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Privacy Policy

By the privacy policy at hand, we inform you about type, scope and processing of personal data within our website and associated websites, functions and content as well as external websites such as our profiles on social media networks and platforms. “AFI” and/or “we” refers to AFI Solutions GmbH as the responsible party providing this website. “Newsletter” means newsletters, e-mails and other electronic notifications containing advertising information.

“Personal data” or “data” within the meaning of this privacy policy refers to personal data in accordance with Art. 4(1) of the GDPR. “You” refers to the visitor or user of the websites. “Websites” refer to AFI’s homepages and landing pages which are accessible under the following domains

afi-solutions.com
redpapercenter.com
copilot-im-einkauf.com

 

 Other than that, the definitions in Art. 4 of the GDPR apply to the terms used in this privacy policy (e.g. “processing”, “person responsible” etc.).

AFI collects, processes and uses your personal data in compliance with the applicable data protection law. As far as AFI collects, processes and/or uses personal data, this is always for a specific purpose.

1) Person responsible

AFI Solutions GmbH
Sigmaringer Straße 109
70567 Stuttgart
Germany

2) Purposes and legal basis of data processing

2.1 We process the following types of data
- inventory data (e.g. first and last names, addresses)
- contact data (e.g. e-mail, phone numbers)
- content data (e.g. text input)
- usage data (e.g. visited websites, access times)
- meta/communication data (e.g. device information, IP addresses).

2.2 Purposes of processing personal data
- provision of our website, its functions and content,
- processing of inquiries via our contact form,
- safety measures,
- marketing (also in the form of IAM).

2.3 Contact via the contact form
When contacting us (e.g. via the contact form, e-mail, phone or social media), the user’s details are used for the processing of the contact request and its handling in line with Art. 6(1b) of the GDPR. User information can be stored in a customer relationship management system (“CRM”) or the like.

We delete the requests if they are no longer required. We review their requirement every two years. Furthermore, the statutory duty to preserve records applies.

2.4 Hosting
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services as well as technical maintenance services that we use for the purpose of operating this online service.

On doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online service on the basis of our legitimate interests in an efficient and secure provision of this online service in line with Art. 6(1f) of the GDPR in conjunction with Art. 28 of the GDPR (conclusion of order processing contract).

2.5 Collection of access data and log files
Based on our legitimate interests within the meaning of Art. 6(1f) of the GDPR, we or our hosting provider collect data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, data and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the website visited previously), IP address and the requesting provider. Servers in this sense are our web, content, application and database servers which we use for the operation of the website.

We automatically collect the IP address (from which you access), files (accessed by you), date and time of your access in order to detect and subsequently correct any technical and functional errors on the website.

We store server log files for security reasons (e.g. to investigate misuse or fraud) for a maximum of 31 days and delete them afterwards. Data, of which further storage is necessary for evidentiary purposes, will only be deleted after final clarification of the respective incident.

2.6 WiredMinds Analysis
The tracking pixel technology of WiredMinds AG (www.wiredminds.de) is used to evaluate the visitor behavior on our website. It collects, processes and stores data in order to create user profiles under an alias. As far as possible and useful, these user profiles are rendered anonymous. Cookies are used for this purpose. Cookies are text files that are stored on the computer of the visitor and serve to recognize internet browsers. The collected data, general or personal, will be sent to WiredMinds or stored directly by WiredMinds. WiredMinds may store the data generated during visits to the website in anonymous user profiles. This data is not used to identify visitors to websites unless the visitor has given his consent. Furthermore, it is not linked to personal information about the person behind a pseudonym. IP addresses are directly rendered anonymous by deleting the last numerical sequence.

2.7 Google Analytics
Based on our legitimate interest (i.e. interest in the analysis, optimization and economic operation of our online services within the meaning of Art. 6(1) of the GDPR), Google Analytics, a web analysis service of Google LLC (“Google”) is applied. Google uses cookies. The information generated by the cookie regarding the use of the online service by users is generally transferred to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Framework and thereby offers a guarantee to comply with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online service by users, to compile reports on the activities within this online service and to provide us with further services associated with the use of this online service and the use of the internet. In the course of this, pseudonymous user profiles can be created from the processed data.

We apply Google Analytics only with activated IP anonymization. This means that Google will shorten the IP address of users within EU member states or other contracting member states of the EEA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.

The IP address transferred by the user’s browser is not associated with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly. They can also prevent Google from collecting data, which was generated by the cookie and relates to their use of the online service, and from processing this data by downloading and installing the browser plugin available under the following link:http://tools.google.com/dlpage/gaoptout?hl=de.

For further information on data use by Google, setting and objection options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Personal data of users will be deleted or made anonymous after 14 months.

2.8 Use of LiveZilla
This website uses technologies of LiveZilla GmbH, Byk-Gulden-Straße 18, 78224 Singen, Germany (http://www.livezilla.net/home/de/) to collect and store anonymous personal data for the purpose of web analysis and operation of a live chat system to answer live support requests, from which user profiles are created using pseudonyms. The pseudonymized user profiles are not associated with personal data about the bearer of the pseudonym without explicit and separate consent. It is technically ensured that IP addresses are automatically anonymized. The usage profiles are used to analyze visitor behavior and are evaluated to improve and design the service on our website in line with demand. Cookies may be used for this purpose. These are little text files that are stored locally on the terminal device of the visitor to the website and thereby allow for a recognition when the visitor returns to our website. The pseudonymized usage profiles are not associated with personal data about the bearer of the pseudonym without explicit and separate consent. The information generated by the cookie about your use of this website (including your IP address) will be transferred to and stored by a LiveZilla server. LiveZilla will use this information to evaluate your use of the website, to compile reports on the website activities for the maintainers of the site and to provide further services associated with the use of the website and the internet. LiveZilla may also transfer this information to third parties where required by law or where third parties process this data on LiveZilla’s behalf. LiveZilla does not associate your IP address with any other data. You may prevent the installation of cookies by a respective setting on your browser software. However, please note that by doing so, you might not be able to use this website to its full extent.

All personal data collected by the use of LiveZilla’s technologies will be deleted without substitution within a period of 30 days, beginning with their collection.

If you request documents, information and/or quotations to be sent via the live chat system, we will transfer your request from LiveZilla to our CRM system to send you the requested information by e-mail to the provided e-mail address afterwards. For this purpose, we process the real name as well as the e-mail address provided by you. If we do not receive a response from you within 30 calendar days beginning with the dispatch of the respective e-mail to you, we will delete the e-mail dispatched to you, including the personal data transferred to our CRM system to answer your request, without substitution.

2.9 Newsletter
We only send newsletters with the consent of the recipient or within the scope of legal permission. If the content of a newsletter is specifically described within the scope of a subscription, this is decisive for the consent of the recipients. In addition, our newsletters contain information about our services and/or us.

The subscription to our newsletter takes place in a so-called double opt-in procedure, i.e. after subscription you will receive an e-mail in which we ask you to confirm your subscription. This confirmation is necessary to ensure that no one can subscribe to the newsletter with other e-mail addresses. Subscriptions to our newsletter are logged in order to be able to prove the subscription process in conformity with the law. This includes the storage of the time of subscription and confirmation and the IP address. Changes to your data stored with the dispatch service provider are also logged. Simply enter your e-mail address to subscribe to our newsletter. Optionally, you can enter a name in the subscription process, e.g. for a personal address in the newsletter.

The dispatch of our newsletter and the associated performance measurement is based on the recipients’ consent in line with Art. 6 (1a), Art. 7 of the GDPR in conjunction with Section 7, Subsection 2, No. 3 of the German Unfair Competition Act (UC) or on the basis of legal permission in line with Section 7, Subsection 3 of the UC. Logging of the subscription process is based on our legitimate interest in line with Art. 6 (1f) of the GDPR. We are interested in using a user-friendly and secure newsletter system that serves our commercial interests, meets the expectations of users and allows for proof of granted consent. You are entitled at any time to cancel your subscription. For this purpose, just click the “unsubscribe” or “cancellation” button available at the bottom of each newsletter you receive. We are entitled to store e-mail addresses after cancellation of the subscription for up to three years on the basis of our legitimate interests before finally deleting them. This storage allows for proof of previously granted consent. Further processing of this data takes place exclusively for the purpose of warding off possible claims based on a consent granted allegedly insufficient or in an insufficient scope or in an inadequate manner. An immediate deletion is possible if the previously granted consent is confirmed at the same time as the corresponding application.

2.9.1 Newsletter - dispatch service provider
Dispatch of the newsletter takes place through the dispatch service provider SC-NETWORKS GMBH, Enzianstr. 2, 82319 Starnberg, Germany. The privacy policy of the dispatch service provider can be viewed here: [ PRIVACY POLICY SC-Networks GmbH ]. The dispatch service provider is deployed on the basis of our legitimate interests in line with Art. 6(1f) of the GDPR and an order processing contract in line with Art. 28(3, sentence 1) of the GDPR. The dispatch service provider can use the recipients’ data in pseudonymized form, i.e. without assignment to a user, to optimize or improve his own services, e.g. for technical optimization of the dispatch and the display of the newsletters or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to contact them himself or to pass the data on to third parties.

2.9.2 Newsletter - performance measurement
The newsletters contain a so-called “web beacon” (tracking pixel), i.e. a pixel-sized file which is downloaded from our server when the newsletter is opened. If we use a dispatch service provider, it will be downloaded from his server. Within the scope of this retrieval, technical information, such as information about your browser and your system, as well as your IP address and time of retrieval, are initially collected. This information is used to technically improve the services by means of technical data or the target groups and their reading behavior based on their retrieval location (which can be determined using the IP address) or the access time. The statistical surveys also include determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients, but it is neither our object in view nor that of the dispatch service provider (if deployed) to observe individual users. The main objective of the evaluations is to understand the reading habits of our users and to adapt our content correspondingly or to send different content according to the interests of our users.

2.10 Cookies, pixels and right of objection in direct advertising
“Cookies” are small files that are stored on the users’ computers. Different data can be stored within the cookies. A cookie is primarily used to store user information (or information on the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies or “session cookies” or “transient cookies” are cookies which are deleted after a user leaves an online service and shuts down his browser. In such a cookie, the contents of a shopping cart in an online shop or a login status can be stored for example. “Permanent” or “persistent” cookies are those which remain stored after the browser is shut down. The login status can be stored when the users revisit these after several days. Furthermore, the user information which is used for reach measurement or marketing purposes can be stored in such a cookie. “Third party cookies” are cookies that are offered by providers other than the person responsible for operating the online service (if they are only his cookies, they are referred to as “first party cookies”).

We may apply temporary or permanent cookies and provide the necessary information regarding these within the framework of our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the respective option in the system settings of their browser. Stored cookies may be deleted in the system settings of the browser. Exclusion of cookies can lead to functional restrictions of this online service.

A general objection against the use of cookies for online marketing purposes can be declared at numerous services and - particularly in the case of tracking - via the US website www.aboutads.info/choices/ or the EU website www.youronlinechoices.com. Furthermore, the storage of cookies can be carried out by shutting them down in the browser settings. However, please note that by doing so, you might not be able to use this website to its full extent.

We use so-called pixels, web beacons (tracking pixels), Clear GIFs or similar mechanisms (hereinafter referred to as “pixel”). A pixel is an image file or a link to an image file that is injected in the website code but is not located on your device (e.g. computer, smartphone etc.). We mostly use pixels for the same reasons as cookies. They allow us to count the number of users that are visiting our website for example or - if the e-mail program of the user permits HTML - to determine if and when an e-mail has been opened. Pixels help us to check and optimize the efficiency of our website and our advertising measures. A direct reference to a person is not made when using pixels. Personal tracking does not take place. Commonly, pixels work in conjunction with cookies. If you have deactivated cookies, pixels will then determine only an anonymous visit to a website.

2.11 Data transfer to third parties
Unless otherwise stated, data will not be transferred to third parties.

 

 

3) Legal bases of data processing

Legal basis for obtaining consents is Art. 6(1a) and Art. 7 of the GDPR, legal basis for processing to perform our service and performance of contractual measures as well as for responding to inquiries is Art. 6(1b) of the GDPR, legal basis for processing to perform our legal duties is Art. 6(1c) of the GDPR and legal basis for processing to preserve our legitimate interests is Art. 6(1f) of the GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1d) serves as the legal basis.

On a supplementary basis, the other legal bases explicitly mentioned in this privacy policy shall apply.

Provided that we disclose data to other persons and companies (contract processors or third parties) within the context of our processing, transmit it to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transmission of data to third parties, such as payment service providers, in line with Art. 6(1b) of the GDPR, is necessary for contractual performance), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interest (e.g. when using contractors, web hosts etc.). If we commission third parties with the processing of data on the basis of a so-called order processing contract, this takes place in line with Art. 28 of the GDPR.

 

4) Online presence in social media networks and platforms, integration of third-party services and content
We maintain online presence within social networks and platforms to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing policies of their respective hosts apply. Unless otherwise stated in our privacy policy, we only process the data of users if they are communicating with us within social networks and platforms, e.g. when they leave posts on our online presence or send us messages.

We apply content or service packages of third-party suppliers to involve their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”) within our online service based on our legitimate interest (i.e. interest in the analysis, optimization and commercial operation of our online service in line with Art. 6(1f) of the GDPR).

This always presupposes that third-party providers of this content perceive the IP address of the users because they could not send the content to their browsers without the IP address. Therefore, the IP address is required for the display of this content. We make every effort to only use content whose respective provider uses the IP address merely for the delivery of the content. Furthermore, third-party providers can also use so-called pixel tags (invisible graphics also referred to as “web beacons” or “tracking pixels”) for statistical or marketing purposes. By means of these “pixel tags”, information such as the traffic of visitors on the pages of this website may be analyzed. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referential websites, visiting time and other information about the use of our online service as well as be linked to such information from other sources.

4.1 Youtube
We integrate videos of the platform “YouTube” provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

4.2 Google Maps
We integrate maps of the service “GoogleMaps” provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include in particular IP address and location data of the users. However, this data is not collected without the users’ consent (as a rule within the framework of the settings of their mobile devices). This data may be processed in the USA. Privacy https://www.google.com/policies/privacy/, opt-out: adssettings.google.com/authenticated.

4.3 Use of Facebook Social Plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and commercial operation of our online service within the meaning of Art. 6(1f) of the GDPR), we use social plugins (“plugins”) of the social network facebook.com which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). These plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognizable by one of the Facebook logos (a white letter “f” on a blue tile and the terms “like”, “I like” or a “thumbs up” symbol) or are characterized with the add-on “Facebook social plugin”. List and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Framework and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user accesses a function of this online service that contains such a plugin, his device sets up a direct connection to Facebook’s servers. The content of the plugin is transmitted directly to the user’s device and integrated into the online service. Thereby, user profiles can be created from the processed data. We therefore have no influence on the amount of data Facebook collects with the help of this plugin and inform users according to present knowledge as a result.

By integration of the plugins, Facebook receives information that a user has accessed the corresponding web page of the online service. If the user is logged in to Facebook, Facebook can assign the access to the web page to his Facebook account. When users interact with the plugins, e.g. when they press the “like”-button or leave a comment, the respective information is directly transferred to Facebook from your device and stored with Facebook. If a user is not a Facebook member, it is still possible for Facebook to find out and store his IP address. According to Facebook, only an anonymized IP address is stored in Germany.

Purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the corresponding rights and setting options for the privacy protection of users, can be found in Facebook’s privacy policy: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him via this online service and link it to his membership data stored with Facebook, he must log out of Facebook before using our online service and delete his cookies. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings https://www.facebook.com/settings?tab=ads or via the US-American website http://www.aboutads.info/choices/ or via the EU website http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices such as desktop computers or mobile devices.

4.4 Twitter
We integrate functions and content of the Twitter service provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA into our online service. This may include, for example, content such as images, videos or texts and buttons with which users can express their appreciation of the content or subscribe to the authors of the content or our contributions. If the users are members of the Twitter platform, Twitter can assign their access to the above-mentioned content and functions to the user profiles on Twitter. Twitter is certified under the Privacy Shield Framework and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active).

4.5 Instagram
We integrate functions and content of the Instagram service provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA into our online service. This may include, for example, content such as images, videos or texts and buttons with which users can express their appreciation of the content or subscribe to the authors of the content or our contributions. If the users are members of the Instagram platform, Instagram can assign their access to the above-mentioned content and functions to the user profiles on Instagram. Privacy policy: http://www.instagram.com/about/legal/privacy/.

4.6 XING
We integrate functions and content of the XING service provided by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany into our online service. This may include, for example, content such as images, videos or texts and buttons with which users can express their appreciation of the content or subscribe to the authors of the content or our contributions. If the users are members of the XING platform, XING can assign their access to the above-mentioned content and functions to the user profiles on XING. Privacy policy:https://www.xing.com/app/share?op=data_protection.

4.7 LinkedIn
We integrate functions and content of the LinkedIn service provided by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, into our online service. This may include, for example, content such as images, videos or texts and buttons with which users can express their appreciation of the content or subscribe to the authors of the content or our contributions. If the users are members of the LinkedIn platform, LinkedIn can assign their access to the above-mentioned content and functions to the user profiles on LinkedIn. Privacy policy: www.linkedin.com/legal/privacy-policy.

LinkedIn is certified under the Privacy Shield Framework and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active).

 

5) Deletion of personal data
We delete or limit the processing of data handled by us in line with Art. 17 and 18 of the GDPR. Unless otherwise regulated in this privacy policy, we delete the data stored by us as soon as it is no longer required for the purpose of processing and there are no legal duties to preserve records preventing deletion. If the data is not deleted because it is required for other and legally permissible purposes, their processing is limited, i.e. the data is blocked and not processed for other purposes. This applies particularly to data subject to retention under commercial or tax law.

German law currently provides for the following retention periods: 6 years in line with section 257(1) of the German Commercial Code (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, posting documents etc.) and 10 years in line with section 147(1) of the German Revenue Code (books, records, management records, posting documents, commercial and business letters, documents relevant for taxation etc.).

 

6) Your rights
In line with Art. 7(3) of the GDPR, you have the right to revoke consent granted in line with Art. 7(3) of the GDPR with effect for the future.
In line with Art. 15 of the GDPR, you have the right to request confirmation as to whether the data concerned is being processed and to request information and copies of the data.
In line with Art. 16 of the GDPR, you have the right to request the completion of data or the correction of incorrect data concerning you.
In line with Art. 17 of the GDPR, you have the right to request that relevant data is promptly deleted or, alternatively, to demand a restriction on the processing of data in line with Art. 18 of the GDPR.
In line with Art. 20 of the GDPR, you have the right to request receipt of data concerning you, which you have provided to us, and to demand its transmission to other persons responsible.
In line with Art. 21 of the GDPR, you can object to the future processing of data concerning you at any time. The objection may take place particularly against processing for direct advertising purposes.
In line with Art. 77 of the GDPR, you have the right to file a complaint with the appropriate supervisory authority.

 

7) Data protection official of the person responsible
Contact details of our data protection official:

AFI Solutions GmbH
Data Protection Official
Sigmaringer Straße 109
70567 Stuttgart
E-Mail: datenschutzspamgeschützt@spamgeschütztafi-solutions.com

AFI Solutions GmbH as of 1 May 2018

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