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Política de privacidad

Protecting your privacy is very important to us. For this reason, all our data processing procedures (e.g. collection, processing and transfer of data) comply with the statutory provisions of European and German data protection law.

The following statement gives you an overview of which personal data is requested from you on our websites, how that data is used and passed on, how you can obtain information about the information provided to us, and what security measures we take in order to protect your data.
 

1. Who is your point of contact (controller) for your data protection concerns? 

The Controller for all data processing operations carried out via our websites, within the meaning of data protection regulations, is:

RugGear GmbH,
i_Park Tauberfranken 8,
D-97922 Lauda-Königshofen,
+49 0160 97017530
europe@remove-this.ruggear.com 
 

In compliance with the relevant legal requirements, we have appointed a data protection officer for our company.
You can reach our data protection officer at privacy@remove-this.ruggear.com.

 

2. What data do we need from you for you to use of our websites? What data is collected and stored when you use our websites? 

Personal data means any information relating to an identified or identifiable natural person (“Data Subject”), such as your name, address, telephone number, date of birth, bank details and IP address.

As a basic principle, we collect and use personal data from our users only where this is necessary in order to provide a functional website and to deliver our content and services. As a rule, personal data concerning our users is collected and used only with the user’s consent. An exception is made in cases where prior consent cannot be obtained for practical reasons and processing of the data is permitted by law.

Usage data

When you use our website, the following data, known as usage data, are logged and stored for internal system-related and statistical purposes only:

IP, directory protection user, date, time, pages accessed, logs, status code, data volume, referrer, user agent, host name accessed.

The data are also stored in our system’s log files. These data are not stored together with other personal data concerning the user.

The legal basis for temporary storage of data and log files is Art. 6 (1) (f) of the General Data Protection Regulation (GDPR).

Temporary storage of the IP address by the system is necessary to enable delivery of  the website to the user’s computer. For this purpose, the user’s IP address must be stored for the duration of the session.

Data are stored in log files to ensure the functioning of the website. The data are also used to optimise the website and to ensure the security of our information technology systems. In this context, the data is not evaluated for marketing purposes.

This also constitutes our legitimate interest in data processing pursuant to Art. 6 (1) (f) GDPR.

The data are erased once they are no longer required for the purposes for which they were collected. Data collected for provision of the website are erased once the respective session has ended.

Data stored in log files are erased after a maximum of 60 days. Data may be stored for longer periods. In this case, user IP addresses are deleted or obscured, so that they can no longer be associated with the requesting client.

Ways to contact us

We have a contact form available for you on our website, which you can use to contact us easily by electronic means and address your concerns to us.

We collect the following data via the support request form:

Mandatory field: First name, last name, email address, your matter of concern, country, Telephone, reason for the request
optional: model name, IMEI number, serial number

At the time the respective contact form is sent, the following data is also processed:

IP address, time stamp, name of your browser 
Before the data is processed, you will be informed about the intended use of your data as part of the sending process and will be referred to this privacy statement.

To provide this contact forms, we use a technology partner who we have placed under an obligation to comply with data protection regulations accordingly pursuant to Article 28 of the GDPR as part of an agreement on the processing of personal data on our behalf.

You can contact us via the e-mail address provided. In this case, the user's personal data transferred along with the email will be stored.

We use your data only to process your request, and we may contact you for this purpose using the contact data provided. This data will not be used for advertising or marketing purposes. In individual cases, it may be necessary to pass on your data to third parties if this arises from the reasons stated in your request. This is the case, for example, with a support ticket that we cannot process ourselves, but can only one be processed efficiently and to your satisfaction by one of our partners. In individual cases, partners can also have their place of business outside the EU.

The legal basis for processing the data transmitted via the contact form or in the course of sending an email is Art. 6 (1) (f) of the GDPR. If the contact is aimed at concluding a contract or fulfilling contractual obligations, the additional legal basis for the processing is Article 6 (1) (b) of the GDPR. In the event of any data that may be transmitted to partners outside the EU when support tickets are processed by our partners, Art. 49 (1) (b) of the GDPR is the legal basis applied.

Personal data are processed solely in order to facilitate contact. This also constitutes the required legitimate interest in processing the data. The other personal data processed during the process for sending the contact form serves to prevent misuse of the contact form and ensure the security of our information technology systems.

The data are erased once they are no longer required for the purposes for which they were collected. Personal data from the contact forms and that sent by email is erased at the end of the respective conversation with the user. The conversation ends when the circumstances indicate that the issue in question has been definitively clarified.

The additional data collected during the process of sending the respective contact form is deleted after a period of 21 days at the latest.

Right to object

You shall have the option at any time to object to your personal data being processed. For this purpose, please use the contact options listed above. If you contact us by e-mail and object to the storage of your personal information, the conversation cannot not continue.

In that case, all personal data stored at the time of contact will be erased.

We may occasionally ask you to provide information anonymously as part of surveys. We need this in order to make the content more interesting for you and make sure the information we provide is always up to date. These surveys are voluntary of course; your information will be collected anonymously and treated confidentially. Identification of users is ruled out in this regard.

 

3. How will my data be used and, where applicable, passed on to third parties and for what purpose will this be done?

We use the personal data you provide to answer your inquiries, to process your orders and for the purpose of technical administration of our websites.

Your personal data will only be passed on to third parties if this is necessary for the purpose of contract processing, for billing purposes or to collect a fee or process support requests or if you have expressly given your consent. We are also entitled to pass on personal data for debt collection purposes, but only if the legal requirements for this are met, of course.

The legal basis for the transmission of data to third parties for the purpose of contract processing, billing purposes and processing support requests is Article 6 (1) (b) of the GDPR.



4. What security measures have we taken to protect your data?

General security routines 

We have implemented a variety of security measures to reasonably and adequately protect personal information. Our databases are protected by physical, technical and procedural measures that restrict access to information to specially authorised persons, in accordance with this Privacy Statement. Our information system is behind a software firewall in order to prevent access from other networks connected to the Internet. Only employees who need the information to perform a specific task will have access to personal information. Our employees are trained in security and data protection practices. With e-mail communication, we cannot guarantee complete data security.

Google reCAPTCHA 

In order to protect input forms (e.g. newsletter registration, registration, login) on our websites, we use the “reCAPTCHA” service from Google. Using this service enables a distinction to be made as to whether the relevant input is of human origin or whether it is made through automated machine processing, especially for abusive purposes.

By interacting with reCAPTCHA, the referrer URL, the IP address, the behavior of website visitors, information about the operating system, browser and length of stay, cookies, display instructions and scripts, the user's input behavior and mouse movements in the area of the reCAPTCHA checkbox are transmitted to Google. The IP address transmitted as part of the reCAPTCHA process is not merged with other Google data unless you are logged into your Google account at the time you use reCAPTCHA. If you want to prevent Google from transmitting and storing data about you and your behavior on our website, you must log out of your Google account before you visit one of our websites on which the reCAPTCHA plug-in is provided.

The use of reCAPTCHA and the information obtained through it is in accordance with Google's data protection regulations, which you can access at https://policies.google.com/privacy. Further information about the service can be found at https://www.google.com/recaptcha/about/.

The legal basis for data processing is Article 6 (1) (c) in conjunction with Article 32 of the GDPR on the one hand and Article 6 (1) (f) of the GDPR on the other hand. Safeguarding our websites against misuse and spam using the reCAPTCHA plugin is deemed a security measure needed for technical reasons and, at the same time, within the sphere of our legitimate interest pursuant to Article 6 (1) (f) of the GDPR. In this context, the collection and transmission of the IP address to Google also serves to verify the source of the access to the relevant website and make an automated decision about further authentication requirements to prevent automated, especially abusive website access and distributed denial of service attacks.

 

5. E-mail advertising (e.g. e-mail newsletter)

This website uses CleverReach to send newsletters. The provider is CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede. CleverReach is a service that can be used to organize and analyze newsletter distribution. The data you enter to receive the newsletter (e.g. email address) is stored on CleverReach's servers in Germany.
Our free newsletter informs you regularly by email about new products and special offers. The data you enter here is used to personalize the newsletter and will not be passed on to third parties. You can unsubscribe from the newsletter or revoke your consent at any time by sending an email to newsletter@remove-this.ruggear.net or by following this link. After you have finished receiving the newsletter, your data will be deleted within one month, provided that deletion does not conflict with any legal retention requirements. In submitting the data you have entered, you thereby consent to the data processing and acknowledge our our privacy statement.

Our newsletters sent with CleverReach enable us to analyze the behavior of newsletter recipients. Among other things, this makes it possible to analyze how many recipients opened the newsletter message and how often which link in the newsletter was clicked on. With the help of so-called conversion tracking, it can also be analyzed whether a predefined action (e.g. purchasing a product on this website) took place after clicking on the link in the newsletter. Further information on data analysis through the CleverReach newsletter can be found at: https://www.cleverreach.com/en-de/newsletter-tool/newsletter-reporting/.
For more detailed information, please see CleverReach's privacy policy at: https://www.cleverreach.com/en-de/privacy-policy/
As CleverReach's services involve contract data processing within the meaning of Article 28 (1) of the GDPR, we have concluded a contract with the company in which CleverReach undertakes to process the data in accordance with the General Data Protection Regulation.

We only use your data to send the newsletter. It will not be passed on to third parties.

The legal basis for processing the data processed in connection with sending the newsletter and newsletter tracking is your consent in accordance with Art. 6 (1) (a) of the GDPR.
 

6. When you use our websites, a cookie is placed on your computer. What does that mean?
  
Meaning and types of cookies used

We use so-called cookies on our websites. Cookies are small amounts of data in the form of text information which the web server sends to your browser. These are simply saved on your hard drive or stored in the memory of the device you are using. In each case, cookies can only be read by the server that previously placed them.  They contain information about what you have viewed on a website, and when. Cookies themselves only identify the IP address of your computer, so they do not store any personal information, such as your name. The data stored in the cookies are not linked to your personal data (name, address, etc.).

We use cookies to make our website more user-friendly. Some elements of our website require that the requesting browser be identified even after a page change. In the cookies, only the language settings are stored and transferred. These are cookies that are needed for technical reasons.

We also use cookies on our website that enable an analysis of users' browsing habits. In this way, for example, the following data may be transferred:

1. Search terms entered
2. Frequency of site access
3. Use of website functions
 

The user data collected in this way are pseudonymized by technical means. Thus, the data can no longer be associated with the requesting user. The data will not be stored together with other personal data belonging to users.

You can decide for yourself whether or not to allow cookies. Interacting appropriately with our cookie banner or changing your browser settings (usually found under “Options” or “Settings” in the browser menus) gives you the choice of accepting all cookies or rejecting all cookies.

Purposes and legal basis for the use of cookies

The legal basis for processing personal data using cookies needed for technical reasons is Section 25 (2) (2) of the TTDSG (Telemedia Data Protection Act) for the setting of such cookies on your device and Article 6 (1) (1) (f) of the GDPR for any subsequent processing required on our systems.

The purpose of using cookies required for technical purposes is to facilitate the use of websites for users. Some features of our websites cannot be provided without using cookies. These require the browser to be identified even after a page change. 

The use of cookies for analysis and marketing purposes is aimed at improving the quality of our website and its contents. Using analysis cookies, we learn how the website is used, thus enabling us to constantly optimise our content. On your terminal device, in particular, we only carry out processing based on cookies or other identifiers (e.g. browser fingerprints, pixels) that is not technically necessary for the function of our websites with your consent, which you give via the separate cookie banner the first time you visit our websites. The legal basis for this cookie-based processing is Article 25 (1) (1) of the TTDSG for the setting of cookies on your device and Article 6 (1) (a) of the GDPR for possible subsequent processing outside of your terminal device on our systems or those of our partners. Cookies that are not necessary for the functioning of our websites will not be set until you have given your consent. 

Revocation of consent given for the use of cookies

You can revoke your consent for the use of cookies at any time via our cookie banner; you can access the cookie banner again via the corresponding link in the footer of our website and then use it to make the appropriate cookie settings. You can, of course, reject cookies that are not needed for technical reasons the first time you visit our website via our cookie banner.

You can also delete cookies at any time or adjust the corresponding cookie settings of the browser you use. For more information on how to delete and/or manage cookies via your browser settings, please visit the help pages for the respective browser. Please remember that disabling or restricting cookies must be done for each browser you use.  

 

7. Use of third-party tools

Google Analytics 4 

On our websites, we use Google Analytics , a web analytics service from Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 4, USA (“Google”). Google Analytics uses so-called “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website, as described in the section on cookies above. The information generated by the cookies about your use of this website are usually transferred to a Google server in the USA and stored there. In Google Analytics 4, IP address anonymization is enabled by default.  Due to IP anonymization, your IP address will be truncated by Google in European Union Member States or other signatory states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there.

According to Google, the IP address transmitted by your browser via Google Analytics will not be merged with other Google data..
During your website visit, your user behaviour is recorded in the form of “events”. 
 

Events can include:

  • Page views
  • First visit to the website
  • Start of the session
  • Websites visited
  • Your “click path”, interaction with the website
  • Scrolls (whenever a user scrolls to the bottom of the page (90%))
  • Clicks on external links
  • Internal search queries
  • Interaction with videos
  • File downloads
  • Language setting

Also recorded are: 

  • Your approximate location (region)
  • Date and time of visit
  • Your IP address (in truncated form)
  • Technical information about your browser and the devices you use (e.g. language settings, screen resolution)
  • Your Internet provider
  • Referrer URL (via which website/advertising medium you arrived at this website)

We use the User ID function. User ID allows us to assign a unique, permanent ID to one or more sessions (and the activities within those sessions) and analyze user behaviour across devices.

Google will use this information on our behalf for the purpose of evaluating your use of the website, to compile reports on website activity, and to provide other services relating to website and Internet usage to the website operator. 

Recipients of the data are/can be:

  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor in accordance with Art. 28 GDPR)
  • Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
  • Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

For the USA, the European Commission adopted its adequacy decision on July 10, 2023. Google LLC is certified according to the EU-US Privacy Framework. Given that Google servers are distributed worldwide and a transfer to third countries (for example to Singapore) cannot be completely ruled out, we have also concluded the EU standard contractual clauses with the provider.

Your browser’s IP address transferred via Google Analytics will not be combined with other Google data. You can prevent the storage of cookies by using the appropriate setting in your browser software. However, please note that if you do this, you may not be able to make full use of all the features of this website. You can also prevent the collection of data generated by the cookie and relating to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Withdrawal of consent previously granted:
You can revoke your consent at any time via the cookie banner on our websites, which you can access via the “Cookie Settings” link in the footer of our websites.

Alternatively, you can prevent Google Analytics from collecting data, especially in Internet browsers on mobile devices, by clicking on the following link:
 

Deactivate Google Analytics 

This causes a so-called opt-out cookie to be stored on your device, which prevents future collection of your data by Google Analytics when visiting this website.

Please note that if you delete cookies in your browser settings, this may result in the opt-out cookie from Google Analytics also being deleted, meaning you will have to re-activate it.

More information on how Google Analytics works and the terms of use and privacy policy for this service are available at www.google.com/analytics/terms/de.html and www.google.de/intl/de/policies/privacy/. We would also like to point out that our websites use Google Analytics with the anonymizeIP extension, which means that IP addresses are truncated for further processing in order to prevent any association with an individual.

YouTube videos

For a visually improved presentation, we have also integrated videos on our websites that are hosted via our YouTube channel. YouTube is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“YouTube”). For integration, we use the so-called extended data protection mode. This means that videos are integrated without cookies being set to record usage behavior. Usage behavior is therefore not monitored in order to personalize the provision of videos. However, cookies needed for technical reasons are set, without which playing the videos on our websites would not be possible. According to YouTube, these cookies do not collect any personal data but, rather, only process technical data that is necessary to provide the videos. However, the extended data protection mode does not necessarily rule out data being passed on to YouTube partners. This means that YouTube connects to the Google DoubleClick network regardless of whether you are watching a video.

The use of YouTube is based on Art. 6 (1) of the GDPR and Article 25 (1) of the TTDSG insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

Further information about data protection at YouTube can be found in their privacy statement at: https://policies.google.com/privacy



8. Rights of the Data Subject

If your personal data are processed, you are a Data Subject within the meaning of the GDPR, and you shall have the following rights vis-à-vis the Controller:

Access, rectification, restriction of processing and erasure

You shall have the right at any time, free of charge, to request information about the data being stored about you, their origin and recipients, and the purpose of the data processing via our websites. In addition, you shall have the right to rectification, erasure and restriction of processing of your personal data, provided that the legal requirements are met.

Right to data portability

You shall have the right to obtain the personal data which you have provided to us as the Controller in a structured, commonly used and machine-readable format. We may fulfil the conditions of this right by providing a csv export of the customer data processed concerning you.

Right to be informed

If you have exercised your right to rectification, erasure or restriction of processing by the Controller, the Controller has an obligation to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or deletion of the data or restriction of processing, unless this proves to be impossible or entails disproportionate effort.

You shall have the right to be informed about these recipients by the Controller.

Right to object

You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; this also applies to profiling based on these provisions

The Controller will no longer process personal data concerning you, unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing is for the assertion, exercise or defence of legal claims.

If the personal data concerning you are processed for direct marketing purposes, you shall have the right to object at any time to the processing of your personal data for the purpose of such marketing; this shall also apply to profiling where it is associated with such direct mail.

Contradict

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Directive 2002/58 /EC notwithstanding, you shall have the option, in relation to the use of information society services, of exercising your right to object by means of automated procedures using technical specifications.

Revocation of declarations of consent under data protection law

In addition, you may withdraw your consent at any time with future effect using the contact details provided under point 1.

Right to lodge a complaint with the data protection authority 

If you believe that the processing of personal data concerning you breaches the EU General Data Protection Regulation, you shall have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, your place of employment or the place where the suspected breach took place.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.

 

9. Changes to this Privacy Policy

We reserve the right to change this Privacy Statement for good cause and without prior notice. Please consult this page regularly, therefore, for possible changes to this Privacy Statement.
 

As per: 23.04.2024