Data protection statement
1. General
The protection of your personal data is important to us. We process your personal data obtained as part of the conclusion of a contract in accordance with the statutory data protection requirements for the purposes listed below. Personal data within the meaning of this privacy policy refers to all information related to your person. In particular, this includes your contract data, including your contact and billing details.
2. Responsible Body
The company responsible for the processing of your personal data is Bäderbetriebe Kleve GmbH, Flutstr. 36, 47533 Kleve, Tel.: 02821/593-0, Fax: 02821/593-160, Email: info@stadtwerke-kleve.de
3. Contact details
If you have any questions or comments about the data protection policy of Bäderbetriebe Kleve GmbH (for example, information about or an update to your personal data), please contact our data protection officer, quoting the keyword “data protection”: Mr Markus Verstegen, Tel.: 02821/593-114, Fax: 02821/593-160 or by email: datenschutz@stadtwerke-kleve.de
4. Purposes of processing and receiving
4.1 Contract Processing
Bäderbetriebe Kleve GmbH or service providers commissioned by us process your personal data in order to fulfil the contract with you. This includes, among other things, billing for use of the pool and other services as well as associated communication with you.
In order to fulfil the contract, i.e. for the purpose of determining your consumption, billing, payment processing and the sending of letters and invoices, we also transfer your personal data to third parties (e.g. shipping providers). The legal basis for the processing and provision of your personal data is consequently processing for the purpose of contract fulfilment and contract execution.
4.1 Contract Processing
Bäderbetriebe Kleve GmbH or service providers commissioned by us process your personal data in order to fulfil the contract with you. This includes, inter alia, charging for the use of the public swimming pool or any other services, as well as the associated communication with you.
In order to fulfil the contract, bill you for the services, process payment and forward you letters and invoices, we also transmit your personal data to third parties (e.g. shipment service providers). The legal basis for the processing and provision of your personal data is thus the processing in order to fulfil the contract and execute the contract.
4.2 Advertising and customised offers using customer data analysis
Bäderbetriebe Kleve GmbH also uses your personal data to provide you with information about products.
In order to address advertising to you, we share your name and address with third parties and order processors (e.g. shipping providers, media agencies), who process them to create send you advertising material.
In addition, Bäderbetriebe Kleve GmbH will ensure that the communication channels chosen for advertising (post and, for self-advertising for existing customers, also by email) have the lowest possible level of disruption for you.
Insofar as you have given your consent, Bäderbetriebe Kleve GmbH will transmit your e-mail address and your first and last name to social media networks (such as Google or Facebook) in pseudonymised form using a so-called hash value. These networks will then carry out an internal comparison with the user data available to them. If this comparison shows that you are registered on one of these social media networks, Bäderbetriebe Kleve GmbH advertisements will be displayed on the respective social network, for example through ad banners or other advertising.
You have the right to revoke your consent at any time with future effect, without affecting the lawfulness of the processing carried out on the basis of the consent until the point of revocation. The easiest way to revoke your consent is to send notification to the contact details given above.
4.3 Credit assessment
Bäderbetriebe Kleve GmbH is entitled to obtain credit information about you. For this purpose, Bäderbetriebe Kleve GmbH will transmit your name, address and, if applicable, date of birth to the credit reference agency Creditreform Emmerich Wolters KG, ‘s-Heerenberger Straße 172, 46446 Emmerich. In the event of negative information about characteristics of your creditworthiness, Bäderbetriebe Kleve GmbH may reject a contractual relationship with you. The legal basis for the processing is a balancing of interests. Our legitimate interest lies in assessing your creditworthiness and reducing the risk of payment defaults.
4.4 Other recipients and purposes
Bäderbetriebe Kleve GmbH has some of the aforementioned processes and services carried out by carefully selected and commissioned processors (in particular, IT service providers).
The service providers commissioned by Bäderbetriebe Kleve GmbH may include in particular: Print service providers, call centres, selected specialist companies and craftsmen. They process personal data on our behalf.
If the processors do not work for us in the context of order processing, e.g. craftsmen or other specialist companies, the legal basis for the transfer of data is that the services of third parties are necessary for the purpose of optimised and efficient performance of the contract with you, or the fulfilment of our contractual obligations. The legal basis for the transfer of your customer data to third parties is a balancing of interests.
5. Specific online topics
5.1 Logfiles
The processing of the IP address serves to protect against or enable the tracing of hacker and cyber attacks. The processing of the remaining data aids delivery of the contents of our website, guarantees the functionality of our IT systems, optimises our website and ensures the functionality of the website. The data in the log files is always stored separately from the other personal data of users.
This processing of your above-mentioned data is necessary to protect the legitimate interests of Bäderbetriebe Kleve GmbH and is justified by a balancing of interests in favour of Bäderbetriebe Kleve GmbH. Bäderbetriebe Kleve GmbH has a legitimate interest in ensuring that the website and the services offered there are technically functional and in protecting the website from attacks. Your legitimate interest in ensuring that the above-mentioned data is not used for this purpose does not outweigh the legitimate interest of Bäderbetriebe Kleve GmbH, since Bäderbetriebe Kleve GmbH uses this data appropriately in accordance with the described processing purpose, and you also benefit from the functionality of the website.
Your personal data will be deleted after 14 days at the latest, unless Bäderbetriebe Kleve GmbH is legally obliged to retain it or its retention is permitted by law.
5.2 Web analysis and web optimisation through cookies and tracking pixels
We use cookies and tracking technologies on our website. These are used to optimise our website, to further develop services and for marketing purposes. In the following paragraphs we explain the technologies and how they work.
When you visit our website, we will store information on your computer in the form of a cookie, which we will automatically recognise the next time you visit. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. If a user accesses a website, a cookie can be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is accessed again.
The use of cookies helps us to offer you unrestricted use of our website. With the help of cookies, we make your visit to our website as convenient as possible. Cookies allow us, amoung other things, to adapt a website to your interests or to save your user name so that you do not have to re-enter it each time you visit.
We also use tracking pixels on our website. Tracking pixels are small graphics on web pages that enable log file recording and log file analysis. Tracking pixels write information to the cookie file in the user’s browser when the user visits the website. The use of tracking pixels enables us to display targeted information and content.
An overview of the cookies and pixels used on our website, the data processed in each case and the corresponding recipients can be found here.
Bäderbetriebe Kleve GmbH uses cookies and pixels from the following categories:
5.3 Required cookies and pixels
Necessary cookies ensure our website operates without any technical failures. They ensure the stability of the website, provide a secure log-in, save the progress of your order, your log-in data and your shopping basket. The cookie and pixel list is here available and informs you about the required cookies we use.
The data collected from you in this way is pseudonymised by technical means, so it is no longer possible to assign the data to you. The data will not be stored together with other personal data about you. When you access our website, an info banner informs you about the use of cookies and refers you to this data protection information. There is also information on how you can prevent the storage of cookies in the browser settings.
This processing of your above-mentioned data is technically necessary 5for the secure operation of our website. Technically you can prevent the setting of cookies via your browser settings. However, we would like to point out that the secure and functional operation of our website cannot then be guaranteed.
5.4 Marketing cookies
Marketing cookies help us to provide you with personalised advertisements on and off our website – www.sternbuschbad.de. The cookie and pixel list is here available and informs you about the required cookies we use.
In this context we also use cookies for the purpose of so-called remarketing, retargeting or lookalike retargeting. Here, the cookie with the corresponding information permits recognition of the user’s browser and a corresponding retargeting on external websites (so-called retargeting). Furthermore, statistical twins of the original cookie profiles are identified and addressed on the basis of the cumulative cookie information. This is referred to as lookalike retargeting.
We also use cookies in this context for use-related advertising (so-called behavioural advertising). On our website, data with usage information (e.g. websites visited, number of visits, visiting times, length of stay on individual pages) is stored on the user’s hard drive by means of cookies. These user profiles are anonymised and evaluated in a technical (statistical) evaluation process in order to enable selection based on the interests of the respective user when internet advertising (e.g. banners) is subsequently placed on other websites. Behavioural targeting is carried out by third-party companies in accordance with the list that can be viewed here, who also place advertising for websites of other providers. These third-party companies then create the aforementioned user profiles themselves using cookies and use their respective targeting systems to select the collected data for the purpose of user-targeted advertising.
When you access our website, our so-called cookie banner informs you about the use of cookies for marketing purposes and asks for your consent to process the personal data used in this context. You will also be referred to this privacy policy. The legal basis for processing personal data using cookies and pixels for marketing purposes is your corresponding consent.
You have the right to revoke your consent at any time with future effect, without affecting the lawfulness of the processing carried out on the basis of the consent until the point of revocation. The easiest way for you to revoke your consent is to “deactivate” the relevant cookies or cookie types at any time using the appropriate tool in the footer of our homepage.
The information transmitted to us by the cookies and pixels is stored by us for the following periods after collection and then automatically deleted.
The information transmitted to us by the cookies and pixels is stored by us for the following periods after collection and then automatically deleted.
Marketing cookies 6 months
Required cookies 24 hours
6. Recipients of your personal data
6.1 Third parties and processors
Your personal data will also be used by other companies that work on behalf of Bäderbetriebe Kleve GmbH (“processors”) or that operate in the context of business partnerships with Bäderbetriebe Kleve GmbH (“third parties”). Possible recipients of your data include shipping providers, call centres, IT service providers, consultants or consulting firms, other service and cooperation partners. For details, please refer to the descriptions of data processing.
6.2 Recipients outside the European Union (EU)
Bäderbetriebe Kleve GmbH has individual services and performances carried out by carefully selected and commissioned service providers which have their headquarters outside the European Economic Area (“third country”), e.g. Google. In these cases, transfer to a third country takes place. To the extent required by law to establish an adequate level of protection for your data, Bäderbetriebe Kleve GmbH uses appropriate guarantees to establish an adequate level of data protection in accordance with legal requirements, including, among other things, EU standard contracts. You have the option of requesting further information at any time and of receiving copies of relevant agreements. You have the option of requesting further information at any time and of receiving copies of relevant agreements.
7. Duration of storage and deletion of your data
We delete your personal data when the contractual relationship with you is terminated, all mutual claims have been fulfilled and there are no other legal obligations to retain data or legal justification for the storage. We may use your postal address for a maximum period of 24 months after termination of the contractual relationship. The legal basis for the processing is a balancing of interests. In certain cases Bäderbetriebe Kleve GmbH will continue to use your data anonymously for analysis purposes.
If during the term of the contractual relationship with Bäderbetriebe Kleve GmbH you have given your consent to be contacted by email or telephone for advertising purposes, we will use this consent for a maximum period of 12 months after you have given your consent, unless a longer period of use is justified by objective reasons.
8. Company appearances on social media
By presenting Bäderbetriebe Kleve GmbH in social media (e.g. Facebook, Instagram) we would like to seek active communication with you and offer you the opportunity to learn about our company, products and services in this way. It should be noted that in the context of these company presentations, processing of personal data in countries outside the European Union is possible. If you use the corresponding company websites, cookies are usually stored on your computer. These cookies are used to record user behaviour and user interests. Generally speaking, the resulting data is used for the purposes of market research and advertising, with advertisements being shown depending on usage behaviour which are presumed to correspond to the interests of the users.
We process the personal data of users on the basis of our legitimate interest in communication with individual users. Furthermore, it is possible that you may be asked by the provider of the respective social medium to consent to the processing of your data. Bäderbetriebe Kleve GmbH has no influence on the data collected by the provider or the data processing procedures, nor are we aware of the full extent of the data collection, the purposes of the processing, or the storage periods. We also have no information about the deletion of the collected data by the respective provider. Accordingly, we would like to point out that the rights of the data subject must be asserted against the provider, as ultimately only the provider has direct access to the data collected and can take appropriate measures and provide information.
9. Your rights
In accordance with the statutory provisions (including any applicable restrictions under the GDPR and/or the German Data Protection Act), you can assert the following rights against us:
9.1 Access to personal data
You have the right to access your data stored with us.
9.2 Rectification
At your request, we will rectify the data stored about you if it is incorrect or inaccurate.
9.3 Deletion
If you wish, we will delete your data, unless other legal regulations (e.g. legal storage obligations) or an overriding interest on our part (e.g. to defend our rights and claims) prevent this.
9.4 Restriction
Having regard to the legal requirements, you can request that we restrict the processing of your data.
9.5 Data transfer
You also have the right to receive your data under the statutory requirements in a structured, commonly used, machine-readable and interoperable format, and to transmit it to a third party.
9.6 Complaints
You have the right to address any questions or complaints to a supervisory authority, in particular in the member state of your habitual residence, your place of employment or place of the suspected infringement. The supervisory authority responsible for us is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (www.ldi.nrw.de).
9.7 Withdrawal
If you have given us separate consent to process your personal data, you can withdraw this consent at any time. The lawfulness of the processing of your data until revocation remains unaffected by withdrawal.
9.8 Objection
You may also object to the processing of your data (see box for more information). To exercise these rights, you can contact us using one of the contact details set out in section 2.
Information about your right to object
You have the right to object at any time to the processing of your data on the basis of a balancing of interests or in the public interest, if there are reasons which relate to your particular situation. This also applies to profiling based on this provision.
If you object, we will no longer process your personal data unless we can demonstrate compelling reasons for processing that are worthy of protection and outweigh your interests, rights and freedoms, or unless the processing serves to assert, exercise or defend legal claims. Frame in Word
We also process your personal data in order to carry out direct advertising. If you do not wish to receive any advertising, you have the right to object to this at any time; this also applies to profiling, insofar as it is related to such direct marketing. We will take this objection into account for the future.
The objection can be made in any format and should be addressed to:
Bäderbetriebe Kleve GmbH, Flutstr. 36, 47533 Kleve, Tel.: 02821/593-0, Fax: 02821/593-160, Email: info@stadtwerke-kleve.de
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