GDPR
We appreciate your visit on our website www.ateel.com and your interest in our company.
The protection of your personal data such as your ip-number, your date of birth, your name, telephone number and your address, etc. is important to us.
The purpose of this privacy policy is to inform you about the processing of your personal data that we collect when you visit our website. The following data protection declaration serves to fulfil the information obligations arising from the GDPR. These can be found e.g. in Art. 13 and Art. 14 GDPR.
- Controller
The controller regarding this website within the meaning of art. 4(7) GDPR and other national data protection laws of the Member States and other provisions under the GDPR is:
ATEEL S.à r.l.
14, Op Huefdréisch
L-6871 Wecker
Luxembourg
E-Mail: info@ateel.com
Tel.: +352 28335 0
- Creation of log files
Each time you access our website, our system automatically collects data and information of your accessing device (like personal computer, Mobile Phone, Tablet).
- Scope of the processing and personal data processed
- Information concerning the browser type and the Browser version used
- The operating system of the accessing device
- Host name of the accessing computer
- The IP address of the accessing device
- Date and time of access
- Websites and resources (images, files, additional page content) which were accessed
- Websites which refers to our website and which directed the users device to our website (referrer tracking)
- notification whether the retrieval was successful;
- Volume of data transferred
This data is stored in the log files of our system. This data is not stored together with personal data of a specific user in such a way that individual users can be identified.
- Legal basis for the processing of personal data
Art. 6(1)(f) GDPR (legitimate interest). Our legitimate interest lies in the following, outlined purpose.
- Purpose of data processing
Temporary (automated) storage of data is necessary for the course of a website visit to enable delivery of the website. The storage and processing of personal data is also carried out to maintain the compatibility of our website for as many visitors as possible and to combat abuse and troubleshooting. For this purpose, it is necessary to log the technical data of the retrieving computer in order to be able to react as soon as possible to display errors, attacks on our IT systems and/or errors in the functionality of our Internet site. In addition, the data serves us to optimise the website and to generally ensure the security of our IT systems.
- Duration of storage
The aforementioned technical data will be deleted as soon as they are no longer needed to ensure the compatibility of the website for all visitors, but no later than 3 months after our website has been accessed.
- Possibility to object and demand deletion
You can object to the processing at any time in accordance with Art. 21 DSGVO and request the deletion of data in accordance with Art. 17 DSGVO. Which rights you are entitled to and how to assert them can be found at the bottom of this data protection declaration.
- Special Functions
Our site offers different functions which collect personal data as follows:
Application form
- Scope of the processing and personal data processed
The data you enter in the form fields of the application form and uploaded if necessary will be processed to fulfil the purpose stated below.
- Legal basis for the processing of personal data
Art. 6 para. 1 lit. b DSGVO (implementation of (pre)contractual measures)
- Purpose of data processing
Review and process the application documents you upload using the form.
- Duration of storage
The data will be deleted as soon as the application has been processed and there is no longer a legitimate interest in the storage of the application data. Your application documents will therefore be deleted after 6 months at the latest if no employment relationship is established.
- Possibility to object and demand deletion
You can object to the processing at any time in accordance with Art. 21 DSGVO and request the deletion of data in accordance with Art. 17 DSGVO. Which rights you are entitled to and how to assert them can be found at the bottom of this data protection declaration.
- Statistical evaluation of the visits to the website – Webtracker
We collect, process and store the following data when you access this website or individual files on the website: IP address, website from which the file was retrieved, name of the file, date and time of the retrieval, transferred data volume and notification of the success of the retrieval (so-called web log).
We use this access data exclusively in non-personalized form for the continuous improvement of our Internet offer and for statistical purposes. We also use the following web trackers to evaluate visits to this website:
- Google Tagmanager
- Scope of the processing of personal data
On our site we use the service of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Tag Manager). Google Tag Manager provides a technical platform to run and bundle other web services and web tracking programs using so-called “tags”. Google Tag Manager stores cookies on your computer in this context and analyses your surfing behaviour (so-called “tracking”) if web tracking tools are executed by Google Tag Manager. This data sent by individual tags integrated in Google Tag Manager is merged, stored and processed by Google Tag Manager under a uniform user interface. All embedded tags are listed separately in this privacy policy. For more information about the privacy practices of the tools embedded in Google Tag Manager, please see the appropriate section of this privacy statement. When using our website with activated integration of Google Tag Manager tags, data, such as in particular your IP address and your user activities are transferred to servers of Google Ireland Limited and processed and stored outside the European Union, e.g. in the USA. The EU Commission has determined that an adequate level of data protection can exist in the USA if the data processing company has submitted to the US-EU Privacy Shield Agreement and the export of data to the USA has been made permissible in this way. This is the case with Google Ireland Limited. With regard to the web services integrated via Google Tag Manager, the regulations in the respective section of this data protection declaration apply. The tracking tools used in Google Tag Manager ensure that the IP address of Google Tag Manager is anonymized before transmission by IP anonymizing the source code. Google Tag Manager only allows the anonymized collection of IP addresses (so-called IP masking).
- Legal basis for the processing of personal data
In accordance with Art. 6 Para. 1 letter a DSGVO, the legal basis for data processing is your consent in our reference banner regarding the use of cookies and web tracking (consent through unambiguous confirming action or behaviour)
- Purpose of data processing
On our behalf, Google will use the information obtained using Google Tag Manager to evaluate your visit to this website, to compile reports on website activity and to provide us with additional services related to website and internet usage.
- Duration of storage
Google will store the data relevant for the function of Google Tag Manager for as long as it is necessary to fulfil the booked web service. The data collection and storage is anonymous. If there is any personal reference, the data will be deleted immediately, unless they are subject to legal retention obligations. In any case, the data will be deleted after expiry of the obligation to retain the data.
- Possibility to object and demand deletion
You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser, installing a script blocker in your browser or activating the “Do Not Track” setting of your browser. You can also prevent the collection of data generated by the Google cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link http://tools.google.com/dlpage/gaoptout?hl=de. The security and privacy policy of Google can be found at https://policies.google.com/privacy.
- Google-Analytics
- Scope of the processing of personal data
On our site we use the web tracking service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter Google Analytics). Google Analytics uses cookies within the framework of web tracking, which are stored on your computer and which enable an analysis of the use of our website and your surfing behaviour (so-called tracking). We carry out this analysis on the basis of Google Analytics’ tracking service in order to constantly optimise our website and make it more readily available. When you use our website, data such as your IP address and your user activities are transferred to servers operated by Google Ireland Limited.
By activating IP anonymization within the Google Analytics tracking code of this website, your IP address will be anonymized by Google Analytics before transmission. This website uses a Google Analytics tracking code, which has been extended by the operator gat._anonymizeIp(); to allow only an anonymized collection of IP addresses (so-called IP masking).
- Legal basis for the processing of personal data
Art. 6(1)(a) GDPR (Consent), either in the context of registration with Google (opening a Google account and acceptance of the data protection information implemented there) or, if you have not registered with Google, by explicit consent.
- Purpose of data processing
On our behalf, Google will use this information to evaluate your visit to this website, to compile reports on website activity and to provide us with other services relating to the use of the website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not merged with other data of Google Ireland Limited.
- Duration of storage
According to Google, they will store the data relevant for the provision of web tracking as long as it is necessary to fulfil the web service. Data is collected and stored anonymously. If there is a personal reference, the data will be deleted immediately, unless they are subject to legal storage obligations. In any case, the deletion will take place after expiry of the storage obligation.
- Possibility to withdraw consent
If you have given us express permission to process your personal data (Art. 6(1)(a) GDPR or art. 9(2)(a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.
You can also prevent Google from collecting the data generated by the Google cookie and relating to your use of the website (including your IP address) and Google from processing this data by downloading and installing the browser plug-in available at the following link (http://tools.google.com/dlpage/gaoptout?hl=en). Google’s security and privacy policy can be found at https://policies.google.com/privacy?hl=en.
- Integration of external web services and processing of data outside the EU
On our website we use active Java Script content from external providers, so-called web services. By accessing our website, these external providers may receive personal information about your visit to our website. In this case, it may be possible that they process data outside the EU. You can prevent this by installing a Java Script Blocker such as the browser plug-in ‘NoScript’ (www.noscript.net or www.ghostery.com) or by deactivating Java Script in your browser. This may result in functional restrictions on Internet pages that you visit. We use the following external web services:
- Google Services
We use the following web services by the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter: GOOGLE IRELAND): Doubleclick, Google Fonts, Google, Google APIs, gstatic.
These services are loaded integrated in our website. We use the data to ensure the complete functionality of our website. In this context, your browser may transmit personal data to GOOGLE IRELAND. The legal basis for the data processing is art. 6(1)(f) GDPR. The legitimate interest is an error-free functioning of the website. The data is erased as soon as the purpose for its collection has been fulfilled. You can find additional information on the handling of the transferred data in the data privacy statement of Google: https://policies.google.com/privacy.
- Google Maps
- Scope of the processing of personal data
On our site we use the map service of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Maps). Google Maps is integrated on the website via the Google API to visualise location information and display it in the form of a map. To display the map, the processing of the IP address by Google Maps is technically necessary. With regard to the other web services integrated via Google Apis, the regulations in the respective section of this data protection declaration on Google Apis apply.
- Legal basis for the processing of personal data
Art. 6 lit. f DSGVO (legitimate interest). Our legitimate interest lies in being able to provide you with a visual representation of the usual presentation of location information on the Internet.
- Purpose of data processing
On our behalf, Google will use the information obtained via Google Maps to show you the map. Using Google Maps you will find us faster and more accurate than with a mere non-interactive map.
- Duration of storage
Google will store the data relevant for the function of Google Maps for as long as it is necessary to fulfil the booked web service. The data collection and storage is anonymous. If there is any personal reference, the data will be deleted immediately, unless they are subject to any legal obligation to keep them. In any case, the data will be deleted after the expiry of the obligation to retain the data.
- Possibility to withdraw consent
You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser, installing a script blocker in your browser or activating the “Do Not Track” setting of your browser. The security and privacy policy of Google can be found at https://policies.google.com/privacy. You can object to the processing at any time in accordance with Art. 21 DSGVO and request the deletion of data in accordance with Art. 17 DSGVO. Which rights you are entitled to and how to assert them can be found at the bottom of this data protection declaration.
- Joint Controllership
We have entered into a joint processing agreement with Google with regard to Google Maps. You can find the content at https://privacy.google.com/intl/de/businesses/mapscontrollerterms/.
- MyFonts Counter
A web service of the company Monotype Imaging Holdings Inc, 600 Unicorn Park Drive, 01801 Woburn, United States of America (hereinafter: MyFonts Counter) is loaded on our website. If you have activated Java-Script in your browser and have not installed a Java-Script blocker, your browser may transmit personal data to MyFonts Counter. Further information on how the transferred data is handled can be found in the MyFonts Counter data protection declaration: http://www.myfonts.com/info/legal/#Privacy.
You can prevent the collection and processing of your data by MyFonts Counter by deactivating the execution of script code in your browser or by installing a script blocker in your browser.
- Squarespace and Cronofy Docs
We operate an appointment booking tool for end customers (individual inspections, classic car appraisals, etc.) through our technical service provider ATEEL S.à r.l. and collaborate with the companies:
– Squarespace, 8 Clarkson St, New York, NY 10014, USA, and
– Cronofy Docs, New York branch, 228 Park Ave S, New York, NY 10003, USA.
Both companies offer ready-made solutions, have headquarters or branches in the USA, and store your data there.
We use the booking tool from Squarespace. In this process, personal data is transmitted to Squarespace (e.g., email address, phone number, first name, last name, address – street, house number, postal code, city, and language skills).
We also work with Cronofy Docs in connection with the operation of the appointment booking tool regarding the synchronization of the business Outlook calendars of our employees and customers who wish to input appointments into their calendars.
Personal data is also transmitted to Cronofy Docs. Cronofy Docs reads and stores the following data of individuals whose calendars are synchronized: for example, the person’s name, company/organization, email address, phone number, address, calendar appointments, and any information contained in the calendar.
- Legal basis for the processing of personal data
The legal basis for processing is the necessity for the performance of a contract to which the data subject is a party or to take pre-contractual measures upon the data subject’s request, in accordance with Art. 6(1)(b) of the GDPR. Your contact with us is aimed at fulfilling a contract, namely concluding a usage agreement regarding the appointment booking tool.
- Purpose of processing personal data
For the purpose of booking and managing appointments, your personal data is transferred to servers outside the European Union (to the USA), processed, and stored there. Both partner companies based in the USA were able to offer us exactly the tailor-made solutions we needed for such a tool.
The EU Commission has determined that an adequate level of data protection exists in the USA when the data-processing company in the USA meets certain certification criteria and the data export to the USA is carried out in a permissible manner. Both are the case here, and the prerequisites for the transfer of personal data to a third country such as the USA are met:
The EU has issued an effective adequacy decision with the USA (ensuring comparable data protection standards in a third country).
Both ATEEL partner companies, Squarespace and Cronofy Docs, are certified under the “EU-US Data Privacy Framework.”
Personal data will be deleted once the purpose of their collection has been fulfilled.
For more information on how the transmitted data is handled, please refer to Squarespace’s Privacy Policy, which you can find at the following link: Privacy Policy – Squarespace, as well as Cronofy Docs’ Privacy Policy at: Privacy Notice | Cronofy Docs.
- Information concerning the use of cookies
- Scope of the processing of personal data
On various pages we integrate and use cookies to enable certain functions of our website and to integrate external web services. The so-called “cookies” are small text files that your browser can store on your access device. These text files contain a characteristic character string that uniquely identifies the browser when you return to our website. The process of saving a cookie file is also known as “setting a cookie”. Cookies can be set both by the website itself and by external web services
- Legal basis for the processing of personal data
Art. 6 para. 1 lit. f DSGVO (legitimate interest) or Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a DSGVO (consent).
The relevant legal basis can be seen from the cookie table listed later in this section.
In general, in the case of cookies that are collected on the basis of a legitimate interest, our legitimate interest is to ensure the functionality of our website and the services integrated into it (technically necessary cookies). It is also possible that the cookies increase their user-friendliness and enable a more individual approach. In this case we have weighed up your interests against ours.
With the help of cookie technology, we can only identify, analyse and track individual website visitors if the website visitor has consented to the use of the cookie in accordance with Art. 6 para. 1 lit. a DSGVO.
- Purpose of data processing
The cookies are set by our website or external web services in order to maintain the full functionality of our website, to improve the user-friendliness or to pursue the purpose stated with your consent. Cookie technology also enables us to recognise individual visitors by means of pseudonyms, e.g. an individual or random ID, so that we can offer more individual services. Details are listed in the following table.
- Duration of storage
Our cookies are stored in your browser until they are deleted or, in the case of a session cookie, until the session has expired. Details are given in the table below:
Cookie-Name | Server | Reciving Party | Purpose | Legal basis | Storage Duration | Category |
_gid | ateel.com | Google-Analytics | This cookie assigns an ID to a user so that the web tracker can summarize the user’s actions under this ID. | Opt-In | 24 hours | Analytics |
_ga | ateel.com | Google-Analytics | This cookie assigns an ID to a user so that the web tracker can summarize the user’s actions under this ID. | Opt-In | 24 Months | Analytics |
gat_gtag_UA* | ateel.com | Google-Analytics | This cookie assigns an ID to a user and maps the user’s actions under this ID in conjunction with Google Tag Manager. | Opt-In | 70 seconds | Analytics |
borlabs-cookie | www.ateel.com | Webseitenbetreiber | Cookie that stores the user’s decision about the cookie banner. | Technically required | 12 months | Cookie-Banner |
wp-rest-enabled-ping | www.ateel.com | Webseitenbetreiber | This cookie enables us to save individual comfort settings selected by you and to keep them available for your current and future visits to the site. | Technically required | 60 minutes | Configuration |
bO_jYAHVpmsKCTu | www.ateel.com | Webseitenbetreiber | This cookie enables us to save individual comfort settings selected by you and to keep them available for your current and future visits to the site. | Legitimate interest | 24 hours | Configuration |
axiBnuPXVy | www.ateel.com | Ateel | This cookie enables us to save individual comfort settings selected by you and to keep them available for your current and future visits to the site. | Legitimate interest | 24 hours | Configuration |
- Possibility to object, withdraw consent and demand deletion
You can adjust your browser according to your wishes so that the setting of cookies is generally prevented. You can then decide on the acceptance of cookies on a case-by-case basis or accept cookies in principle. Cookies can be used for various purposes, e.g. to recognise that your accessing device has already been connected to our website (permanent cookies) or to save recently viewed offers (session cookies). If you have given us express permission to process your personal data (art. 6(1)(a) GDPR or art. 9(2)(a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.
- Data security and data protection, communication by e-mail
Your personal data is protected by technical and organizational measures during collection, storage and processing such that they are not accessible to third parties. In case of unencrypted communication by e-mail, we cannot guarantee complete data security on the transmission path to our IT systems, so that we recommend encrypted communication or mail for information with a high confidentiality requirement.
- Right to access and correct data – deletion of data – limitation of processing -withdrawal of consents – right to object
- Right of access
You have the right to request confirmation as to whether we process your personal data. If this is the case, you have a right of access and information specified in art. 15(1) GDPR, provided that the rights and freedoms of other persons are not infringed (art. 15(1) GDPR). We will also be happy to provide you with a copy of the data.
- Right to correction
Pursuant to art. 16 GDPR, you have the right to have incorrectly stored personal data (such as address, name, etc.) corrected by us at any time.
- Right to erasure
Pursuant to art. 17(1) GDPR, you have the right to demand that we delete the personal data collected about you in the following cases:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
- the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and there is no other legal ground for the processing
- you have objected to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR
- the personal data have been unlawfully processed
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject
- the personal data have been collected in relation to the offer of information society services referred to in art. 8 (1) GDPR
Pursuant to art. 17(3) GDPR, the right does not exist insofar as the processing is necessary for the exercise of the right to freedom of expression and information. Moreover, it does not exist if it has been collected on the basis of a legal obligation, or if the data serve the assertion, exercise or defence of legal claims.
- Right to limitation of processing
According to art. 18(1) GDPR you have the right in individual cases to demand the restriction of the processing of your personal data.
This is the case if
- the accuracy of the personal data is disputed
- the processing is unlawful
- the data are no longer required for the processing purpose but are used for the assertion, exercise or defence of legal claims
- an objection has been filed against the processing pursuant to art. 21(1) GDPR and it is still unclear which interests predominate.
- Right to withdraw consent
If you have given us express permission to process your personal data (art. 6(1) a GDPR or art. 9(2)(a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.
- Right to object to data processing
Pursuant to art. 21 GDPR, you may at any time object to the processing of your personal data if such processing is carried out on the basis of art. 6(1)(f) GDPR e.g. where the processing is carried out on the basis of the legitimate interests.
- How can I obtain my rights?
You can obtain your rights, if you inform us:
ATEEL S.à r.l.
14, Op Huefdréisch
L-6871 Wecker
Luxembourg
E-Mail: gdpr@ateel.com
Tel.: +352 28335 0
- Data Portability
You have the right to receive the personal data that you have transmitted to us in a structured, common and machine-readable format and transfer it to another data controller provided that:
- the processing is based on consent pursuant to art. 6(1)(a) or 9(2)(a) GDPR
- contract pursuant art. 6(1)(b) GDPR ;
- the processing is carried out by automated means.
You can also request your personal data to be directly transferred to another controller, insofar as this is technically feasible. The exercise of this right shall not adversely affect the rights and freedoms of others.
- Right to lodge a complaint to the CNPD or any other competent supervisory authority
If you suspect that your data is being illegally processed on our site, you can take legal actions in order bring the problem to a judicial clarification. This option does not interfere with any other legal option you might have.
Regardless of this, you have the option of contacting the CNPD or any other competent supervisory authority. You have the right to lodge a complaint to the competent supervisory authority in the EU Member State of your place of residence, workplace and/or place of alleged infringement, i.e. you can choose the supervisory authority to which you will be lodging a complaint in the above places. The supervisory authority to which the complaint was submitted will then inform you of the status and results of your complaint, including the possibility of a judicial remedy under art. 78 GDPR.
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