Privacy Policy

We take data protection seriously

The protection of your privacy when processing personal data is a very important concern for us. When you visit our website, our web servers store, by default, the IP of your Internet Service Provider, the website from which you visit us, the pages you visit on our site, and the date and duration of your visit. This information is essential for the technical transmission of the websites and secure server operation. A personalized evaluation of this data does not take place.

If you send us data via a contact form, this data will be stored on our servers in the course of data backup. Your data will be used by us exclusively to process your request. Your data will be treated with strict confidentiality. It will not be passed on to third parties.

Controller:
EDS Automotive GmbH
Detmoldstraße 2 / 1st Floor
D-80935 Munich
Tel.: +49 89 550 069 44
E-Mail: info@eds-automotive.com

Personal Data

Personal data is data about your person. This includes your name, your address, and your email address. You do not have to disclose any personal data to be able to visit our website. In some cases, we need your name and address as well as other information to be able to offer you the desired service.

The same applies if we supply you with informational material upon request or if we answer your inquiries. In these cases, we will always point this out to you. Furthermore, we only store the data that you have transmitted to us automatically or voluntarily.

When you use one of our services, we generally only collect the data that is necessary to offer you our service. We may ask you for further information, which is, however, of a voluntary nature. Whenever we process personal data, we do so to be able to offer you our service or to pursue our commercial goals.

Contacting Us

When you contact us (e.g., via contact form, email, telephone, or social media), the information of the inquiring persons is processed to the extent necessary to answer the contact requests and any requested measures.

The answering of contact requests within the framework of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and, for the rest, on the basis of legitimate interests in answering the inquiries.

• Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., entries in online forms).
• Data subjects: Communication partners.
• Purposes of processing: Contact requests and communication.
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Automatically Stored Data

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Date and time of the request
• Name of the requested file
• Page from which the file was requested
• Access status (file transferred, file not found, etc.)
• Web browser and operating system used
• Complete IP address of the requesting computer
• Amount of data transferred

This data is not merged with other data sources. The processing is carried out in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website.

For reasons of technical security, in particular to defend against attempted attacks on our web server, this data is stored by us for a short period. It is not possible for us to draw conclusions about individual persons on the basis of this data. After seven days at the latest, the data is anonymized by shortening the IP address at the domain level, so that it is no longer possible to establish a reference to the individual user. In anonymized form, the data is also processed for statistical purposes; a comparison with other data sets or a transfer to third parties, even in excerpts, does not take place.

Cookies

Our websites use so-called cookies. Cookies are small data packets that do not cause any damage to your computer. They are stored on your end device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or they are automatically deleted by your web browser.

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies can be used to analyze user behavior or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions you desire (e.g., for the shopping cart function), or to optimize the website (e.g., cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent for the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25 (1) of the German Telecommunications Digital Services Data Protection Act (TDDDG)); the consent can be revoked at any time.

Google Maps

This site uses the map service Google Maps. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. With the help of this service, we can embed map material on our website.

To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transmission. If Google Maps is activated, Google may use Google Fonts for the purpose of uniform display of fonts. When you call up Google Maps, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

The use of Google Maps is in the interest of an attractive presentation of our online offers and to make it easy to find the places we have indicated on the website. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user's end device (e.g., device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

More information on handling user data can be found in Google's privacy policy: https://policies.google.com/privacy?hl=en.

The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

Online Presence on Social Media

If you have given your consent to the respective social media operator in accordance with Art. 6(1)(a) GDPR, when you visit our online presences on our social media channels, your data will be automatically collected and stored for market research and advertising purposes, from which usage profiles are created using pseudonyms. These can be used, for example, to place advertisements inside and outside the platforms that presumably correspond to your interests. Cookies are usually used for this purpose. For detailed information on the processing and use of data by the respective social media operator, as well as a contact option and your rights and setting options in this regard to protect your privacy, please refer to the providers' privacy policies linked on their respective websites. Should you nevertheless require help in this regard, you can contact us.

Security

We have taken technical and administrative security precautions to protect your personal data against loss, destruction, manipulation, and unauthorized access. All our employees and service providers working for us are bound by the applicable data protection laws.

Whenever we collect and process personal data, it is encrypted before being transmitted. This means that your data cannot be misused by third parties. Our security precautions are subject to a continuous improvement process and our privacy policies are constantly being revised. Please make sure you have the latest version.

What data is processed and from what sources does this data originate?

We process the data that we have received from you in the context of initiating or processing a contract, on the basis of consent, or as part of your application to us or your employment with us.

Personal data includes:

• Customers: e.g., first and last name, address, contact details (email address, telephone number, fax), bank details.
• Applicants and employees: this includes, e.g., first and last name, address, contact details (email address, telephone number, fax), date of birth, data from CV and letters of reference, bank details, religious affiliation, photographs.
• Business partners: e.g., the designation of their legal representatives, company name, commercial register number, VAT ID number, company number, address, contact person details (email address, telephone number, fax), bank details.
• Online meeting participants: email, name, audio recordings, video recordings.
• Visitors to our company: this includes name and signature.

For what purposes and on what legal basis is the data processed?

We process your data in accordance with the provisions of the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act 2018, as amended:

• for the fulfillment of (pre-)contractual obligations (Art. 6(1)(b) GDPR):

Your data is processed for the purpose of contract execution. The data is processed in particular when initiating business and carrying out contracts with you:

• Applicant management
• Personnel administration
• Payroll accounting
• Customer contracts
• Supplier contracts
• Financial accounting

• for the fulfillment of legal obligations (Art. 6(1)(c) GDPR):

Processing of your data is necessary for the purpose of fulfilling various legal obligations, e.g., from the German Commercial Code or the German Fiscal Code.

• for the protection of legitimate interests (Art. 6(1)(f) GDPR):

Based on a balancing of interests, data processing may take place beyond the actual fulfillment of the contract to protect the legitimate interests of us or third parties. Data processing to protect legitimate interests occurs, for example, in the following cases:

• Advertising or marketing
• To track visits and for access control
• Obtaining credit reports, especially in cases of high risk or to minimize the risk of default in long-term investments in advance
• Judicial and extra-judicial assertion, exercise and/or defense of legal claims (in particular existing contract data, performance data and related advice as well as findings from the ongoing customer relationship)
• Prevention and investigation of criminal offenses
• Video surveillance
• Taking photographs at company events with subsequent publication

• within the scope of your consent (Art. 6(1)(a) GDPR):

If you have given us consent to process your data

Processing of personal data for advertising purposes

You can object to the use of your personal data for advertising purposes at any time, either in whole or for individual measures, without incurring any costs other than the transmission costs according to the basic tariffs.

Under the legal requirements of § 7 para. 3 of the German Act Against Unfair Competition (UWG), we are entitled to use the email address you provided when concluding the contract for direct advertising for our own similar goods or services. You will receive these product recommendations from us regardless of whether you have subscribed to a newsletter.

If you do not wish to receive such recommendations by email from us, you can object to the use of your address for this purpose at any time without incurring any costs other than the transmission costs according to the basic tariffs. A message in text form is sufficient for this. Of course, an unsubscribe link is always included in every email.

Who receives my data?

As a rule, personal data is processed by us as the controller. However, processing by transferring or disclosing personal data to third parties may be necessary in the course of carrying out our activities, especially if one of the following reasons based on the stated legal basis exists:

• It is necessary for the performance of a contract with the data subject or for the implementation of pre-contractual measures at their request (Art. 6(1)(b) GDPR).
• The disclosure is necessary for the establishment, exercise or defense of legal claims and there is no reason to assume that the data subject has an overriding legitimate interest in not having their data disclosed (Art. 6(1)(f) GDPR).
• There is a legal obligation to disclose the data (Art. 6(1)(c) GDPR).
• We have valid consent (Art. 6(1)(a) GDPR).

Categories of recipients in the context of our duties and activities can in particular be:

• Postal, telecommunications, and transport service providers
• Payment and financial service providers
• Sales and business partners and other persons and companies involved in the provision of a service
• Authorities, courts, opposing parties in a claim, other parties involved

In addition, we will indicate if other recipients are considered in the individual processing operations.

Processing by service providers

To carry out our activities, we also use instruction-bound service providers as processors in accordance with Art. 28 GDPR in the context of processing personal data, who are also considered recipients of the data in terms of data protection. A data processing agreement ensures in particular that processing is carried out on the basis of our instructions, that sufficient guarantees for compliance with suitable technical and organizational measures exist, and that the rights of data subjects are guaranteed.

In general, we use service providers for the following processing purposes:

• Hosting of our online offers/websites with providers (infrastructure and platform services, computing capacity, storage space and database services).
• Care, maintenance and servicing of the online offers/websites.
• Implementation, care, maintenance and servicing of IT systems.
• Document and information management.
• Communication, contact and conference systems (email, contacts, appointments, messenger, video conference, etc.).
• File and data carrier destruction

How long will my data be stored?

We generally store personal data as long as it is necessary for the purposes of the respective processing, as long as statutory or regulatory retention periods exist, or as long as we have a legitimate interest in the storage or a corresponding consent from the data subject exists.

We store certain data according to the following rules for the respectively specified duration and delete or destroy it after the specified storage period has expired:

• If the processing is based on your consent, we will delete the data concerned after your revocation
• If none of the following retention periods apply, we will delete
• 3 years: Data and content on legal transactions (including their preparation) as far as necessary for the ability to provide information and defense and for the assertion or defense of claims. This also includes data for marketing and customer care, unless they also fall under a category for a longer storage period.
• 6 years: received and sent commercial letters (§ 257 para. 1 no. 2 and 3, para. 4 HGB - German Commercial Code)
• 10 years: Documents relevant for taxation, accounting records, commercial books (§§ 147 para. 1 AO - German Fiscal Code, 257 para. 1 no. 1 and 4, para. 4 HGB - German Commercial Code).
• 30 years: Data stored due to special circumstances in our own or a third party's interest, as corresponding limitation periods or special retention periods exist (e.g., enforceable titles, special limitation periods).

Is personal data transferred to a third country?

As a matter of principle, we do not transfer any data to a third country. A transfer will only take place in individual cases on the basis of an adequacy decision of the European Commission, standard contractual clauses, suitable guarantees or your express consent.

What are my data protection rights?

You have the right to information, rectification, erasure or restriction of the processing of your stored data at any time, a right to object to the processing as well as a right to data portability and to lodge a complaint in accordance with the requirements of data protection law.

Right to information:

You can request information from us as to whether and to what extent we process your data.

Right to rectification:

If we process your data that is incomplete or incorrect, you can request its correction or completion from us at any time.

Right to erasure:

You can request the erasure of your data from us if we process it unlawfully or if the processing disproportionately interferes with your legitimate interests in protection. Please note that there may be reasons that prevent immediate erasure, e.g., in the case of legally regulated retention obligations.

Regardless of the exercise of your right to erasure, we will delete your data promptly and completely, unless there is a transactional or legal retention obligation to the contrary.

Right to restriction of processing:

You can request us to restrict the processing of your data if

• you contest the accuracy of the data, for a period enabling us to verify the accuracy of the data.
• the processing of the data is unlawful, but you oppose erasure and request restriction of data use instead,
• we no longer need the data for the intended purpose, but you still need this data to assert or defend legal claims, or
• you have objected to the processing of the data.

Right to data portability:

You can request that we provide you with your data, which you have provided to us, in a structured, common and machine-readable format and that you can transmit this data to another controller without hindrance from us, provided that

• we process this data on the basis of a consent given and revocable by you or for the performance of a contract between us, and
• this processing is carried out by automated means.

If technically feasible, you can request a direct transfer of your data to another controller from us.

Right to object:

If we process your data for legitimate interests, you can object to this data processing at any time; this would also apply to profiling based on these provisions. We will then no longer process your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims. You can object to the processing of your data for the purpose of direct marketing at any time without giving reasons.

Right to lodge a complaint:

If you are of the opinion that we are violating German or European data protection law when processing your data, please contact us to clarify any questions. Of course, you also have the right to contact the supervisory authority responsible for you, the respective state office for data protection supervision.

If you wish to assert one of the aforementioned rights against us, please contact our data protection officer. In case of doubt, we may request additional information to confirm your identity.

Am I obliged to provide data?

The processing of your data is necessary to conclude or fulfill your contract with us. If you do not provide us with this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and will consequently have to terminate it. However, you are not obliged to give consent to data processing with regard to data that is not relevant for the performance of the contract or is not required by law.

Changes to this privacy policy

We reserve the right to change our privacy policies if this should become necessary due to new technologies. Please make sure you have the latest version. If fundamental changes are made to this privacy policy, we will announce them on our website.

All interested parties and visitors to our website can reach us on data protection matters at:

Projekt 29 GmbH & Co. KG
Ostengasse 14
93047 Regensburg

Tel.: 0941 2986930
Fax: 0941 29869316
E-Mail: anfragen@projekt29.de
Internet: www.projekt29.de