1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is PAJ UG (haftungsbeschränkt), Am Wieschen 1, 51570 Windeck, Deutschland, Tel.: +49 (0) 2292 39 499 59, E-Mail: info@paj-gps.de. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
2) Data Collection When You Visit Our Website
2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
3) Cookies
In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called "session cookies"), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.
If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.
You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.
Please note that the functionality of our website may be limited if cookies are not accepted.
4) Contacting Us
4.1 WhatsApp Business
We offer visitors to our website the opportunity to contact us via the WhatsApp news service of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For this purpose, we use the so-called "Business Version" of WhatsApp.
If you contact us via WhatsApp in connection with a specific business transaction (e.g. an order placed), we will store and use the mobile telephone number you use at WhatsApp and - if provided - your first name and surname in accordance with Art. 6 para. 1 lit. b. GDPR to process and answer your request. Based on the same legal basis, we will ask you via WhatsApp to provide further data (order number, customer number, address or e-mail address), if necessary, in order to be able to allocate your enquiry to a specific transaction.
If you use our WhatsApp contact for general enquiries (e.g. about the range of services, availability or our website), we will store and use the mobile phone number you use at WhatsApp and - if provided - your first and last name in accordance with Art. 6 Para. 1 lit. f GDPR based on our justified interest in the efficient and prompt provision of the requested information.
Your data will always be used only to answer your request via WhatsApp. Your data will not be passed on to third parties.
Please note that WhatsApp Business gains access to the address book of the mobile device we use for this purpose and automatically transfers telephone numbers stored in the address book to a server of the parent company Meta Platforms Inc. in the USA. To operate our WhatsApp Business account, we use a mobile device whose address book saves only the WhatsApp contact data of those users who have also contacted us via WhatsApp.
This ensures that each person whose WhatsApp contact data is stored in our address book has already consented to the transmission of his WhatsApp telephone number from the address books of his chat contacts in accordance with Art. 6 Para. 1 lit. a GDPR when using the app on his device for the first time by accepting the WhatsApp terms of use. The transmission of data of such users who do not use WhatsApp and/or have not contacted us via WhatsApp is therefore excluded.
For the purpose and scope of data collection and the further processing and use of data by WhatsApp, as well as your rights and setting options for protecting your privacy, please refer to WhatsApp's data protection information: https://www.whatsapp.com
In the course of the above-mentioned processing, data may be transferred to servers of Meta Platforms Inc. in the USA.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
4.2 When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.
The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.
5) Commentary Function
Within the scope of the commentary function on this website, in addition to your comment, information on the time of writing the comment and the name of the commentator you have chosen is stored and published on the website. Furthermore, your IP address is logged and stored. This IP address is stored for security reasons in case the person concerned violates the rights of third parties or posts illegal content by submitting a comment. We need your e-mail address to contact you if a third party should object to your published content as unlawful. The legal basis for the storage of your data is Art. 6 (1) point b and f GDPR. We reserve the right to delete comments if they are objected to as unlawful by third parties.
6) Processing of Data for the Purpose of Order Handling
6.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Para. 1 lit. b GDPR.
If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by post or e-mail) about upcoming updates within the legally stipulated period of time within the framework of our statutory duty to inform pursuant to Art. 6 Para. 1 lit. c GDPR. Your contact details will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent that this is necessary for the respective information.
In order to process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.
6.2 Amazon
We use the following provider for order processing: Amazon EU S.a r.l., 38 avenue John F. Kennedy, L-1855 Luxembourg
Name, address and, if applicable, other personal data will be passed on to the provider in accordance with Art. 6 (1) point b GDPR exclusively for the purpose of processing the online order. Your data will only be passed on insofar as this is actually necessary for the processing of the order.
6.3 Use of Payment Service Providers
- Amazon Pay
Online payment methods from the following provider are available on this website: Amazon Payments Europe s.c.a., 38 avenue John F. Kennedy, L-1855 Luxembourg
If you select a payment method of the provider for which you make an advance payment (e.g. credit card payment), your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.
- Apple Pay
If you choose the payment method "Apple Pay" of Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, the payment processing is carried out via the "Apple Pay" function of your terminal device operated with iOS, watchOS or macOS by debiting a payment card deposited with "Apple Pay". Apple Pay uses security features built into the hardware and software of your device to protect your transactions. In order to release a payment, it is therefore necessary to enter a code previously defined by you and to verify it using the "Face ID" or "Touch ID" function of your terminal.
For the purpose of payment processing, your information provided during the ordering process, along with information about your order, will be transmitted to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay for payment processing. The encryption ensures that only the website from which the purchase was made can access the payment information. After the payment is made, Apple sends your device account number and a transaction-specific dynamic security code to the originating website to confirm the payment.
If personal data is processed in the described transmissions, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 Para. 1 lit. b GDPR.
Apple retains anonymised transaction data, including the approximate amount of the purchase, the approximate date and time and whether the transaction was completed successfully. Anonymisation completely excludes any personal reference. Apple uses the anonymised data to improve Apple Pay and other Apple products and services.
When you use Apple Pay on iPhone or the Apple Watch to complete a purchase made through Safari on Mac, the Mac and the authorization device communicate through an encrypted channel on Apple's servers. Apple does not process or store this information in any format that can identify you personally. You can disable the ability to use Apple Pay on your Mac in your iPhone preferences. Go to "Wallet & Apple Pay" and disable "Allow payments on Mac".
For more information about Apple Pay privacy, please visit the following web address: https://support.apple.com
- Google Pay
If you choose the payment method "Google Pay" of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), the payment processing is carried out via the "Google Pay" application of your mobile device running at least Android 4.4 ("KitKat") and having an NFC function by charging a payment card deposited at Google Pay or a payment system verified there (e.g. PayPal). For the release of a payment via Google Pay in the amount of more than 25,- € the prior unlocking of your mobile device by the respective verification measure (e.g. face recognition, password, fingerprint or pattern) is required.
For the purpose of payment processing, your information provided during the ordering process, together with the information about your order, will be forwarded to Google. Google then transmits your payment information stored in Google Pay in the form of a unique transaction number to the source website, which is used to verify a payment. This transaction number does not contain any information about the real payment data of your means of payment deposited with Google Pay, but is created and transmitted as a uniquely valid numeric token. For all transactions via Google Pay, Google acts merely as an intermediary to process the payment transaction. The transaction is carried out exclusively in the relationship between the user and the source website by debiting the means of payment deposited with Google Pay.
If personal data are processed in the described transmissions, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 para. 1 lit. b GDPR.
Google reserves the right to collect, store and evaluate certain transaction-specific information for each transaction made via Google Pay. This includes the date, time and amount of the transaction, the merchant's location and description, a description provided by the merchant of the goods or services purchased, photos that you have attached to the transaction, the name and email address of the seller and buyer or the sender and recipient, the payment method used, your description of the reason for the transaction and, if applicable, the offer associated with the transaction.
According to Google, this processing is carried out exclusively in accordance with Art. 6 para. 1 lit. f GDPR on the basis of the legitimate interest in proper accounting, verification of transaction data and optimisation and maintenance of the functionality of the Google Pay service.
Google also reserves the right to combine the processed transaction data with other information which is collected and stored by Google when using other Google services.
The terms of use of Google Pay can be found here:
https://payments.google.com
Further information on data protection at Google Pay can be found at the following Internet address:
https://payments.google.com
- Paypal
Online payment methods from the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg
If you select a payment method of the provider for which you make an advance payment, your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.
When selecting a payment method of the provider with which the provider makes advance payments, you will also be asked to provide certain personal data (first name and surname, street, house number, postcode, city, date of birth, e-mail address, telephone number, if applicable data on alternative means of payment) during the ordering process.
In order to safeguard our legitimate interest in determining the solvency of our customers, this data is passed on to the provider by us for the purpose of a credit check in accordance with Art. 6 (1) point f GDPR. On the basis of the personal data provided by you as well as further data (such as shopping cart, invoice total, order history, payment history), the provider checks whether the payment option selected by you can be granted with regard to payment and/or bad debt risks.
The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data.
You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for the contractual processing of payments.
- SOFORT
Online payment methods from the following provider are available on this website: SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany
If you select a payment method of the provider for which you make an advance payment (e.g. credit card payment), your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.
- Stripe
Online payment methods from the following provider are available on this website: Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland
If you select a payment method of the provider for which you make an advance payment (e.g. credit card payment), your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.
6.4 Electronic termination option for continuing obligations with consumers
Consumers who have concluded contracts on this website for continuing obligations for which payment is required (e.g., subscription contracts) have the option of terminating these contracts via an electronic button in accordance with the applicable notice periods. Pressing the button leads to a confirmation page on which the consumer can provide more detailed information on the termination, clearly identify himself and subsequently declare his termination electronically. The collection of personal data and its transmission to us is carried out in accordance with Art. 6 (1) point b GDPR and only to the extent necessary for the proper processing of the termination. Pursuant to Art. 6 (1) point b GDPR, the provided personal data will also be used to confirm receipt of the termination declaration and the termination date by electronic means in text form. The additional legal basis for such processing is Art. 6 (1) point c GDPR. We are legally obliged to provide an electronic termination option for consumer contracts concluded by means of electronic commerce regarding continuing obligations for which payment is required.
7) Web Analysis Services
Google (Universal) Analytics
This website uses Google (Universal) Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").
Google (Universal) Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website (including the abbreviated IP address) is usually transferred to a Google server and stored there and may also be transferred to the servers of Google LLC. in the USA.
This website uses Google (Universal) Analytics exclusively with the extension "_anonymizeIp()", which ensures anonymization of the IP address by shortening it and excludes the possibility of direct personal reference. Through the extension, your IP address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area before. Only in exceptional cases will the full IP address be transferred to a server of Google LLC. in the USA and shortened there.
On our behalf, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide us with further services related to the use of the website and the Internet. The IP address transmitted by your browser within the framework of Google (Universal) Analytics is not combined with other Google data.
All the processing described above, in particular the setting of Google Analytics cookies for reading information on the terminal device used, is only carried out if you have given us your express consent in accordance with Art. 6 Para. 1 letter a GDPR. Without this consent, the use of Google Analytics during your visit to our website will not take place.
You can withdraw your consent at any time with effect for the future. To exercise your right of withdrawal of consent, please deactivate this service in the "Cookie-Consent-Tool" provided on the website.
We have concluded an order processing agreement with Google, which ensures the protection of our site visitors' data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Further information about Google (Universal) Analytics can be found here: https://policies.google.com
Demographics
Via a special function called "Demographics", Google Analytics also enables the compilation of statistics with statements about the age, gender and interests of site visitors based on an evaluation of interest-related advertising and with the use of third-party information. This allows the definition and differentiation of user groups of the website for the purpose of target-group-optimized marketing measures. However, data sets collected via "Demographics" cannot be assigned to a specific person.
Details on the processing operations initiated and on Google's handling of data collected from websites can be found here: https://policies.google.com
Google Signals
On this website, the "Google Signals" service can also be used as an extension of Google Analytics. With Google Signals, cross-device reports can be created by Google (so-called "cross-device tracking"). If you have activated "personalised ads" in your Google account settings and you have linked your internet-enabled devices to your Google account, Google can analyse user behaviour across devices and create database models based on this, provided you have given your consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR (see above). The logins and device types of all page visitors who were logged into a Google account and performed a conversion are taken into account. The data shows, among other things, on which device you first clicked on an ad and on which device the associated conversion took place. Insofar as Google Signals is used, we do not receive any personal data from Google, but only statistics compiled on the basis of Google Signals. You have the option of deactivating the "personalised ads" function in the settings of your Google account and thus turning off the cross-device analysis. To do this, follow the instructions on this page: https://support.google.com
Further information can be found here: https://support.google.com
UserIDs
As an extension of Google Analytics, the "UserIDs" function can also be used on this website. By assigning individual UserIDs, we can have Google create cross-device reports (so-called "cross-device tracking"). This means that your usage behaviour can also be analysed across devices if you have given your corresponding consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR, if you have set up a personal account by registering on this website and are logged into your personal account on different end devices with your relevant login data. The data collected in this way shows, among other things, on which end device you clicked on an ad for the first time and on which end device the relevant conversion took place.
8) Retargeting/Remarketing/ Referral Advertising
Facebook pixel for creating custom audiences (without Cookie Consent Tool)
Within our online offer, the so-called "Facebook pixel" of the social network Facebook is applied. It is operated by Meta Platforms Ireland Limited, 4 Grand Canal Quay, Square, Dublin 2, Ireland (hereinafter "Facebook").
If a user clicks on an advertisement placed by us, which is displayed on Facebook, an addition is added to the URL of our linked page by Facebook pixels. If our page allows data to be shared with Facebook via pixels, this URL parameter is written into the user's browser via a cookie, which is set by the linked page itself. This cookie is then read by Facebook Pixel and enables the data to be forwarded to Facebook.
With the help of the Facebook pixel, Facebook is able to determine visitors of our online offer as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, the Facebook pixel to display Facebook ads placed by us will be presented only to Facebook users who have shown an interest in our online offer or who demonstrate certain characteristics (e.g., interest in certain topics or products determined by means of the websites visited) which we will transmit to Facebook (so-called "custom audiences"). When using Facebook pixels, we also want to ensure that our Facebook ads match the potential interest of users and are not annoying. This allows us to evaluate the effectiveness of Facebook ads for statistical and market research purposes by tracking whether users were forwarded to our website after clicking on a Facebook ad ("conversion").
The collected data is anonymous and does not provide us with any information about the user’s identity. However, the data is stored and processed by Facebook to enable a connection to the respective user profile and to allow Facebook to use the data for its own advertising purposes in accordance with the Facebook Data Usage Guidelines (https://www.facebook.com
The data processing associated with the use of the Facebook pixel is based on our predominantly legitimate interest in the evaluation, optimization and economic operation of our online offer and our advertising measures in accordance with Art. 6 (1) point f GDPR.
The information generated by Facebook is usually transferred to a Facebook server and stored there. This may also result in transmission to the servers of Meta Platforms Inc. in the USA.
If you want to object to the collection by Facebook pixels and the use of your data for presenting Facebook ads, you can set an opt-out cookie by clicking on the following link, which deactivates Facebook pixel tracking:
disable Facebook pixels
This opt-out cookie only works in this browser and only for this domain. If you delete your cookies in this browser, you must click on the above link again.
To the extent required by law, we have obtained your consent to the processing of your data as described in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future. In order to exercise your right of revocation, please follow the procedure described above.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
9) Tools and Miscellaneous
This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box.
Using the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.
The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point GDPR based on our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.
Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.
Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.
10) Rights of the Data Subject
10.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:
- Right of access by the data subject pursuant to Art. 15 GDPR;
- Right to rectification pursuant to Art. 16 GDPR;
- Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
- Right to restriction of processing pursuant to Art. 18 GDPR;
- Right to be informed pursuant to Art. 19 GDPR;
- Right to data portability pursuant to Art. 20 GDPR;
- Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
- Right to lodge a complaint pursuant to Art. 77 GDPR.
10.2 RIGHT TO OBJECT
IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
11) Duration of Storage of Personal Data
The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).
If personal data is processed basis on an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.
If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.
When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If personal data is processed for the purpose of direct marketing based on Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.
Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.
Privacy Policy
1) Introduction and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and we appreciate your interest. Below we inform you about the handling of your personal data when using our website. Personal data are all data with which you can be personally identified.
1.2 The data controller for this website, within the meaning of the General Data Protection Regulation (GDPR), is PAJ UG (limited), Am Wieschen 1, 51570 Windeck, Germany, Tel.: +49 (0) 2292 39 499 59, Email: info@paj-gps.de. The data controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 The data controller has appointed a data protection officer, who can be contacted as follows: Johannes Schmitz, Am Wieschen 1, 51570 Windeck, +49 (0) 2292 3949959, j.schmitz@paj-gps.de
2) Collection of Data When Visiting Our Website
2.1 When using our website for informational purposes only, i.e., if you do not register or otherwise provide us with information, we only collect the data that your browser sends to our server (so-called “server log files”). When you visit our website, we collect the following data that is technically necessary to display the website to you:
- The website visited by you
- Date and time of access
- Amount of data sent in bytes
- Source/reference from which you accessed the site
- Browser used
- Operating system used
- IP address used (possibly in anonymized form)
Processing is carried out in accordance with Art. 6(1)(f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to subsequently check the server log files if there are concrete indications of illegal use.
2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the data controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the sequence “https://” and the lock symbol in your browser line.
3) Cookies
In order to make your visit to our website attractive and to enable the use of certain functions, we use cookies, which are small text files that are stored on your device. Some of these cookies are automatically deleted after you close your browser (so-called “session cookies”), while others remain on your device for a longer period and enable us to save page settings (so-called “persistent cookies”). In the latter case, you can check the duration of storage in your web browser’s cookie settings.
If some of the cookies we use also process personal data, such processing is carried out in accordance with Art. 6(1)(b) GDPR for the performance of the contract, in accordance with Art. 6(1)(a) GDPR in the event of consent given, or in accordance with Art. 6(1)(f) GDPR to protect our legitimate interests in the optimal functionality of the website and a user-friendly and effective design of the visit to the page.
You can configure your browser to be informed about the setting of cookies and to decide individually on their acceptance or to exclude the acceptance of cookies for specific cases or in general.
Please note that if you do not accept cookies, the functionality of our website may be limited.
4) Contact
4.1 Zammad
For processing customer inquiries, we use the email ticket system of the following provider: Zammad GmbH, Marienstraße 11, 10117 Berlin, Germany.
When you send contact requests through our website via email, they are stored and organized in the ticket system to enable chronological processing and improve the service experience. You can track the current status of your request processing via the individually assigned ticket number.
For the organization and processing of inquiries, personal data is collected, transmitted to the provider, stored, and read to the extent of its provision, but at least name, surname, and email address.
The legal basis for processing this data is our legitimate interest in efficient customer service management, responding as quickly as possible to your inquiry, and optimizing our service offering in accordance with Art. 6(1)(f) GDPR.
We have entered into a data processing agreement with the provider to ensure the protection of our website visitors’ data and prohibit unauthorized transmission to third parties.
4.2 WhatsApp Business
We offer visitors to our website the opportunity to contact us via the WhatsApp messaging service of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, using the “Business” version of WhatsApp.
If you contact us via WhatsApp for a specific business purpose (e.g., a placed order), we store and use the mobile number you use on WhatsApp and, if provided, your first and last name in accordance with Art. 6(1)(b) GDPR to process and respond to your inquiry. With the same legal basis, we may ask you to provide further data (order number, customer number, address, or email) to assign your inquiry to a specific process.
If you use our WhatsApp contact for general inquiries (such as about our service range, availability, or our website), we store and use the mobile number you use on WhatsApp and, if provided, your first and last name in accordance with Art. 6(1)(f) GDPR based on our legitimate interest in efficiently and promptly providing the requested information.
Your data is always used only to respond to your inquiry via WhatsApp. No transmission to third parties takes place.
Please note that WhatsApp Business has access to the address book of the mobile device we use to operate our WhatsApp Business account and automatically transfers the phone numbers stored in the address book to a server of the parent company Meta Platforms Inc. in the USA. For the operation of our WhatsApp Business account, we use a mobile device in whose address book only the WhatsApp contact details of those users who have also contacted us via WhatsApp are stored.
This ensures that anyone whose WhatsApp contact details are stored in our address book has already consented to the transmission of their WhatsApp phone number from the address books of their chat contacts by accepting WhatsApp’s terms of use the first time they used the app on their device, in accordance with Art. 6(1)(a) GDPR. Therefore, the transmission of data from users who do not use WhatsApp and/or who have not contacted us via WhatsApp is excluded.
For more information on the purpose and scope of data collection and the further processing and use of data by WhatsApp, as well as your rights and options to protect your privacy, please refer to WhatsApp’s privacy policy: https://www.whatsapp.com
As part of the aforementioned processing, data may be transferred to servers of Meta Platforms Inc. in the USA.
For data transfers to the USA, the provider has adhered to the EU-US Data Privacy Framework (EU-US Data Privacy Shield), which ensures compliance with the European data protection level based on a adequacy decision of the European Commission.
4.3 In the context of contacting us (e.g., via a contact form or email), personal data is processed exclusively for the purpose of processing and responding to your inquiry and only to the extent necessary.
The legal basis for processing this data is our legitimate interest in responding to your inquiry in accordance with Art. 6(1)(f) GDPR. If your contact is directed to the conclusion of a contract, then the additional legal basis for processing is Art. 6(1)(b) GDPR. Your data will be deleted when it can be deduced from the circumstances that the matter in question has been conclusively resolved and provided there are no legal retention obligations.
5) Commentary Function
Within the framework of the comment function on this website, in addition to your comment, details such as the time of creation of the comment and the commentator’s name you have selected are also stored and published on this website. Additionally, your IP address is logged and stored. This IP address storage is carried out for security reasons and in the event that the affected person violates the rights of third parties or publishes illegal content with a comment. We need your email address to contact you in case a third party alleges that the published content is illegal.
The legal bases for storing your data are Art. 6(1)(b) and (f) GDPR. We reserve the right to delete comments if they are contested as illegal by third parties.
6) Use of Customer Data for Direct Advertising
6.1 Subscription to our email newsletter
When you subscribe to our email newsletter, we regularly send you information about our offers. The only requirement for sending the newsletter is your email address. Providing additional data is voluntary and is used to address you personally. For sending the newsletter, we use the double opt-in procedure, which ensures that you only receive the newsletter once you have explicitly confirmed your consent to receive it via a verification link sent to the provided email address.
By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6(1)(a) GDPR. We record the IP address provided by your internet service provider (ISP) as well as the date and time of subscription, to be able to trace any possible misuse of your email address at a later time. The data collected during newsletter subscription is used strictly for specific purposes.
You can unsubscribe from the newsletter at any time using the unsubscribe link provided in the newsletter or by sending a message to the responsible party mentioned at the beginning. Once unsubscribed, your email address will be immediately deleted from our newsletter distributor, unless you have given express consent for further use of your data or we reserve the right to use your data for additional purposes permitted by law and about which we will inform you in this statement.
6.2 Klaviyo
The sending of our email newsletter is done through this provider: Klaviyo, 225 Franklin St, Boston, MA 02110, USA.
Based on our legitimate interest in effective and user-friendly newsletter marketing, we transmit the data provided during newsletter registration to this provider for handling newsletter distribution on our behalf in accordance with Art. 6(1)(f) GDPR.
Subject to your express consent under Art. 6(1)(a) GDPR, the provider also performs statistical evaluation of newsletter campaign success using web beacons or tracking pixels in sent emails, which can measure open rates and specific interactions with newsletter content. Device-specific information (e.g., access time, IP address, browser type, and operating system) is also collected and evaluated, but not combined with other data sets.
You can revoke your consent to newsletter tracking at any time with effect for the future.
We have entered into a data processing agreement with the provider that protects the data of visitors to our website and prohibits transmission to third parties.
For data transfers to the USA, the provider has adhered to the EU-US Data Privacy Framework (EU-US Data Privacy Shield), which ensures compliance with the European data protection level based on an adequacy decision of the European Commission.
6.3 Product availability notification by email
For temporarily unavailable items, you can subscribe to receive email notifications about product availability. We only need your email address to send you this notification. Providing additional data is voluntary and can be used to address you personally. For sending emails, we use the double opt-in procedure, which ensures that you will only receive a notification after you have expressly confirmed your consent via a verification link sent to your email address.
By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6(1)(a) GDPR. We save the IP address assigned by your Internet service provider (ISP) and the date and time of subscription, to be able to track any possible misuse of your email address at a later time. The data collected when registering for our product availability email notification service is used strictly for specific purposes.
You can unsubscribe from availability notifications at any time by sending a message to the responsible party mentioned at the beginning. After unsubscribing, your email address will be immediately deleted from our distribution list unless you have given express consent for further use of your data or we reserve the right to use your data for additional purposes permitted by law and about which we will inform you in this statement.
6.4 Email Shopping Cart Reminders
If you abandon your purchase with us before completing the order, you have the option to be reminded via email about the contents of your virtual shopping cart once.
We only need your email address to send this reminder. Providing additional data is voluntary and can be used to address you personally. For email delivery, we use the double opt-in procedure, ensuring that you will only receive a notification after you have explicitly confirmed your consent via a verification link sent to your email address.
By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6(1)(a) GDPR to send a shopping cart reminder. We save the IP address assigned by your Internet service provider (ISP) as well as the date and time of subscription, to be able to track any possible misuse of your email address at a later time. The data collected when registering for our email notification service is used strictly for specific purposes.
You can unsubscribe from shopping cart reminders at any time by sending a message to the responsible party mentioned at the beginning. After unsubscribing, your email address will be immediately deleted from our distribution list unless you have given express consent for further use of your data or we reserve the right to use your data for additional purposes permitted by law and about which we will inform you in this statement.
6.5 Visitor Recovery Software
This website utilizes the visitor recovery software solution provided by Exceed Solutions GmbH, c/o Bennet Polenz, Bunsenstr. 5, 22765 Hamburg.
We process your session data (URL, referrer URL, page access times and redirects, content information about the user’s session, e.g., products in the cart; product price; categories, delivery price, purchase time, etc.), session ID for identification, to present you with additional products that may be of interest. To the extent that we store or access this information on your device, this is done based on your consent in accordance with § 25 Abs. 1 TTDSG. Subsequent processing of your personal data is also based on your consent.
7) Data Processing for Order Management
7.1 To the extent necessary for contract performance for delivery and payment purposes, the personal data collected by us will be transmitted according to Art. 6(1)(b) GDPR to the responsible carrier and the responsible bank.
If, based on a corresponding contract, we owe you updates for goods with digital elements or for digital products, we process the contact data you provide when placing the order (name, address, email address) to personally inform you about pending updates within the legally prescribed period via the appropriate communication medium (e.g., by postal or email), in accordance with our legal information obligations according to Art. 6(1)(c) GDPR. Your contact details will be strictly used for the purpose of communicating the updates we owe and will be processed only to the extent necessary for each information.
To process your order, we also work with the following service provider(s) who assist us wholly or partially in executing the closed contracts. Certain personal data is transmitted to these service providers in accordance with the following information.
7.2 Amazon
For order management, we use the following provider: Amazon EU S.à r.l., 38 avenue John F. Kennedy, L-1855 Luxembourg.
The name, address, and other personal data are transmitted exclusively for the purpose of managing the online order to the provider according to Art. 6(1)(b) GDPR. The transmission of your data only occurs to the extent that it is actually necessary for order management.
8) Web Analytics Services
8.1 Google Analytics 4
This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), to analyze the usage of our website.
By default, when visiting the website, cookies for Google Analytics 4 are set, which are small text fragments stored on your device and collect certain information. This information includes your IP address, which is truncated by Google in its last digits to prevent direct identification of individuals.
The information is transmitted to Google servers and processed there. This may also involve transfers to Google LLC based in the USA.
Google uses the information collected on our behalf to evaluate your use of the website, compile reports on website activity for us, and provide other services related to website usage and internet usage. The IP address transmitted and truncated by your browser as part of Google Analytics is not combined with other Google data. The data collected in the context of Google Analytics 4 is stored for two months and then deleted.
All the processing described above, especially the setting of cookies on the device used, only occurs if you give us your explicit consent according to Art. 6(1)(a) GDPR.
Without your consent, Google Analytics 4 will not be used during your visit to the site. You can revoke your consent at any time with future effect. To exercise your right to revoke, deactivate this service using the “cookie consent tool” provided on the website.
We have entered into a data processing agreement with Google that ensures the protection of our site visitors’ data and prohibits unauthorized disclosure to third parties.
You can find more legal information about Google Analytics 4 at https://policies.google.com
Demographic Features
Google Analytics 4 uses the special function “demographic features” and can generate statistics that provide information about the age, gender, and interests of site visitors. This is done by analyzing advertising and third-party information. This allows for identifying audiences for marketing activities. However, the data collected cannot be associated with a specific person and is deleted after two months of storage.
Google Signals
As an extension of Google Analytics 4, this website may use Google Signals to enable cross-device reporting. If you have activated personalized ads and have linked your devices to your Google account, Google can analyze your cross-device usage behavior, subject to your consent to use Google Analytics, according to Art. 6(1)(a) GDPR, and create database models, including cross-device conversions. We do not receive personal data from Google, only statistics. If you wish to stop cross-device analysis, you can disable the “Personalized advertising” feature in your Google account settings. Follow the instructions on this page: https://support.google.com
UserIDs
As an extension of Google Analytics 4, this website may use the “UserIDs” feature. If you have given your consent to use Google Analytics 4 according to Art. 6(1)(a) GDPR, have created an account on this site, and have logged in on various devices with that account, your activities, including conversions, can be analyzed across devices.
For data transfers to the USA, the provider has adhered to the EU-US Data Privacy Framework, which ensures compliance with the European data protection level according to a decision of adequacy by the European Commission.
8.2 Microsoft Clarity
This website uses the web analytics service provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
By using cookies and/or similar technologies (tracking pixels, web beacons, algorithms to read device and browser information), the service collects and stores pseudonymized visitor data, including device information such as IP address and browser data, to statistically analyze usage behavior on our website and create pseudonymized usage profiles. This allows, among other things, the evaluation of movement patterns (e.g., heatmaps) showing the duration of page visits and interactions with page content (such as text entries, scrolls, clicks, and mouse movements). Pseudonymization essentially removes the possibility of direct identification of the individual. No combination is made with other clear data collected about you.
All the processes described above, especially reading or storing information on the device used, are only carried out if you have given us your explicit consent in accordance with Art. 6(1)(a) GDPR. You can revoke your consent given at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
We have entered into a data processing agreement with the provider ensuring the protection of our site visitors’ data and prohibiting unauthorized disclosure to third parties.
For data transfers to the USA, the provider has adhered to the EU-US Data Privacy Framework, which ensures compliance with the European data protection level according to a decision of adequacy by the European Commission.
9) Page Functionality
Google Web Fonts
This page uses Web Fonts provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, for a uniform presentation of fonts.
When you access a page, your browser loads the necessary Web Fonts into your cache to display texts and fonts correctly, and establishes a direct connection to the provider’s servers. During this process, certain browser information, including your IP address, is sent to the provider.
Data may also be transmitted to: Google LLC, USA.
The processing of personal data when connecting to the font provider is only carried out if you have given us your explicit consent in accordance with Art. 6(1)(a) GDPR. You can revoke your consent at any time with future effect by deactivating this service using the cookie consent tool provided on the website. If your browser does not support Web Fonts, a standard font from your computer will be used.
For data transfers to the USA, the provider has adhered to the EU-US Privacy Shield, which ensures compliance with the European data protection level according to a decision of adequacy by the European Commission.
10) Cookie Consent Tool
This website uses a cookie consent tool to obtain effective user consents for cookies requiring consent and cookie-based applications. The cookie consent tool is presented to users in the form of an interactive user interface when accessing the page, where consents for certain cookies and/or cookie-based applications can be given by checking boxes. The tool ensures that all cookies/services requiring consent are only loaded if the respective user has given explicit consent. This ensures that such cookies are only installed on the user’s device if consent is given.
The tool sets technically necessary cookies to save your cookie preferences. No personal data of users is processed in general.
If personal data is processed in individual cases to store, assign, or record cookie settings (such as IP address), this is done in accordance with Art. 6(1)(f) GDPR, based on our legitimate interest in a user-specific, user-friendly consent management for cookies, and therefore on a legal configuration of our internet presence.
Another legal basis for processing is Art. 6(1)(c) GDPR. As controllers, we are legally obligated to make the use of cookies that are not technically necessary dependent on the consent of the respective user.
To the extent necessary, we have entered into a data processing agreement with the provider ensuring the protection of our page visitors’ data and prohibiting unauthorized transfer to third parties.
You can find more information about the operator and the settings options of the cookie consent tool directly in the corresponding user interface on our website.
11) Rights of the Data Subject
11.1 The applicable data protection law grants you the following rights vis-à-vis the controller concerning the processing of your personal data (rights of access and intervention), for which reference is made to the corresponding legal basis:
- Right of access according to Art. 15 GDPR;
- Right to rectification according to Art. 16 GDPR;
- Right to erasure according to Art. 17 GDPR;
- Right to restriction of processing according to Art. 18 GDPR;
- Right to be informed according to Art. 19 GDPR;
- Right to data portability according to Art. 20 GDPR;
- Right to withdraw consent granted according to Art. 7(3) GDPR;
- Right to lodge a complaint according to Art. 77 GDPR.
11.2 RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERWHELMING LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL TERMINATE THE PROCESSING OF THE AFFECTED DATA. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR IF THE PROCESSING SERVES TO ESTABLISH, EXERCISE, OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA TO CARRY OUT DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THIS PURPOSE. YOU CAN EXERCISE YOUR OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL TERMINATE THE PROCESSING OF YOUR DATA FOR DIRECT MARKETING PURPOSES.
12) Duration of Personal Data Storage
The duration of personal data storage is based on the corresponding legal basis, the purpose of processing, and, if applicable, also on relevant legal retention periods (e.g., commercial and tax retention periods).
When personal data is processed based on express consent in accordance with Art. 6(1)(a) GDPR, it will be stored until you revoke your consent.
If there are legal retention periods for data processed in the context of contractual obligations or similar based on Art. 6(1)(b) GDPR, this data will be routinely deleted after the retention periods expire, provided it is no longer necessary for contract execution or preparation and/or there is no legitimate interest on our part in its continued storage.
When personal data is processed based on Art. 6(1)(f) GDPR, it will be stored until you exercise your right to object according to Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
In the case of processing personal data for direct marketing purposes based on Art. 6(1)(f) GDPR, it will be stored until you exercise your right to object according to Art. 21(2) GDPR.
Unless otherwise specified elsewhere in this statement regarding specific processing situations, stored personal data will be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.