Data Protection

Section 1 Information on the collection of personal data

(1) By the present Privacy Policy, we are informing you of how we collect personal data concerning you when you use our website.  Personal data are all data that relate to you personally, such as your name, address, email addresses, as well as individualized data regarding your user behavior.

(2) The controller pursuant to Article 4 paragraph 7 of the European General Data Protection Regulation (GDPR) is Waggonbau Graaff GmbH, Heinrich-Nagel-Straße 1, 31008 Elze, Tel.: +49 5068 18203, E-Mail: info@waggonbau-graaff.de. (referred to hereinbelow as “we” or “us”). Our Data Protection Officer can be reached by email at thomas.mombrei@vtg.com or by sending us a letter to the above address, specifying “der Datenschutzbeauftragte” (Attn: The Data Protection Officer).

(3) When you contact us via email or using a contact form, we will store the data you provide to us (your email address and, as the case may be, your name and your telephone number) to allow us to respond to your query.  The processing of these data is justified since we do so in order to pursue our legitimate interests, these consisting of our interest in responding to queries you address to us, pursuant to Article 6 paragraph 1, first sentence, letter f) of the GDPR.  We will erase the data accruing in this context once it is no longer necessary to store them for this purpose, or we will restrict the processing should statutory retention obligations exist.  While providing these data to us is voluntary, it may be that, if you do not provide them, we will be unable to reply to your query or to process it.

(4) Should we avail ourselves, in order to provide individual functions of our offering, of service providers with whom we have concluded a contract, or should we wish to use your data for advertisement purposes, you will find below detailed information on the respective processes this entails.  In this context, we will also provide you with the criteria determining the duration of the period for which data will be stored.

 

Section 2 Your rights

(1) You are entitled to the following rights vis-à-vis ourselves regarding the personal data concerning you:

  • Right of access pursuant to Article 15 of the GDPR,
  • Right to rectification or to erasure pursuant to Articles 16 und 17 of the GDPR,
  • Right to restriction of processing pursuant to Article 18 of the GDPR,
  • Right to object to the processing pursuant to Article 21 of the GDPR,
  • Right to data portability pursuant to Article 20 of the GDPR.

(2) Moreover, you are entitled to the right to file a complaint with the competent supervisory authority for data protection matters regarding our processing of the personal data concerning you.

 

Section 3 Collection of personal data when you visit our website

(1) If you use the website for purposes of obtaining information only, in other words, if you do not register and do not provide us with information in any other way, we will collect only those of the personal data concerning you that your browser transfers to our server.  If you wish to view our website, we will collect the following data, which we need in order to display our website to you and in order to warrant its stability and security (the legal basis therefor is Article 6 paragraph 1, first sentence, letter f) of the GDPR):

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status / HTTP status code
  • The amount of data transmitted in each case
  • Website from which the request originates
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

(2) In addition to the data set out above, cookies will be stored on your computer when you use our website.  Cookies are small text files that are stored on your hard disk such that they are matched to the browser you use; they serve the party placing the cookie on your hard disk (in the present case: us) to obtain certain information.  Cookies cannot implement any programs or transfer viruses onto your computer.  They serve to make the internet offering more user-friendly and more effective as a whole.

(3) Use of cookies:

a)  This website uses the following types of cookies, the scope and functioning of which are explained below:

  • Transient cookies (on this, see b)

b)  Transient cookies will be erased automatically once you close your browser.  This includes in particular session cookies.  They store what is referred to as a “session ID,” by which different retrievals performed by your browser can be matched to the joint session.  This allows us to recognize your computer again when you return to our website, and thus to give you a better user experience, since it enables us to recognize the user preferences you had at your previous visit and to take consideration of them.  The session cookies are erased once you log out or close your browser.  You may erase any cookies that have been placed on your computer at any time.  Before we place the cookies on your hard disk, you will see a notice to that effect on the website and will be asked to grant your consent.

c)  You can configure your browser settings in keeping with your preferences and, for example, can refuse to accept third-party cookies or all cookies.  We should point out that, in this event, it may not be possible for you to use all functions of this website.

 

Section 4 Further functions and offerings of our website

(1) Besides allowing visitors to use our website for purely informational reasons, we also offer a range of services which you may use if you are interested.  As a rule, you must provide further personal data for this purpose, which we will use in order to provide the respective service; they are governed by the above-referenced principles on the processing of data.  While providing such data is voluntary, it may be that you will not be able to use the services offered if you refrain from providing them to us.

(2) In some instances, we will avail ourselves of external service providers in order to process your data.  We have carefully selected the service providers to whom we have awarded a contract; they are bound to our instructions and are subject to regular controls.

(3) Moreover, we will share the personal data concerning you with third parties only if this is necessary in order to correspond to your query or to provide the offered services.

 

Section 5 Objection to the processing of your data or revocation of consent

(1) If you have consented to your data being processed, you may revoke this content at any time.  Such revocation of consent will impact the permissibility of processing the personal data concerning you once you have declared it.

(2) Inasmuch as we base the processing of the personal data concerning you on an exercise of balancing our reciprocal interests, you may object to the processing of your data at any time.  This is the case in particular where processing your data is not necessary to perform an agreement in place with you, which we will present in each case when we subsequently describe the functions.  Where you exercise such right of objection, we ask that you provide us with the reasons for which we should not continue processing the personal data concerning you.  In the event of your lodging an objection and providing us with the grounds therefor, we will review the factual situation and will either cease processing the personal data concerning you, or will make modifications to the data processing, or will indicate to you the absolutely mandatory grounds meriting protection based on which we will continue processing the personal data concerning you.

 

Section 6 Newsletter

(1) By your consent, you have the opportunity to sign up for our newsletter, which we use to inform you of our current offerings of interest.  The goods and services advertised will be set out in the declaration of consent.

(2) For you to sign up for our newsletter, we use a process known as the “double opt-in” process.  This means that once you have registered, we will send an email to the email address you have provided to us, asking you to confirm that you wish to receive the newsletter.  Should you fail to confirm your registration within twenty-four (24) hours, your data will be blocked and will automatically be erased once one (1) month has lapsed.  Moreover, we will store the IP addresses you have used and the time at which you registered / sent us a confirmation.  The purpose of this procedure is to give us an evidentiary record of your registration and to allow us to clear up any potential abuse of the personal data concerning you.  The collection of the personal data concerning you for this purpose is justified pursuant to Article 6 paragraph 1, first sentence, letter f) of the GDPR.

(3) The only information you must mandatorily provide to us in order for the newsletter to be sent to you is your email address.  Any provision of further, separately marked data is voluntary; they will be used to address you personally.  Once we receive your confirmation, we will store your email address for purposes of sending the newsletter to you.  The legal basis therefor is Article 6 paragraph 1, first sentence, letter a) of the GDPR.  We will store the data you provide to us in the context of granting your consent and will use them to send our newsletter to you until you revoke your consent as described in the following paragraph below.

(4) You may revoke your consent to receiving the newsletter at any time and may unsubscribe from the newsletter.  To do so, you can click on the link included in every newsletter email or you may declare your revocation by sending a message using the contact details provided in the website information.

As of: May 2018

Waggonbau Graaff GmbH
Data protection officer