We appreciate your interest in our company. Data protection is a very high priority for the management of Bornemann-Etiketten GmbH. It is generally possible to use the website of Bornemann-Etiketten GmbH without providing any personal data. If a data subject would like to avail of special services of our company via our website, the processing of personal data may be necessary, however. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, for example the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations that apply to Bornemann-Etiketten GmbH. By means of this data protection policy, our company would like to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Further, this data protection policy will explain to data subjects the rights available to them.
As the controller and operator of the internet site, Bornemann-Etiketten GmbH has implemented various technical and organisational measures in order to ensure the best possible protection of the personal data processed via this internet site. However, internet-based data transfer may in general be subject to security gaps, meaning that absolute protection cannot be guaranteed. For this reason, every data subject has the alternative option of transmitting their personal data to us in another way, for example by telephone.
1. Definition of terms
a) Personal data
Personal data is all information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"). A natural person is considered identifiable when he/she can be identified, directly or indirectly, in particular by means of association with an identifier such as a name, an identification number, a location, an online ID or one or more particular characteristics which are an expression of the physical, genetic, psychological, economic, cultural or social identity of this natural person.
Processing is every procedure carried out with or without the help of automated processes or every such operational sequence in connection with personal data, such as the collection, the capturing, the organisation, the allocation, the saving, the adaption or changing, the selection, the querying, the use, the disclosure through transmission, the dissemination or other form of provision, the comparison or the linking, the limitation, the deletion or the destruction of the data.
c) Limitation of processing
Limitation of processing is the marking of saved personal data with the goal of limiting its future processing.
Profiling is any type of automated processing of personal data involving the use of personal data to evaluate certain personal aspects related to a natural person, in particular to analyse or predict aspects regarding work performance, economic situation, health, personal preferences, interests, reliability, behaviour, place of residence or change of location of this natural person.
Pseudonymisation is the processing of personal data in a way which makes the association of the personal data with a specific data subject no longer possible without using additional information, as long as this additional information is stored separately and subject to technical and organisational measures that guarantee that the personal data cannot be associated with an identified or identifiable natural person.
f) Controller or controller of data processing
The controller or controller of data processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
A recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. Public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
i) Third parties
A third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Consent by the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller
Controller within the meaning of the GDPR, other data protection legislation applicable within the European Union member states and other provisions with a data protection character is:
Tel.: +49 (0)202 / 47897-0
The data subject can prevent the placing of cookies at any time by adjusting the settings of the internet browser used, thus permanently objecting to the placing of cookies. In addition, a cookie already placed can be deleted at any time via the internet browser or other software program. This is possible in all major internet browsers. If the data subject deactivates the placing of cookies in the browser used, it may be that not all functions of our website are fully useable.
If personal data is processed by individual cookies used by us, the processing takes place in accordance with Art. 6 paragraph 1f GDPR to preserve our legitimate interest in the best possible functionality of the website as well as to ensure the customer-friendly and effective design for visitors to the site.
4. Collection of general data and information
The Bornemann-Etiketten GmbH website collects a range of general data and information with every access of the website by a data subject or automated system. This general data and information is saved in the log files of the server. The information collected may include (1) the browser type and version, (2) the operating system used by the accessing system, (3) the internet site referring the accessing system to our website (so-called referrer), (4) the sub-pages accessed on our site via an accessing system, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information that serve to defend against risk in the case of attacks on our IT systems.
In using this general data and information, Bornemann-Etiketten GmbH does not make any associations with the data subject. This information is rather required to (1) properly deliver the content of our internet site, (2) optimise the content of our website as well as the advertisements for it, (3) ensure the long-term functionality of our IT systems and the technology of our internet site, and (4) to provide law enforcement with the necessary information in the event of a cyber attack for the purposes of law enforcement. This anonymously collected data and information is thus evaluated by Bornemann-Etiketten GmbH statistically and moreover for the aim of increasing data protection and data security in our company, ultimately to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files is stored separately from the personal data provided by a data subject.
Processing takes place in accordance with Art. 6 paragraph 1f GDPR on the basis of our legitimate interest in the improvement of the stability and functionality of our website. The disclosure or other use of the data does not take place. However, we reserve the right to check the log files at a later date should concrete indications point to illegal use.
5. Contact options via the website
The Bornemann-Etiketten GmbH website contains information based on the statutory regulations that enables fast electronic contact to our company as well as direct communication with us, including a general electronic post address (email address). If a data subject contacts the controller by email or via a contact form, the personal data provided by the data subject will be saved automatically. Such data as provided voluntarily by a data subject to the controller will be saved for the purposes of processing or to contact the data subject. This personal data will not be passed on to third parties.
Legal basis for the data processing is our legitimate interest in answering your enquiry in accordance with Art. 6 paragraph 1f GDPR.
6. Routine deletion and blocking of personal data
The controller processes and saves personal data of the data subject only for the period which is required for the fulfilment of the purposes of saving, or insofar as this is provided for by European regulations or legislature or by another legislator in laws or provisions to which the controller is subject.
Once the purpose of saving the data is eliminated or if a retention period set by the European regulations or legislature or another responsible legislator expires, the personal data will be blocked or deleted, routinely and in accordance with the statutory regulations.
7. Rights of the data subject
a) Right to information
Any person affected by the processing of personal data has the right granted by the European directives and regulatory bodies to receive information from the controller, free of charge, on the personal data saved about his/her person and to receive a copy of this information. In addition, the European directives and regulatory bodies have granted the data subject information to the following information:
- the purposes of the processing
- the categories of personal data processed
- the recipients or categories of recipients to whom the personal data was disclosed or will be disclosed, in particular in the case of recipients in third countries or in international organisations
- if possible, the planned duration for which the personal data will be saved or, if this is not possible, the criteria for determining this period
- the existence of a right to correct or delete the personal data pertaining to them or to limitation of processing by the controller or the right of objection to this processing
- the existence of a right to complain to the supervisory authority
- when the personal data is not collected from the data subject: all information on the origin of the data
- the existence of an automated decision-making process including profiling pursuant to Art. 22 paragraphs 1 and 4 GDPR and – at least in these cases – meaningful information on the logic involved as well as the scope and the desired effects of this sort of processing for the data subject
In addition, the data subject has a right to information as to whether or not personal data has been transmitted to a third country or an international organisation. If this is the case, the data subject also has the right to receive information on the appropriate guarantees in connection with the transmission.
If a data subject wishes to exercise this right to information, he or she can contact an employee of the controller at any time.
b) Right to correction
Any person affected by the processing of personal data has the right granted by the European directives and regulatory body to demand the rectification of any inaccurate personal data. In addition, the data subject has the right, taking the purposes of the processing into consideration, to demand the completion of any incomplete data – also by means of a supplementary declaration.
If a data subject wishes to exercise this right to correction, he or she can contact an employee of the controller at any time.
c) Right to deletion (right to be forgotten)
Any person affected by the processing of personal data has the right granted by the European directives and regulatory body to demand of the controller that the personal data pertaining to them is immediately deleted, provided that one of the following conditions applies and as long as the processing is not necessary:
- The personal data was collected or otherwise processed for such purposes as are no longer required.
- The data subject revokes his/her consent on which the processing was based pursuant to Art. 6 paragraph 1 (a) GDPR or Art. 9 paragraph 2 (a) GDPR and there are no other legal grounds for the processing.
- The data subject objects to the processing pursuant to Art. 21 paragraph 1 GDPR and there are no compelling, legitimate reasons for the processing, or the data subject objects to the processing pursuant to Art. 21 paragraph 2 GDPR.
- The personal data was processed unlawfully.
- The deletion of the personal data is required for the fulfilment of a legal obligation in accordance with EU law or the laws of the member states to which the controller is subject.
- The personal data was collected in relation to services offered by the information society in accordance with Art. 8 paragraph 1 GDPR.
If one of the above-mentioned reasons applies and a data subject wishes to request deletion of personal data saved by Bornemann-Etiketten GmbH, the data subject can contact an employee of the controller in this regard at any time. The employee of Bornemann-Etiketten GmbH will ensure that the deletion process is carried out without delay.
If the personal data have been made public by Bornemann-Etiketten GmbH and our company, as controller, is obliged to delete the personal data in accordance with Art. 17 paragraph 1 GDPR, Bornemann-Etiketten GmbH shall take reasonable measures (also technological), taking the available technology and costs of implementation into consideration, to inform other parties responsible for the processing of the personal data that the data subject has requested of these other parties and for Bornemann-Etiketten GmbH the deletion of all links to this personal data or of copies or replications of this personal data, provided the processing is not necessary. The employee of Bornemann-Etiketten GmbH will ensure that the procedures are carried out as necessary in the individual case.
d) Right to the restriction of processing
Any person affected by the processing of personal data has the right granted by the European directives and regulatory body to demand of the controller that the processing is restricted, provided that one of the following conditions applies:
- The accuracy of the personal data is contested by the data subject, and restriction is then for a period which allows the controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject rejects the deletion of the personal data and instead requires the restriction of the use of the personal data.
- The controller no longer requires the personal data for the purposes of processing but the data subject requires it for the assertion, exercise or defence of legal claims.
- The data subject has objected to the processing pursuant to Art. 21 paragraph 1 GDPR and it is not yet clear if the legitimate grounds of the controller take priority over those of the data subject.
If one of the above-mentioned reasons applies and a data subject wishes to request restriction of personal data saved by Bornemann-Etiketten GmbH, the data subject can contact an employee of the controller in this regard at any time. The employee of Bornemann-Etiketten GmbH will ensure that restriction of processing will be undertaken.
e) Right to data portability
Any person affected by the processing of personal data has the right granted by the European directives and regulatory bodies to receive the personal data pertaining to them in a structured, commonplace and machine-readable format. The data subject also has the right to transfer this data to another controller without hindrance by the controller to whom the data was transmitted, provided that the processing is based on consent pursuant to Art. 6 paragraph 1 (a) GDPR or Art. 9 para9 paragraph 2 (a) GDPR, or on a contract pursuant to Art. 6 paragraph 1 (b) GDPR and the processing is carried out by means of automated processes, provided that the processing is not required for the fulfilment of a task that lies in the public interest or in the exercise of official authority which has been transferred to the controller.
In addition, in the exercise of their right to data portability pursuant to Art. 20 paragraph 1 GDPR, the data subject must effect the right that the personal data is transferred directly from one controller to the other, provided this is technically feasible and no rights or freedoms of a third person are hereby affected.
The data subject can contact an employee of Bornemann-Etiketten GmbH at any time to exercise the right to data portability.
f) Right to objection
Any person affected by the processing of personal data has the right granted by the European directives and regulatory body to object, for reasons arising from their particular situation, to the processing (based on Art. 6 paragraph 1 (e) or (f) GDPR) of the personal data pertaining to them at any time. This also applies to profiling based on these provisions.
In the event of objection, Bornemann-Etiketten GmbH no longer processes the personal data, unless we can prove compelling, protection-worthy reasons for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves the assertion, exercise or defence of legal claims.
If Bornemann-Etiketten GmbH processes personal data in order to undertake direct marketing, the data subject always has the right to object to the processing of personal data for the purposes of this sort of advertising. The same applies to profiling, provided it is also connected to such direct marketing. If the data subject objects to Bornemann-Etiketten GmbH’s processing for the purposes of direct marketing, Bornemann-Etiketten GmbH will no longer process the personal data for these purposes.
The data subject also has the right, for reasons arising from their particular circumstances, to object to the processing of their personal data by Bornemann-Etiketten GmbH for scientific or historical research purposes or statistic purposes pursuant to Art. 89 paragraph 1 GDPR, unless such processing is required for the fulfilment of a task that lies in the public interest.
If a data subject wants to exercise this right to objection, he or she can directly contact an employee of Bornemann-Etiketten GmbH in this regard at any time. In connection with the use of services of the information society and notwithstanding Regulation 2002/58/EC, the data subject is also free to exercise their right to objection by means of automated procedure in which technical specifications are used.
g) Automated decision-making in individual cases, including profiling
Any person affected by the processing of personal data has the right granted by the European directives and regulatory body to not be subject to decision-making based exclusively on automated processing (including profiling) which has legal effects for the data subject or similarly effects him or her considerably, provided that the decision (1) is not required for the conclusion or fulfilment of a contract between the data subject and the controller, or (2) is permissible based on the regulations of the EU or its member states to which the controller is subject and these regulations contain reasonable measures for the protection of the rights and freedoms of the legitimate interests of the data subject, or (3) is undertaken with the express consent of the data subject.
If the decision is (1) required for the conclusion or fulfilment of a contract between the data subject and the controller or (2) is carried out with the express consent of the data subject, Bornemann-Etiketten GmbH shall take reasonable measures to protect the rights and freedoms as well as the legitimate interests of the data subject, to which at least the right to the intervention of a person on the part of the controller, to the presentation of one’s own standpoint and to appealing the decision belong.
If a data subject wants to exercise this right with regards to automated decision-making, he or she can contact an employee of the controller in this regard at any time.
Any person affected by the processing of personal data has the right granted by the European directives and regulatory body to revoke consent for the processing of personal data at any time.
If a data subject wants to exercise this right to revocation, he or she can contact an employee of the controller in this regard at any time.
i) Right to appeal to the supervisory authority
Any person affected by the processing of personal data has the right granted by the European directives and regulatory body in accordance with Art. 77 GDPR to appeal to the supervisory authority. In principle, you can contact the supervisory authority responsible for your usual place of residence or workplace or our registered office in this regard.
8. Data protection provisions on the use and application of Google Analytics (with anonymisation function)
Bornemann-Etiketten GmbH has integrated components of Google Analytics (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the harvesting, collection and evaluating of data on the behaviour of visitors on websites. A web analysis service also includes data about the website from which a data subject was directed to another website (so-called referred), which pages of the website were visited or how often and for how long were the pages accessed. Web analysis is primarily used for the optimisation of a website and for a cost-benefit analysis of internet advertising.
Operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The controller uses the “gat._anonymizelp” add-on for the web analysis by Google Analytics. By means of this add-on, the IP address of the data subject is truncated and anonymised by Google if the access on our website comes from a member state of the European Union or from another member state of the Agreement on the European Economic Area.
The full IP address is transferred to a Google server in the USA and truncated there only in exceptional cases. In these exceptional cases, this processing is carried out in accordance with Art. 6 paragraph 1f GDPR on the basis of our legitimate interest in the statistical analysis of user behaviour for optimisation and marketing purposes.
The purpose of the Google Analytics component is the analysis of the stream of visitors to our website. Google uses the extracted data and information, for example, to evaluate the use of our website, compile reports for us which show the activity on our website, and to provide other services associated with the use of our website.
Google Analytics places a cookie on the data subject’s IT system. What cookies are has already been explained above. By placing a cookie, Google can undertake analysis of the use of our website. Every time one of the individual pages of this website operated by Bornemann-Etiketten GmbH and on which a Google Analytics component is integrated is visited, the internet browser on the IT system of the data subject will be made automatically by the respective Google Analytics component to transmit data for the purposes of online analysis. In the context of this technical process, Google will receive information on personal data, such as the IP of the data subject, which Google uses for example to determine the origin of the visitor and clicks and subsequently to enable commission invoicing.
Personal information such as the time of the visit, the location from which the visit was made and the frequency of the visits to our website from the data subject is saved by means of cookies. This personal data, including the IP address of the internet connection used by the data subject is transferred to Google in the USA for every visit to our website. This personal data will be stored in the USA. In certain circumstances, Google will pass this personal data collected by technical means to third parties.
The data subject can prevent the placing of cookies at any time by adjusting the settings of the internet browser used, as already explained above, thus permanently objecting to the placing of cookies. Setting the internet browser in this way will also prevent a cookie from being placed by Google on the IT system of the data subject. In addition, a cookie already placed by Google Analytics can be deleted at any time via the internet browser or other software program.
Further information and the applicable data protection policy of Google can be found at https://policies.google.com/privacy and at https://www.google.com/analytics/terms/gb.html. Google Analytics is explained in more detail under this link: https://www.google.com/analytics/.
9. Tools and miscellaneous
9.1 Google Maps
On our website we use Google Maps (API) by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Maps is a web service for displaying interactive (country) maps to visualise geographic information. Our location is displayed to you and explaining directions made easier by using Google Maps.
When you use any subpage in which a maps by Google Maps is integrated, information on your use of our website (e.g. your IP address) is transferred to a Google server in the USA and stored there. This happens regardless of whether Google provides a user account through which you are logged in or if there is no user account. If you are logged into Google, your data is associated directly with your account. If you don't want association with your profile at Google, you have to log out before activation of the button. Google stores your data (even for non-logged in users) as usage profiles and evaluates them. Such an evaluation is conducted in particular in accordance with Art. 6 paragraph 1f GDPR on the basis of Google’s legitimate interest in the display of tailored advertisements, market research and/or needs-based design of its website. You are entitled to object to the formation of this user profile by addressing Google to exercise the right.
Google LLC is certified for the U.S. European Data Protection Convention "Privacy Shield" based in the United States, which guarantees compliance with the EU data protection.
Google Maps is used in the interests of the uniform and attractive appearance of our site. This constitutes a legitimate interest within the meaning of Art. 6 paragraph 1f GDPR.
9.2 Google Web Fonts
For the uniform appearance of fonts, this site uses so-called web fonts that are provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). When you access a page, your browser loads the required web fonts into your browser cache in order to display text and fonts correctly.
To this end, the browser used by you must connect to the Google servers. Through this, Google becomes aware that your IP address accessed our website. Google Web Fonts is used in the interests of the uniform and attractive appearance of our online site. This constitutes a legitimate interest within the meaning of Art. 6 paragraph 1f GDPR. If your browser does not support Web Fonts, a standard font will be used by your computer.
Google LLC is certified for the U.S. European Data Protection Convention "Privacy Shield" based in the United States, which guarantees compliance with the EU data protection.
10. Duration for which the personal data is saved
The criterion for the duration of the saving of the personal data is the respective legal retention period. After expiry of the retention period, the corresponding data will be routinely deleted, as long as it is no longer required for the fulfilment or initiation of a contract.
11. Legal or contractual requirements for the provision of personal data; necessity for conclusion of the contract; duties of the data subject to provide personal data; possible consequences of non-provision
We hereby inform you that the provision of personal data is to an extent required by law (e.g. tax regulations) or may arise out of contractual arrangements (e.g. information on the contractual partner). It may be necessary for the conclusion of a contract that a data subject provides us with personal data that must then be processed by us. The data subject is obligated, for example, to provide us with personal data when our company concludes a contract with him or her. Failure to provide the personal data means that the contract with the data subject cannot be concluded. Before the data subject provides personal data, he/she should contact one of employees. Our employee will explain to the data subject if the provision of the personal data is legally or contractually required or necessary for the conclusion of the contract, whether the obligation to provide the personal data exists, and which consequences the non-provision of the personal data could have.
12. Existence of automated decision making/profiling
As a responsible company, we do not make use of an automated decision-making process or profiling.