VERWAY World S.L.U.
represented by its Managing Director Mr Ilhan Dogan
Gran Via Puig de Castellet no. 1, Bl. 1, 1 B
07180 Santa Ponsa, Spain
(hereinafter referred to as: VERWAY)
For the assertion of rights relating to data protection or for questions regarding the use, collection, or processing of your personal data, please contact our data protection officer:
SBS DATA PROTECT GmbH
1. SECURITY AND PROTECTION OF YOUR PERSONAL DATA
As the data controller as defined under data protection regulations, we commit ourselves to protecting your personal data and treating it confidentially. The collection, storage, modification, transmission, blocking, erasure, and use of your personal data is always carried out in accordance with the applicable data protection regulations, especially the EU General Data Protection Regulation (GDPR).
In order to protect your rights, we have adopted technical and organisational measures, and also ensured that external service providers commissioned by us comply with the data protection regulations.
2. STORAGE DURATION
We store your personal data as long as necessary to achieve the purpose for which it was stored or for as long as stipulated by law.
Data that we process on the basis of your consent will be stored until your consent is revoked or for as long as the data is required.
We store data that we process for the purpose of a contractual relationship with you for as long as the contractual relationship exists and beyond if statutory retention periods require us to do so.
Data that we process on the basis of a legitimate interest will be stored as long as the legitimate interest exists and your interest in its deletion is not judged to be higher.
3. ACCESS DATA
If you use the website for information purposes only, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which are technically necessary for us to display our website to you and to guarantee its stability and security:
- IP address
- Date and time of request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Request status/HTTP status code
- The amount of data transmitted
- The website making the request
- Operating system and device
- The language and version of the browser software
However, our web server stores this information separately from other data; it is not possible for us to assign this data to a specific person. After an anonymous evaluation for statistical purposes, this information will be deleted immediately.
This data processing is based on Art. 6 para. 1 clause 1 lit. f GDPR and serves to protect our legitimate interest in the optimal presentation of our website.
4. LOG FILES
In addition, log file information (your IP address) will be saved as soon as you log into your account and make changes there (e.g. place an order or change your contact details). For security reasons, this information is stored for as long as it is necessary to investigate abusive or fraudulent activities and will only then be deleted. Data which must be retained as potential evidence is not deleted until the relevant incident has been ultimately clarified.
This data processing is based on Art. 6 para. 1 clause 1 lit. f GDPR and serves to protect our legitimate interest in preventing the misuse of our website.
In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are allocated and stored on your hard disk in association with the browser you are using and through which the site which sets the cookie transmits certain information. Cookies cannot run programmes or deliver viruses to your computer. They serve to make our website more user-friendly and effective overall.
Our website uses the following types of cookies, the scope and functionality of which are explained below:
a) temporary cookies are automatically deleted when you close the browser. These include, especially, session cookies. These store a so-called session ID with which various requests from your browser can be assigned to the common session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out.
b) Persistent cookies are automatically deleted after a specified period, which may differ, depending on the cookie. You can delete the cookies at any time in the security settings of your browser.
c) Flash cookies used are not recorded by your browser, but instead by your Flash plug-in. These objects store the required data of your browser independently and do not have an automatic expiry date.
d) Third party cookies are not set by VERWAY, but by a third party. Third-party cookies are created, for example, by the plug-ins (see below) of such social networks as Facebook or Instagram, or by the services of Google Analytics, You Tube, etc. which are integrated into the VERWAY website. These third-party cookies are generated by integrated plug-ins or technologies of the respective organisations. VERWAY has no control over the cookies and privacy settings of these services or organisations and expressly declares that the respective cookie & privacy policies of these third-party providers apply to these services.
To get more information about these cookies, see the links below.
YouTube, Google Analytics:
You can configure your browser settings according to your wishes and refuse to accept cookies. If you do not want Flash cookies to be used, you must install a corresponding add-on, e.g. “Better Privacy” for Mozilla Firefox or the Adobe Flash Killer Cookie for Google Chrome. You can prevent the use of HTML 5 storage objects by using private mode in your browser. We also recommend that you regularly delete your cookies and your browser history manually. Please note that by deactivating cookies you may not be able to use all functions of this website.
When you contact us by email or via a contact form, the data you provide (your email address, and if applicable your name and your telephone number) will be stored by us in order to answer your questions. We will delete this data once its storage is no longer necessary, e.g. when your enquiry has been addressed. Otherwise, its further processing will be restricted if we are required by law to continue storing it.
The legal basis of the processing is your consent in accordance with Art. 6 para. 1 clause 1 lit. a GDPR.
7. COLLECTION OF PERSONAL DATA RELATING TO CONTRACTS AND PAYMENTS
We store the following personal data of customers placing an order with us:
- Telephone number
- Fax number
- E-mail address
- A different delivery address, as applicable
- Any VAT ID
- Credit card, bank, and bank transfer details.
We use this data solely for the purpose of fulfilling the order and any necessary communication with you. These include the initiation, contracts, processing, warranty, and any refunds related to such orders. This data will be stored until the order has been completely filled. If commercial and tax law retention periods require it, certain data may be stored for up to 10 years.
The recording and processing takes place within the framework of the contract between VERWAY and the customer per Art. 6 para. 1 clause 1 lit. b GDPR. The further storage of the data for tax and commercial law reasons is based on legal requirements as permitted by Art. 6 para. 1 clause 1 letter c GDPR.
8. TRANSFER OF DATA TO THIRD PARTIES
We share your personal data with third parties only when it is absolutely necessary to fill your order or to preserve our legitimate interests. We also use external service providers to fill orders. Separate contract data processing contracts have been concluded with the service providers to ensure the protection of your personal data.
- As part of hosting our server systems and administering the IT systems required for hosting, the data of website visitors, customers, distribution partners, or others may be processed by service providers based in France, Spain, Scotland, or Germany. This includes at least the following data: IP address, log files, name, first name, address, email, telephone number, birthday, account details, VAT ID number, if applicable.
- In order to carry out the delivery, the customer’s name, address, email, and telephone number will be disclosed to the forwarding agent. This data transfer takes place to fulfil the contractual relationship with you as a customer. The legal basis for this data processing is Art. 6 para. 1 clause 1 lit. b GDPR.
- In order to process payments, the customer’s name, address, email, and telephone number will be disclosed to the payment service provider. In detail:
This data transmission takes place in order fulfil our contractual relationship with you as a customer and/or distribution partner, as well as to safeguard our legitimate interests. The legal basis for this data processing is Art. 6 para. 1 clause 1 lit. b and lit. f GDPR.
As part of a SEPA transfer, your payment data will not be forwarded by us to third parties.
When paying by credit card, the invoice number, the invoice amount, information about the products ordered, the contract language, and currency are forwarded to the respective service provider and/or credit card issuer.
For customers from Austria, who have selected payment via eps-transfer, your first name, name, IBAN and BIC will be forwarded to the following payment service providers:
Studiengesellschaft für Zusammenarbeit im Zahlungsverkehr GmbH, Frankgasse 10/8 1090 Vienna, Austria.
The data processing described above takes place for the purpose of carrying out the contractual relationship with you as a customer or on the basis of the consent granted when selecting your payment method. The legal basis for this data processing is Art. 6 para. 1 clause 1 lit. a or lit. f GDPR.
9. USE OF GOOGLE ANALYTICS
Please be aware that, should you delete cookies from your browser settings, the opt-out cookie may also be deleted and will need to be reactivated.
This website uses Google Analytics with the “anonymizeIP” extension. As a result, IP addresses are only processed in truncated form in order to prevent Google from identifying specific individuals’ use of the site. If the data collected about you are personally identifiable, they will be blocked immediately and the personal data deleted as soon as possible.
We use Google Analytics to analyse and regularly improve the function of our website Using the statistics and insights gained, we can improve our offer and make it more interesting for you as a user. Google has agreed to comply with the EU-US Privacy Shield, https://www.privacyshield.gov/, with regard to any personal data transferred to the USA.
Information about the third-party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Google terms and conditions:
This website also uses Google Analytics for an analysis of visitor flows across all devices, that is carried out via a user ID (Google Universal Analytics). You can disable the device cross-analysis of your use in your customer account under “My data”, “Personal data”.
This data processing is used to measure and evaluate visitor flows on our website in order to obtain a precise overview of the visitor numbers, usage interests, and other relevant information for the organisation of our business and the design of our website. This data processing is carried out on the basis of Art. 6 para. 1 clause 1 lit. f GDPR and serves to protect our legitimate interest in the optimal presentation of our website.
VERWAY uses the technical platform and services of Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland for the information services offered here (hereinafter: Facebook). In addition, there is a link to the VERWAY Facebook page on the website.
In the view of the European Court of Justice, per Art. 26 GDPR, Facebook and the operator of a Facebook fan page share responsibility for the personal data processed via the Facebook fan page. For this reason, Facebook and VERWAY have entered into a joint responsibility agreement which can be viewed here.
VERWAY provides the following information on data processing on our Facebook fan page:
The processing of your personal data on the VERWAY Facebook fan page is a shared responsibility with:
Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland
Processing of data
When accessing a Facebook fan page, the IP address of your device is transmitted to Facebook. According to Facebook, this IP address is anonymised and deleted after 90 days, if it is a German IP address. In addition, Facebook stores other information about user devices, such as the type of browser used. It may be possible for Facebook to assign IP addresses to individual users. If you are logged in to your Facebook account while visiting our fan page, a cookie with your Facebook ID will be set on your device. This cookie will allow Facebook to track your visit to our fan page and how you interacted with it. Facebook uses this information to present content or advertising tailored to you.
If you do not want this, you should log out of your Facebook account or disable the “Stay signed in” feature. We also recommend deleting cookies on your device and stopping and restarting your browser. This process deletes the information Facebook can use to link to you.
However, if you want to use the interactive features of our fan page, you would have to log in to Facebook again with your Facebook credentials. This also makes it possible for Facebook to link to you again.
The manner in which Facebook uses the data from visits to Facebook pages for its own purposes, the extent to which activities on the Facebook page are assigned to individual users, how long Facebook stores this data and whether data from a visit to the Facebook page is passed on to third parties is not conclusively and clearly identified by Facebook and it is not known to us. As a user of our fan page, we can only refer you to the information provided by Facebook concerning its data protection practices.
The data collected about you in this context will be processed by Facebook and may be transferred to countries outside the European Union.
Facebook describes in general terms what information it receives and how this data is used in its data usage guidelines. There you will also find information on how to contact Facebook and how to set up advertisements. You can read more about how Facebook uses your data at: https://www.facebook.com/about/privacy.
Facebook Inc., the U.S. parent company of Facebook Ireland Ltd. is certified under the EU-U.S. privacy shield and thus has committed itself to adhere to European data protection directives. Further information about the privacy shield status of Facebook is available at https://www.privacyshield.gov.
We cannot rule out the transmission and further processing of personal data of users and visitors to the Facebook page in third countries, such as the United States, as well as the possible associated risks for the users and visitors.
In addition, Facebook provides Insights, a set of statistical data available to VERWAY as a fan page operator. Facebook generates the statistics and makes them available to us. As operator of the fan page, we have no influence on their production and cannot prevent it. As part of the “Insights” function, the following information is presented to us in the categories “Fans”, “Subscribers”, “Persons reached” and “Interacting persons” for given period of time:
page activities such as page views, page preview, page actions; reach such as likes, hits, and referrals; posting such as posting interactions, video views, comments, shared content.
Facebook provides more information on this under the following link:
VERWAY uses this data available in aggregate form to make your posts and activities on their Facebook page more attractive for users and visitors The legal basis for this data processing is Art. 6 para. 1 clause 1 lit. f GDPR, namely our legitimate interest in optimizing our website.
We store the information provided by Facebook for as long as your interest in its deletion or anonymisation does not prevail.
If you no longer want your data processed as described here, please use the functions “I do not like this page anymore” and/or “Unfollow this page” to unlink your user profile to our fanpage.
Your rights as a data subject
12. USE OF SOCIAL MEDIA PLUG-INS
We currently use the social media plug-ins of these providers:
Facebook, YouTube, Instagram, Twitter.
We use the so-called two-click solution . This means that if you visit our site, initially no personal data will be passed on to the providers of these plug-ins. You can recognize the provider of the plug-in by the marking on the box above its initial letter or the logo. We offer you the possibility to communicate directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it, the plug-in provider receives the information that you have accessed the corresponding website of our online offer. By activating the plug-in, data is automatically transmitted to the respective plug-in provider and stored there (US providers in the USA). Since the plug-in provider collects data mainly via cookies, we recommend that you delete all cookies using your browser’s security settings before clicking on the greyed-out box.
We have no influence on the data collected and data processing processes, nor are we aware of the full extent of data collection, the purposes of processing, the storage periods. We also have no information on the deletion of the data collected by the plug-in provider.
The plug-in provider stores the data collected about you as user profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation is also made for users who are not logged in, to display customised advertising and to inform other users of the social network about your activities on our website. You have a right to object to the creation of these user profiles. You must contact the respective plug-in provider to exercise this right. Through the plug-ins we offer you the possibility to interact with social networks and other users, so that we can improve our offering and make it more interesting for you as a user.
The data is passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected with us will be directly assigned to your existing account with the plug-in provider. When activating the activated button and link the page, for example, the plug-in provider also stores this information in your user account and communicates this to your contacts in public. We recommend that you log out regularly after using a social network, especially before activating the button, as this way you can avoid being assigned to your profile with the plug-in provider.
For more information on the purpose and extent of the data collection and its processing by the plug-in provider, please refer to the privacy statements of these providers provided below. Here, you will also find further information on your rights and settings options for protecting your privacy:
YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is a subsidiary of Google LLC, which, in turn, has submitted to the EU-US Privacy Shield, www.privacyshield.gov/.
Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbor, Dublin 2, Ireland; Facebook Inc., the US parent company of Facebook Ireland Ltd., is certified under the EU-US Privacy Shield and is committed to abiding by European data protection law. Further information about the privacy shield status of Facebook is available at https://www.privacyshield.gov/. You can find the complete Facebook data protection policy here: https://www.facebook.com/full_data_use_policy
This data processing is based on Art. 6 para. 1 clause 1 lit. a GDPR on the basis of your voluntary consent and on the basis of Art. 6 para. 1 clause 1 lit. f GDPR and serves to protect our legitimate interest in the optimal presentation of our website.
13. YOUR RIGHTS AS A DATA SUBJECT
You have the right to:
- information about the processing of your data
- to correct or delete your data
- restrict the processing of your data
- object to the processing of your data
- data portability
- to revoke your previous consent with future effect
- complain to a data protection supervisory authority
Last updated: 4 January 2019