We take the protection of your data very seriously and are entirely committed to recording and storing as little of it as possible. What we do collect is used to constantly improve the running of the website. It is possible to use the site without supplying personal data, and not all information collected is personally identifiable – unless you give us your name, either in an email, on one of our forms or when you order something from us.
## When you use one of the services offered on our website or ## make a purchase, we collect and store personal information, so for example your name, your address, your email address or your telephone number. We will only collect and store your data in this way if you have either given us your express permission to do so or in accordance with applicable law and on the basis of the new EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act.
We provide information here on when and why we collect your personal information, precisely what we collect, how we use it and how we keep it secure. We also provide you with information on your rights with respect to this data.
On this site we use SSL data encryption. This helps to keep private information private, for example when you contact us in any way. You can tell that the web connection is secure when the web address in the address bar of your browser begins with “https://” (the extra ‘s’ stands for security) and the bar displays a green padlock symbol.
1. Regulatory Compliance Contact Details
Data controller for our website as defined by the General Data Protection Regulation and other applicable data protection laws is:
International Tube Association e.V.
Heinz-Ingestau-Straße 9, 40474 Duesseldorf, Germany
+49 211 947 5650 / email@example.com / www.itatube.org
2. Terms and Definitions
- “Personal data” – any information related to a natural person or ‘data subject’ that can be used to directly or indirectly identify the person;
- “Data subject” – an identified or identifiable natural person whose personal data is processed; a natural person is seen as identifiable, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person;
- “Processing” – any operation or series of operations performed on personal data, whether or not by automated means, including collection, recording, evaluation, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- “Restriction of Processing” – marking of stored personal data in order to restrict its processing in the future;
- “Profiling” – any automated processing that uses personal data to evaluate personal aspects and predict future actions and aspects of a natural person, in particular with reference to employment, economic situation, health, personal preferences, interests, reliability, behaviour, whereabouts or change of location; ## as an organisation committed to protection of your data we undertake to refrain from any form of profiling;
- “Pseudonymisation” – processing of personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
- “Filing system” – any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
- “Controller” – the natural or legal person, public authority, agency or any 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 processing are determined by EU or Member State laws, the controller (or the criteria for nominating the controller) may be designated by those laws;
- “Processor” – a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
- “Recipient” – a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, 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; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
- “Third party” – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
- “Consent” of the data subject – any freely given, specific, informed and unambiguous indication of his or her wishes by which the data subject, either by a statement or by a clear affirmative action, signifies agreement to personal data relating to them being processed;
- “Personal data breach” – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
- “Cross-border processing” – processing of personal data when the controller or processor is established in more than one Member State, and the data processing takes place in more than one Member State, OR processing activities that take place in a single establishment in the Union, but that affect data subjects from more than one Member State;
- “Relevant and reasoned objection” – an objection to a draft decision as to whether there exists an infringement of the Regulation or not, or whether envisaged action in relation to the controller or processor complies with the Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union.
3. Legal basis for the processing of data
When we hold and process your personal data, we do so based on the terms of the new EU General Data Protection Regulation (GDPR), “Lawfulness of processing”, and the German Federal Data Protection Act, as follows:
- Processing requiring consent for one or more specific purposes is done on the basis of Article 6 (1), point (a) of the GDPR.
- Processing necessary for the performance of a contract to which the data subject is party (e.g. delivery of an order or delivery or receipt of other service) or in order to take steps at the request of the data subject prior to entering into a contract (e.g. responding to inquiries about our services or products) is done on the basis of Article 6 (1), point (b) of the GDPR.
- Where processing is necessary for compliance with a legal obligation to which the controller is subject, e.g. compliance with tax laws or statutory storage obligations, this is done on the basis of Article 6 (1), point (c) of the GDPR.
- If processing were deemed necessary in order to protect the vital interests of the data subject or of another natural person, it would be done on the basis of Article 6 (1), point (d) of the GDPR.
- Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party – except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data – it is done on the basis of Article 6 (1), point (f) of the GDPR. A legitimate interest pursued by us would be the conduct of our business for the support and in the interests of our employees and shareholders.
We may need your personal data for compliance reasons (i.e. to comply with legal processes such as those prescribed by tax or commercial law) or for entering into or performance of a contract. If we’re not supplied with this data (e.g. name, address or other personal details of a contract partner), we will be unable to enter into a contract.
4. Log files
Our Internet server, in common with most others, automatically creates log files to record certain details of your activity on our website, such as
- the IP address of the connection you used to go online and your ISP (Internet Service Provider),
- a time and date stamp for your visit to our website,
- the URL of the web pages you visit,
- any data that you have requested while visiting our website,
- general information about the web browser you used (particularly the browser type and version) and your operating system, and occasionally
- wtheebsite you used to access our website (known as the “referrer”).
We use this data in the following ways:
- to connect you to the required webpage,
- for statistical purposes,
- to continue to grow and develop our Internet services ## and to improve the relevance of any advertising we display,
- to safeguard the functionality and integrity of our network and information systems and to help defend against attacks on our information systems, and
- to provide law enforcement agencies with the necessary data and details in the event of an attack on our information systems.
Log files do not contain any personal information: We collect this data anonymously and store it separately from all personal data made available to us by data subjects. ## IP addresses are stored in an abbreviated and thus anonymous form, dropping the last octet.
5. Cookies and user profiles
In accordance with legal provisions and to the extent that you haven’t made use of your legal right to object to the processing of your personal data in this way, we can use and evaluate pseudonymised user profiles
- to provide user-friendly services that require cookies
- for advertising and marketing purposes, and
- to offer improved and more relevant services.
Some of our services require that we use so-called cookies.
A cookie is a small piece of data sent from a website and stored in your web browser on your computer or other device. Cookies enable us to collect information from your visit to our website that help us to identify your browser and differentiate it from the browsers of other data subjects.
Most browsers are automatically configured to accept cookies. However, you can modify your browser at any time so that it disables cookies or requests permission before accepting them. Please note that if you simply disable all of our cookies or cookies in general in your browser settings, you may find that certain sections or features of our website will not work, because your browser may prevent us from setting functionally required cookies.
- web traffic analytics, and
- visitor tracking via ad networks.
6a. Web traffic analytics (version for Piwik)
The web traffic analysis also puts together geographical user profiles via the IP addresses of visitors to our website. ## The IP addresses are abbreviated before they are stored by deleting the last octet, so that a regional categorization (also known as ‘IP geolocation’) but no actual identification of the individual user is possible.
6b. Web traffic analytics (version for Google Analytics)
This website uses Google Analytics for the statistical analysis of visitor activity. This is a web analytics service offered by Google Inc., which means that they are active on our behalf as a processor. Google Inc. conduct their data tracking and processing activities using their own servers, which tend to be USA-based rather than in the European Union. Data collected from visitors to our website is used to create pseudonymous user profiles.
We use “Google Analytics” with their IP anonymization feature turned on. This masks the IP address of our users by removing the last octet before storage or processing begins. The abbreviation of the IP address is done in this case not by us, but by Google Inc.
Important note: You can manage the setting of cookies in general, or prevent it altogether, by adjusting the settings directly on your browser. Alternatively, you can prevent the data collected by cookies from being used or processed by Google if you download and install their opt-out browser add-on here: http://tools.google.com/dlpage/gaoptout?hl=en-GB
You can read the “Google Analytics” data privacy and security information provided by Google Inc. here: https://support.google.com/analytics/answer/6004245?hl=en
7. Using email and contact forms
Whenever you send us an email or fill in a contact form, you voluntarily provide us with personal information which is recorded and used by us for the purpose of getting in touch or fulfilling other services that you may have requested. This information can include your name, address or email address, your telephone number and any other data you may have provided.
In addition, whenever you use a form provided on our website to get in touch, the IP address you used will also be recorded.
We make a point of ensuring that all personal data collected in this way is used solely for the purpose of responding to queries or delivering services. We will never share this data with others unless we are legally obliged to do so.
8. Using our social media links
Whenever you use the links provided by our website to let you interact with our social media pages (such as Twitter, Facebook or Google+), these networks collect data, over the recording, processing, sharing or other use of which we have no control. You can avoid this by not using these links when you visit our website.
The data collection functions specific to these social media networks are only activated when you hit the button or icon that represents the link on our web pages. Our website has these functions deactivated by default.
9. Using our newsletter sign-up
If you have signed up to receive our regular newsletter, you will have filled in a form which provides us with certain personal information, in particular your email address.
For legal reasons our newsletter subscription procedure makes use of the best-practice ‘double-opt in’ process which sends an automatically generated verification email to the email address you have provided in the sign-up process. This allows us to confirm that the owner of said email address is in actual fact the person who wants to subscribe to our newsletter.
We will only use the personal data collected as part of the subscription process
- to send you the newsletter, or
- to email you with information or queries that are necessary or required for the proper implementation or improvement of our newsletter service.
You can cancel your newsletter subscription or withdraw your agreement to the retention of your personal data – also known as ‘the right to be forgotten’ – at any time by clicking on the link provided in every newsletter or by sending a request directly to the data controller for the website. In the event of either a cancellation or a withdrawal of your consent and barring any other legal obligation, we will erase the personal data in question and stop sending you the newsletter.
As well as the data provided on the subscription form, we also record the date and time of your sign-up as well as the IP address you used. This is done both for our own legal protection as well as to secure our technical systems against misuse.
## Our newsletters contain tracking pixels, also known as pixel tags or web beacons; these are tiny graphics embedded in the email and their activation is logged when the email is opened so that we can track if and when a newsletter is accessed. They also allow us to track the use of any links that the newsletter might contain. We record and evaluate this data for the sole purpose of collating statistics on our newsletter service or enhancing and personalising it to fit the profile of the individual subscriber.
10. Retention period, deletion and blocking of personal data
Your personal data will only be retained for as long as is necessary to fulfil the purpose for which it was collected, or for as long as we are legally obliged to do so.
We will routinely block or delete any personal data we hold – without the need for an actual request on your part – as soon as it is no longer required to fulfil a purpose or contract or as soon as the legal retention period has come to an end, in compliance with legal requirements.
11. Your rights as data subject
The following describes the rights that you (the data subject) have with regard to your personal data and that we (the data controller) must comply with. Should you wish at any time to request compliance with any of these rights, you can contact us; we recommend you do this in writing or by emailing us at firstname.lastname@example.org .
12. The right of confirmation,
i.e. the right to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed.
- The right of access,
i.e. where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data is not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. ## (NB: We do not use profiling, nor any other method of automated decision-making.)
- Where personal data is transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
- The right to provision of a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others.
13. The right to rectification,
i.e. the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
14. The right to erasure (‘right to be forgotten’),
i.e. the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, whereby the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- the data subject withdraws consent on which the processing is based according to point (a) of Article 6 (1), or point (a) of Article 9 (2) of the GDPR, and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant to Article 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2);
- the personal data has been unlawfully processed;
- the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data has been collected in relation to the offer of information society services referred to in Article 8 (1) of the GDPR.
Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller shall take reasonable steps, taking account of available technology and the cost of implementation, and including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
This shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9 (2) as well as Article 9 (3) of the GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) of the GDPR, in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims.
15. The right to restriction of processing,
i.e. the right to obtain from the controller restriction of processing where one of the following applies:
- accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead;
- the controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pursuant to Article 21 (1) of the GDPR, pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. A data subject who has obtained restriction of processing shall be informed by the controller before the restriction of processing is lifted.
16. The right to data portability,
i.e. the right of the data subject to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided, where:
- the processing is based on consent pursuant to point (a) of Article 6 (1) or point (a) of Article 9 (2) or on a contract pursuant to point (b) of Article 6 (1) of the GDPR; and
- the processing is carried out by automated means.
In exercising his or her right to data portability, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. This right shall not adversely affect the rights and freedoms of others.
The exercise of the right to data portability shall be without prejudice to the right to erasure (‘right to be forgotten’). That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
17. The right to object,
i.e. the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6 (1) of the GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where personal data is processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1) of the GDPR, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects him or her.
This shall not apply if the decision:
- is necessary for entering into, or performance of, a contract between the data subject and a data controller;
- is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
- is based on the data subject’s explicit consent.
In the cases referred to in points (a) and (c) above, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
Decisions referred to in points (a), (b) and (c) above shall not be based on special categories of personal data – referred to in Article 9(1) of the GDPR – unless the data subject has given explicit consent to the processing of the personal data for one or more specified purposes, or processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.