Primo Holding GmbH (hereinafter referred to as "Primo" or "we"), as operator of the website primo-group.de (hereinafter also referred to as "our website"), is pleased that you have visited our website. Below we inform you about the processing of personal data when using our website.
I. Definitions
Our privacy policy uses terms defined in the EU General Data Protection Regulation (GDPR). In order to make the data protection declaration readable and understandable, we have explained these terms below:
(1) Personal data:
According to the GDPR, personal data is any information relating to an identified or identifiable natural person. This means information such as your name, date of birth, address, email address, IP address or telephone number, as well as your user behaviour. In contrast, information that is not directly associated with your real identity - such as generally preferred websites by all users or the number of users of a site - is not referred to as personal data.
(2) Person affected
A person affected is any identified or identifiable natural person whose personal data are processed by the controller.
(3) Processing
Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
(4) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
(5) Controller or person responsible for processing
The controller or person responsible for 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 Union Member State law, the controller or the specific criteria for its designation may be provided for under Union or Union Member State law.
(6) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
(7) Recipient
A recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Union Member State law shall not be considered as recipients.
(8) Third party
A third party is a natural or legal person, public authority, agency or other body other than the person affected, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.
(9) Consent
Consent shall mean any freely given specific and informed indication of the data subject's wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.
II. Data controller and data protection officer
(1) The responsible person [Art. 4 No. 7 GDPR].
The responsible person within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection provisions is:
PRIMO Holding GmbH
Urbanstr. 4
D-70839 Gerlingen
Tel.: +49 7156 602 50 40
E-Mail: info@primo-group.de
Web: https://primo-group.de/en
hereinafter referred to as "the responsible person" or "we" or "us".
III. Principles for the processing of personal data
(1) Scope of the processing of personal data
As a matter of principle, we collect and use personal data of our users only insofar as this is necessary for the provision of a functional website as well as our contents and services. The collection and use of your personal data is generally only carried out with your consent. However, an exception applies in cases where it is not possible to obtain prior consent for actual reasons and the processing of the data is nevertheless permitted by legal regulations.
(2) Legal basis for the processing of personal data
The data transmitted or collected by you will be collected, used, processed, stored and, if necessary - if required by law or contractually necessary - forwarded to third parties exclusively within the framework of the applicable data protection laws (GDPR, Federal Data Protection Act and Telemedia Act).
Various legal grounds for the processing of your personal data arise from Art. 6 GDPR, to which reference is made in each case in this data protection declaration:
1. Article 6 (1)(a) GDPR ist Rechtsgrundlage für Verarbeitungsvorgänge personenbezogener Daten, wenn eine Einwilligung der betroffenen Personen vorliegt.
2. Article 6(1)(b) GDPR is the legal basis for the processing of personal data that is necessary for the performance of a contract to which the data subject is a party. This legal basis also refers to those processing operations which are necessary for the performance of pre-contractual measures.
3. if we have to process personal data in order to comply with a legal obligation of our company, the legal basis for this is Art. 6 (1) c) GDPR.
4. Article 6(1)(d) GDPR serves as the legal basis if the vital interests of the data subject or another natural person require the processing of their personal data.
5. if the processing of personal data is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override this first interest of our company or the interest of a third party, this processing is carried out on the legal basis of Art. 6 (1) f) GDPR.
(3) Deletion of data and storage period
As soon as the purpose of storing the respective personal data of the person affected ceases to apply, it will be deleted or blocked. However, storage may take place beyond this point in time if a legal basis has been provided for this in European or national regulations, laws or other provisions to which we are subject as the data controller. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a necessity for the continued storage of such data for the conclusion or performance of a contract.
IV. General data processing in connection with the provision of our website and creation of log files
The scope and type of collection and use of your data differs depending on whether you visit our website only to retrieve information or make use of our offers or the option of e-mail contact in the contact form (see V below):
(1) Visiting our website
For the purely informational use of our website, it is generally not necessary for you to provide us with personal data. Rather, during your visit to our website, we automatically collect, use and store information in the server log files that is transmitted to us by the respective browser used.
(2) Collected - not necessarily personal - data
The following data is collected:
1. information about your browser: Type, language and the version you are using (e.g. Mozilla Firefox, Microsoft Internet Explorer, Apple Safari, Google Chrome).
2. the operating system you use
3. the Internet service provider you use
4. your IP address
5. date and time of your access
6. websites from which your system accesses our website
7. websites that are accessed by your system via our website
8. time zone difference to Greenwich Mean Time (GMT)
9. content of the request (specific page)
10. access status/http status code
11. amount of data transferred in each case
The data is stored in the log files of our system. This data is not stored together with other personal data of the user such as your name, address, telephone number or e-mail address.
(3) Legal basis
The legal basis for this temporary storage of the data and the log files is Art. 6 (1) f) GDPR (cf. above III. (2) 5.), as our legitimate interests in this storage as set out below outweigh your interests, fundamental rights and freedoms: The IP address is considered a personal data. The temporary storage of the IP address by the system is necessary to enable the transmission of our website to your browser. For this purpose, the IP address must remain stored for the duration of the session. The storage in log files is done to ensure the functionality of our website. In addition, we use the data to optimise our website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
(4) Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of our website, this is the case when the respective session has ended. If the data was stored in log files, this is the case after 14 days at the latest. However, storage beyond this period is also possible. In this case, however, your IP address will be deleted or alienated, so that an assignment to your person is no longer possible.
(5) Possibility of objection and removal
The collection of data for the provision of our website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for you to object in this respect.
V. Contact form and e-mail contact
If you use our offers on the website via the contact form or the e-mail contact to communicate with us, this requires the provision of your personal data:
(1) Description and scope of data processing
Contact forms are available on our website, which can be used for electronic contact. If you use this option, the data entered in the respective contact form will be transmitted to us and stored. Except for the e-mail address, all data are voluntary. These data are:
1. your surname, first name and the name of your company
2. your e-mail address
3. your telephone number, the type of property you are interested in, how you would like to be contacted (telephone or e-mail) and your message.
At the time of sending the message, the following data will also be stored:
1. your IP address
2. date and time of registration
For the processing of the data, your consent is obtained during the sending process and reference is made to this data protection declaration.
In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the contact.
As an alternative to the contact forms, it is possible to contact us via the e-mail address provided, info(at)primo-group.de. In this case, your personal data transmitted by e-mail will be stored.
(2) Legal basis for data processing
The legal basis for the processing of data is, if and insofar as your consent is given, Art.6 (1) lit.a) GDPR (cf. above III. (2) 1.).
The legal basis for the processing of data transmitted in the course of sending an e-mail is also Art.6 para.1 lit.f) GDPR (cf. above III. (2) 5.). If the e-mail contact already aims at the conclusion of a contract, the additional legal basis for the processing is Art.6 para.1 lit.b) GDPR (cf. above III. (2) 2.)
(3) Purpose of the data processing
The processing of personal data from the contact forms or an e-mail sent to us serves us solely to process the contact. This also constitutes the necessary legitimate interest in processing the data if it is processed on the basis of Art. 6 (1) f) GDPR. The other personal data processed during the sending process serve our interest in preventing misuse of the contact forms and ensuring the security of our information technology systems.
(4) Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. This is the case for personal data from the contact forms as well as for data sent by e-mail when the respective conversation with the user has ended. The conversation is deemed to have ended when it is clear from the circumstances that the matter in question has been conclusively clarified.
The additional personal data collected during the sending process - IP address and date and time of registration - are deleted after a period of seven days at the latest.
(5) Possibility of objection and removal
You have the option to revoke your consent to the processing of personal data at any time. If you contact us by e-mail or via our contact forms, you can object to the storage of your personal data at any time. In such a case, however, the conversation cannot be continued. All personal data stored in the course of contacting us by e-mail or using the contact forms will be deleted in this case within a period of 7 days after receipt of the objection in our company.
(6) SSL encryption
To protect your transmitted data, we use SSL encryption. You can recognise such encrypted connections by the prefix "https://" in the page link in the address line of your browser. All data that you transmit to our website - for example when using our contact forms - cannot be read by third parties thanks to SSL encryption.
VI. Your rights as a person affected
If we process your personal data, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis us as the controller:
(1) Right to information
You may request confirmation from us as to whether personal data concerning you is being processed by us.
If such processing is taking place, you may further request information from us about the following:
1. the purposes for which the personal data are processed;
2. the categories of personal data which are processed;
3. the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
4. the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period;
5. the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
6. the existence of a right of appeal to a supervisory authority;
7. any available information about the origin of the data if the personal data is not collected from you as the data subject.
You have the right to request information on whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Art.46 GDPR in connection with the transfer.
(2) Right to rectification
You have a right of rectification and/or completion vis-à-vis us as data controller or, for example, Google, if the personal data we process concerning you is inaccurate or incomplete. We must carry out the rectification without delay.
(3) Right to restriction of processing
You may request the restriction of the processing of personal data relating to you under the following conditions:
(a) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
(c) we no longer need the personal data for the purposes of processing, but you need it for the assertion, exercise or defence of legal claims; or
(d) if you have objected to the processing pursuant to Art.21(1) GDPR and it is not yet clear whether the legitimate grounds asserted by us override your grounds.
If the processing of personal data relating to you has been restricted, this data may - apart from being stored - only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or a Union Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by us before the restriction is lifted.
VI. Reservation of the right to change
We reserve the right to amend this data protection declaration in order to bring it into line with the applicable provisions at any time, as well as our offers on the website.