Data protection

I. Name and Address of the Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:

Pneuhage Fleet Solution GmbH
At the Rossweid 23 – 25
D-76229 Karlsruhe

Tel: 0721 6188-0
Fax: 0721 6188-402
E-Mail: backoffice@pneu.com

II. Name and Address of the Data Protection Officer

Der Datenschutzbeauftragte des Verantwortlichen ist:

Pneuhage Management GmbH & Co. KG
Datenschutzbeauftragter
At the Rossweid 23 – 25
D-76229 Karlsruhe

E-Mail: datenschutz@pneu.com
Tel: 0721 6188-0

III. General Information about Data Processing

1. Scope of processing personal data

We collect and use personal data of our users only to the extent necessary for providing a functioning website as well as our content and services (initiation, conclusion, execution, and handling of automotive-related service offerings for companies). The collection and use of personal data of our users is generally based on the user’s consent. An exception applies in cases where obtaining prior consent is not possible for factual reasons and the processing of data is permitted by legal provisions.

2. Legal basis for processing personal data

If we obtain the data subject’s consent for processing personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

For the processing of personal data necessary for the performance of a contract to which the data subject is a party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for carrying out pre-contractual measures.

If processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Article 6(1)(c) GDPR serves as the legal basis.

In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

If processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, Article 6(1)(f) GDPR serves as the legal basis for processing.

3. Data erasure and storage duration

Personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply.

In the event that you send us job application data through our website or by other electronic means, we will immediately delete the data if we do not initiate an application process. If we initiate an application process or if you send us job application data upon our request, we will delete your data at the latest four months after the completion of the application process if no employment relationship is established as a result. Storage beyond this period may occur if expressly consented to by you.

Furthermore, storage may take place if provided for by European or national legislatures in Union regulations, laws, or other provisions to which the controller is subject. Blocking or deletion of data also occurs when a storage period prescribed by the aforementioned standards expires, unless there is a necessity for further storage of the data for the conclusion or performance of a contract.

4. Kategorien von Empfängern

The recipients of the personal data processed through our website are generally, unless otherwise specified below, the controller or the responsible company (see Section I of this privacy statement). The data will only be transmitted to third parties (service partners) within the scope of service provision. However, transmission to third parties is carried out in compliance with the provisions of the GDPR and the BDSG (new) as well as other applicable data protection regulations, if and to the extent that this is necessary for the conclusion and performance of a contract concluded via our website (contract initiation, contract performance (even if you commission services that are wholly or partially provided by third parties), and contract processing (e.g., external service providers)), as required by law, within the framework of the requirements prescribed by the respective law and any balancing of the affected interests. Such a case may arise, for example, in the context of criminal investigations. Such transmission also takes place if there is a valid consent from you.

If you transmit your data to us to apply for employment with our company, data will be transmitted exclusively to the respective department(s) responsible within our company.

IV. Provision of the Website and Creation of Log Files

1. Description and Scope of Data Processing

When you visit our website, our system automatically collects data and information from the computer system of the accessing device.

The following data may be collected for the purpose of error analysis:

• Information about the browser type and version
• The user’s operating system
• The user’s IP address
• Date and time of access

The data is also stored in log files on our system. The storage of this data together with other personal data of the user does not take place.

2. Legal Basis for Data Processing

The legal basis for the temporary storage of data and log files is Article 6(1)(f) of the GDPR.

3. Purpose of Data Processing

The temporary storage of the IP address by the system is necessary to deliver the website to the user’s device. For this purpose, the user’s IP address must remain stored for the duration of the session. The storage in log files is done to ensure the functionality of the website. Furthermore, the data serves us to optimize the website and ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also constitute our legitimate interest in data processing pursuant to Article 6(1)(f) of the GDPR.

4. Duration of Storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of data collected to provide the website, this is the case when the respective session is ended. In the case of data stored in log files, this will be no later than 14 days, unless otherwise specified in this privacy statement

5. Objection and Removal Option

The collection of data to provide the website and the storage of data in log files are mandatory for the operation of the website. Therefore, there is no possibility for the user to object.

V. Use of Cookies

Our website does not use cookies.

VI. Newsletter

1. Description and Scope of Data Processing

Through our website, you can subscribe to our newsletter, through which we send you news about our company, products, special offers, or other informative advertisements. You can access the newsletter subscription form through a designated button. For the newsletter, we store your first name, last name, email address, and, if provided, your product interests, as indicated in the registration form.

2. Legal Basis for Data Processing

The legal basis for processing the data is your consent, Art. 6(1)(a) of the GDPR. Additional legal basis for processing is Art. 6(1)(b) of the GDPR, as the data is used for the conclusion and performance of the newsletter subscription agreement.

3. Purpose of Data Processing

The data is used for the purpose of delivering the newsletter and personalizing it. Additionally, the transmitted data is used for market research purposes by capturing and storing the response (your interaction) to the newsletter regarding our products, offers, and information. Such data is also used in an abstract form without personal reference for general statistical purposes.

4. Storage Duration

The data used for newsletter subscriptions and personalization is stored as long as the newsletter subscription is active. Once the newsletter subscription is terminated, the data is deleted. However, this does not apply to general statistical data that we have collected from the newsletter subscription and its interaction, which has no personal reference and is used solely for general statistical purposes.

4. Objection and Removal Options

You can unsubscribe from the newsletter at any time by sending us a revocation of your consent to receive the newsletter. The revocation will be effective for the future. You can revoke your consent by email, postal mail, using an unsubscribe link in the respective newsletter text, or by phone.

VII. Branch Locator

1. Description and Scope of Data Processing

Through our website, you can search for branches where our services are offered using a provided form (Branch Locator). In this process, we collect your postal code if you enter it and record the selection of one or more chosen branches, but we do not store this information.

2. Legal Basis for Data Processing

The legal basis for processing the data is your consent, Art. 6(1)(a) of the GDPR.

3. Purpose of Data Processing

Through the Branch Locator, we enable you to conveniently and quickly find our branches where the services displayed on our website are offered.

4. Storage Duration

The data collected through the Branch Locator is not stored by us.

5. Objection and Removal Options

You can prevent the collection of your data by not entering a postal code in the Branch Locator.

VIII. Communication via Our Website

1. Description and Scope of Data Processing

Through the telephone numbers, email addresses, or contact form provided on our website, you can send us inquiries and information, which are stored by us under general information or, if you are an existing customer, associated with your customer profile or any provided email address or phone number. Telephone information is not recorded but stored as text (telephone note) in keywords or summarized format if necessary. The stored information usually includes your first name, last name, email address, individual information in the text and notification field, your phone number, any transmitted address information, and whether you request a callback.

2. Legal Basis for Data Processing

The legal basis for processing the data, if consent from the user exists, is Art. 6(1)(a) of the GDPR. The legal basis for processing data transmitted via email, the contact form, or telephone is Art. 6(1)(f) of the GDPR. If the communication aims to conclude a contract, an additional legal basis for processing is Art. 6(1)(b) of the GDPR.

3. Purpose of data processing

The processing of personal data serves to provide special, individual information about our products, if necessary in advance of an interest in our services.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose of their collection. This is the case for the personal data from the input mask of the free field if the service order has been carried out and the communication is no longer to be stored for the protection of contractual or legal interests. This depends on the content of the additional data you have submitted. If these are business letters, they are kept for six years, the information is used for a possible business annual financial statement for ten years, otherwise usually three years (contractual interest).

5. Possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, by telephone or via our contact form, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. All personal data stored in the course of establishing contact will be deleted in this case, if and to the extent that this is not required by statutory regulations, e.g. according to the Commercial Code or the Tax Code, or any other justification according to data protection regulations, which makes retention necessary after weighing all interests, is contrary.

IX. Links on XING and LinkedIn

1. Description and scope of data processing

In the footer of our website there are pictograms with the logos of the providers LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland) and XING (XING SE, Dammtorstraße 30, 20354 Hamburg, Germany) (hereinafter “Provider”). Under these logos there is a link to the login page of the respective provider. By clicking on this link, their respective start page will be called up so that you can log in to the respective service and access our business area stored there. Personal data will not be stored or collected by us by clicking on the respective link. However, by clicking on the respective link and calling up these pages, personal data may be collected by the respective provider. This is the exclusive knowledge and respective responsibility of the provider. If you already have an account with these providers, you have already consented to the type, content and scope of data processing by the provider.

Further information on data protection at Xing can be found at https://privacy.xing.com/de/datenschutzerklaerung

Further information on data protection at LinkedIn can be found https://de.linkedin.com/legal/privacy-policy?

2. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. f) GDPR.

3. Purpose of data processing

By calling up the start pages of the respective provider via our link, you have the opportunity to quickly and conveniently access our business area with these providers.

4. Duration of storage

We do not store any data when you access the related XING or LinkedIn websites via our link on this website.

5. Possibility of objection and removal

You can prevent personal data from being transferred to the providers of the XING and LinkedIn services by not clicking on the links on our homepage that refer to the offers of these providers or otherwise using them to access their websites.

X. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the DSGVO and you have the following rights towards the person responsible:

1. Right to information

You can request confirmation from the person responsible as to whether personal data concerning you will be processed by us.

If such processing exists, you can request information from the person responsible about the following information:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data that are processed;

(3) the recipients or the categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4) the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;

(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

(6) the existence of a right of appeal to a supervisory authority;

(7) all available information about the origin of the data if the personal data is not collected from the data subject;

(8) the existence of automated decision-making, including profiling, in accordance with Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the scope and the intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you are being transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate guarantees in accordance with Art. To be informed in connection with the transmission in accordance with Art. 46 GDPR.

2. Right to rectification

You have a right to rectification and/or completion to the person responsible, provided that the processed personal data concerning you is incorrect or incomplete. The person responsible must make the correction immediately.

3. Right to restriction of processing

Under the following conditions, you can request the restriction of the processing of personal data concerning you:

(1) if you dispute the accuracy of the personal data concerning you for a period that enables the controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you refuse the deletion of the personal data and instead request the restriction of the use of the personal data;

(3) the controller no longer needs the personal data for the purposes of processing, but you need it to assert, exercise or defend legal claims, or

(4) if you have objected to the processing in accordance with Art. 21 para. 1 DSGVO and it has not yet been determined whether the legitimate reasons of the person responsible outweigh your reasons.

If the processing of personal data concerning you has been restricted, this data may only be processed – apart from its storage – with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the person responsible before the restriction is lifted.

4. Right to erasure

1. a) Obligation to delete

Sie können von dem Verantwortlichen verlangen, dass die Sie betreffenden personenbezogenen Daten unverzüglich gelöscht werden, und der Verantwortliche ist verpflichtet, diese Daten unverzüglich zu löschen, sofern einer der folgenden Gründe zutrifft:

You can request from the controller that the personal data concerning you be deleted immediately, and the controller is obliged to delete this data immediately if one of the following reasons applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You revoke your consent on which the processing is based in accordance with Art. Art. 6 Para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.

(3) You submit in accordance with Art. Art. 21 Para. 1 DSGVO and there are no overriding legitimate reasons for the processing, or you object to the processing in accordance with Art. Art. 21 Para. 2 GDPR, you have the right to object to the processing.

(4) The personal data concerning you have been processed unlawfully.

(5) The deletion of the personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the person responsible is subject.

(6) The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 para. 1 DSGVO.

1. b) Information to third parties

If the person responsible has made the personal data concerning you public and is obliged to delete it in accordance with Art. Art. 17 Para. 1 DSGVO, he shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform the persons responsible for data processing who process the personal data that you, as the data subject, have requested the deletion of all links to this personal data or of copies or replications of this personal data from you.

1. c) Exceptions

The right to erasure does not exist to the extent that processing is necessary

(1) to exercise the right to freedom of expression and information;

(2) to fulfil a legal obligation that requires processing under the law of the Union or the Member States to which the person responsible is subject, or to perform a task that is in the public interest or in the exercise of official authority vested in the person responsible;

(3) for reasons of public interest in the field of public health in accordance with Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Art. Art. 89 Para. 1 DSGVO, insofar as the right referred to in section a) is likely to make it impossible or seriously impair the achievement of the objectives of this processing, or

(5) to assert, exercise or defend legal claims.

5. Right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients by the person responsible.

6. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. In addition, you have the right to transfer this data to another person responsible without hindrance from the person responsible to whom the personal data was provided, provided that

(1) the processing is based on a consent pursuant to Art. Art. 6 Para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. Art. 6 Para. 1 lit. b DSGVO is based and

(2) the processing is carried out using automated procedures.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right of objection

You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is based on Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions.

The controller no longer processes the personal data concerning you, unless he can prove compelling reasons worthy of protection for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is related to such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

Notwithstanding Directive 2002/58/EC, you have the option of exercising your right of objection in connection with the use of information society services by means of automated procedures using technical specifications.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.

9. Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – that has a legal effect on you or significantly affects you in a similar way. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the person responsible,

(2) is permissible on the basis of Union or Member State legislation to which the controller is subject, and such legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or

(3) with your express consent.

However, these decisions may not be based on special categories of personal data in accordance with Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the cases mentioned in (1) and (3), the controller shall take appropriate measures to safeguard the rights and freedoms and your legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

10. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

As of: 03.05.2023