only receive anonymized, statistical data about our online shop and our advertising measures via its services. We do not receive any further data, in particular, we cannot identify users from this information. We have no influence on the data collected by Google, nor are we aware of the full extent of the data collection and the storage period. We have also concluded a contract with Google Inc. (USA) for order processing in accordance with Art. 28 GDPR.

5.4. The legal basis for (i) the processing of your data for marketing purposes is your consent pursuant to Art. 6 (1) sent. 1 lit. a GDPR; (ii) the processing of anonymous data for statistical purposes is our legitimate interest in the design of our online shop and the efficiency of advertising pursuant to Art. 6 para. 1 sent. 1 lit. a GDPR.

6. Social Media Links

So-called social media links from Facebook, Instagram, Linkedin, and Pinterest are used on our website.

If you click on one of the social media links, you will be directed to our social media account with the social network in question. The respective network collects personal data about you; for more information, please see our privacy policy for social media and the privacy statements of the respective social media providers.

If you do not want the social networks to directly assign the data collected via our website to your profile on the respective service, you must log out of the respective service before visiting our website.

7. YouTube-Videos

7.1. We have embedded YouTube videos in our online shop, which are stored at http://www.YouTube.com and which are directly accessible from our online shop. Embedding is executed as “extended data protection mode”, i.e., no personal data shall be collected by YouTube if you do not access the video.

7.2. YouTube is a service of Google Inc. (address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Responsible Person und contact person in the EU is Google Ireland Limited (address: Gordon House, Barrow Street, Dublin 4, Ireland).

7.3. Personal data shall only be collected by YouTube, when you access a video. We have no influence on the scope of data collected. The collection of data is independent from the fact that you may have or have not a user account at YouTube.

If you are logged in at your Google account, your data shall be matched to your Google account. If you do not want this kind of matching, you have to log-out of your Google account prior to accessing a video.

YouTube stores your data as user profile and uses this data for purposes of marketing, market research and/or optimizing its website. This is done (also for users who are not logged-in) to provide user related advertising and to inform other users of social networks about your activities in our online shop.

You may find more information on purpose and scope of data collection and processing by YouTube in its data privacy notice, where you can also find information about your data subject rights and setting options to protect your privacy: https://policies.google.com/privacy?hl=en-US

We track personal data for analytical purposes (e.g., number of clicks to a video, time of access), which we transfer to Google Analytics to create statistics.

7.4. Legal basis: your consent, art. 6 para. 1 sent. 1 lit. a GDPR.

8. Comments and Contributions

8.1. You have the option to publish a comment or contribution in our online shop blog. When you send your comment / contribution your IP address shall be documented in a server log file. We need this data to analyze and eliminate interruptions as well as to store the creator of the comment / contribution in the event of non-lawful content. The IP address shall be deleted automatically after 7 days when there is no prevailing interest for criminal prosecution.

8.2. Legal basis: legitimate interest to maintain and enhance technical functionality and to enable criminal prosecution, art. 6 para. 1 sent. 1 lit. f GDPR.

8.3. We reserve the right to delete comments or contributions that are not related to our products and services.

9. Closing Provisions

9.1. Beyond the data processing as set forth in this Data Privacy Notice there may be additional data processing by third parties, if you have given your consent to certain processing to that third party, in particular, that it may monitor your web and app browser history and connect it to the account, which you have with that third party, and to use your account information to show personalized commercials to you no matter which website you access.

Third-party can be (non-exhaustive list): service provider for analysis and marketing (e.g., Google), YouTube, Social Media Networks (e.g., Facebook, Pinterest, Instagram), payment service provider (e.g., PayPal).

9.2. If you do not want a third party collecting and using your personal data for statistics, marketing, and creation of user profiles, you can prevent cookies by changing certain settings of your browser or your user account.

• browser settings (e.g., suppressing third-party cookies, i.e., you do not receive commercials of third parties);
• deactivation of cookies for conversion tracking, i.e., cookies of certain domains are blocked (note: this setting will be deleted when you delete all your cookies at the end of the browser session);
• deactivation of personalized commercials http://www.aboutads.info/choices (note: this setting will be deleted when you delete all your cookies at the end of the browser session);
• permanent deactivation in your browser settings at Firefox, Internet Explorer or Google Chrome: http://www.google.com/settings/ads/plugin
• deactivation of your device code in your device settings.

You can also object to the creation of user profiles, please turn to the respective third party to exercise your rights.