Privacy Notice pursuant to Art. 12 et seq. GDPR

I.Identity and contact details of the controller 

 Your contact as controller within the meaning of the European General Data Protection Regulation („GDPR”) and other national data protection laws of the member states as well as other provisions of data protection law is:

 Vestel HOLLAND B.V. Germany Branch Office 
 Parkring 6
 85748 Garching b. München, Germany

 (hereinafter referred to as "we", "us" or "our")

II.Contact details of the data protection officer 

 The protection of your personal data has a high priority for us. To reflect this importance, we have commissioned a consulting firm specializing in data protection and data security to handle these central issues. Our data protection officer also comes from this highly experienced group of experts.

 We are counselled by:

 MAGELLAN Rechtsanwälte, Brienner Straße 11, 80333 Munich / www.magellan-datenschutz.de/en 

 For all questions concerning data protection and data security, please contact our data protection officer directly at MAGELLAN Rechtsanwälte:

 E-Mail: datenschutz_vestel@magellan-legal.de / Tel.: (+49) 089-552950

III.Data processing on our website 

 1.Website functions 

 i.Provision of the website and creation of log files 

 a.Legal basis 

 Legal basis for the processing of your personal data in the context of providing the website and the creation of log files is Art. 6 (1) lit. f GDPR.

 b.Purpose 

 The temporary storage of your personal data by us is necessary to enable the website to be delivered to your computer. For this purpose, your personal data must be stored for the duration of the session.
 Your personal data are stored in log files to ensure the functionality of the website. Your personal data also help us to optimise the website and to ensure that our IT systems are secure. Your personal data will not be processed in any other way

c.Duration of storage 

 The data are erased as soon as they are no longer necessary to achieve the purpose for which they were collected. In case your personal data are recorded for the purpose of providing the website, this happens as soon as the relevant session has ended.

 If your personal data is stored in log files, they will be erased after three months at the latest. If the log files are stored beyond this period, your personal data will be made anonymous so that it is no longer possible to assign them to a website visitor. 

d.Objection and rectification option 

 The collection of your personal data for the provision of the website and the storage of your personal data in log files is necessary in order to operate the website. Consequently, you cannot object to this data processing.

ii.Use of technically necessary cookies

a.Legal basis

Legal basis for the processing of your personal data in the context of the use of technically necessary cookies is Art. 6 (1) lit. f GDPR.

b.Purpose

The purpose of using technically necessary cookies is to make it easier for you to use our website. Some functions of our website cannot be offered without the use of cookies. For this, it is necessary that your browser is recognised again after a page change. Your personal data will not be processed in any other way.

c.Duration of storage

The data are erased as soon as they are no longer necessary to achieve the purpose for which they were collected; this happens, in particular, as soon as the relevant session has ended.

d.Objection and rectification option

An overview of the technically necessary cookies used on our website can be found at the bottom of the page.

Cookies are stored on your computer and transmitted from the computer to our website. Therefore, you have complete control over the use of cookies.

By adjusting the settings of your browser you can deactivate or restrict the transmission of cookies. You can also, at any time, delete cookies that have already been stored. This can also be done automatically. However, if you deactivate cookies for our website, you might not be able to use all website´s functions to their full extent.

 2.Marketing and communication 

 i.Contact form and email contact 

 a.Legal basis 

 Legal basis for the processing of your personal data transmitted in the course of contacting us is Art. 6 (1) lit. f GDPR. If you contact us in order to conclude a contract, Art. 6 (1) lit. b GDPR is an additional legal basis for the processing of your personal data.

 b.Purpose 

 The processing of your personal data when contacting us only takes place to process your request.

 c.Duration of storage 

 The data are erased as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of any personal data sent in the course of contacting us, this happens when your request has been processed and no legal retention periods prevent erasure.

 d.Objection and rectification option 

 You can always object to the processing of your personal data in the context of contacting us for the future. In this case, however, we will not be able to process your request any further. All personal data stored in the context of contacting us will be erased, unless legal retention periods prevent erasure.

 

 ii.Direct marketing 

 a.Legal basis 

 Legal basis for the processing of your personal data in the context of direct marketing measures is either your declared consent pursuant to Art. 6 (1) lit. a GDPR or the lawful basis of Art. 6 (1) lit. f GDPR or § 7 (3) UWG (German Act against unfair competition, “Gesetz gegen den unlauteren Wettbewerb” - “UWG”).

 b.Purpose 

 The purpose of processing your personal data in the context of direct marketing measures is to send you updates and offers as well as to promote turnover by selling goods or services.

 c.Duration of storage 

 Your personal data are erased as soon as they are no longer necessary to achieve the purpose for which they were collected; this is particularly the case, when withdraw your given consent or you object to the processing of your data for this purpose.

 d.Objection and rectification option 

 You can withdraw your consent at any time for the future or object to the processing of your personal data within the context of direct marketing measures at any time for the future.

 

 iii.Google Analytics 

 a.Legal basis 

 Legal basis for the processing of your personal data in the context of the use of Google Analytics by means of so-called “performance cookies” and “retargeting cookies” is your declared consent in accordance with Art. 6 (1) lit. a GDPR. 

 b.Purpose 

 The processing of your personal data enables us to optimise the user-friendliness of our website and promote turnover by selling goods or services.

 c.Duration of storage 

 Your personal data will be erased as soon as you withdraw your declared consent or your personal data is no longer needed for the aforementioned purposes.

 d.Objection and rectification option 

 You will find an overview of the cookies used on our website at the bottom of the page. 

 You can revoke your declared consent to the processing of your personal data within the context of the use of Google Analytics at any time for the future by proceeding as follows:

 (1)Changing the consent settings on our website 

 On our website, we offer you the possibility to simply revoke the processing of your personal data in the context of the use of Google Analytics.

 To do this, you simply need to click on the tab „Cookie management “ in the footer.

 (2)Changing the settings of your browser 

 Alternatively, you can deactivate or restrict the transmission of cookies in general by changing the settings in your browser. You can delete already stored cookies at any time. This can also be done automatically. If technically necessary cookies for our website are also deactivated, it is possible that not all functions of the website can be used to their full extent.

 (3)Browser add-on 

 If you do not want your personal data to be processed by Google Analytics, you can also install the browser add-on to deactivate Google Analytics. This add-on instructs the JavaScript of Google Analytics (ga.js, analytics.js and dc.js) executed on websites not to allow the sending of information to Google Analytics.

 If you want to disable Google Analytics, go to the page below and install the Google Analytics disablement add-on for your browser. For detailed information on installing and uninstalling the add-on, please refer to the relevant help resources for your browser.

 The latest versions of Internet Explorer occasionally load the add-on to disable Google Analytics after personal information has already been sent to Google Analytics. Therefore, if you use Internet Explorer, the add-on will install cookies on your computer. These cookies ensure that any data collected is immediately deleted from the server that collected it. Make sure that third-party cookies are not disabled for Internet Explorer. If you delete your cookies, the add-on will reset these cookies within a short period of time to ensure that your Google Analytics browser add-on continues to work properly.

 The browser add-on to disable Google Analytics does not prevent personal data from being sent to the website or other tracking services.

 For more information on terms of use and privacy, please visit:

 www.google.com/analytics/terms/de.html  or

 support.google.com/analytics/answer/6004245?hl=de.

 IP anonymization is activated on our website.

 3.Data protection and legal disputes 

 i.Data subjects´ requests pursuant to Art. 12 et seq. GDPR 

 a.Legal basis 

 Legal basis for the processing of your personal data in the context of processing your data protection related-request (“data subjects´ request”) is Art. 6 (1) lit. c in connection with Art. 12 et seq. GDPR. Legal basis for the subsequent documentation regarding the handling of your data subject´s request in accordance with the legal provisions is Art. 6 (1) lit. f GDPR.

 b.Purpose 

 The purpose of processing your personal data in the context of handling your data subject´s request is to answer your data protection-related enquiry. The subsequent documentation regarding the processing of your request is to fulfil the obligation of accountability required by law, Art. 5 (2) GDPR.

 c.Duration of storage 

 The data are erased as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the processing of data subject´s requests, pursuant to § 41 BDSG (German Federal Data Protection Act, “Bundesdatenschutzgesetz” - “BDSG”) in connection with § 31 (2) Nr. 1 OWiG (German Regulatory Offences Act, “Gesetz über Ordnungswidrigkeiten” – “OWiG”), this is three years after the conclusion of the respective procedure.

 d.Objection and rectification option 

 You can object to the processing of your personal data for the future at any time in the context of the processing of data subject´s requests. In this case, however, we will not be able to process your request any further.

 The documentation of the processing of the respective data subject´s request is mandatory by law. Consequently, you cannot object to this data processing.

 

 ii.Defending and enforcing legal claims 

 a.Legal basis 

 Legal basis for the processing of your personal data in the context of defending and enforcing legal claims is Art. 6 (1) lit. f GDPR.

 b.Purpose 

 The purpose of processing your personal data in the context of defending and enforcing legal claims is the defence of unjustified claims and the legal enforcement of claims and rights.

 c.Duration of storage 

 The data are erased as soon as they are no longer necessary to achieve the purpose for which they were collected.

 d.Objection and rectification option 

 The processing of your personal data in the context of defending and enforcing legal claims is absolutely necessary for the defence and enforcement thereof. Consequently, you cannot object to this processing.

IV.Other data processing outside the scope of our website 

 1.Call centre and service request 

 i.Legal basis 

 The legal basis for the processing of your personal data in the context of our call centre or service requests, is Art. 6 (1) lit. b GDPR or Art. 6 (1) lit. f GDPR. If you have consented to the processing of your personal data, Art. 6 (1) lit. a GDPR is the legal basis for this processing.

 ii.Purpose 

 The purpose of processing your personal data is to process your call and/or any service and repair enquiries. The processing of your personal data within the scope of your call is necessary to ensure the best possible fulfilment of our services. The processing of your personal data to contact you in the event of a repair request enables us to process your repair quickly and efficiently.

 iii.Duration of storage 

 Your personal data are erased as soon as they are no longer necessary for the purpose for which they were collected. This is given at the latest in the case of the successful processing and completion of your service or repair request and as long as no retention periods prevent erasure.

 iv.Objection and rectification option 

 The processing of your personal data is mandatory for the execution and handling of the respective service and repair request. Consequently, there is no possibility for you to object to this processing.

 If the processing of your data in the context of our call centre is based on consent, you can revoke this consent at any time for the future.

 

 2.Sale of goods and provision of services 

 i.Legal basis 

 The legal basis for the processing of your personal data in the context of the sale of goods and the provision of services is Art. 6 (1) lit. b GDPR.

 ii.Purpose 

 The purpose of the processing of your personal data in the context of the sale of goods and the provision of services is the fulfilment of a contract between you and us.

 iii.Duration of storage 

 Your personal data are erased as soon as they are no longer necessary to achieve the purpose for which they were collected. In the event that your personal data is processed in the context of the sale of goods or the provision of services, this shall be the case if the contract has been fulfilled and all claims arising from the contractual relationship have become statute-barred or there are no statutory retention periods.

 iv.Objection and rectification option 

 The processing of your personal data within the scope of the sale of goods and the provision of services is absolutely necessary for the fulfilment of the contract. Therefore, there is no possibility for you to object to this processing.

 

 3.Customer / supplier registration, business transaction and ongoing business relationship 

 i.Legal basis 

 The legal basis for the processing of your personal data as well as the personal data of the contact persons of your company within the scope of the customer / supplier registration, the business transaction and the ongoing business relationship is Art. 6 (1) lit. b GDPR or Art. 6 (1) lit. f GDPR.

 If you or the contact persons of your company have given your consent, Art. 6 (1) lit. a GDPR is an additional legal basis for the processing of your personal data as well as the personal data of the contact persons of your company.

 ii.Purpose 

 The purpose of processing your personal data as well as the personal data of the contact persons of your company within the framework of the customer and supplier registration, the conclusion of the business transaction and the ongoing business relationship is the establishment, execution and termination of the respective order as well as the consideration of your company for future contract awards or tenders.

 iii.Source 

 If we have not received your personal data directly from you, the contact person of your company has provided your personal data to us in the context of the customer / supplier registration.

 iv.Duration of storage 

 Your personal data as well as the personal data of the contact persons of your company are erased as soon as they are no longer necessary to achieve the purpose for which they were collected.

 In the case of customer / supplier registration, business transactions and ongoing business relationships, this is given when the contract, on which the order or offer is based, has been fulfilled and all claims arising from the contractual relationship have become statute-barred or there are no longer any statutory retention periods.

 In the case of consideration of your company for future contract awards or tenders, this is given when your company is no longer interested in being considered for future contract awards or tenders.

 v.Objection and rectification option 

 The processing of your personal data as well as the personal data of the contact persons of your company is absolutely necessary for the establishment, execution and termination of the respective contract, order or offer. Therefore, there is no possibility for you or for the contact person of your company to object to this processing.

 Should you or the contact persons of your company have given your consent to the processing of your personal data, this consent may be revoked at any time for the future. You or the contact persons of your company can also object to the processing of your personal data for the future in the context of the consideration of your company for future orders or offers.

V.Categories of recipients 

 Within our company, the offices and departments that receive personal data are those that need them to fulfil the aforementioned purposes. In some cases we work together with different service providers and therefore transfer your personal data to other trusted recipients. These can include:

• HR department
• Possible superiors of the applicant concerned
• Specialist departments
• Financial accounting
• Controlling / auditing
• Data protection officer
• Banks
• Credit agencies such as SCHUFA
• Scanning service
• Print shops
• Letter shops
• IT service provider
• Logistics partners
• Service providers
• Repair service provider
• Insurance
• Lawyers and courts
• Affiliated companies

VI.Data transfers to third countries 

 As part of the processing of your personal data, we may transfer your personal data to trustworthy service providers or affiliated companies in third countries. Third countries are countries outside of the European Union (EU) or the European Economic Area (EEA).

 We only work with service providers who provide us with the appropriate safeguards for the security of your personal data and can guarantee that your personal data will be processed strictly in accordance with the European data protection standards. A copy of these appropriate safeguards can be examined at our premises.

 If we transfer personal data to third countries, we do so on the basis of a so-called “adequacy decision” of the European Commission or, in the absence of such a decision, on the basis of so-called “standard data protection clauses”, which have also been adopted by the European Commission.

VII.Your rights 

 You have the following rights against us:

 1.Right of access 

 You have the right to access as to whether or not and, if so, what your personal data of you are being processed by us. Is this the case, we will additionally give you access to the following:

 (1)the purposes of the processing;
 (2)the categories of personal data concerned;
 (3)the recipients or categories of recipients of your personal data;
 (4)the envisaged period of storage or the criteria used to determine the envisaged period of storage;
 (5)any other rights you have;
 (6)where we have not obtained the personal data from you: any available information as to their source;
 (7)if available: the existence of automated decision-making and any information about the logic involved, as well as the significance and the envisaged consequences of the processing.

 2.Right to rectification 

 You have the right to rectification and/or completion of the personal data that is being processed by us, if it is inaccurate or incomplete.

 3.Right to restriction of processing 

 You have the right to restriction of processing of your personal data, provided that

 (1)we verify the accuracy of your personal data being processed by us;
 (2)the processing of your personal data is unlawful;
 (3)you need the personal data being processed by us for the purpose of prosecution when we no longer need your personal data for the purpose of processing;
 (4)you have objected to the processing of your personal data and we are in the process of verifying your objection.

 4.Right to erasure 

 You have the right to erasure of your personal data, provided that

 (1)we no longer need your personal data for its original purpose;
 (2)you withdraw your consent and there is no other legal ground for processing your personal data;
 (3)you object to the processing of your personal data and, unless it is about direct marketing, there are no overriding grounds for further processing;
 (4)the processing of your personal data is unlawful;
 (5)the erasure of your personal data is required by law;
 (6)your personal data have been collected in relation to the offer of information society services when you were a minor.

 5.Right to notification 

 If you have asserted your right to rectification, erasure of data or restriction of processing, we will communicate any rectification, erasure of data or restriction of processing to any recipients of your personal data.

 6.Right to data portability 

 You have the right to receive your personal data processed by us on the basis of your consent or for the performance of a contract in a structured, commonly used and machine-readable format as well as to transmit them to another controller. If it is technically feasible, you have the right to have them directly transmitted from us to another controller.

 7.Right to object 

 You have the right to object to the processing of your personal data on particular grounds. If this is the case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing.

 If your personal data is being processed for the purpose of direct marketing, you have the right to object at any time.

 8.Right to withdraw 

 You have the right to withdraw your consent given to us at any time. The withdrawal of the consent does not affect the lawfulness of the processing carried out based on the consent before your withdrawal.

 9.Right to lodge a complaint with a supervisory authority 

 Regardless of any other administrative or judicial remedy, you have the right to lodge a complaint with the competent supervisory authority, if you believe that the processing of your personal data by us violates the provisions of the GDPR.

 The competent supervisory authority for us is:

 Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
 Promenade 27
 91522 Ansbach, Germany

VIII.Overview of the cookies used in our website 

 For the operation of this website we use different cookies, as described above. The following table lists the cookies that are used on this website.

 1.Technically necessary cookies 

If you have any questions, please do not hesitate to contact our data protection officer at any time.