Introduction.

This Privacy Policy applies to all personal information collected and processed by Sanyei (Deutschland) GmbH (“Sanyei” or “We”) and its subsidiaries both online and offline, through all forms of media, including but not limited to Sanyei’s websites , their social media presence, blogs and other communication channels, as well as in the use or purchase of products and use of services, when registering for our Newsletter or contacting us via contact form or by e-mail to customer support.

Personal information is any information relating to an identified or identifiable natural person, such as, for example, names, addresses, telephone numbers, e-mail addresses, contract, accounting and billing information that is an expression of a person’s identity.

Protecting your privacy is of particular concern to Sanyei. We therefore use the information that we collect and process about you only in accordance with the applicable legal provisions, in particular the EU Data Protection General Regulation (GDPR) and the German Federal Data Protection Act (BDSG). Data protection and information security are an integral part of our Corporate policy.

Responsibility (“Controller”).

As Controller and responsible for the processing of your data is Sanyei Deutschland GmbH; exceptions are explained later in this Privacy Policy. Our contact details are as follows:

Sanyei (Germany) GmbH

Oststraße 152

D-40210 Dusseldorf

Tel: +49 (0) 211/36 30 51

Fax: +49 (0) 211/3 61 35 32

E-Mail: info@sanyei.de

 

How your data is collected, stored, and how it is used and for what purposes.

1. a) When visiting the website

When you visit our website www.ion-sei.com, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called

log file

. The following information is automatically collected and stored until it is deleted automatically:

• IP address of the requesting computer,
• date and time of access,
• name and URL of the retrieved file,
• Website from which access is made (so-called “Referrer URL”),
• the browser used and, if applicable, the operating system of your computer as well as the name of your access provider.

The data as described above will be processed by us for the following purposes:

• Ensuring a smooth connection of the website,
• Ensuring comfortable use of our website,
• Evaluation of system security and stability as well
• For further administrative purposes.

The legal basis for data processing is Art. 6 para. 1 sent. 1 lit. f GDPR. Our legitimate interest derives from the data collection purposes listed above. We will not use the collected data for the purpose of drawing conclusions about your identity.

In addition, we use cookies and analysis services when visiting our website. For more details, please check below in this Privacy Policy and our Cookie Policy.

1. b) When registering for our Newsletter

Upon your express consent in accordance with Art. 6 para. 1 sent. 1 lit. a GDPR we use your e-mail address to regularly send you our Newsletter. For the receipt of the Newsletter the indication of an e-mail address is sufficient. For sending the Newsletter, we use the so-called double opt-in procedure, which means that we will only send you a Newsletter by e-mail if you have previously explicitly confirmed to us that we should activate the Newsletter service. We will then send you a notification e-mail asking you to confirm that you wish to receive our Newsletter by clicking on a link in this e-mail.

Deregistration from the Newsletter is always possible, regularly via a link at the end of each Newsletter. Alternatively, you can also send your unsubscribe request at any time to info@sanyei.de using the keyword “Unsubscribe Newsletter” by e-mail. Further information can be found under “Newsletter”.

1. c) By using our contact form

For questions of any kind, we offer you to contact us via the contact form provided on the website. It is necessary to provide a valid e-mail address so that we know who the request came from and to answer it. Further information may be provided voluntarily by you.

The data processing for the purpose of contacting us is in accordance with Art. 6 para. 1 sent. 1 lit. a GDPR based on your voluntarily given consent.

The personal data provided by you when using the contact form will be automatically deleted after the request has been made, unless you have consented to further use of your data for advertising purposes, possibly involving partner companies. Your once given consent may be revoke against us at any time.

As a result of revocation, we are no longer allowed to continue the data processing based on this consent for the future.

You are not obliged to provide Sanyei with personally identifiable information. However, if you choose not to disclose certain information, you may not be able to request our products and services, participate in our programs and promotions (e.g., contests, surveys), or use some of the features of our website.

Disclosure of your data to third parties

1. a) Transmission of data to other controllers

Your personal data will only be transmitted by us to other third parties if this is necessary for the fulfillment of the contract, if we or the third party have a legitimate interest in passing on your data or if you have given consent to it. Details of the legal grounds can be found in the subsection “Legal grounds for Transmission”. If data is transmitted to third parties on the basis of a legitimate interest, this will be explained in this Privacy Policy. In addition, data may be transmitted to other parties, as far as we are obliged to do so due to legal provisions or enforceable administrative or court orders.

1. b) Transmission to service providers

We engage external service providers with tasks such as programming or data hosting. We have carefully selected these service providers and monitor them regularly, in particular their careful handling and safeguarding of the data stored with them. All service providers are obliged by us to confidentiality and compliance with legal requirements.

Legal grounds for Transmission

We will not transmit your personal data to third parties for purposes other than those listed below.

We only share your personal information with third parties if:

• You have given express consent according to Art. 6 para. 1 sent. 1 lit. a GDPR
• Disclosure pursuant to Art. 6 para. 1 sent. 1 lit. f GDPR is necessary for asserting, exercising or defending legal claims and there is no reason to assume that you have a predominantly legitimate interest in not disclosing your data,
• In the event that disclosure pursuant to Art. 6 para. 1 sent. 1 lit. c GDPR is a legal obligation, or
• it is legally permissible according to Art. 6 para. 1 sent.1 lit. b GDPR ad it is required for the settlement of contractual relationships with you.

Transfer to recipients outside the EEA

Sanyei may also transfer personal information to recipients located outside the EEA in so-called Third countries (e.g. USA). In this case, we ensure that the recipient has either an adequate level of data protection prior to distribution, e.g. due to a decision on adequacy of the EU Commission for the respective country (e.g. Japan) under Article 45 par. 3 GDPR or based on the agreement of so-called EU Standard contractual clauses of the European Union (SCC) with the recipient according to Art. 46 para.2 lit. c GDPR or your consent to the disclosure or other exceptions according to Art. 49 GDPR.

You can obtain from us an overview of the recipients in third countries and a copy of the specific arrangements agreed to ensure the appropriate level of data protection. Please use the information under “controller”.

Google Analytics

For the purpose of customizing and continually optimizing our pages, we use Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”).

Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website by you. In this context, pseudonymised usage profiles are created and cookies are used. The information generated by the cookie about your use of this website such as

• browser type / version,
• used operating system,
• Referrer URL (the previously visited page),
• host name of the accessing computer (IP address),
• Time of the server request

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading the browser plug-in available under the following link and install:

http://tools.google.com/dlpage/gaoptout?hl=de

Google has submitted to the Privacy Shield Agreement between the European Union and the United States and is certified as such. As a result, Google agrees to comply with the standards and regulations of European data protection law. You can find further information in the following linked entry:

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Social media plug-ins

Based on Art. 6 para. 1 p. 1 lit. f GDPR, we use so-called “social plug-ins” of the social networks “Facebook” and “Instagram” in order to make our company and our product better known. The commercial purpose for the use of these is to be regarded as a legitimate interest within the meaning of GDPR. The responsibility for the operation compliant with data protection rests by their respective providers. The integration of these plug-ins by us is realized in the way of the so-called “two-click method”, in order to protect visitors of our website in the best possible way.

1. a) Facebook

On our website social media plugins from Facebook are used to personalize their use. For this we use the “LIKE” or “SHARE” button. This service is offered by Facebook.

If you visit a page of our website that contains such a plugin, your browser establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to your browser and integrated by Facebook into the website.

By integrating the plugins, Facebook receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Facebook account or are currently not logged in to Facebook. This information (including your IP address) is transmitted from your browser directly to a Facebook server in the US and stored there.

If you are logged in to Facebook, Facebook can assign the visit to our website directly to your Facebook account. If you interact with the plugins, for example by pressing the “LIKE” or “SHARE” button, the corresponding information is also transmitted directly to a Facebook server and stored there. The information will also be posted on Facebook and displayed to your Facebook friends.

Facebook may use this information for the purpose of advertising, market research and tailor-made Facebook pages. For this purpose, Facebook uses the according user, interest and relationship profiles, e.g. for example, to evaluate your use of our website in relation to the advertisements displayed on Facebook, to inform other Facebook users about your activities on our website, and to provide other services related to the use of Facebook.

If you do not want Facebook to assign the data collected via our website to your Facebook account, you must log out of Facebook before visiting our website.

For the purpose and scope of the data collection and further processing and use of the data by Facebook, as well as your related rights and settings options for the protection of your privacy, please refer to the privacy policy (https://www.facebook.com/about/privacy/) of Facebook.

1. b) Instagram

Our website also uses social plugins operated by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”).

The plugins are marked with an Instagram logo, for example in the form of an “Instagram camera”.

When you visit a page of our website that contains such a plugin, your browser connects directly to Instagram’s servers. The content of the plugin is transmitted by Instagram directly to your browser and integrated into the page. Through this integration, Instagram receives the information that your browser has accessed the corresponding page of our website, even if you do not have an Instagram profile or are currently not logged in to Instagram.

This information (including your IP address) is sent from your browser directly to an Instagram server in the US and stored there. If you’re logged in to Instagram, Instagram can instantly associate your visit to our website with your Instagram account. If you interact with the plugins, for example, press the “Instagram” button, this information is also transmitted directly to an Instagram server and stored there.

The information will also be posted on your Instagram account and displayed there to your contacts.

If you do not want Instagram to directly map the data collected through our website to your Instagram account, you’ll need to log out of Instagram before visiting our website.

For more information, please see the privacy policy (https://help.instagram.com/155833707900388) of Instagram.

1. c) LinkedIn

Our website uses social plugins from the LinkedIn Network, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). You can recognize LinkedIn plugins recognize by the LinkedIn logo or the “Recommend” button on the website.

When you visit a page of our advertising that contains such a plugin, your browser connects directly to LinkedIn’s servers. The content of the plugin is transmitted by LinkedIn directly to your browser and integrated into the page. The integration gives LinkedIn the information that your browser has accessed the corresponding page of our advertising presence, even if you don´t have a LinkedIn profile or are currently not logged in to LinkedIn. This information (including the IP address) is sent from your browser directly to a LinkedIn server in the United States and stored there.

If you’re logged in to LinkedIn, LinkedIn can instantly associate the visit to our website with your LinkedIn account. If you interact with the plugins, for example by clicking on the “LinkedIn” button, the corresponding information is also transmitted directly to a LinkedIn server and stored there. The information will also be published on your LinkedIn account and displayed there to your contacts.

For information on the purpose and scope of the data collection and the further processing and use of the data by LinkedIn, as well as your rights and setting options for protecting your privacy, please refer to LinkedIn’s privacy policy:

https://www.linkedin.com/static?key=privacy_policy&trk=hb_ft_priv

Newsletter

We only send Newsletter with your consent. By subscribing to our Newsletter, you agree to the receipt and the procedures as described. Insofar as the contents of a Newsletter are concretely described, these are decisive for your consent. Our Newsletter contains information about our offers and promotions as well as our company.

Double opt-in and logging

The registration for our Newsletter is made by the so-called “double opt-in”. This means that after signing up, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one else can register with a false e-mail addresses.

The registration for the Newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of both the login and the confirmation time as well as the IP address. Also the changes to your data stored in “MailChimp” will be logged.

“MailChimp”

The Newsletter is distributed via MailChimp, a Newsletter distribution platform of the by Rocket Science Group, LLC, 675 Ponce De Leon Ave NE # 5000, Atlanta, GA 30308, USA.

The e-mail addresses of the recipients of our Newsletter, as well as their other information described in these notes, are stored on MailChimp’s servers in the USA. MailChimp uses this information to send and evaluate the Newsletter on our behalf. Furthermore, MailChimp may use this information to optimize or improve its own services, for example for the technical optimization of the distribution and the presentation of the Newsletters or for economic purposes, in order to determine the countries the recipients are located. However, MailChimp does not use the data of the recipients of our Newsletter to contact you or to pass them on to third parties.

We trust on the reliability, IT and data security of MailChimp. MailChimp is certified under the US-EU “Privacy Shield” and is committed to complying with EU privacy regulations. Furthermore, we have concluded a “Data Processing Addendum” with MailChimp. This is a contract in which MailChimp commits to protect our users’ privacy, and processing their data on our behalf in accordance with its privacy policy and, in particular, not to disclose it to third parties. The privacy policy of MailChimp can be found here.

https://mailchimp.com/legal/privacy/

Registration Details

To subscribe to the Newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to provide your first and last name. This information is only to personalize the Newsletter. We also ask you to optionally specify your date of birth, gender and industry. We only use this information to adapt the content of the Newsletter to the interests of our users.

Statistical survey and analysis

The Newsletters contain a so-called “web-beacon”, which is a pixel-sized file that is called up from the MailChimp server when the Newsletter is opened. As part of this call, technical information such as information about the browser and your system, as well as your IP address and time of call will be collected. This information is used to improve the technical performance of services based on the specifications of the users and their reading habits, based on their locations (which can be determined using the IP address) or times of access.

The statistical surveys also include determining whether the Newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual Newsletter recipients. However, it is neither our purpose nor that of MailChimp to observe individual users. Rather, the evaluations serve 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.

Online call and data management

There are cases where we direct the recipients of our Newsletter to the MailChimp websites. For example, our Newsletters contain a link that enables the recipients of our Newsletter to retrieve Newsletter online (for example, in the case of display problems in the e-mail program). Furthermore, as a recipient of our Newsletter, you can subsequently correct your data such as the e-mail address. Also, the privacy policy of MailChimp is only available on their page.

In this context, we point out that on the websites of MailChimp Cookies are used and thus personal data is processed by MailChimp, their partners and service providers (for example, Google Analytics). We have no influence on this data collection. Further information can be found on the privacy policy of MailChimp. We also inform you about the possibility of objecting to the data collection for advertising purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European area).

Termination / Revocation

You may terminate the receipt of our Newsletter at any time by revoking your consent. A link to unsubscribe the Newsletter can be found at the end of each Newsletter. After termination, your data will be deleted except for the e-mail address. The e-mail address is stored in a block list and it is only used to ensure that we do not send any further e-mails to your e-mail address.

Legal grounds

The consent to the distribution to the e-mail addresses is based on Art. 6 para. 1 lit. a, 7 GDPR and § 7 para.2 no.3, and para.3 UWG. The use of the mail service provider MailChimp, the implementation of statistical surveys and analysis as well as the logging of the registration process are based on our legitimate interests in accordance with. Art. 6 para. 1f GDPR. We are interested in using a user-friendly and secure Newsletter system that serves both our business interests and users’ expectations.

Surveys using SurveyMonkey

For individual surveys, we use SurveyMonkey of SurveyMonkey Europe UC, 2nd Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland, a web service to create and evaluate online surveys. The participation in the surveys is voluntary and the respondents hereby declare their express consent to the processing of their personal data in accordance with Art. Art. 6 (1) lit. a GDPR. The data is stored for the duration of the survey as well as the evaluation.

We expressly to point out that SurveyMonkey initially stores the data on your server and reserves the right to collect, process, use and forward data for its own purposes. In particular, Cookies, ad tracking and IP addresses are used or recorded. SurveyMonkey also reserves the right to transfer this data to third parties, including cross-border, to other countries. The collected personal data is also transmitted on US-American servers where they are collected, processed and stored. Survey Monkey is certified under the Privacy Shield Agreement and has committed to comply with European data protection law.

https://www.privacyshield.gov/participant?id=a2zt0000000Gn7zAAC&status=Active

For further information, please read the relevant sections of SurveyMonkey’s Privacy Policy.

https://de.surveymonkey.com/mp/legal/privacy-policy/

After the end of the evaluation of a survey, we delete the survey data from the SurveyMonkey account. Within 90 days, the data will be permanently removed from SurveyMonkey’s system.

https://help.surveymonkey.com/articles/de/kb/Data-Ownership

Survey participants may contact us at any time requesting the deletion of their survey data, including the personal data, if any. Subsequent correction of individual answers after submitting the survey is not possible.

Retention periods.

As a matter of principle, we store your data as long as necessary for the provision of our online service and associated services or we have a legitimate interest in the further storage. In all other cases, we will delete your personal information other than information we may need to retain in order to comply with legal obligations (for example, we may be required to maintain records due to tax and commercial retention requirements, such as contracts and invoices Period to be provided).

Safety measures.

Sanyei uses industry-standard security measures such as encryption (SSL) and firewalls to protect its websites against loss, misuse and manipulation of information that is under the control of Sanyei. However, no security system is 100% fail-safe. We are not responsible for the consequences of security breaches except as a result of our negligence.

Your rights.

You have the right:

• in accordance with Art.15 GDPR, to request information about your personal data processed by us. In particular, you will be provided with information on the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned retention period, the right to rectification, deletion, limitation of processing or opposition, the existence of a The right to complain, the source of their data, if not collected from us, and the existence of automated decision-making including profiling and, where appropriate, significant information about their details;
• in accordance with Art. 16 GDPR, to immediately demand the correction of incorrect or to complete personal data stored with us;
• in accordance with Art. 17 GDPR, to demand the deletion of your personal data stored by us, unless the processing for the exercise of the right to freedom of speech and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of Legal claims is required;
• to demand the restriction of the processing of your personal data according to Art. 18 GDPR, as far as the accuracy of the data is disputed by you, the processing is unlawful, but you reject its deletion and we no longer need the data, but you assert this, Exercise or defense of legal claims or you have objected to the processing in accordance with Art. 21 GDPR;
• in accordance with Art. 20 GDPR, to receive your personal data provided to us in a structured, standard and machine-readable format or to request transmission to another person responsible;
• according to Art. 7 para. 3 GDPR, to revoke your once given consent to us at any time. As a result, we are not allowed to continue the data processing based on this consent for the future and
• to complain to a supervisory authority pursuant to Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or work or our company headquarters.

Sanyei account

If you have created a Sanyei account through our website, you can access your data via the “Personal settings” button, and you also have the necessary options to update, change or even delete the data stored there. Regarding our advertising related messages, there is also an “opt-out” option available.

Information for parents.

This website is basically intended for the use for adults only and is not intended for persons under the age of 16. In accordance with the law, permission must be obtained from parents or caregivers before information is collected and processed from persons under the age of 16.

If the registration or other information submitted to our websites indicates that the visitor is under the age of 16, we will not allow the user to continue sharing personal information. Furthermore, all information up to this point will be deleted from our data.

Change of privacy policy.

From time to time, Sanyei may make changes to this Privacy Policy without notice. Please check this privacy policy regularly for changes. Altered privacy statements are effective from the date of publication. If you do not agree to changes to this Privacy Policy, please change your settings or stop using the Site. By visiting the Sanyei website after announcing any changes, you acknowledge the validity of updated privacy statements.

This privacy policy is currently valid and is valid as of May 2019.