Modified 19 February 2021
We appreciate your interest in our websites. The protection of your privacy is very important to us. Below we inform you in detail about the handling of your data.
Our privacy obligations
We will review this policy regularly, and we may update it from time to time.
The types of personal information we collect and hold
We collect personal information about our users to provide our products, services and customer service. Our products, services and customer support are provided through many platforms, including, among others, websites, phone applications, email and telephone. The specific platform and the product, service or support with which you interact may affect the personal data we collect.
How we collect personal information
Information that you specifically give us
While you use our products and services, you may be required to provide certain types of personal information. This can happen through our websites, our applications, our online chat systems, our phone, paper forms or face-to-face meetings.
We may request, collect, or process the following information:
- Account Details – username, password
- Contact Details – email address, phone number, website url
- Location Details – physical address, billing address
- Identity Details – full name, business name
- Content Data – text input, photographs, videos
- Financial Information – credit card details, wire transfer details, payment processor details, tax numbers.
- User Generated Content – barcode numbers, ISBN numbers, ISSN numbers, product names and descriptions, other product information, attachments, user profiles, user reviews, user messages etc.
Information we collect as you use our service
We keep records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform, such as when a user has viewed a page or clicked a button.
When you contact us, we may collect personal information that is intrinsic to the communication. For example, if we are contacted by you by email, we will collect the email address used.
We may collect or process the following information::
- Metadata – IP address, computer and connection information, referring web page, standard web log information, language settings, timezone, etc.
- Device Information – device identifier, device type, device plugins, hardware capabilities, etc.
- Actions – pages viewed, buttons clicked, time spent viewing, search keywords, etc.
- Usage Data – websites visited, interest in content, access times
Processes: Intended to make our websites and services work in the way you expect.
Authentication, Security, and Compliance: Intended to prevent fraud, protect your data from all unauthorized parties, and comply with legal requirements.
Preferences: Intended to help remember information about how you prefer the websites to behave and look...
Notifications: Intended to allow or prevent notices of information or options that we think could improve your use of our websites. For example, we might use a Cookie that stops us from showing you the email signup notification if you have already seen it.
Analytics: Intended to help us understand how visitors use our websites. For example, we might use a Cookie that tells us how our search suggestions correlate to your interactions with the search pages.
You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of our websites. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. Please note that changing any of these settings does not prevent the display of certain advertisements to you.
Links to other sites
How we use personal information
The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:
- to provide our services or product you have requested;
- to provide technical or other support to you;
- to answer enquiries about our services, or to respond to a complaint;
- to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications);
- to allow for debugging, testing and otherwise operate our platforms;
- to conduct data analysis, research and otherwise build and improve our platforms;
- to comply with legal and regulatory obligations;
- if otherwise permitted or required by law; or
- for other purposes with your consent, unless you withdraw your consent for these purposes.
The ‘lawful processing’ grounds on which we will use personal information about our users are (but are not limited to):
- when a user has given consent;
- when necessary for the performance of a contract to which the user is party;
- processing is necessary for compliance with our legal obligations;
- processing is necessary in order to protect the vital interests of our users or of another natural person.
- processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.
When we disclose personal information
Our third party service providers
The personal information of users may be held or processed on our behalf, including ‘in the cloud’, by our third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
Our third party service providers include:
- Cloud hosting, storage, networking and related providers
- Email messaging providers
- Payment and banking providers
- Marketing and analytics providers
- Security providers
Third party applications
Other disclosures and transfers
We may also disclose your personal information to third parties for the following purposes:
- if necessary to provide our services or product you have requested;
- we receive court orders, subpoenas or other requests for information by law enforcement;
- if otherwise permitted or required by law; or
- for other purposes with your consent.
As we are a global organisation, with offices around the world, your personal information may be processed by staff in any of our offices.
Accessing, correcting, or downloading your personal information
You have the right to request access to the personal information UPC Warehouse holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer.
You also have the right to request the correction of the personal information we hold about you. If you require assistance please contact our customer support.
Exercising your other rights
You have a number of other rights in relation to the personal data UPC Warehouse holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, and provide protection for the legitimate users of our marketplace – these data uses are protected against the below rights.
You have the right to:
- opt-out of direct marketing, and profiling for marketing
- temporary restriction of processing.
Erasure – Some personal information and user generated content cannot be deleted as they are used to record contracts, document financial transactions, and are used in providing important product information for the retail marketplace. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymised from the personal data.
Temporary restriction to processing – under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our privacy officer.
Unless stated elsewhere, users may exercise any of the above rights by contacting our Privacy Officer.
We use various safeguards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
To contact our Privacy Officer
If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:
For the purposes of the GDPR, our Privacy Officer is also our Data Protection Officer (DPO).
While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days of receipt.
Relevant Legal Basis for Data Collection in the EU
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.
We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 DSGVO).
Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (eg if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to a legal obligation or based on our legitimate interests (eg the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR
Transfers to third countries
If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”.
Rights of data subjects
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR. You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you. In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR. You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible. You have gem. Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
Deletion of data
Order processing in the online shop and customer account
We process the data of our customers as part of the ordering process in our online shop to allow them to select and order the selected products and services, as well as their payment and delivery, or execution.
The processed data includes inventory data, communication data, contract data, payment data and persons affected by the processing belong to our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery and customer service. Here we use session cookies for the storage of the shopping cart contents and permanent cookies for the storage of the login status.
Processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The information marked as required for the establishment and fulfillment of the contract is required. We disclose the data to third parties only in the context of extradition, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if necessary for the fulfillment of the contract (for example, on customer’s request upon delivery or payment).
On some websites, users can optionally create a user account, in particular by being able to view their orders. As part of the registration, the necessary mandatory information will be communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. Information in the customer account remains until its deletion with subsequent archiving in case of a legal obligation. It is the responsibility of the users to secure their data upon termination before the end of the contract.
As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO.
The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation).
External payment service providers
We use external payment service providers, through whose platforms the users and we can make payment transactions. These providers have their own privacy policies that apply to the data they collect.
As part of the fulfillment of contracts, we set the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Incidentally, we use external payment service providers on the basis of our legitimate interests. Art. 6 para. 1 lit. b. DSGVO in order to offer our users effective and secure payment options.
For the payment transactions, the terms and conditions and the privacy notices of the respective payment service providers, which are available within the respective websites, or transaction applications apply. We also refer to these for further information and assertion of rights of withdrawal, information and other data subjects.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers. Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this majority of company-related data permanently.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us.
Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.
Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.
The dispatch of the newsletter and the associated performance measurement are based on a consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 DSGVO i.V.m § 7 Abs. 2 No. 3 UWG or if consent is not required, based on our legitimate interests in the direct marketing acc. Art. 6 para. 1 lt. F. DSGVO i.V.m. § 7 Abs. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent.
Termination / Revocation – You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Google Tag Manager
Google Tag Manager is a solution that allows us to manage so-called web site tags through one interface (including, for example, Google Analytics and other Google marketing services in our online offering). The tag manager itself (which implements the tags) does not process users’ personal data. With regard to the processing of users’ personal data, reference is made to the following information about Google’s services. Usage Policy: https://www.google.com/analytics/tag-manager/use-policy/
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout
The personal data of users will be deleted or anonymized after 26 months.
Google Universal Analytics
We use Google Analytics in the design as “Universal Analytics”. “Universal Analytics” means a process of Google Analytics, in which the user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”) ,
Targeting with Google Analytics
We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services, only those users who have shown an interest in our online offering or who have certain characteristics (eg interests in specific topics or products visited by them) that we submit to Google (so-called “remarketing” or “Google Analytics audiences”). With Remarketing Audiences, we also want to make sure that our ads meet the potential interest of users.