Privacy Policy

Privacy Policy and Cookies Policy

This Privacy Policy satisfies the disclosure requirements according to Art. 12 ff. of the EU General Data Protection Regulation (“GDPR”) and provides a summary of the processing of your personally identifiable information (“personal data”, “personal information”) on this web-site.

1. Who is accountable for processing my personal data?


Arvato Polska Sp. z o.o. z siedzibą w Warszawie
Oddział Arvato services Polska w Plewiskach
ul. Kolejowa 150
62-064 Plewiska k. Poznania

is responsible for processing your personal data on this website (hereinafter referred to as “we”). We process personally identifiable information (“personal data”) in accordance with GDPR provisions and the German Federal Data Protection Act (BDSG).
This website has sub-sites (subdomains), which belong to subsidiary companies. These sub-domains are

  • https://scm.arvato.com, Arvato Supply Chain Management (Arvato SCM Solutions)
  • https://crm.arvato.com, Arvato Customer Relationship Management (Arvato CRM)
  • https://finance.arvato.com, Arvato Financial Services (Arvato FS)
  • https://it.arvato.com, Arvato Systems


The subsidiary companies are responsible for the processing of your personal data on these subdomains. Detailled information on the subsidiary companies can be found in the website credits.
You can contact our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to: iod@arvato.pl .


2. What data is collected?

When you visit our website, the data of the computer you use to access our website is auto-matically logged (“access data”). This access data includes IP,  server log files that generally consist of information pertaining to your web browser type and version, your operating sys-tem, your internet service provider (ISP), the date and time you used the website, the web-sites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information con-tained in the server log files is not personally identifiable. An IP address is personally identifia-ble when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.

Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or process a matter submitted by you (e.g. search queries, entries made in forms or contracts, click data).


3. What cookies are used?

Cookies are used on our website. Cookies are small text files that are saved to your comput-er when visiting a website. The cookies that are saved can be attributed to the web browser used by you. When the website is visited again, the web browser returns the content of the cookies, thus enabling you, the user, to be recognized. Certain cookies are deleted when you log out or end the browser session (“transient cookies” or “session cookies”). Other cookies are saved for a specific period of time (“temporary cookies”) or indefinitely (“persistent cook-ies”). These cookies are automatically deleted when the defined period lapses. The privacy and security settings of your browser enable cookies to be deleted at any time and also ena-ble you to configure the use of cookies in accordance with your preferences. However, you may not be able to use all the features of our website if you delete the cookies used by our website.

As a general principle, cookies enable online recognition without reference to a specific per-son. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves. Here a distinction is made between cookies that are necessary for the provision of website features, and cookies that are required for other purposes, e.g. analysis of user behaviour or displaying advertising-related content.

The cookies that are required for the provision of website features include the following in par-ticular:

  • Cookies that are used to identify or authenticate the user;
  • Cookies used to temporarily store user input (e.g. the content of a shopping cart or online form);
  • Cookies used to store user preferences (e.g. search or language settings);
  • Cookies that store data to enable the trouble-free rendering of video or audio content.

 

Cookies that are needed for other purposes of the website include analytics cookies to record the usage behaviour of our users and evaluate it in the form of statistics (e.g. advertising ban-ners clicked, sub-pages visited, search queries conducted).


4. What personal data is collected and for what purpose?

The purpose of data processing may be based on technical, contractual or statutory require-ments or result from consent having been given by the user.
We use the data described in section 2 for the following purposes:

  • To provide website features and content and ensure technical security in trouble-shooting technical issues and also to ensure that unauthorized persons do not gain access to our website systems;
  • To conduct marketing reach measurements and web analyses in order to make our website more efficient and interesting for you, and for market research purposes;
  • For communication, completion of precontractual procedures, and customer care pur-poses;
  • To send out newsletters via email;
  • For event registration and participation; and


For information on other data processing purposes, please refer to the sections below of this Privacy Policy.

4.1 Provision of the website

4.1.1 Description and scope of data processing

In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the serv-er log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper func-tioning of our website.

4.1.2 Purpose and legal basis of data processing

The legal basis for the creation of server log files follows from Art. 6(1)(f) GDPR. Our legiti-mate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.

4.1.3 Duration of storage or criteria applied in defining this period

When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.

4.1.4 Options for lodging an objection and having your data removed

You have the right to lodge an objection to the processing of your data contained in the server log files provided . If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.

4.2 Contact form, email and telephone contact information

4.2.1 Description and scope of data processing

On our website you have the option of contacting us by way of a contact form, by email, by telephone or by chat using the designated email address and phone number. If you take ad-vantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us. Depending on the reason you are contacting us (questions about our products and services, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).

4.2.2 Purpose and legal basis of data processing

The legal basis for processing your contact details follows from Art. 6(1)(f) GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6(1)(b) GDPR.

4.2.3 Duration of storage or criteria applied in defining this period

Your contact details are deleted once your request has been processed and further commu-nication has been discontinued. This does apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 6 to 10 years) do not prevent this information from being deleted.

4.2.4 Options for lodging an objection and having your data removed

You have the right to lodge an objection to the processing of your contact information provided . If you would like to exer-cise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, ful-filling a contract or exercising your rights as a data subject.

4.3 Newsletter (Arvato Systems and Arvato SCM)

4.3.1 Description and scope of data processing

On our website you have the option of subscribing to Arvato Systems’s and Arvato SCM’s newsletter by email. Your details are transferred to us from the registration form and pro-cessed in order to send you the Arvato Systems and Arvato SCM newsletter (with the assis-tance of service providers). When registering, your consent is obtained and you are advised of this Privacy Policy. Your details are not shared with third parties. The obligatory information required for receiving Arvato Systems’s and Arvato SCM’s newsletter is your email address. Processing your access data is also necessary to show proof of your giving your consent. Other information may be voluntarily provided in order to address you personally.

4.3.2 Purpose and legal basis of data processing

Processing the information entered by you in the registration form is necessary for advertising pertaining to products and/or services provided by us. The legal basis for this is your consent pursuant to Art. 6(1)(a) GDPR.

4.3.3 Duration of storage or criteria applied in defining this period

Your information is stored for the duration of your subscription to Arvato Systems’s and Arva-to SCM’s newsletter. When cancelling your subscription your details are stored exclusively to show proof that we obtained your consent for sending you Arvato Systems’s and Arvato SCM’s newsletter. The same applies if you have revoked your consent.

4.3.4 Options for lodging an objection and having your data removed

You can revoke your consent to receiving press releases at any time by writing to:

  • Newsletter of Arvato SCM, Arvato Distribution GmbH via E-Mail: contact-scm@arvato.com or via mail to „An der Autobahn 22, 33333 Gütersloh, Germany“;
  • Newsletter of Arvato Systems, Arvato Systems GmbH via E-Mail: info@arvato-systems.de or via mail to „An der Autobahn 200, 33333 Gütersloh, Germany“.


4.4 Events (Arvato Systems)

4.4.1 Description and scope of data processing

On our website you have the option of registering to Arvato Systems’s events. Your details are transferred to us from the registration form and processed. When registering, your con-sent is obtained and you are advised of this Privacy Policy. Your details are not shared with third parties. Processing your access data is also necessary to show proof of your giving your consent. Other information may be voluntarily provided in order to address you person-ally.

4.4.2 Purpose and legal basis of data processing

Processing the information entered by you in the registration form is necessary for participat-ing at the respective event. The legal basis for this is your consent pursuant to Art. 6(1)(a) GDPR.

4.4.3 Duration of storage or criteria applied in defining this period

Your information is stored until the end of the event. This does not apply, if during the event contract negotiations were initiated and your data needs to be stored for the creation of a cus-tomer record.

4.4.4 Options for lodging an objection and having your data removed:

You can revoke your consent to receiving press releases at any time by writing to Arvato Systems GmbH via E-Mail: info@arvato-systems.de or via mail to „An der Autobahn 200, 33333 Gütersloh, Germany“.

4.5 Webtracking

4.5.1 Adobe Tag Manager

This website uses Adobe Tag Manager. Adobe Tag Manager is a service provided by Adobe Systems Software Irland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Tag Manager managers „tags“ (placeholder for website code). Adobe Tag Manager does not collect data and data collected by the tags cannot be accessed by the Adobe Tool Manager.

4.5.2 Google Analytics

This website uses Google Analytics. Google Analytics is a service provided by Google Inc. Google Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as described in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Google Inc., meaning no information can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Google Inc. We ensure that Google Inc. only uses this data as instructed by us under a contract data processing contract we have concluded with Google Inc.

For more information on data processing related to Google Analytics, refer to the Google’s privacy policy: 
https://policies.google.com/privacy?hl=en
.

4.5.3 Adobe Analytics (Omniture)

This website uses Adobe Analytics. Adobe Analytics is a service provided by Adobe Systems Software Irland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as de-scribed in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Adobe meaning no in-formation can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with oth-er data by Adobe. We ensure that Adobe only uses this data as instructed by us under a con-tract data processing contract we have concluded with Adobe.

For more information on data processing related to Adobe Analytics, refer to the Adobe priva-cy policy:
https://www.adobe.com/de/privacy/policy.html.

4.5.4 Purpose and legal basis of data processing

The legal basis for collecting and analyzing pseudonym usage profiles follows from Art. 6(1)(f) GDPR / Section 15(3) German Telemedia Act (TMG). We have a legitimate interest in optimiz-ing the user-friendliness of our website and performing marketing reach measurements.

4.5.5 Duration of storage or criteria applied in defining this period

As a general rule, the data that is collected and analyzed in association with Google and Ado-be Analytics remains stored until you raise an objection to it being used in this manner. Analyt-ics cookies are stored for a maximum of 24 months.

4.5.6 Options for lodging an objection and having your data removed

You can raise an objection to the use of Google Analytics by changing your browser settings and/or clicking on the following links to download and install the browser plug-ins and/or opt-out:

4.6 Links to other websites

This website contains links to the website of other website operators. Clicking on the links takes you to the respective websites (e.g. Facebook, YouTube). With the exception of your access data to make the other website available, no data of yours is transmitted to these website operators.
Our Privacy Policy only covers our website; we are not responsible for the privacy policies of other websites. Nevertheless we recommend that you read the privacy policies of the web-sites you access by clicking on the links leading to them.

4.7 External services and content on our website

We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.
That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services or content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.

For further information on the purpose and scope of the collection and processing of your data, please refer to the privacy policy of the responsible provider (under data protection law) of the services or content integrated by us:

5. Who comes into possession of my personal data?

Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking and identification
). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.

No sharing of information with other recipients such as advertising partners, providers of so-cial media services or credit institutions (“third parties”) takes place.


6. Is my personal data processed outside of the EU or EEA (‘transfer to a third coun-try’)?

The use of Google Analytics as described in section 4.4 above causes personal data to be transferred to a third country since the data centers of Google Inc. are located outside of the European Union and the European Economic Area (“EU or EEA”). Such transfers of personal data to third countries may result in your personal information being transmitted to a country which does not provide for the same standard of data protection as the EU or EEA. However, by being certified under the EU-US Privacy Shield, Google Inc. ensures that a level of data protection comparable to that in the EU/EEA is ensured. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.

7. What data privacy rights do I have?

You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data port-ability).

If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1.

Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situa-tion to raise an objection to the processing of your data that is done on the basis of Art. 6(1)(f) GDPR. You also have the right to lodge an objection to the processing of your personal infor-mation for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.

You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is:


You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is Prezes Urzędu Ochrony Danych Osobowych (PUODO).
You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.


8. To what extent does automated decision-making take place?

We do not use any fully automated decision-making processes for any of the purposes set out in section 4.


9. Is profiling done?

No profiling takes place for any of the purposes set out in section 4.



Date of this Privacy Policy: May 2018