Privacy policy

1. Objective and responsibility

1.1. This privacy policy informs you about the nature, scope and purpose of the processing of personal data within PINPOOLS or PINPOOLS associated websites, functions and content (hereinafter also collectively referred to as “Online Offer” or “Website”). The Privacy Policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) used on which the Online Offer is executed.

1.2. Provider of the online offer and responsible under data protection law is PINPOOLS GmbH, Karlstraße 27, 40210 Düsseldorf. Managing directors: Alexander Lakemeyer and Heribert-Josef Lakemeyer: [email protected] (hereinafter referred to as “we” or “us”). For further information about us as well as contact possibilities we refer to our imprint: (https://pinpools.com/sp/imprint)

2. Basic information on data processing and legal basis

2.1. The personal data of users processed within the scope of this online offer includes inventory data (e.g., names and addresses of customers), contract data (e.g., services used, names of clerks, payment information), usage data (e.g., the web pages visited of our online offer, interest in our products) and content data (e.g., entries in the contact form).

2.2. The term “user” includes all categories of data subjects. They include our business partners, customers, buyers, sellers, interested parties and other visitors to our online offer. The terms used, such as “user”, are to be understood as gender-neutral.

2.3. We process users’ personal data only in compliance with the relevant data protection regulations. This means that the users’ data will only be processed if a legal permission exists. I.e., in particular if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) as well as online services, or is required by law, a consent of the users is available, as well as due to our legitimate interests (i.e. interest in the analysis), optimization and economic operation and security of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR, in particular in the case of range measurement, creation of profiles for advertising and marketing purposes, as well as collection of access data and use of third-party services.

2.4. As of 25.05.2018 (hereinafter referred to as the “GDPR effective date”), the validity of our processing of personal data is determined solely by the GDPR and then applicable data protection laws, which include in particular the BDSG-Neu. Within the scope of this data protection declaration, terms and regulations of the GDPR are already used, which, however, basically correspond in terms of content to the regulations and terms of the laws applicable until the GDPR effective date. If terms are not defined below, their meaning up to the GDPR effective date is to be understood in the sense of correspondingly applicable data protection regulations. Insofar as legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR is referred to, Section 28 (1) sentence 1 no. 2 and Section 15 (3) of the German Telemedia Act (TMG) shall apply as the legal basis for our legitimate interests until the effect of the GDPR unfolds as of May 25, 2018.

2.5. With regard to the processing of personal data on the basis of the Data Protection Regulation (GDPR), we point out that the legal basis of consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures is Art. 6 para. 1 lit. b GDPR, the legal basis for processing for the performance of our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR.

3. Security measures

3.1. We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

3.2. The security measures include in particular the encrypted transmission of personal data between your browser and our server.

4. Provision of contractual services

We process inventory data (e.g., names and addresses as well as contact data of users), contractual data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services within the meaning of. Art. 6 para. 1 lit b. GDPR.

5. Disclosure of data to third parties and third-party providers

5.1. Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for billing purposes or for other purposes if these are necessary to fulfill our contractual obligations to users.

5.2. If we use subcontractors to provide our services, we take appropriate legal precautions as well as corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal regulations.

5.3. If content, tools or other means from other providers (hereinafter collectively referred to as “third party providers”) are used within the scope of this data protection declaration and their named registered office is located in a third country, it is to be assumed that a data transfer takes place to the third party providers’ countries of domicile. Third countries are countries in which the GDPR is not directly applicable law, i.e. basically countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if there is an adequate level of data protection, user consent or otherwise legal permission.

6. Contacting

6.1. When contacting us (via contact form or e-mail), the user’s details are processed for the purpose of handling the contact request and its processing.

6.2. The user’s details may be stored in our customer relationship management system (“CRM system”) or comparable inquiry organization and must be stored as business letters for 6 years due to legal requirements.

7. Comments and contributions.

7.1. When users leave ratings or comments, based on our legitimate interests as defined in Art. 6 para. 1 lit. f. GDPR their IP addresses are stored.

7.2. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

7.3. The authors agree to the storage of IP addresses and their use (which may include disclosure, if objectively justified), in the event that claims are made against us by third parties.

8. Registration and cancellation

8.1. In the course of registration by the users, the required mandatory information will be provided to the users. This includes in particular:

• E-mail address (Only for logged in users visible, non-public information);
• Password (non-public information, stored in encrypted form);
• First name and last name of the user (Only for logged in users visible, non-public information);
• Company name (public information);
• Company address (Only for logged in users visible, public information);
• telephone number (Only for logged in users visible, public information).

8.2. In addition to the aforementioned data, each User decides for himself/herself on further information, which in principle constitutes public information (except in the case of payment data);

8.3. The public profile information of the Users (which includes the company information) is viewable by other Users and searchable by them. The locations of the users can be displayed on a map.

8.4. In the context of registration and renewed registrations as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so within the meaning of Art. 6 para. 1 lit. c GDPR.

8.5. The content of private messages exchanged between users is only stored for the purpose of transmission and is not otherwise processed by us.

8.6. Upon termination, we are entitled to delete the user profiles of the users. It is the responsibility of the users to save their profile information.

8.7. Upon termination of the user account, the user’s data will be deleted in accordance with the information on termination in the GTC, provided that it relates to the user account and is not stored for other legally permitted or necessary reasons (e.g. order transactions based on tax law retention obligations).

8.8. It is the responsibility of the users to save their data in case of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

9. Analysis, user profiles Interest-based content and ads

9.1. We process the profile data of users on the basis of our legitimate interests (i.e. interest in the analysis), optimization and economic operation of our online offer as well as optimization of the user experience of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR the profile details of the users, as well as their contributions from offers, comments and other posts (but not private messages), in order to display content (e.g. news or advertisements) prepared for their potential interests.

9.2. We process usage data of our customers (e.g., the visited web pages of our online offer, interest in our products as well as submitted offer requests) in a user profile on the basis of our legitimate interests in advertising and market research purposes pursuant to Art. 6 para. 1 lit. f GDPR, e.g., to suggest product information to customers based on their previously used services by displaying it within our online offer or to analyze and optimize the development of our online offer.

9.3. In the context of the analysis of the buyer’s requests to sellers, we store only the information about the product and the buyer and seller. The content of the exchanged individual messages is stored only for the purpose of transmission and is not otherwise processed by us.

9.4. In order to be able to display interest-based content, so-called user profiles are created. This means, for example, that we store the information that the user’s company is located in Berlin and belongs to a certain industry, so that we can provide the user with offers that match the location and industry.

10. Collection of access data

10.1. Based on our legitimate interests, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

10.2. Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.

11. Cookies & Reach Measurement

11.1. Cookies are information that is transmitted from our web server or third-party web servers to the users’ web browsers and stored there for later retrieval. Cookies may be small files or other types of information storage. Unless explicitly stated in this privacy policy, we only use so-called “session cookies”, which are only stored for the duration of the current visit within our online offer (e.g. to enable the storage of your login status and thus the use of our online offer at all). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close the browser, for example.

11.2. Users will be informed about the use of cookies in the context of pseudonymous reach measurement within the scope of this privacy policy.

11.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

11.4. You can object to the use of cookies used for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (https://optout.networkadvertising.org) and additionally the US website (https://www.aboutads.info/choices) or the European website (https://www.youronlinechoices.com/uk/your-ad-choices).

12. Google Analytics

12.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.

12.2. Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

12.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

12.4. We use Google Analytics only with activated IP anonymization. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

12.5. The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available under the following link: (https://tools.google.com/dlpage/gaoptout).

12.6. You can find out more information about data use by Google, setting and objection options on Google’s websites: (https://www.google.com/intl/de/policies/privacy/partners) (“Data use by Google when you use our partners” websites or apps’), (https://www.google.com/policies/technologies/ads) (“Data use for advertising purposes”), (https://www.google.de/settings/ads) (“Manage information Google uses to show you ads”).

13. Google Re/Marketing Services

13.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) the marketing and remarketing services (in short “Google marketing services”) of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

13.2. Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

13.3. The Google marketing services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products he or she has been interested in on other websites, this is referred to as “remarketing”. For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website.') With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers of Google. The aforementioned information may also be linked on the part of Google with such information from other sources. If the user subsequently visits other websites, he can be shown ads tailored to his interests.

13.4. The user’s data is processed pseudonymously as part of the Google marketing services. I.e. Google does not store and process e.g. the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.

13.5. The Google marketing services used by us include, among others, the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked across the websites of AdWords customers. The information obtained using the cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. The AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

13.6. We may integrate third-party advertisements based on the Google marketing service “DoubleClick”. DoubleClick uses cookies that allow Google and its partner websites to serve ads based on users’ visits to this website or other websites on the Internet.

13.7. We may integrate third-party advertisements based on the Google marketing service “AdSense”. AdSense uses cookies to enable Google and its partner websites to display ads based on users’ visits to this website or other websites on the Internet.

13.8. We may also use the service “Google Optimizer”. Google Optimizer allows us to track the effect of various changes to a website (e.g. changes to input fields, design, etc.) as part of so-called “A/B testing”. Cookies are placed on users’ devices for these testing purposes. Only pseudonymous data of the users is processed in the process.

13.9. Furthermore, we may use the “Google Tag Manager” to integrate and manage the Google analysis and marketing services on our website.

13.10. For more information on the use of data for marketing purposes by Google, please refer to the overview page: (https://www.google.com/policies/technologies/ads), Google’s privacy policy is available at (https://www.google.com/policies/privacy).

13.11. If you wish to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google: (https://www.google.com/ads/preferences).

14. Newsletter

14.1. With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

14.2. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Apart from that, our newsletters contain information on chemical products as well as on PINPOOLS and services offered within PINPOOLS.

14.3. Double-Opt-In and Logging: The registration for our newsletter is done in a so-called double-opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address.

14.4. Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name, so that we can address you personally in the newsletter, as well as your industry and website, so that we can get to know our readers and adapt the newsletter content to their interests.

14.5. Statistical collection and analyses - The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

14.6. The use of the dispatch service provider, performance of the statistical surveys and analyses as well as logging of the registration process, are carried out on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users.

14.7. Cancellation/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. In doing so, your consents to its sending will expire at the same time. You will find a link to cancel the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and cancelled this subscription, their personal data will be deleted.

15. Integration of third-party services and content

15.1. We use within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as “content”). This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

15.2. The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, in part, already mentioned here, objection options (so-called opt-out). :- External fonts from Google, Inc., (https://www.google.com/fonts) (“Google Fonts”. The integration of Google Fonts is done by a server call at Google (usually in the USA). Privacy policy: (https://www.google.com/policies/privacy/), Opt-Out: (https://www.google.com/settings/ads/).- Maps of the service “Google Maps” of the third party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: (https://www.google.com/policies/privacy/), Opt-Out: (https://www.google.com/settings/ads/).- Videos of the platform “YouTube” of the third party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: (https://www.google.com/policies/privacy/), Opt-Out: (https://www.google.com/settings/ads/).- Note on Google, Inc.: Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Usage of Intercom: We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and your anonymous user ID or email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom's use of cookies, please visit Terms and Policies | Intercom. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). For more information on the privacy practices of Intercom, please visit Terms and Policies | Intercom. Intercom’s services are governed by Intercom’s terms of use which can be found at Terms and Policies | Intercom. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

16. User rights

16.1. Users have the right, upon request and free of charge, to receive information about the personal data that we have stored about them. In addition, users have the right to correct incorrect data, restrict processing and delete their personal data, if applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to lodge a complaint with the competent supervisory authority (Die Landesbeauftragte f).

16.2. Users can also revoke their consent, in principle with effect for the future.

17. Deletion of data

17.1. The data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the user data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for reasons of commercial or tax law.

17.2. According to legal requirements, the data is stored for 6 years in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

18. Right of objection

Users may object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against processing for direct advertising purposes.

19. Changes to the data protection declaration

19.1. We reserve the right to change the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. Insofar as user consents are required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.

19.2. Users are requested to inform themselves regularly about the content of the data protection declaration.

Status: 22.05.2018

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