Privacy Policy

Last updated: [Date]
Version: 1.0

1. Controller

The controller responsible for the processing of personal data on this website is:

[Company name]
[Street address]
[Postal code, City]
[Country]

Phone: [+XX XXX XXX XXXX]
E-mail: [privacy@example.com]
Commercial register: [HRB XXXXXX, Court]
VAT ID: [DE XXXXXXXXX]
Represented by: [Name of managing director]

2. Data Protection Officer

Our Data Protection Officer can be contacted at:

[Name]
E-mail: [dpo@example.com]
Address: [as above, Attn: Data Protection Officer]

3. General information

This privacy policy informs you about the nature, scope and purpose of the processing of personal data within our online offering. We process your personal data in accordance with the applicable data protection regulations, in particular the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG), as well as the German Telecommunications Digital Services Data Protection Act (TDDDG).

4. Your rights as a data subject

You have the following rights with respect to your personal data:

Right of access (Art. 15 GDPR): You may request information about whether and what personal data we process about you.
Right to rectification (Art. 16 GDPR): You may request the correction of inaccurate data.
Right to erasure (Art. 17 GDPR): You may request the deletion of your data, subject to legal retention obligations.
Right to restriction of processing (Art. 18 GDPR): You may request that we restrict the processing of your data.
Right to data portability (Art. 20 GDPR): You may receive your data in a structured, commonly used and machine-readable format.
Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests at any time.
Right to withdraw consent (Art. 7(3) GDPR): Where processing is based on consent, you may withdraw it at any time with effect for the future.
Right to lodge a complaint (Art. 77 GDPR): You may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

The competent supervisory authority for us is:

[Name of the competent data protection authority]
[Street address, e.g. Kavalleriestraße 2-4, 40213 Düsseldorf]
E-mail: [poststelle@example.de]
Website: [https://www.example-dpa.de]

5. Access data and server log files

When you access this website, our server automatically collects information in so-called server log files, which your browser transmits to us. This includes:

IP address of the requesting computer
Date and time of the request
Name and URL of the retrieved file
Referrer URL
Browser used and, if applicable, the operating system of your computer
Name of your access provider

Legal basis: Art. 6(1)(f) GDPR (legitimate interest).
Purpose: Ensuring the technical security and stability of our website.
Storage period: 7 days; after this period, the data is either deleted or anonymised.

6. Cookies and similar technologies

We use cookies on our website. Cookies are small text files that are stored on your device and help us make our website function properly and, with your consent, provide additional services.

6.1 Strictly necessary cookies

These cookies are essential for the operation of the website and cannot be deactivated. They are usually only set in response to actions made by you that amount to a request for services, such as setting your language preferences, signing in or filling in forms.

Name	Purpose	Retention
`CLAIM_SESSION`	Session management	Session (until browser closed)
`CLAIM_lang`	Stores your language preference	12 months
`CLAIM_consent`	Stores your cookie consent decision	6 months

Legal basis: Art. 6(1)(f) GDPR, § 25(2) No. 2 TDDDG (strictly necessary for the provision of the service expressly requested by the user).

6.2 Consent-based services: Google reCAPTCHA

To protect our forms from automated abuse (spam, bot submissions), we use the "reCAPTCHA" service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

When enabled, reCAPTCHA analyses various information (e.g. IP address, length of stay on the website, mouse movements, device and browser information) to determine whether the entries are made by a human or by an automated program. This service is loaded only after you have given your explicit consent via our cookie banner.

In the course of this processing, personal data may be transferred to Google LLC in the United States. Google is certified under the EU-U.S. Data Privacy Framework, which the European Commission has recognised as providing an adequate level of data protection (Commission Implementing Decision of 10 July 2023).

Cookies set by reCAPTCHA:

Name	Purpose	Retention
`_GRECAPTCHA`	Bot detection by Google	6 months
Additional Google cookies	See Google's privacy policy	Varies

Legal basis: Art. 6(1)(a) GDPR (consent), § 25(1) TDDDG.
Purpose: Protection against automated submissions (spam, bots).
Recipient: Google Ireland Limited (EU); onward transfer to Google LLC (USA).
Retention: See table above; subject to Google's own retention policy.

You can withdraw your consent at any time via the "Cookie Settings" link in the footer of this website. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

For more information on Google's data processing, please see: https://policies.google.com/privacy

7. Claim submission form

When you submit a claim through our online form, we process the following personal data:

Name
E-mail address
Phone number
Partner code and delivery note number
Description of the claim
Optional: uploaded images related to the claim

Legal basis: Art. 6(1)(b) GDPR (performance of a contract or pre-contractual measures).
Purpose: Processing and handling of your claim, contacting you regarding its status, quality assurance, and legal documentation.
Recipients: Authorised employees of our company, and where applicable, our logistics partners or legal advisers if necessary for the handling of the claim.
Retention: Claims data is retained for [X years] after the closure of the claim, in line with statutory retention obligations (e.g. §§ 147 AO, 257 HGB in Germany).

Provision of this data is not legally required but is necessary for us to process your claim. Without this data, we are unable to handle your request.

8. Claim status check

When you check the status of an existing claim, we process the identifiers you provide (e.g. claim number) solely to retrieve and display the status of your claim.

Legal basis: Art. 6(1)(b) GDPR.
Purpose: Providing status information on your claim.
Retention: No separate retention; data is processed only for the duration of your session.

9. Data security

We use appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

Communication between your browser and our server is encrypted using TLS (HTTPS).

10. Changes to this privacy policy

We reserve the right to modify this privacy policy to ensure that it always complies with current legal requirements or to reflect changes to our services. The new privacy policy will then apply to your next visit.

11. Contact for data protection inquiries

If you have any questions about the processing of your personal data, you can contact us directly at the contact details provided in Section 1 or our Data Protection Officer (Section 2).