Privacy Policy

I. General information and legal basis

The following statement informs you about the type of personal data collected on this website by us as the responsible body, for what purpose, and to what extent this data is made available to third parties.

1. Responsible body

ALSO Nederland B.V.
Inundatiedok 18
3439 JJ Nieuwegein
Tel.: (+31) 085-2226666
E-Mail: marcom.nl@also.com

Data protection supervisor

You can contact our data protection officer by post at the above address or by e-mail at privacy.nl@also.com.

2. Legal basis for processing

The processing of personal data requires a legal basis, which we would like to present to you below.

In the case of processing of personal data for which we obtain the consent of the data subject, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

In the case of the processing of personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6 (1) (b) GDPR serves as the legal basis. This also includes processing operations that are necessary for the implementation of pre-contractual measures.

Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Article 6 (1) (c) GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first interest, Article 6 (1) (f) GDPR serves as the legal basis for the processing. The legitimate interest of our company lies in the execution of our business activities as well as in the analysis, optimisation and maintenance of the security of our online offering.

II. Log Files, Hosting

The server statistics automatically store data that the browser transmits to us within the scope of our legitimate interest in analysis and for security reasons (so-called "log files"). Specifically, these are the following data:

Language and version of the browser software
Operating system used and its interface
Referrer URL (the previously visited page)
Host name of the accessing computer (IP address)
Date and time of the server request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Amount of data transferred
Access status/ HTTP status code.

As a rule, we cannot assign this data to specific persons and are therefore not used for profiling or behavioral analysis. This data is not combined with other data sources. The data will be deleted within 90 days after a statistical evaluation and for the purpose of detecting possible misuse . Data whose further retention is necessary for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

We provide all webshop hosting services ourselves and do not use any hosting service providers for this. The hosting serves to provide infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services in order to maintain the operation of this online offering.

In doing so, we process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of this online offer.

III. Contractual processing

The personal data provided by you for contractual purposes, e.g. in the case of quotation requests, such as name, address or e-mail address, will only be used internally to answer your enquiries, process your orders or provide you with access to certain contractual information.

IV. Contact, application data, events

1. Contact

If you contact us by e-mail, your details will be stored by us in order to answer your questions.

As a matter of principle, data will not be passed on to third parties, unless applicable data protection regulations justify a transfer or we are legally obliged to do so. You can revoke your consent at any time with effect for the future. To do so, please contact the responsible office of ALSO by post at the above address or by e-mail to the contact of the data protection officer mentioned there. In the event of revocation, your data will be deleted immediately, unless there is a legal exception for further processing. Otherwise, your data will be deleted if we have processed your request or the purpose of storage has ceased to apply and there are no other conflicting legal exceptions.

2. Applicant data

You can also apply to us, e.g. by e-mail. The data entered will be processed and used exclusively for the purpose of selecting applicants. With your application, you agree that you will be contacted and informed in writing and/or by telephone as part of the application process. Please note that your data will not be stored anonymously, but will be accessible to our HR department and the positions relevant to the position to be filled. We would like to evaluate all applicants only on their qualifications regardless of race, ethnic origin, gender, religion or belief, disability, age or sexual identity. We therefore ask you to refrain from providing such information in your application as far as possible. You can have your application changed or deleted at any time and revoke your consent. To do so, please contact the Human Resources Department of ALSO at the above address or by e-mail at [human-resources-de@also.com].

3. Events

If you register for or participate in events, incentives, conferences or comparable events of ALSO, your personal data will be collected for the purpose of enabling the planning, implementation and billing of these offers. This means that when you register for the event, ALSO processes and stores the personal data you provide (e.g. company, title, first and last name as well as e-mail address) for the purposes mentioned. You will be contacted by e-mail to provide you with the necessary information about your participation and the content of the event.

External Links

We may link to landing pages or invitations to external domains, such as those of event venues. The operators of the linked websites and not ALSO are responsible for the content of these websites and their compliance with applicable data protection regulations.

The legal basis for the processing of your data here is Art. 6 lit. b GDPR, i.e. the processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject. The categories of recipients of your personal data are ALSO Deutschland GmbH and, if necessary, employees of booking agencies, hotels and travel agencies.

Photo and film recordings

We reserve the right to take photos and film recordings during the event for marketing purposes. As soon as this is the case, we will inform you at the latest at the beginning of the event. As a rule, photos and film recordings are made of people who take on a special role (e.g. speakers, moderators, etc.) or show groups of participating people as well as depict the atmosphere of the event.

We publish these photos and film recordings on the ALSO website, on our social media presences such as LinkedIn, Twitter, Facebook and Instagram and use them to create a photo summary or a video with highlights of the event. If you do not wish to appear in these photos and films, we ask you to inform the photographer of this.

The legal basis for data processing with regard to photo and film recordings is our legitimate interest in accordance with Art. 6 (1) (f) GDPR. This consists of documenting the event with photos and film recordings for marketing purposes and using them for information and representation purposes. The legal basis for the creation of photo and video recordings of individuals is the obtaining of your consent in accordance with Art. 6 (1) (a) GDPR, which you can revoke at any time. If necessary, please contact the organiser ALSO, either by post to the above address or by e-mail to the address of the data protection officer given there.

V. Cookies

This site uses cookies. Cookies are small text files that are stored on your computer and through which certain information flows to the entity that sets the cookie. They are used to make the website more user-friendly and effective and/or to make it easier for you to navigate our website.

We only set cookies that are not strictly necessary with your consent. You can revoke this consent at any time for future use.

Consent is voluntary and you can also use our website without accepting cookies. You can also configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies or delete cookies that have already been stored. If you do not accept cookies, please note that in this case our offer may not work error-free. Unless we provide any other information on the individual topics mentioned in this privacy policy or in the cookie banner, the lifespan of the cookies refers to 24 months. You can find out which function on our website sets cookies below under the individual functions.

You can opt out of the use of cookies at any time in our consent management tool (see point XII Usercentrics Consent Management) is managed. There you have the opportunity to change the decisions you have made and to give or revoke your consent retrospectively. The call is possible via the use of cookie settings button or at the bottom of our website via the link "Cookie bar".

VI. Advertising

On our website you will be offered the opportunity to subscribe to newsletters on various topics and products. If you would like to receive such a newsletter, we need a valid e-mail address from you that allows us to verify that you are the owner of the e-mail address provided or that the owner agrees to receive the newsletter.

As part of the double opt-in procedure used by us, we will send you a confirmation e-mail to the address provided for this purpose after providing your e-mail address, in which we will ask you to confirm that you wish to receive the newsletter. If you do not confirm this within 24 hours, your data relating to the sending of the newsletter will be automatically deleted. If you confirm your wish to receive the newsletter, we will store your e-mail address until you unsubscribe from the newsletter.

We only send newsletters with your consent in accordance with Art. 6 (1) (a) GDPR or a legal permission.

This means that we also use your contact details for advertising purposes, provided that we do not require your consent for this (e.g. for direct mail advertising, direct advertising for our own similar goods and services within existing customer relationships).

The legal basis for this is our legitimate interest (Art. 6 para. 1 f GDPR). Our legitimate interest lies in customer care and the provision of information about our products and services.

We work with a shipping service provider. According to its own information, the mailing service provider may use this data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the mailing service provider does not use the data of our newsletter recipients to write to them themselves or to pass them on to third parties.

The newsletter is sent via "Adobe Marketo Engage", Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland. You can view the privacy policy of the shipping service provider here: https://www.adobe.com/de/privacy/policy.html.

You can revoke your consent to the storage of your data, your e-mail address and their use to send the newsletter at any time. A link to unsubscribe from the newsletter can be found at the end of each newsletter. If users have only subscribed to the newsletter and have cancelled this subscription, their personal data will be deleted.

VII. Registration

Our website offers a registration option. The personal data entered as part of the registration process will be transmitted to the Data Controller. The data is stored exclusively for the purpose of internal use by us.

During registration, the user's IP address as well as the date and time of registration are stored. This is to prevent misuse of the services. The data will not be passed on to third parties. There is an exception if there is a legal obligation to pass it on.

The registration of the data is necessary for the provision of content or services. Registered persons have the option of deleting or modifying the stored data at any time. The data subject will receive information about the personal data stored about him or her at any time.

VIII. Credit check

In the case of new customers, a credit check is carried out by Schufa and Creditreform before creating a customer account and thus concluding a contract. As part of this audit, certain personal data will be transmitted to and processed by these service providers and will be requested by the data controller. Depending on the type of company, this data may have a personal reference.

Personal data processed:

Crefo number
Identification number
Name of the company
Address (street, house number, postcode, city and country)

The processing of this data is necessary for us to assess the business risk and ensure that the available payment options are adequate. For this purpose, the legal basis for this data processing is our legitimate interest in accordance with Art. 6 para. 1 f GDPR. If you do not wish to provide us with the data, you will not be able to use our services.

The results of the credit check will be treated confidentially and will not be disclosed to third parties, unless applicable data protection regulations justify a transfer or we are legally obliged to do so.

In return for the information, ALSO receives supplements over a period of 12 months in the event of current changes. After that, the monitoring takes effect, i.e. the supplementary period limited to the duration of the customer relationship. This can be terminated at the end of the month with Creditreform, with Schufa after 12 months after purchase.

This means that in both cases, ALSO stores your data for at least one year. Thereafter, ALSO may have the update discontinued at its own discretion on the basis of the risk assessment described above.

IX. Webshop

1. enclosure

To use our webshop, it is necessary to create an account. For this purpose, we process the following personal data:

Company name
Address (street, house number, postcode, city and country)
VAT ID
Payment method (SEPA)
E-mail address

2. Use

The processing of the above-mentioned personal data is carried out for the following purposes:

Fulfilling orders and delivering products, processing payments, communicating with customers regarding orders and requests.

The legal basis for data processing is Art. 6 (1) (b) (performance of a contract) and (c) (fulfilment of a legal obligation) GDPR.

If you do not wish to provide us with the personal data described above, you will not be able to use our services.

3. Storage period

ALSO stores your personal data for the duration of the contractual relationship and beyond that for the periods specified in the context of statutory retention obligations.

X.Our social media presence

You can find us under online presences within social networks and platforms. We would like to use these presences to communicate with our customers, interested parties and users who are active there and to inform them about our services and our company.

The processing of the personal data of the users active there is carried out on the basis of our legitimate interests in communicating and providing information to and with the users. If consent to data processing by users has been given within the framework of the respective social platform, the processing is carried out on this basis of consent.

If you visit one of our social media presences, we are jointly responsible with the operator of the social platform for the data processing operations triggered during this visit. In principle, you can assert your rights (information, rectification, deletion, restriction of processing, data portability and complaint, see the following point "Rights of the data subject") both against us and against the operator of the respective social platform.

We would like to point out that, despite the joint responsibility, we do not have full influence on the data processing operations of the social platform and, if necessary, forward the rights request to the respective operator in order to better process the rights of the data subject. Our options are generally based on the corporate policy of the respective provider.

You can find our storage details below. We have no influence on the storage period of your data, which is stored by the operator of the social platform for its own purposes. For details, please contact the operators of the social networks directly (e.g. in their privacy policy, see below).

Depending on the following social platform, the data processing of users may also take place outside the area of the European Union.

Data transfers to Google and Meta are made on the basis of the adequacy decision for the EU-US data protection agreement "Data Privacy Framework" (ensuring the level of data protection for data processing by data importers based in the USA). You can find more information about the Data Privacy Framework here: https://www.dataprivacyframework.gov/

As a rule, user data is processed by the platforms for market research and advertising purposes. For example, user profiles can be created from the user's usage behavior and resulting interests. In turn, the user profiles can be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For this purpose, cookies are usually stored on the user's computer, in which the user's usage behavior and interests are stored. Data can also be stored in the usage profiles, regardless of the devices used by the users. This is done in particular if the users are members of the respective platforms and are logged in to them.

For a detailed description of the respective processing and the possibilities for objection, we refer to the information of the providers linked below.

Facebook (Pages, Groups)

(Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland)

The basis for this is an agreement on the joint processing of personal data: https://www.facebook.com/legal/terms/page_controller_addendum

Opt-Out: https://www.facebook.com/settings?tab=ads und http://www.youronlinechoices.com

Whatsapp

(Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland)

The basis for this is an agreement on the joint processing of personal data: https://www.facebook.com/legal/terms/page_controller_addendum

Google/ YouTube

(Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland)

Opt-Out: https://adssettings.google.com/authenticated

X (Twitter)

(X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A.)

Opt-Out: https://twitter.com/personalization

LinkedIn

(LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland)

Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

XING

(New Work SE, Am Strandkai 1, 20457 Hamburg, Germany, Tel.: +49 40 419 131-0, Fax: +49 40 419 131-11, E-Mail: info@xing.com)

Opt-Out: https://www.xing.com/settings/privacy/data

XI. Disclosure of data to third parties

a. General and Contractual Purpose

We pass on data to third parties if this is necessary for the fulfilment of the contract and/or if we are legally obliged and/or entitled to do so in individual cases.

b. Tools for the economic operation of the website

In some cases, we use external service providers within the scope of your consent or our legitimate interests with regard to the analysis, optimisation and economic operation of the online offering. If you have given your consent for tools that are not necessary for the operation of the website, you can also have these settings changed at any time. Below we list our service providers.

If your data is to be used for other purposes, we will inform you in advance and only use the data if you have previously expressly given your further consent.

1. Google

Within the scope of your consent, we use services for the optimisation and economic operation of our online offering, for which Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") is responsible. Google is a participant in the EU-US data protection agreement "Data Privacy Framework" (ensuring the level of data protection for data processing by data importers based in the USA). You can find more information about the Data Privacy Framework here: https://www.dataprivacyframework.gov/

a. Youtube

We use YouTube, a service provided by Google, to embed videos.

These videos are stored on www.youtube.com and can be played directly from our site. YouTube uses cookies for data collection and statistical data analysis. YouTube uses cookies to, among other things, collect reliable video statistics, prevent fraud and improve the user experience. The information generated by the cookie about your use of this website (including your IP address) will be transmitted to YouTube servers in the USA and stored there. Your IP address cannot be assigned unless you have logged in to YouTube or another Google service before accessing the page or are permanently logged in. If you do not wish this, you will need to log out of your Youtube account and your other Google accounts. Through the YouTube cookies, we receive statistical values for the retrieval of individual videos embedded on the website without any reference to the respective user.

The embedded videos from YouTube are used within the scope of the permitted use by YouTube, which all users must accept. If you see copyright infringement, please report it directly to YouTube. We use embedded YouTube videos in extended privacy mode. This means that YouTube does not store cookies for a user who views a website with an embedded YouTube video player but does not click on the video to start playback. If the YouTube video player is clicked, YouTube may be able to store cookies on the user's computer. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Youtube. For more information on YouTube's official privacy policy, please refer to https://www.google.de/intl/de/policies/privacy/ and https://support.google.com/youtube/answer/171780?hl=dehttps://support.google.com/youtube/answer/171780?hl=de.

2.Meta

Within the scope of your consent, we use services of the social network facebook.com, which is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, for the analysis, optimisation and economic operation of our online offer ("Facebook").

Meta is a participant in the EU-US data protection agreement "Data Privacy Framework" (ensuring the level of data protection for data processing by data importers based in the USA). You can find more information about the Data Privacy Framework here: https://www.dataprivacyframework.gov/

b.Facebook Custom Audiences und Website Custom Audiences

Our website uses the advertising tools Custom Audiences and Website Custom Audiences. from Facebook. In this case, a non-reversible and non-personal checksum (hash value) is generated from your usage data, which is transmitted to Facebook for analysis and marketing purposes on its social platform and stored in the USA.

The Meta pixel is directly integrated by Facebook when you visit our website and can store a so-called cookie, i.e. a small file, on your device. If you then log in to Facebook or visit Facebook while logged in, your visit to our website will be noted in your profile. The data collected about you is anonymous to us, so it does not allow us to draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and can be used by Facebook as well as for its own market research and advertising purposes. If we transmit data to Facebook for comparison purposes, it will be encrypted locally on the browser and only then sent to Facebook via a secure https connection. This is done solely for the purpose of establishing a comparison with the data that is also encrypted by Facebook.

Furthermore, when using the Meta pixel, we use the additional function "extended matching" (data such as telephone numbers, e-mail addresses or Facebook IDs of the users) to form target groups ("Custom Audiences" or "Look Alike Audiences") transmitted to Facebook (encrypted). Further information on "extended matching": https://www.facebook.com/business/help/611774685654668).

To prevent the collection of your data by means of the meta pixel on our website, please follow the following link: https://www.facebook.com/ads/website_custom_audiences/ If you click on the link, an "opt-out" cookie will be stored on your device. If you delete the cookies in this browser, you will have to click the link again. Furthermore, the opt-out only applies within the browser you are using and only within our web domain on which the link was clicked.

Also on the basis of our legitimate interests, we use the "Custom Audiences from File" procedure of the social network Facebook, Inc. In this case, the email addresses of the newsletter recipients are uploaded to Facebook. The upload process is encrypted. The sole purpose of the upload is to determine recipients of our Facebook ads. We want to make sure that the ads are only shown to users who are interested in our information and services.

If you would like to object to the use of Facebook Website Custom Audiences, you can also do so under https://www.facebook.com/ads/website_custom_audiences/ . To do this, you need to log in to your Facebook account.

For further information on the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your rights in this regard and setting options to protect your privacy, please refer to Facebook's privacy policy under http://www.facebook.com/about/privacy/, as well as specifically for Facebook Custom Audiences under https://www.facebook.com/ads/website_custom_audiences/.

3. Mapp

Our website uses the marketing and tracking tool Mapp from Mapp Digital Germany GmbH, Sandstr. 3, 80335 München https://mapp.com/de/. The Mapp pixel is integrated into our website and, with your consent, can store a so-called cookie, i.e. a small file, on your device. The cookie tracks your online behaviour and allows us to adapt our offer directly to your wishes. Further information on the data protection of Mapp Digital Germany GmbH can be found at: https://mapp.com/privacy/

4. Whatfix

In order to be able to provide you with automated answers to initial and frequently asked questions about products and services, we use the website assistant of Whatfix Private Limited, No.1289/1090E, 18th Cross Road, Sector 3, HSR Layout, Bangalore, Karnataka - 560102 India. The legal basis for the processing of your non-exclusively personal data is your consent in accordance with Art. 6 (1) (a) GDPR. Your consent is given via the cookie consent tool described below and can be revoked there at any time. Whatfix Private Limited's privacy policy can be found at: https://whatfix.com/privacy-policy/

EU standard contractual clauses have been agreed with Whatfix, so that possible measures have been taken to ensure European data protection law.

XII. Usercentrics Consent Management

We use the Usercentrics Consent Management Platform (Usercentrics) of Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany. Usercentrics collects log file data and consent data using JavaScript. This JavaScript allows us to inform the user of their consent to certain cookies and other technologies on our website and to obtain, manage and document them.

The legal basis for the processing of the data is Art. 6 (1) (c) GDPR. The aim is to know the preferences of the users and act accordingly. The data will be deleted as soon as it is no longer needed for our logging. The shelf life of the cookie is 60 days. On the one hand, the retention of the revocation certificate is based on our accountability pursuant to Art. 5 (2) GDPR. This obliges to comply with the processing of personal data in accordance with the General Data Protection Regulation. On the other hand, the retention period in the regular limitation period pursuant to § 195 BGB is three years. You can permanently prevent the execution of JavaScript at any time by making the appropriate settings in your browser, which would also prevent Usercentrics from executing the JavaScript. For more information about Usercentrics' privacy practices, please visit: https://usercentrics.com/de/datenschutzerklarung/

XIII. Data storage outside the EU/EEA

As indicated in the individual tool descriptions, we use third-party tools outside the EU/EEA. Insofar as this is necessary for the purposes communicated, it may happen that your IP address is processed outside the European Economic Area, where a level of data protection that meets the European standard is not consistently guaranteed and confirmed (e.g. by means of an appropriate guarantee within the meaning of Art. 46 GDPR or an adequacy decision of the European Commission pursuant to Art. 45 GDPR). Therefore, it cannot be ruled out in particular that security authorities in a third country gain access to your IP address without you being able to take legally effective action against it.

The transfer of the IP address to these third-party providers takes place in accordance with Art. 49 (1) (a) GDPR on the basis of your consent expressly given in the consent banner. This consent is voluntary. You can revoke this at any time with effect for the future. You will not suffer any disadvantages as a result.

In the opinion of some U.S. third-party providers, a level of protection corresponding to the European standard is already guaranteed on the basis of the conclusion of so-called standard contractual clauses as well as additional measures taken within the meaning of the Schrems II case law. However, since the suitability of such measures to ensure an adequate level of data protection is disputed, we have decided to transmit your IP address exclusively with your consent. In our own cases, we base data transfers to U.S. third-party providers on the EU-U.S. Data Privacy Framework.

XIV. Automated decision-making

We use automated decision-making to match deliveries and personal data with export control and sanctions lists issued by the European Union and other countries from which exports may be made. Depending on the outcome of this review, we are obliged to implement appropriate measures within the framework of export control regulations specified by the European Union and other countries from which exports are to be made. The legal basis for the processing of the data is Art. 6 (1) (c) GDPR. The comparison ensures compliance with applicable export law.

XV. Rights of the data subject

You have the right to information about the personal data we hold about you. In accordance with the legal provisions, you also have the right to rectification of incorrect data, blocking, data portability and deletion of your personal data. If you have given your consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal.

You can object to the future processing of your personal data at any time in accordance with the legal requirements. In particular, the objection may be made to the processing for direct marketing purposes.

To do so, please contact the responsible office at the ALSO address mentioned above by post or by e-mail to the address of the data protection officer given there.

You also have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates the legal provisions.

XVI. Duration of storage of personal data

Unless we have provided storage information on the specific points, the following applies: We store personal data for the duration of the respective statutory retention period or for as long as the purpose of the collection exists. After expiry of the retention period, the data will be routinely deleted, unless there is a necessity for the initiation of a contract or for the fulfilment of the contract. Unless the user's data is erased because it is required for other purposes permitted by law, their processing will be limited as far as possible. Accordingly, the data will be blocked as far as possible and will not be processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax reasons.

XVII. Security

We make every effort to process your personal data by taking all technical and organizational means in such a way that the provisions of the data protection laws are complied with and thus to protect this data. Our website or communication with us via our website is encrypted via HTTPS.

Privacy Policy

1. General information

We take the protection of personal data very seriously and adhere to the relevant legal regulations. The following declaration informs you about the type of personal data that is collected on this website, the purpose for which it is used and the extent to which this data is made available to third parties.

2. Responsible for data processing

This data protection policy applies to data processing by ALSO International B.V., Wijchenseweg 20, 6537 TL Nijmegen, Netherlands, Tel.: +31 24 357 9999 (hereinafter: "ALSO" or "we"), accessible at info@also.com.

3. Data protection officer

You can address your data protection concerns to our customer service staff or directly to our data protection officer at privacy.nl@also.com or by post to ALSO International B.V. , Wijchenseweg 20, 6537 TL Nijmegen, Netherlands.

4. Data processing when visiting our website

When you visit our website, information is automatically sent to us by the web browser you are using to enable the structure of our website. The information provided includes the IP address of the requesting Internet-capable device, the date and time of the request and browser information. This information is temporarily stored in a so-called log file and automatically deleted after 9 weeks at the latest. The collected data does not allow any direct conclusions about your identity.

The legal basis for the processing of the IP address is Art. 6 Par. 1 S.1 lit. f General Data Protection Regulation ("GDPR"). The purpose of processing the data is to ensure the smooth establishment of connections and system security. Our legitimate interest lies in the security of your data, recognition and defence of attempted attacks, for statistical evaluation and for the optimisation and provision of our online services.

Furthermore, we use cookies and analysis services when you visit our website. For further details, please refer to points 7 and 8.

5. New customer registration and business

When registering as a new customer, we process your transmitted data in accordance with Art. 6 para. 1 lit. b or lit. f GDPR for the purpose of carrying out pre-contractual measures. During the registration process, we obtain a credit report on you from Creditsafe. We process the creditworthiness information in accordance with Art. 6 para. 1 lit. f GDPR on the basis of a justified interest in a stable business relationship.

During the business relationship, we process your data on the basis of Art. 6 para. 1 lit. a GDPR, if you have given us permission to use your data, e.g. for certain marketing campaigns or incentives.

Furthermore, we process your data in accordance with Art. 6 para. 1 lit. b GDPR for pre-contractual measures such as offers or the implementation of purchase or leasing contracts.

6. Events

If you register for or participate in events, incentives, conferences or similar ALSO events, your personal data will be collected for the purpose of planning, implementing and invoicing these offers.

The categories of recipients of your personal data are ALSO International B.V. and, if necessary, employees of booking agencies, hotels and travel agencies.

7. Use of cookies

Cookies: We use cookies for certain offers. These are small text files that are stored on your computer. This enables us to recognise if you visit websites from the same computer repeatedly.

Session cookies are cookies that are only stored on your computer for the duration of an Internet session and are required for transactions. These session cookies are used exclusively for connection control and navigation and enable you to surf our website in a user-friendly manner (e.g. for processing a purchase while you are logged on to our shop systems). Session cookies are deleted again when you end your browser session.

For certain offers, we use persistent cookies which serve to recognise visitors and are stored on your computer for future sessions. These cookies are valid for 6 to 24 months (e.g. a persistent cookie is required to prevent your surfing behaviour from being recorded by the tracking tools used).

You have the option of setting your browser so that these cookies are not stored at all or so that the cookies are deleted at the end of your Internet session. Please note, however, that in this case you may not be able to use all the functions of our online service.

You can also manage the use of cookies in our Consent Management Tool (see section 8) at any time. You can change the decision made there at any time and subsequently grant or revoke your consent. For this purpose, you can call up the setting options here.

8. Usercentrics Consent Management Plattform

We use the Usercentrics Consent Management Platform (Usercentrics) of Usercentrics GmbH, Rosental 4, 80331 Munich, Germany. Usercentrics collects log file data and consent data using JavaScript. This JavaScript enables us to inform the user about his or her consent to certain cookies and other technologies on our website and to obtain, manage and document these.

The legal basis for processing the data is Art. 6 para. 1 lit. c GDPR. The aim is to know the preferences of users and to act accordingly.

The data is deleted as soon as it is no longer required for our logging. The durability of the cookie is 60 days. The consent data must be stored for six years. The revocation certificate of a previously granted consent is kept for three years. On the one hand, the storage is based on our accountability in accordance with Art. 5 para. 2 GDPR. This obliges us to comply with the processing of personal data in accordance with the General Data Protection Regulation. On the other hand, the retention period within the regular limitation period is three years.

You can permanently prevent the execution of JavaScript at any time by making the appropriate settings in your browser, which would also prevent Usercentrics from executing the JavaScript.

9. Google Tag Manager

This website uses the Google Tag Manager. This service allows website tags to be managed through an interface. The Google Tool Manager only implements tags. This means: no cookies are used and no personal data is collected. The Google Tool Manager triggers other tags, which in turn may collect data. However, the Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, it will remain in effect for all tracking tags if they are implemented with the Google Tag Manager.

10. Newsletter

On the ALSO website, users are given the opportunity to subscribe to our company's newsletters. Pursuant to art. 6, par. 1 lit. a GDPR, we process your data on the basis of a granted consent.

ALSO uses ELAINE from Artegic AG for the newsletter dispatch. ALSO informs its customers and business partners at regular intervals by means of a newsletter about (if possible individual) information about products, promotions, competitions and news from ALSO. We also occasionally use the service for surveys to increase customer satisfaction. The newsletter of our company can only be received by the person concerned if (1) the person concerned has a valid e-mail address and (2) the person concerned registers to receive the newsletter. A confirmation e-mail will be sent to the e-mail address registered for the first time by a person concerned for sending the newsletter using the double opt-in procedure. This confirmation e-mail serves to check whether the owner of the e-mail address has authorised the receipt of the newsletter as a data subject.

When registering for the newsletter, we also save the IP address assigned by the Internet service provider (ISP) of the computer system used by the person concerned at the time of registration as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of the e-mail address of a data subject at a later date and therefore serves to provide legal protection for the person responsible for processing.

The personal data collected during registration for the newsletter is used exclusively for sending our newsletter. In addition, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or for registration, as might be the case if there are changes to the newsletter offer or if technical conditions change. The personal data collected within the scope of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be cancelled by the person concerned at any time. The consent to the storage of personal data, which the person concerned has given us for the newsletter dispatch, can be revoked at any time. For the purpose of revoking this consent, there is a corresponding link to the unsubscription form in every newsletter. Furthermore, it is also possible to unsubscribe from the newsletter at any time directly on the website of the data controller or to inform the data controller in another way.

Newsletter-Tracking

The newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. By means of the embedded counting pixel, the person in charge can see whether and when an e-mail was opened by a person concerned. Adapted links can also be used to record which links in the e-mail were opened by the person concerned.

Such personal data collected via the tracking pixels and links contained in the newsletters are stored and evaluated by the data controller in order to optimise the sending of the newsletter and to adapt the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled to revoke the declaration of consent given in this regard at any time. This is equal to unsubscribing from receiving the newsletter.

ELAINE will be used on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f. GDPR and a contract processing agreement pursuant to Art. 28 para. 3 sent. 1 GDPR.

ELAINE may use the data of the recipients in pseudonymous form, i.e. without allocation to a user, for the optimisation or improvement of its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletters or for statistical purposes. However, ELAINE does not use the data of our newsletter recipients to write to them itself or to pass on the data to third parties.

The newsletters are sent via the mailing service provider "MailChimp", a newsletter mailing platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The Privacy Policy of the mail order service provider can be viewed here: https://mailchimp.com/legal/privacy/. Mailchimp is operated based on our legitimate interests according to art. 6 par. 1 lit. f. GDPR and an order processing contract according to art. 28 para. 3 sent. 1 GDPR.

Mailchimp can use the data of the recipients in pseudonymous form, i.e. without allocation to a user, to optimize or improve its own services, e.g. for technical optimization of the sending and presentation of the newsletter or for statistical purposes. However, Mailchimp does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

11. Google Webfonts

Google web fonts are used to improve the visual presentation of various information on this website. The web fonts are transferred to the cache of the browser when the page is called up in order to use them for the display. If the browser does not support Google Web Fonts or prevents access, the text is displayed in a standard font. When the page is called up, no cookies are set for the website visitor. Data transmitted in connection with the page view is sent to resource-specific domains such as fonts.googleapis.com or fonts.gstatic.com. They are not associated with data that may be collected or used in connection with the parallel use of authenticated Google services such as Gmail. You can set your browser so that the fonts are not loaded from the Google servers. Information on the data protection conditions of Google Webfonts is available at: https://developers.google.com/fonts/faq#Privacy .

General information on data protection is available in the Google Privacy Center at:

https://policies.google.com/privacy?hl=nl

12. Youtube

We use YouTube, a service from Google, to integrate videos.

These videos are stored on www.youtube.com and can be played directly from our site. YouTube uses cookies for data collection and statistical data evaluation. YouTube uses cookies to collect reliable video statistics, prevent fraud and improve user experience, among other things. The information generated by the cookie about your use of this website (including your IP address) is transmitted to and stored on YouTube servers, including in the USA. Your IP address cannot be assigned unless you have logged in to YouTube or another Google service before visiting the site or unless you are permanently logged in. If you do not wish to do so, you must log out of your YouTube account and your other Google Accounts.

The YouTube cookies provide us with statistical data on the retrieval of individual videos embedded in the website without any reference to the individual user. YouTube's embedded videos are used to the extent permitted by YouTube, which all users must accept. If you see any copyright infringement, please report this directly to YouTube. We use embedded YouTube videos in an enhanced privacy mode. This means that YouTube does not store cookies for a user who views a website with an embedded YouTube video player, but does not click on the video to start playback. When the YouTube video player is clicked, YouTube may store cookies on the user's computer. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or of the use of these data by YouTube. For more information on YouTube's official Privacy Policy, please visit https://policies.google.com/privacy?hl=nl and https://support.google.com/youtube/answer/171780?hl=nl .

13. Storage period of personal data

We store personal data for the duration of the respective legal retention period or as long as the purpose of the collection exists. After expiry of the retention period, the data is routinely deleted, unless it is necessary for the initiation of a contract or for the fulfilment of a contract. If the users' data is not deleted because it is required for other and legally permissible purposes, its processing is restricted as far as possible. Accordingly, the data will be blocked where possible and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.

14. Contact forms and contacting

We offer you the opportunity to contact us via contact forms, telephone, e-mail and social media. The data transmitted in this way is processed for the purpose of processing the contact enquiry with the person responsible based on Art. 6 Par. 1 lit. b for contracts and pre-contractual measures such as offers and Art. 6 Par. 1 lit. f for other enquiries. Your data may be stored and processed in our CRM system.

15. Automated decision

We use automated decisions when matching shipments and personal data with export control and sanction lists of the European Union and other countries from which exports may be made. Depending on the outcome of this review, we may be required to implement appropriate measures under export control regulations imposed by the European Union and other countries from which exports may be made. The legal basis for the processing of the data is Art. 6 para. 1 lit. c GDPR. The comparison ensures compliance with applicable export law.

16. Safety information

By taking all technical and organisational measures, we make every effort to process your personal data in such a way that the regulations of the data protection laws are observed and to protect these data..

17. Modification of the Privacy Policy

ALSO reserves the right to amend this Privacy Policy at any time in accordance with the applicable data protection regulations and other statutory provisions.

18. Where will my data be processed?

Your data will be processed within the EU and the EEA. To the extent permitted by law, data processing also takes place in non-European countries.

19. Transfer of data to third parties

We pass on data to third parties if this is necessary for the fulfilment of the contract and / or we expressly state this in this data protection declaration and / or we are legally obliged and / or entitled to do so in individual cases.

Based on the legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR and with recital 48 of the GDPR, we may pass on your data to affiliated companies of the ALSO Group.

20. Rights of data subjects

In accordance with Art. 15 GDPR, you have a right to information about the processing of your personal data.

Furthermore, you are free to exercise your rights of correction, deletion or, if deletion is not possible, restriction of processing and data transferability in accordance with articles 16-18, 20 GDPR. Should you wish to exercise this right, please contact our data protection officer.

If you believe that your personal data is not being processed in compliance with the data protection laws, we would kindly ask you to contact our data protection officer.

Furthermore, you have the right to complain to the responsible supervisory authority at any time.

Competent supervisory authority of ALSO:

Autoriteit Persoonsgegevens
Prins Clauslaan 60
P.O. Box 93374
2509 AJ Den Haag/The Hague

Tel. +31 70 888 8500
Fax +31 70 888 8501
info@autoriteitpersoonsgegevens.nl
https://autoriteitpersoonsgegevens.nl/nl

You also have the right to object to the processing of your personal data at any time in accordance with Art. 13 para. 2 lit. b GDPR.

Personal data which you transmit to us in the course of exercising data subject rights will be stored by us in accordance with Art. 6 para. 1 lit. f GDPR in the legitimate interest. The legitimate interest consists in the verifiability of your request.

Under the conditions of Article 21 (1) GDPR, data processing may be objected to for reasons arising from the specific situation of the data subject.

The above general right of objection applies to all processing purposes described in this Privacy Policy which are processed based on Art. 6 para. 1 sent. 1 lit. f GDPR. We are only obliged to implement such a general objection if you provide us with reasons of overriding importance (e.g. a possible danger to life or health).

***

Privacy Policy

I. General information and legal basis

1. Responsible body

2. Legal basis for processing

II. Log Files, Hosting

III. Contractual processing

IV. Contact, application data, events

1. Contact

2. Applicant data

3. Events

V. Cookies

VI. Advertising

VII. Registration

VIII. Credit check

1. enclosure

2. Use

3. Storage period

X.Our social media presence

1. Google

a. Youtube

2.Meta

3. Mapp

4. Whatfix

XII. Usercentrics Consent Management

XIII. Data storage outside the EU/EEA

XIV. Automated decision-making

XV. Rights of the data subject

XVI. Duration of storage of personal data

XVII. Security

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