Privacy policy for communication via WhatsApp and processing of data in the USA
Content:
1. Who is responsible for data processing and who can I contact?
2. What is it about?
3. How is your data processed when using WhatsApp?
4. Who receives your data?
5. When is your data deleted?
6. What rights do you have when it comes to the processing of your data?
7. Changing and updating the privacy policy
If you would like to communicate with us via WhatsApp, we ask you to note the following information on the functionality, encryption, risks of WhatsApp, use of metadata within the Facebook group of companies and your objection options.
You do not have to use WhatsApp and can contact us through alternative means, such as via phone or email. Please use the contact options provided to you or the contact options provided on our website.
1. Who is responsible for data processing and who can I contact?
The responsible within the meaning of the General Data Protection Regulation is the:
INTERNORM Kunststofftechnik GmbH
Robert-Bosch-Str. 5
D-49401 Damme
Mail: info@internorm.de
Imprint: https://www.internorm.de/impressum
(hereinafter also referred to as „INTERNORM Kunststofftechnik GmbH“ or „we“)
If you have any questions about this privacy statement or about the protection of your data by INTERNORM Kunststofftechnik GmbH you can also contact our data protection officer at any time:
Carla Holterhus
Mail: datenschutz@internorm.de
2. What is it about?
With WhatsApp (WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland) it is a US service, which means that the data you send via WhatsApp may first be transmitted to WhatsApp in the USA before being forwarded to us. According to Facebook, the transfer takes place on the basis of so-called EU standard contractual clauses.
We would like to point out that according to the European Court of Justice, there is no level of data protection in the USA that corresponds to that in the EU, and in this respect no suitable guarantees for data protection can be given (possible access by state authorities and no enforceability of the rights of those affected).
3. How is your data processed when using WhatsApp?
WhatsApp assures that the communication content (i.e. the content of your message and attached images) is encrypted end-to-end. This means that the content of the messages is not viewable, not even by WhatsApp itself. You should always use an up-to-date version of WhatsApp to ensure that the message content is encrypted.
The following personal data is collected, processed and stored as part of the WhatsApp service:
• Phone number
• WhatsApp name
• Contents of the received and sent WhatsApp messages
• Date and time of the received and sent WhatsApp messages
4. Who receives your data?
However, we would like to point out to you as our communication partners, i.e. in particular customers and interested parties, that WhatsApp cannot see the content, but can find out that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of your device, also location information (so-called metadata). Except for the encrypted content, a transmission of the communication partners’ data within the Facebook group of companies is possible, in particular for purposes of optimizing the respective services and for security purposes. Likewise, communication partners should assume, as long as they have not objected to this, that their data processed by WhatsApp can be used for purposes of marketing or displaying advertising tailored to users. Personal data that you provide in the course of communication will be processed by us in accordance with the requirements of the EU General Data Protection Regulation (DSGVO), the German Federal Data Protection Act (BDSG) and other statutory provisions applicable to electronic commerce, as well as in accordance with the requirements of the competent supervisory authorities.
Since you contact us on your own initiative, we use WhatsApp in relation to our customers in the context of contract initiation as a contractual measure pursuant to Art. 6 para. 1 lit. b DSGVO and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via messengers pursuant to Art. 6 para. 1 lit. f DSGVO.
For more information on the purposes, types and scope of the processing of your data by WhatsApp, as well as the related rights and settings options to protect your privacy, please refer to the privacy notices of WhatsApp: https://www.WhatsApp.com/legal/
5. When will your data be deleted?
In the case of communication via WhatsApp, we delete the WhatsApp messages as soon as we can assume to have answered any information provided by the users, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.
Deletion on the systems we use will take place within the period specified by law.
Furthermore, we would like to point out that we do not transmit the contact data provided to us to WhatsApp without your consent (e.g. by contacting you via WhatsApp originating from us).
We would like to point out that we reserve the right not to answer inquiries via WhatsApp for reasons of your security. This is the case if, for example, communication content requires special confidentiality or a response via Messenger does not meet the formal requirements. In such cases, we refer you to more adequate communication channels.
6. What rights do you have when it comes to the processing of your data?
You have the following rights with respect to INTERNORM Kunststofftechnik GmbH personal data concerning you:
• Right of access
• Right to rectification or erasure
• Right to restriction of processing
• Right to data portability
• Right to withdraw consent given
6.1 Information about your right to object according to Art. 21 DSGVO
Single-case right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 sentence 1 lit. e DSGVO (data processing in the public interest) and Art. 6 (1) sentence 1 lit. f DSGVO (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Article 4 No. 4 DSGVO.
If you object, your personal data will no longer be processed by INTERNORM Kunststofftechnik GmbH . Unless the latter can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms. Or the processing serves the assertion, exercise or defense of legal claims.
Objection to the processing of your data for direct marketing
In individual cases, INTERNORM Kunststofftechnik GmbH processes your personal data for direct advertising. You have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling, insofar as it is associated with such direct advertising.
If you object to processing for the purposes of direct marketing, INTERNORM Kunststofftechnik GmbH will no longer process your personal data for these purposes.
The objection can be made form-free and should preferably be addressed to:
INTERNORM Kunststofftechnik GmbH
Robert-Bosch-Str. 5
D-49401 Damme
Mail: datenschutz@internorm.de
You also have a right of appeal to a data protection supervisory authority in connection with the processing of your personal data:
The State Commissioner for Data Protection of Lower Saxony
Prinzenstraße 5
30159 Hannover
Phone: 0511 120-450
Mail: poststelle@lfd.niedersachsen.de
7. Changing and updating the privacy policy
If you are already a customer of INTERNORM Kunststofftechnik GmbH then your data will also be processed as part of your business relationship with INTERNORM Kunststofftechnik GmbH . Information on this can be found in the Data Protection Notice
We encourage you to periodically review the contents of our privacy notices. We adapt the privacy notice as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact information for companies and organizations in this Privacy Notice, please note that addresses may change over time and please verify the information before contacting us.
Date: September 2021
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