3. Purposes of processing data, legal bases and legitimate interests pursued by GARPA or a third party and categories of recipients
3.1. Accessing our site
When you access our website, the browser used on your device automatically sends information to the server of our website and temporarily saves it in a log file, over which we have no influence. The following information will be collected without your intervention and stored until automatically deleted:
- the IP address of the Internet-enabled device making the requesting,
- the date and time of the access,
- the name and URL of the file accessed,
- the website from which access was made (referrer URL),
- the browser you are using and, if applicable, the operating system of your Internet-capable computer as well as the name of your access provider.
The legal basis for processing the IP address is Art. 6 (1) point f) GDPR. Our legitimate interest arises from the purposes of data collection listed below. We wish to point out that we are not able to draw any direct conclusions about your identity from the data collected, nor can any be drawn through us. The IP address of your device and the other data listed above are used by us for the following purposes:
- to ensure a smooth connection setup,
- to ensure smooth use of our website, and
- to evaluate system security and stability.
The data are stored only as long as is necessary to fulfil the purpose intended for storage and are deleted afterwards automatically. We also use cookies, tracking tools, targeting methods and social media plug-ins for our website. The exact methods involved and how their data are used for this purpose are explained in more detail in section 3.4 below.
If you accept geolocalization in your browser or operating system or other settings of your device, we use this function in order to be able to offer you individual services related to your current location. We process your location data in this way exclusively for this function. The data will be deleted once the use has ended.
3.2. Conclusion, performance or termination of a contract
3.2.1. Processing data upon the conclusion of a contract
The scope of GARPA’s business is the distance selling of goods and services, retail trade within the framework of permits issued by the relevant authorities, and the serial production of goods to be offered. In this context, we process the data required for conclusion, performance or termination of a contract with you. This includes:
- Salutation, Title, First Name, Surname
- Invoice and Delivery Address
- Email Address
- Billing and Payment Information
- Date of Birth
- Telephone Number
Art. 6 (1) point b) of the GDPR serve as the legal basis, i.e. you provide us with the data on the basis of the contractual relationship between you and us. In order to process your email address for online orders, we are also obliged to electronically confirm receipt of your order due to a provision in the German Civil Code (BGB). Art. 6 (1) point c) of the GDPR serve as the legal basis. We store the data collected for performing the contract at least until the expiry of the statutory or possible contractual warranty and guarantee rights, provided we do not use your contact data for advertising purposes (see 3.3. below).
The following data processing operations are also required to process the purchase agreement:
We work together with logistics companies for the purpose of processing the sales contract. The following data may be transmitted to these logistics companies commissioned by us for the purpose of delivering the ordered goods or for announcing them: Information about your delivery address (first name, surname, postal address) as well as your email address and telephone number. The logistics company will contact you prior to delivery to provide you with the time of delivery or to discuss delivery details with you.
3.2.2. Identity, creditworthiness and information to credit agencies
If necessary, we may verify your identity by consulting information from service providers. Art. 6 (1) points b) and f) of the GDPR serve as the legal basis. Authorisation to do so arises from ensuring the protection of your identity and the avoidance of fraud attempts at our expense. The circumstance and the result of our enquiry will be added to your customer account or your guest account for the duration of the contractual relationship.
During the ordering process, we also check your credit rating, provided that you select the payment method ‘on account’. For this purpose we pass on the following types of data to credit agencies cooperating with us: name, address, date of birth. Art. 6 (1) point f) of the GDPR serve as the legal basis. The legitimate interest required under this provision arises from our interest in minimising the credit risk associated with these types of payments. The circumstance and the result of our enquiry will be added to your customer account for the duration of the contractual relationship. Credit decisions are taken individually by our employees and are not the result of automated processes.
Data transmission for credit assessment according to the EU-GDPR
Our company regularly checks your creditworthiness when concluding contracts and in certain cases where there is a legitimate interest, including current customers. In doing so, we work together with Bisnode D&B Schweiz AG, Grossmattstrasse 9, 8902 Urdorf, from whom we receive the necessary data. For this purpose we transmit your name, contact details and date of birth to Bisnode D&B Switzerland.
You can find information about data processing by Bisnode D&B Switzerland here: https://www.bisnode.ch/en-ch/data-privacy/
A copy of your credit report can be obtained via this link.
If you have already made a purchase with us, your data stored by us about you can be supplemented by score values. Scoring is the process of making a forecast of future events based on information collected and past experiences. Such processing is based on Art. 6 (1) point f) of the GDPR. The preparation of such forecasts is to be regarded as a legitimate interest within the meaning of the aforementioned provision. Based on the data stored about your, you will be assigned to statistical groups of people with similar entries in the past. The underlying method used is a well-founded mathematical-statistical method for predicting risk probabilities that has long been tried and tested in practice.
In the event of a delay in payment, we reserve the right to pass on the necessary data to a company commissioned with asserting the claim if other legal requirements have been met. Art. 6 (1) point. b) and Art. 6 (1) point f) of the GDPR serve as the legal basis. The assertion of a contractual claim shall be regarded as a legitimate interest within the meaning of the second provision. Information about the delay in payment or a possible bad debt loss will also be forwarded to credit agencies cooperating with us if other legal requirements have been met. Art. 6 (1) point f) of the GDPR serve as the legal basis. The legitimate interest required here arises from our interest and that of third parties in reducing contractual risks for future contracts.
3.3. Processing data for advertising purposes
The following explanations refer to the processing of personal data for advertising purposes. The DSGVO declares such processing of data based on Art. 6 (1) point f) of the GDPR to be generally conceivable and a legitimate interest. The duration of data storage for advertising purposes does not follow rigid principles and is based on the question of whether storage is necessary for advertising purposes. Please refer to Section 3.3.4 for the procedure to be followed should you wish to assert your right to object.
3.3.1. Advertising purposes of GARPA and third parties
If you have concluded a contract with us, we will store you as a customer in our system. In this case, we process your postal contact details beyond a concrete consent, in order to send you information about products and services in this way. We process your email address, provided we have received it from you, in order to send you information about our own, similar products beyond a concrete consent.
3.3.2. Interest-Oriented Advertising
To ensure that you only receive advertising information that is of supposed interest to you, we categorise and supplement your customer profile with further information. Both statistical information and information about you (e.g. basic details from your customer profile) are used for this purpose. The aim is to provide you with advertising that is solely oriented to your actual or supposed needs and not to trouble you with useless advertising.
3.3.3. Referring friends
If our customers inform us of potential interested parties for our offers (e.g. catalogue request), we collect this personal data provided to us for the purpose of acquiring new customers. We process and use the name and postal address to send our catalogue. For this purpose, we may pass on the personal data provided to us to relevant service providers commissioned by us. We are also obliged to inform the person you have named that you have given us the address data. We store your details (details of the interested party and the fact that you recommended the interested party) as long as this is necessary to fulfil the purpose for reasons of proof. The processing of postal contact data for the purpose of “referring friends” takes place outside the existence of a concrete consent in order to provide interested parties with information about products and services in this way. The GDPR declares such processing of personal data for advertising purposes on the basis of Art. 6 para. 1 lit. f) GDPR as fundamentally conceivable and as a legitimate interest.
3.3.4. Right to object
You can object to your data being processed for the above-mentioned purposes at any time free of charge, separately for the respective communication channel, and with effect for the future. To do so, simply send an email or a letter by post to the contact details listed under Section 2.
If you object to your data being processed, the contact address concerned will be blocked for further processing for advertising purposes. We wish to point out that advertising material may still be sent temporarily in exceptional cases even after receipt of your objection. This is technically due to the necessary lead time of advertisements and does not mean that your right to object has not been considered. We ask for your understanding.
3.3.5. Information on the newsletter
We offer you the possibility of subcribing to our newsletter via our website. In order to make sure that no errors were made when entering the email address, we use the double opt-in process. This means that we will send you a confirmation link after you have entered your email address in the registration field. Your email address will be added to our mailing list only after you click on this confirmation link. Your electronic contact details will be processed solely on the basis of your consent pursuant to Art. 6 (1) point a) of the GDPR. You may revoke your consent at any time with effect for the future. To do so, simply send an email to the email address provided under Section 2 or click on the “Unsubscribe” button at the end of each newsletter.
3.4. Online presence and website optimisation
3.4.1 Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.
Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.
Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
Which cookies and services are used on this website can be found in this privacy policy.
You may revoke your consent or configure your settings for the cookies used on our website by clicking on the following link: Edit cookie settings.
3.4.2. Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
You may revoke your consent or configure your settings for the cookies used on our website by clicking on the following link: Edit cookie settings.
3.4.3. Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.
Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
Browser plug-in
You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.
Google Analytics E-Commerce-Tracking
This website uses the “E-Commerce Tracking” function of Google Analytics. With the assistance of E-Commerce Tracking, the website operator is in a position to analyze the purchasing patterns of website visitors with the aim of improving the operator’s online marketing campaigns. In this context, information, such as the orders placed, the average order values, shipping costs and the time from viewing the product to making the purchasing decision are tracked. These data may be consolidated by Google under a transaction ID, which is allocated to the respective user or the user’s device.
You may revoke your consent or configure your settings for the cookies used on our website by clicking on the following link: Edit cookie settings.
3.4.4. Meta Pixel (formerly Facebook Pixel)
To measure conversion rates, this website uses the visitor activity pixel of Facebook/Meta. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.
This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.
For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy (https://www.facebook.com/about/privacy/). This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
Within the meta pixel, we are using the expanded alignment function.
The expanded alignment allows us to transfer to Meta (Facebook) different types of data (e.g., place of residence, federal state, zip code, hashed email addresses, names, gender, date of birth or phone number) of our customers and prospects we collect through our website. As a result of this activation, we can tailor the offers presented in our advertising campaigns on Facebook to individuals interested in what we offer even more precisely. Moreover, this expanded alignment optimizes the allocation of website conversions and expands custom audiences.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.
In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/.
You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.
If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
You may revoke your consent or configure your settings for the cookies used on our website by clicking on the following link: Edit cookie settings.
3.4.5. Google Ads
The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
3.4.6. Google Ads Remarketing
This website uses the functions of Google Ads Remarketing. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With Google Ads Remarketing, we can assign people who interact with our online offering to specific target groups in order to subsequently display interest-based advertising to them in the Google advertising network (remarketing or retargeting).
Moreover, it is possible to link the advertising target groups generated with Google Ads Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a manner tailored to you as well as on any of your devices (e.g., tablet or PC).
If you have a Google account, you have the option to object to personalized advertising under the following link: https://www.google.com/settings/ads/onweb/.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
You may revoke your consent or configure your settings for the cookies used on our website by clicking on the following link: Edit cookie settings.
3.4.7. Google Conversion-Tracking
This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
You may revoke your consent or configure your settings for the cookies used on our website by clicking on the following link: Edit cookie settings.
3.4.8. Social media
Facebook
We have integrated elements of the social network Facebook on this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.
An overview of the Facebook social media elements is available under the following link: https://developers.facebook.com/docs/plugins/.
If the social media element has been activated, a direct connection between your device and the Facebook server will be established. As a result, Facebook will receive information confirming your visit to this website with your IP address. If you click on the Facebook Like button while you are logged into your Facebook account, you can link content of this website to your Facebook profile. Consequently, Facebook will be able to allocate your visit to this website to your user account. We have to emphasize that we as the provider of the website do not receive any information on the content of the transferred data and its use by Facebook. For more information, please consult the Data Privacy Policy of Facebook at: https://de-de.facebook.com/privacy/explanation.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 Sect. 1 lit. a GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
Instagram
We have integrated functions of the public media platform Instagram into this website. These functions are being offered by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
If the social media element has been activated, a direct connection between your device and Instagram’s server will be established. As a result, Instagram will receive information on your visit to this website.
If you are logged into your Instagram account, you may click the Instagram button to link contents from this website to your Instagram profile. This enables Instagram to allocate your visit to this website to your user account. We have to point out that we as the provider of the website and its pages do not have any knowledge of the content of the data transferred and its use by Instagram.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook or Instagram tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875 and https://de-de.facebook.com/help/566994660333381.
For more information on this subject, please consult Instagram’s Data Privacy Declaration at: https://instagram.com/about/legal/privacy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active
Pinterest
We use elements of the social network Pinterest on this website. The network is operated by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.
If you access a site or page that contains such an element, your browser will establish a direct connection with Pinterest’s servers. During this process, the social media element transfers log data to Pinterest’s servers in the United States. The log data may possibly include your IP address, the address of the websites you visited, which also contain Pinterest functions. The information also includes the type and settings of your browser, the data and time of the inquiry, how you use Pinterest and cookies.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
For more information concerning the purpose, scope and continue processing and use of the data by Pinterest as well as your affiliated rights and options to protect your private information, please consult the data privacy information of Pinterest at: https://about.pinterest.com/en/privacy-policy.
3.4.9. Microsoft Bookings
Our website gives you the option to schedule appointments with us. We use Microsoft Bookings to book these appointments. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, https://learn.microsoft.com/en-us/microsoft-365/bookings/?view=o365-worldwide.
To book an appointment, enter the requested data and the desired date in the form provided. The data entered will be used for planning, conducting and, if necessary, for the follow-up of the appointment. The appointment data will be stored for us on the servers of Microsoft Bookings, whose privacy policy you can view here: https://privacy.microsoft.com/de-de/privacystatement.
The data recorded in this manner will be stored until you ask us to delete them, revoke your consent to the archiving of your data or until the purpose of archiving the data no longer exists. This does not affect mandatory statutory provisions – in particular those governing retention periods.
The legal basis for the processing of the data is Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in ensuring that appointments with customers and prospective customers can be scheduled as easily as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.
Data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be found here: https://learn.microsoft.com/en-us/compliance/regulatory/offering-eu-model-clauses.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000KzNaAAK&status=Active
3.4.10. Matterport
Our website includes a virtual showroom that enables visitors to browse through our collection individually. The operator of this portal is Matterport, Inc, 352 E. Java Dr. Sunnyvale, CA 94089, USA. When you visit one of our pages containing such a virtual tour, a connection to Matterport's servers is established. This will tell the Matterport server which of our pages you have visited. In addition, Matterport obtains your IP address. This also applies if you are not logged in to Matterport or do not have an account with Matterport. The information collected by Matterport is transmitted to the Matterport server in the USA. If you are logged in to your Matterport account, you allow Matterport to directly associate your surfing behaviour with your personal profile. You can prevent this by logging out of your Matterport account beforehand.
The use of Matterport serves the interest of presenting our online offers in an appealing way. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f of the GDPR. If corresponding consent has been requested (e.g. consent to the storage of cookies), processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a of the GDOPR and § 25 para. 1 TTDSG; consent can be revoked at any time.
For more information on how Matterport implements the GDPR and handles user data, see: https://support.matterport.com/hc/en-us/articles/360000904267-Matterport-s-Plan-for-GDPR and in the Privacy Policy of Matterport at: https://matterport.com/legal/data-processing-agreement.
3.4.11. Criteo
This website uses Criteo functions. The provider is Criteo SA, 32 Rue Blanche, 75009 Paris, France (hereinafter referred to as “Criteo”).
Criteo is being used to display interest-based promotional ads within the Criteo advertising network. Your interests are being determined on the basis of your historic user patterns. To that end, Criteo will, for instance, track the products you have viewed, placed in your shopping cart as well as the ones you have purchased. For more information about the specific data recorded by Criteo please use this link: https://www.criteo.com/de/privacy/how-we-use-your-data/.
To be able to display interest-based promotions to you, we or other Criteo partners must be able to recognize you upon return visits. To ensure that this is possible, a cookie is placed and stored on your device. A comparable identifier may also be used that links your user patterns to a pseudonym user profile. For details, please review Criteo’s data protection policy at: https://www.criteo.com/de/privacy/.
Your personal data and the Criteo cookies saved in your browser will be stored for a period of no more than 13 months as of the date they were first recorded.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in targeted advertising campaigns.
Criteo and we are the joint Data Controllers as defined in Art. 26 GDPR. We have entered into an agreement on joint processing with Criteo. The primary content of this agreement is described in a statement by Criteo you may review under the following link: https://www.criteo.com/de/privacy/how-we-use-your-data/.
3.4.12. Microsoft Advertising
We use Universal Event Tracking (UET) on our website via the Microsoft Advertising (formerly Bing Ads) a service of Microsoft Corporation (USA). Microsoft stores a cookie in your browser via UET to enable an analysis of the use of our online offer.
Prerequisite for this is that you have reached our website via an advertisement from Microsoft Advertising. In this way, Microsoft and we can recognise that someone has clicked on an advertisement, been redirected to our online offer and reached a previously determined target page (so-called conversion measurement). No IP addresses are not stored during this process. No further personal information about the identity of the user is communicated.
Microsoft Advertising is only used with your consent. Art. 6 para. 1 lit. a of the GDPR and § 25 para. 1 TTDSG serves as the legal basis. You can revoke your consent at any time in the data protection settings by deactivating conversion tracking.
You can find more information on data protection at Microsoft in the
Microsoft PrivacyPolicy at https://privacy.microsoft.com/de-de/privacystatement.
3.4.13. Matomo
This website uses the open source web analytics service Matomo. Matomo uses technologies that make it possible to recognise users across pages to analyse user behaviour (e.g. cookies or device fingerprinting). The information collected by Matomo about the use of this website is stored on our server. The IP address is anonymised before storage.
Matomo helps us collect and analyse data about visitors’ use of our website. This enables us to find out, among other things, when which page views were made and from which region they come. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).
The use of this analysis tool is based on Art. 6 para. 1 lit. f of the GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and advertising. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a of the GDPR and Section 25 para. 1 of the TTDSG (German Telecommunications Telemedia Privacy Act), insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
3.4.13.1. IP anonymisation
We use IP anonymisation for analyses with Matomo. Your IP address is shortened before analysis so that it can no longer be clearly assigned to you.
3.4.13.2. Hosting
We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on to third parties.
3.4.14. Use of Cookiebot by Usercentrics
Our website uses the "Cookiebot" Consent Management Platform from Usercentrics to manage your consent for the use of cookies and similar technologies in compliance with legal requirements. Cookiebot enables you to determine which cookies are stored on your device through an appropriate consent selection.
Provider: Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich, Germany.
Data Processing: When using Cookiebot, the following data is collected and processed:
- Your IP address in anonymized form (last three digits are set to "0"),
- Date and time of consent,
- Browser user agent,
- URL from which consent was given,
- An anonymous, random, and encrypted key,
- Your consent status as proof of consent.
This data is used to manage and document your consent, ensuring compliance with legal requirements.
Legal Basis: The processing of your personal data is based on Article 6(1)(c) GDPR to fulfill our legal obligations.
Retention Period: Consent data is retained for 12 months and then automatically deleted.
For more information on data protection at Cookiebot, visit: https://www.cookiebot.com/en/privacy-policy/.
3.5. Competitions
You have the opportunity to participate in various competitions on our website, via our social media channels (including Facebook, Instagram, Pinterest) or through our newsletter. Unless otherwise specified in the respective competition or unless you have given us further express consent, the personal data you provide to us in connection with participation in the competition will be used exclusively for the purpose of processing the competition (e.g. determining the winner, notifying the winner, sending the prize). The legal basis for data processing within the framework of competitions is Art. 6 (1) lit. b) of the GDPR. If a declaration of consent is submitted in the context of a competition, Art. 6 (1) lit. a) of the GDPR is the legal basis for data processing based on the consent. If you have given your consent in the context of a competition, your data will be processed based on this consent, and you have the opportunity to revoke this consent at any time with effect for the future.
The data will only be passed on to third parties if this is necessary for the executing the competition (e.g. sending the prize via a logistics company).
The winners’ data will be kept for the duration of the legal warranty claims in the case of material prizes, in order to arrange for any defects to be repaired or replaced.
3.6. Contact
We offer visitors to our websites the opportunity to contact us via a contact form or by email. We use the information you provide via the contact form or by email (required information is marked with an asterisk) exclusively for the purpose of processing your request. This is done on the basis of Art. 6 (1) point f) of the GDPR. Proper handling of your concerns is to be regarded as a legitimate interest within the meaning of the GDPR. If you contact us in connection with a contractual relationship between you and us, Art. 6 (1) point b) of the GDPR, i.e. this contractual relationship, is also the legal basis for processing data. The data provided will be deleted immediately after use, unless there is a legal retention period. Your data will not be used for another purpose or transferred to third parties unless you have consented to this.
3.7. Privacy policy on audio and video conference
Data processing
We use online conference tools, among other things, to communicate with our clients. The tools we use in detail are listed below. If you communicate with us by video or audio conference via the Internet, your personal data will be collected and processed by us and the provider of the respective conference tool.
The conference tools collect all data that you provide/enter to use the tools (email address and/or your telephone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other ‘contextual information’ related to the communication process (metadata).
Furthermore, the provider of the tool processes all technical data required for handling of online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.
If content is exchanged, uploaded or otherwise made available within the tool, this is also stored on the servers of the tool providers. Such content includes, but is not limited to, cloud recordings, chat/instant messages, voice mails uploaded photos and videos, files, whiteboards and other information shared while using the service.
Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the corporate policy of the respective provider. For further information on data processing by the conference tools, please refer to the privacy policies of the respective tools used, which we have listed below this text.
Purpose and legal basis
The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 lit. b of the GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f of the GDPR). Insofar as consent has been requested, the tools in question are used on the basis of this consent; consent can be revoked at any time with effect for the future.
Duration of storage
The data collected directly by us via the video and conference tools will be deleted from our systems as soon as you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory retention periods remain unaffected.
We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details on this matter, please contact the operators of the conference tools directly.
Conference tools used
We use the following conference tools:
Microsoft Teams
We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000KzNaAAK&status=Active
3.8. Access to the GARPA image archive/image database
We use the double opt-in procedure to register to our database. This means that after you register, we will send you an email to the specified email address in which we ask you to confirm that you wish to have your data entered into the database. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify any potential misuse of your personal data.
The functions of the database can be described as follows:
For press contacts: Providing free image and text files for editorial purposes only.
For architects & interior designers: Providing free technical drawings, image and text files for personal, educational and informative purposes, for preparing quotations/cost estimates to end customers in connection with the sale of GARPA products via the company itself and for use in training courses or seminars.
3.9. Furnishing Planner
The Furnishing Planner on this website uses HTML5 storage objects that are stored on your mobile device. These objects store the required data (current plans, saved plans) independently of your browser and do not have an automatic expiry date. No personal data is stored by the Furnishing Planner. You can prevent the use of HTML5 storage objects by using private mode in your browser.
