Privacy Policy

1. General Information

We would like to use the information below to provide you "data subject" with an overview of our processing of your personal data and your rights under data protection law. It is generally possible to use our website without entering personal data. However, if you wish to make use of special services offered by our company through our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we will generally obtain your consent.
Personal data, such as your name, address or email address, is always processed in accordance with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the "Cosel Europe GmbH". The aim of this Privacy Notice is to inform you about the scope and purpose of the personal data we collect, use and process.
As the data controller, we have implemented numerous technical and organizational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps so that absolute protection cannot be guaranteed. For this reason, you are free to submit personal data on alternative ways, such as by phone or by post to us.

2. Data controller

The data controller, as defined by the GDPR, is:

Cosel Europe GmbH
Lurgiallee 6-8
D-60439 Frankfurt am Main
Germany
Phone: +49 (0)69 9500790
Email: privacy at coseleurope.eu

Data controller´s representative: Makoto Hamaguchi

3. Data protection officer

You can reach the data protection officer as follows: 

Stefan Auer
Phone: +49 (0)911 148986 50
Fax: +49 (0)911 148986 59
Email: office at ascon-datenschutz.de

You may contact our data protection officer directly at any time if you have any questions or suggestions regarding data protection.

4. Definitions

This Privacy Notice is based on the terminology used by the European legislature and legislature in the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand, both for the public and for our customers and business partners. To ensure this, we would like to explain in advance the terminology used. Among other things, we use the following terms in this privacy policy.
We use the following terms in this Privacy Notice, among others:

4.1. Personal data

Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

4.2. Data subject

A Data subject is any identified or identifiable natural person whose personal data is processed by the controller (our company).

4.3. Processing

Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4.4. Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

4.5. Profiling

Profiling is any form of automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

4.6. Pseudonymization

Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data cannot be attributed to an identified or identifiable natural person.

4.7. Data processor

Data processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

4.8. Recipient

A recipient is a natural or legal person, public authority, agency, or other body to whom personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

4.9. Third party

Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or the processor, are authorized to process the personal data.

Consent means any freely given specific and informed indication of the data subject's wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

5. Legal basis for processing

Art. 6 (1) lit. a GDPR (icw § 25 (1) German Telecommunications-Telemedia Data Protection Act (TTDSG)) serves our company as the legal basis for processing operations where we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 (1) lit. b GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services.
If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 (1) lit. c GDPR.
In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. In this case, the processing would be based on Art. 6 (1) lit. d GDPR.
Finally, processing operations could be based on Art. 6 (1) lit. f GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary for the protection of a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not overweigh. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47, Sentence 2 GDPR)..

6. Disclosure of data to third parties

Your personal data will not be conveyed to third parties for purposes other than those listed below.
We will only share/convey your personal data with third parties if:

you have given us your express consent to do so in accordance with Art. 6 (1) lit. a GDPR,
the disclosure is permissible in accordance with Art. 6 (1) lit. f GDPR to protect our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
in the event that a legal obligation exists for the disclosure pursuant to Art. 6 (1) lit. c GDPR, as well as

in the context of the processing operations described in this privacy statement, personal data may be transferred to the USA. Companies in the USA only have an adequate level of data protection if they have certified themselves under the EU-US Data Privacy Framework and thus the adequacy decision of the EU Commission pursuant to Art. 45 GDPR applies. We have explicitly mentioned this in the privacy policy for the service providers concerned. In order to protect your data in all other cases, we have concluded commissioned processing agreements based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent can serve as the legal basis for the transfer to third countries in accordance with Article 49 (1) a) of the GDPR. This sometimes does not apply in the case of a data transfer to third countries for which the European Commission has issued an adequacy decision pursuant to Art. 45 of the GDPR.

7. Technology

7.1. SSL/TLS-encryption

This site uses SSL or TLS encryption to guarantee the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact enquiries that you send to us as the operator. You can recognize an encrypted connection by the fact that the address bar of the browser contains a "https://" instead of a "http://" and by the lock symbol in your browser bar.
We use this technology to protect your transmitted data.

7.2. Data collection when visiting the website

When using our website for information purposes only, i.e. when not registering or otherwise transmitting information to us, we only collect data that your browser transmits to our server (in so-called "server log files"). Our website collects a series of general data and information each time you access a website or an automated. This general data and information is stored in the server's log files. The following can be recorded:

browser types and versions used,
the operating system used by the accessing system,
the website from which an accessing system accesses our website (so-called referrer),
the sub-pages accessed via an accessing system on our website,
the date and time of access to the website,
an abbreviated internet protocol address (anonymized IP address) and,
the Internet service provider of the accessing system.

When using this general data and information, we do not draw any conclusions about your person. This information is rather required to:

deliver the contents of our website correctly,
optimize the contents of our website as well as to advertise it,
ensure the permanent operability of our IT systems and the technology of our website, and
provide law enforcement authorities with the information necessary to prosecute in the event of a cyber-attack.

This collected data and information is therefore statistically analyzed and further analyzed by us with the aim of increasing data protection and data security within our company to ultimately ensure an optimum level of protection for the personal data being processed by us. The anonymous data from the server log files is stored separately from all personal data provided by a data subject.
The legal basis for data processing is Art. 6 (1) lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above.

7.3. Hosting by IONOS

We host our website at IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (IONOS).

When visiting our website your personal data (e.g. IP addresses in log files) are processed on the servers of IONOS.
The use of IONOS is based on Art. 6 (1) lit. f GDPR. Our legitimate interest is the high-performance provision of our website.
We have concluded a corresponding agreement with IONOS based on GDPR for commissioned processing. This is a contract required by data protection law, which ensures that IONOS only processes the personal data of our website visitors according to our instructions and in compliance with the GDPR.
Additional information and IONOS`s privacy policy can be found at https://www.ionos.de/terms-gtc/terms-privacy

8. Cookies

8.1. General information about cookies

We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our website.
Information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity.
The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are erased automatically when you leave our website.
In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your end device for a specific period. If you visit our site again to use our services, it is automatically recognized that you have already been with us and which entries and settings you have made so that you do not have to enter them again.
We also use cookies to statistically record the use of our website and to evaluate our offer for you for the purpose of optimization. These cookies enable us to automatically recognize that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period. The respective storage period of the cookies can be found in the settings of the consent tool used.

8.2. Tips for avoiding cookies in common browsers

You can delete cookies, allow only selected cookies or completely deactivate cookies at any time via the settings of the browser you are using. You can find more information on the support pages of the respective providers:

9. Contents of our website

9.1. Contact/ enquiry form

Personal data is collected when you contact us (e.g. using our enquiry form or by email). If you use a enquiry form to get in touch with us, the enquiry form you use will indicate the data being collected. This data is stored and used exclusively for the purpose of responding to your query or establishing contact and the associated technical administration. The legal basis for data processing is our legitimate interest in responding to your request pursuant to Article 6 Paragraph 1(f) GDPR. If the aim of you contacting us is to conclude a contract, processing is also legally based on Article 6 Paragraph 1(b) GDPR. Your data will be erased once we have finished processing your query. This is the case when it can be inferred from the circumstances that the relevant facts have been clarified in a conclusive manner and there are no statutory retention obligations in place that prevent its erasure.

10. Newsletters

10.1. Newsletter for regular customers (without registration)

If you have provided us with your email address when purchasing goods or services, we may periodically email you offers for similar goods or services to those you have already purchased from our range. In accordance with Section 7 (3) of the German Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb, UWG), we do not need to obtain your separate consent for this. In this respect, the data processing is carried out solely based on our legitimate interest in personalized direct advertising in accordance with Art. 6 para. 1 lit. f GDPR. If you have initially objected to the use of your e-mail address for this purpose, no e-mails will be sent by us. You are entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying the responsible person named at the beginning. For this, you will only incur transmission costs according to the prime rates. Upon receipt of your objection, the use of your e-mail address for advertising purposes will cease immediately.

10.2. Marketing newsletter (double opt-in)

On our website you are given the opportunity to subscribe to our company newsletter. What personal data is transmitted to us when ordering the newsletter, is determined by the input mask used for this purpose.
We use our newsletter to regularly communicate our offers to our customers and business partners. You can, therefore, only receive our company’s newsletter if

You have a valid e-mail address and
You have registered for newsletter delivery.

For legal reasons, a confirmation e-mail will be sent to the e-mail address that you entered for the first time for the newsletter dispatch using the double opt-in procedure. This confirmation e-mail is used to verify that you, as the owner of the e-mail address, have authorized the receipt of the newsletter.
When you register for the newsletter, we also store the IP address assigned by your Internet service provider (ISP) of the IT system used by you at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of your e-mail address at a later date and therefore serves our legal protection.
The personal data collected in the context of a registration for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or changes in technical circumstances. No personal data collected as part of the newsletter service will be passed on to third parties. The subscription to our newsletter can be cancelled by you at any time. The consent to the storage of personal data that you have given us for the newsletter dispatch can be revoked at any time. For the purpose of revoking the consent, you will find a corresponding link in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter mailing directly on our website at any time or to inform us of this in another way.
The legal basis for data processing for the purpose of sending newsletters is Art. 6 (1) lit. a GDPR.

11. Our activities in social networks

To allow us to communicate with you on social networks and inform you about our services, we run our own pages on these social networks. If you visit one of our social media pages, we and the provider of the social media network are joint controllers (Art. 26 GDPR) regarding to the processing operations triggered thereby, which concern personal data.
We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers.
We would therefore like to point out as a precautionary measure that your data may also be processed outside of the European Union or the European Economic Area. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your rights to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behavior by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behavior may be assigned directly to your own member profile on the respective social network (if you are logged in).
The processing operations of personal data described are carried out in accordance with Art. 6 (1) lit. f GDPR on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you have to grant your consent to the respective providers to process your data as a user, the legal basis for this processing is Art. 6 (1) lit. a GDPR in conjunction with Art. 7 GDPR.
Since we have no access to these providers? databases, we would like to point out that you would be best placed to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider. More information on the processing of your data on social networks and your options for exercising your right to object or your right of revocation (opt out) is listed below for each of the social network providers we use:

11.1. LinkedIn

(Joint) Data controller responsible for data processing in Europe:
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
Privacy Notice:
https://www.linkedin.com/legal/privacy-policy

12. Your rights as a data subject

12.1. Right to confirmation

You have the right to request confirmation from us as to whether personal data relating to you will be processed.

12.2. Right to information (Article 15 GDPR)

You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us, in accordance with the statutory provisions.

12.3. Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

12.4. Erasure (Article 17 GDPR)

You have the right to demand that we erase the personal data relating to you be deleted without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required.

12.5. Restriction to processing (Article 18 GDPR)

You have the right to request that we restrict the processing of your data if one of the legal requirements is met.

12.6. Data transferability (Article 20 GDPR)

You have the right obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 Paragraph 1(a) GDPR or Article 9 Paragraph 2(a) GDPR or on a contract pursuant to Article 6 Paragraph 1(b) GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us.
Furthermore, when exercising your right to data transferability pursuant to Article 20 Paragraph 1 GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.

12.7. Revocation of consent regarding data protection

You have the right to revoke any consent to the processing of personal data at any time with future effect.

12.8. Lodging a complaint with a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

12.9. Objection (Article 21 GDPR)

You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1 (f) (data processing on the basis of the weighing of legitimate interests) GDPR.
Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims.In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct mar-keting. Should you object to the processing of your data for direct marketing purposes, we will no longer pro-cess your personal data for this purpose.

13. Routine storage, erasure and blocking of personal data

We process and store your personal data only for the period of time necessary to meet the storage purpose or as required by the legal provisions to which our company is subject.

If the storage purpose no longer applies or if a required retention period expires, personal data will be routinely blocked or erased in accordance with the statutory provisions.

14. Duration of storage of personal data

The criterion for the duration of the retention of personal data is the respective legal retention period. Once this period expires, the data in question will be routinely erased, provided it is no longer required for the fulfilment or initiation of the contract.

15. Version and amendments to the Privacy Notice

This Privacy Notice is currently valid and was last updated on September 2023. It may be necessary for us to amend this Privacy Notice in the process of further developing our website and the services we offer through our website or due to changes in legal or regulatory requirements.
This privacy statement has been prepared with the assistance of the privacy software: audatis MANAGER.