Privacy policy

Privacy policy

I. Preamble

For us, trustworthy collaboration starts with the little things. Of course, for us, that also includes protecting your data from the very beginning. We would like to inform you about the type, scope and purpose of how your personal data is processed in this privacy policy with respect to data that arises from visits to our website and, among other things, is used to make our website as pleasant as possible for our customers.
In doing so, we follow the requirements of the European Union’s General Data Protection Regulation (hereinafter: GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz, hereinafter: BDSG), and the German Telemedia Act (Telemediengesetz, hereinafter: TMG).

II. General

a. Controller

The controller within the meaning of the GDPR is:

ComLine GmbH Value Added Distribution
Managing Directors: Harald Lapp, Anja Sobottka
Lise-Meitner-Straße 16
24941 Flensburg
Tel.: +49 461 77 303 300
Fax: +49 461 77 303 390
E-mail: info@comline-shop.de

b. Data Protection Officer

If you have any questions about data protection, we will advise you through Datros GmbH. You can contact our external Data Protection Officer at Lise-Meitner-Straße 15, 24941 Flensburg or via the e-mail address info@datros.de.

c. Terminology

The terminology used in this privacy policy corresponds with that of the GDPR or the BDSG. The main terminology includes the following:

  • ‘personal data’: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is a person 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 (Article 4 No. 1 of the GDPR);
  • ‘processing’: any operation or set of operations carried out on personal data or on sets of 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 (Article 4 No. 2 of the GDPR);
  • ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data (Article 4 No. 10 of the GDPR); and
  • ‘consent’: with respect to the data subject, any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by means of a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her (Article 4 No. 11 of the GDPR).
d. Types of data

We process the following types of data in particular on our website:

  • Inventory data (data required for justification, content design, changes or termination to a contractual relationship; e.g. names and address)
  • liContact details (data via which you or your company is contactable; e.g. e-mail address or telephone number)
  • Content data (content from messages sent; e.g. text entered by you, images, videos)
  • Use data (technical information, e.g. about access times and websites visited)
  • Communication data (data that provides us with information about the communication channel, e.g. the browser you use, device information, and also IP addresses)

The following types of data also arise within the context of business-related processing:

  • Contract data (contract text and object, term, etc.)
  • Payment details (e.g. bank details and accounting history)
e. Data subject groups & general purpose of processing

Personal data is collected from users of this website. Data collected from you is processed to make this website available and to respond to requests. We also collect some data for the purposes of reach measurement and to design our website in a way that is even more attractive for our customers. You can find out what data is specifically collected, on what legal basis this happens, and how we process it, in the specific explanations given in this privacy policy.

f. Right of withdrawal

Of course, you have the right to withdraw your consent at any time with future effect, without stating reasons for this, pursuant to Article 7 Paragraph 3 of the GDPR. It is not necessary for withdrawal to be made in a specific form and it will be effective upon receipt, and observed by us, regardless of the medium used. However, we kindly ask that you send the withdrawal to the following e-mail address to make it easier for both you and for us: info@comline-shop.de.

g. Cookies

We also use ‘cookies’ on our website. We refer you to the corresponding notice when you first access our website. These are small text files, stored locally on your end device, which can also essentially record data about your visit to the respective website. The general purpose of ‘cookies’ is to recognise a user on a website when they visit again and, by way of example, to save such a user from having to enter information or change the settings again. However, ‘session cookies’ can also be placed on your machine exclusively for the duration of a website visit. As an example, these may be used to ensure that a web shop’s shopping cart function works properly. Such a ‘session cookie’ is automatically removed when your browser session ends. You can find out what cookies are used, what data is recorded and for what purposes the data is used in the explanations below.
If you generally want to reject the use of cookies, common browsers also offer this as an option. Please note that this may affect the functionality of this website and other websites.
You also have the option of objecting to cookies being stored by some larger providers for the purposes of online marketing and tracking as a preventative measure. The European website http://www.youronlinechoices.com or the American website http://www.aboutads.info/choices/ provides this as an option.

h. General objection (to advertising)

Please note that you do, of course, always have the right to object to the processing of your personal data in accordance with Article 21 of the GDPR, which is unconnected with the visit to our website.
You also have the right to object to your personal data being processed for the purposes of direct marketing pursuant to Article 21 Paragraph 2 of the GDPR. It is also not necessary for an objection to be made in a specific form and it will be effective upon receipt, and observed by us, regardless of the medium. However, we kindly ask that you send the withdrawal to the following e-mail address to make it easier for both you and for us: info@comline-shop.de.

i. General erasure and restriction provisions

We erase or restrict your personal data pursuant to Article 17 and 18 of the GDPR. Data is in particularly erased by us as soon as the purpose for which the data was originally collected no longer applies, provided that there are no statutory retention periods. As an example, we are legally obligated to store trading books, inventories, opening balances, annual financial statements and individual accounts pursuant to Section 257 Paragraph 1 of the German Commercial Code (Handelsgesetzbuch, HGB), and management reports, group financial statements, group management reports, as well as other organisational documentation, commercial letters and accounting vouchers pursuant to Section 325 Paragraph 2a, for a period of 6 years. If there are statutory retention obligations, we restrict the data so that we can only process it for the legally prescribed purpose.

j. Data security

To guarantee that your data is secure, we use the widespread Secure Socket Layer process (SSL process) to transmit website content, as well as data entered by you. Data sent between your hosting provider and our hosting provider is encoded using 256 bit encryption. If your browser does not support 256 bit encryption, we use 128 bit v3 technology instead.

III. Your rights

The meaning and purpose of our efforts to protect your data is for you to always have full control over the information you provide. As such, in addition to the above-mentioned rights, you also have rights with respect to the personal data recorded by us, which we are pleased to outline below in detail.

a. Right to obtain confirmation of processing

Pursuant to Article 15 of the GDPR, you have the right to obtain confirmation from us about the processing of your personal data.

b. Right of access

If we process your personal data, you have the right to access the data we have pursuant to Article 15 of the GDPR. We will provide information pursuant to the provisions of Article 15 of the GDPR.

c. Right to completion & rectification

Pursuant to Article 16 of the GDPR, you have the right to request that we rectify incorrect personal data relating to you without undue delay. You also have the right to complete incomplete data stored by us.

d. Right to erasure

Pursuant to Article 17 of the GDPR, you have the right to request that your personal data is erased without undue delay if one of the following points applies and if no exceptions apply pursuant to Article 17 Paragraphs 2 and 3 of the GDPR:

  • The personal data is no longer required for the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent on which the processing is based pursuant to Article 6 Paragraph 1 Letter a, or Article 9 Paragraph 2 Letter a, and where there is no other legal basis for processing.
  • The data subject objects to processing pursuant to Article 21 Paragraph 1 and there are no overriding legitimate grounds for processing, or the data subject objects to processing pursuant to Article 21 Paragraph 2.
  • The personal data has been unlawfully processed.
  • The personal data has to be erased to comply with a legal obligation under Union law or Member State law, which the controller is subject to.
  • The personal data has been collected in relation to the offer of information society services referred to in Article 8 Paragraph 1.
e. Right to restriction of processing

Pursuant to Article 18 of the GDPR, you have the right to request that the processing of your personal data is restricted without undue delay if one of the following conditions is met:

  • the accuracy of the personal data is contested by the data subject, for a period of time enabling the controller to verify the accuracy of the personal data;
  • processing is unlawful and the data subject opposes the erasure of the personal data and requests that its use is restricted instead;
  • the controller no longer needs the personal data for the purposes of processing, but it is required by the data subject to assert, exercise or defend legal claims; or
  • the data subject has objected to processing pursuant to Article 21 Paragraph 1, pending the verification of whether the legitimate grounds of the controller override those of the data subject.

If processing has been restricted under Paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent, or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. We will inform you before the restriction is lifted.

f. Right to data portability

Pursuant to Article 20 of the GDPR, you have the right to receive personal data concerning you in a structured, commonly used and machine-readable format and to request that it is transmitted to a third party without hindrance. There may be restrictions to this right pursuant to Article 20 of the GDPR.

g. Right to lodge a complaint

Pursuant to Article 77 of the GDPR, you also have the right to lodge a complaint to the relevant supervisory authorities. You can contact the relevant authorities at the following address: ULD – Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (Independent Centre for Privacy Protection); Holstenstraße 98, 24103 Kiel; Tel.: 0431-9881200: Fax.: 0431-9881223; E-mail: mail@datenschutzzentrum.de.

IV. Processing for technical reasons

a. Hosting the website

To be able to make this website available to you, we work with a hosting provider. This provider supplies the infrastructure for the smooth operation of this website and carries out regular maintenance to ensure that your data is not lost. To ensure that your data is protected and that data protection standards are complied with, we have also imposed an obligation on our hosting provider to observe our high data protection standards, by subjecting it to a data processing agreement pursuant to Article 28 of the GDPR. This provider processes inventory, contact, content, contract, use and communication data for users of this website on the basis of our legitimate interests in maintenance and operation, and website security, pursuant to Article 6 Paragraph 1 Letter f of the GDPR.
Usage data is created every time our website is visited. This particularly includes the name of the website accessed, downloaded files, date and time of access, the respective volume of data transferred, messages about successful website access, the browser type & operating system used, the site previously visited, the IP address and the provider used. This is processed by us or by our hosting provider on behalf of us, and is based on our legitimate interests in protecting against misuse and for security reasons, pursuant to Article 6 Paragraph 1 Letter f of the GDPR. With the exception of personal data that must be further stored for evidence purposes, personal data is stored for a period of 7 days and is then automatically deleted.

b. Web shop cookies

To allow you to register in our web shop and for the shopping cart function to work, we place cookies on your end device that assign you a unique identifier. We use the personal data stored by this cookie on the basis of our legitimate interests in a functioning web shop system, pursuant to Article 6 Paragraph 1 Letter f of the GDPR. The cookie is a ‘session cookie’, which automatically becomes invalid and in general is automatically deleted from your browser when you leave our website and close your browser.

c. Web shop processing

You can register in our web shop system as a guest or with a user profile account. The data requested by you as part of the entry form is processed for the purpose of processing the ordering of items from our web shop, on the basis of Article 6 Paragraph 1 Letter b of the GDPR. We also send your address details to our mailing service provider for the purposes of mailing.

d. Contacting us

If you want to contact us, you can do so via our contact form. We process the data collected there for the purposes of processing your request pursuant to Article 6 Paragraph 1 Letter b of the GDPR. If we stay in touch for business purposes, your personal data may also be processed within the scope of customer relationship management, in a corresponding system. If the data is no longer required to respond to your request, we will delete it, provided that no statutory archiving obligations apply.

e. Newsletters

If you also want to stay informed of our current products and information in future, we give you the option of registering for our e-mail newsletter.
To ensure that third parties do not register using your e-mail address, the registration process is set up as a ‘double opt-in’ process. After you have provided your e-mail address in the corresponding field, and have confirmed registration via the corresponding button, you will receive an e-mail from us containing a link to confirm your registration. By clicking on the link, you are providing your consent to the further use of your personal data required for mailing. For purposes of traceability, we log this registration and the time the registration and confirmation was processed, the IP address and e-mail address given, on the basis of our legitimate interest in providing evidence of registration, pursuant to Article 6 Paragraph 1 Letter f of the GDPR. We use the e-mail address and name given by you to send the newsletter and to personally address it to you. We process this on the basis of your consent pursuant to Article6 Paragraph 1 Letter a, and Article 7 of the GDPR, together with Section 7 Paragraph 2 No. 3 of the German Act Against Unfair Competition (Unlauterer Wettbewerbs-Gesetz, UWG), as well as on the basis of legal permission pursuant to Section 7 Paragraph 3 of the UWG.
If you no longer want us to send you newsletters in the future, you can unsubscribe at any time. You can find a link to unsubscribe from the newsletter at the end of each newsletter. Of course, you can also simply contact us by e-mail at the following address: Click or type here to enter text.
After you unsubscribe, we may store your name and e-mail address for up to 3 years, on the basis of our legitimate interests in providing evidence of previous consent given, pursuant to Article 6 Paragraph 1 Letter f of the GDPR. Data is only provided for these purposes and is restricted for use for other purposes.

V. Using third-party services – technical functionality and information

a. Google Analytics

We use the service ‘Google Analytics’ from Google on our website, on the basis of our legitimate interests pursuant to Article 6 Paragraph 1 Letter f of the GDPR. This allows us to determine what is particularly relevant for visitors to our website, gives us an overview of visitor numbers, and allows us to design our website in an even more attractive way. This is operated by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043 USA; hereinafter: Google). This service also works without cookies being used. The regional origin of the visitor, their operating system and the type of end device is processed. The cookie also stores information about how you found us – the ‘referring websites’ – as well as landing pages, click paths, bounce rates and the length of stay on individual subpages.
The information collected by the cookie is sent to a Google server in the USA and processed there. Our website is configured in such a way that your personal data is truncated before it is sent to an area outside the regulatory area of the European Union or another signatory to the Agreement on the European Economic Area, and is therefore anonymised (IP masking). The IP address sent from your browser as part of Google Analytics will not be merged with other Google data.
Google is also certified under the Privacy Shield agreement and is obligated to comply with European data protection law. Corresponding proof of this status is available at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active. A data processing agreement has also been concluded with Google, which corresponds with the template available at the following link: http://www.google.com/analytics/terms/de.pdf.
You can also prevent the information from being collected by downloading and installing the browser plug-in available at the following link http://tools.google.com/dlpage/gaoptout?hl=de. In this case, a browser cookie is stored that prevents Google from collecting information on this website and other websites.
You can find more information about terms of use and data protection by Google at http://www.google.com/analytics/terms/de.html and https://www.google.de/intl/de/policies/.

b. Google reCAPTCHA

We use the service ‘Google reCAPTCHA’ from Google on our website, on the basis of our legitimate interests in protecting against spam and protecting our form fields from being misused, pursuant to Article 6 Paragraph 1 Letter f of the GDPR. The use of this tool allows us to recognise if people are inputting information into our website or if this is being done via an automated process. For this purpose, content generated by Google is automatically downloaded from Google servers in the form of a small picture puzzle, which you are asked to solve. The original URL, the IP address, the website visitor’s behaviour, information about the operating system used, the browser, length of stay, installed cookies, information about how the website is displayed, and the user’s input and mouse movements in the reCAPTCHA check box is sent to Google when doing so.
Google uses the data collected to digitalise text, to support image recognition and to improve machine learning. You can find more information about data protection by Google at: https://policies.google.com/privacy?hl=de.

VI. Using third-party services – social plug-ins

Of course, our company is also represented on Facebook, Twitter, YouTube, Vimeo and Instagram. We have included links to social media platforms on our website so that you are able to network with us. We have deliberately avoided using plug-ins for this purpose. Personal data is only sent to the respective website when you click onto that website.

a. Vimeo plug-in

We also display videos on our website using a Vimeo plug-in. Vimeo is a service from Vimeo Inc., 555 West 18th Street, NY, New York 10011 (hereinafter: Vimeo). We use Vimeo on the basis of our legitimate interests in our website functioning in an attractive, customer-friendly way, pursuant to Article 6 Paragraph 1 Letter f of the GDPR. If you visit a website that contains a plug-in, your IP address, the website visited by you, and your interaction with this plug-in, is sent to a Vimeo server.
You can find more information about data protection by Vimeo at http://vimeo.com/privacy.

VII. Validity and changes to this privacy policy

This privacy policy is valid as at May 2018 and this is the current version at present. However, if we further develop our website and offerings, or if there are any changes to legal guidelines, it may be necessary to change this privacy policy. You can access the respectively applicable privacy policy at https://www.comline-shop.de/datenschutz/.