Data Protection Declaration
Information on data processing for this website in accordance with Article 13 of the General Data Protection Regulation (GDPR) when collecting personal data from the data subject
Privacy policy (Version: GDPR 2.0, dated 14th October 2021) from the data subject
Polytan GmbH is the controller for this website and, as a provider of a teleservice, must inform you at the start of your visit about the type, scope and purpose of collecting and using personal data, in a precise, transparent, intelligible and easily accessible form, using clear and plain language. This content must be available to you at any time.
We lay great emphasis on the security of your data and on complying with data protection provisions. Personal data is processed based on the provisions of current European and national laws.
With this privacy policy, we would like to explain how we handle your personal data and how you can make contact with us:
Polytan GmbH
Gewerbering 3
86666 Burgheim
Germany
Company register no.: HRB 100406
Managing Director: Mathias Schmidt
Telephone: +49 8432 87-0
Email: info@polytan.com
Our data protection officer
Sven Lenz
Deutsche Datenschutzkanzlei – Datenschutzkanzlei Lenz GmbH & Co. KG
Bahnhofstrasse 50
87435 Kempten
Germany
In case of any questions about data protection or other related concerns, please feel free to send an email to the following email address: datenschutz@sportgroup-holding.com
A. General information
To facilitate a better understanding of the text, we do not use gender-specific terms. The corresponding terms apply equally to all genders for the purpose of equal treatment. The meanings of terms used such as “personal data” or “processing” can be found in Article 4 GDPR.
Personal data processed in the context of this website include:
- Master data (e.g. name and address of client),
- Usage data (e.g. pages visited on our website) and
- Content data (e.g. entries in online forms).
B. Detailed information
Privacy policy
We guarantee that we will only process your data in connection with processing your requests and for internal purposes, as well as for providing services you request or making content available.
Legal basis for processing
We only process your personal data in compliance with relevant data protection provisions. Legal bases:
- to provide our contractual services
- where processing is a statutory requirement
- if we have your electronic consent (e.g. subscribing to a newsletter)
- to enforce our legitimate interests
We are happy to show you where these legal bases are governed:
Processing for the performance of our services and to implement contractual measures
Article 6 (1) b) GDPR
Processing for compliance with our legal obligations
Article 6 (1) c) GDPR
Consent
Article 6 (1) a) and Article 7 GDPR
Processing for the purpose of our legitimate interests
Article 6 (1) f) GDPR
Data transfer to third parties
Please note that data is transferred to third parties.
Your data is only transferred to third parties within the framework of the legal requirements. We only pass on your data if this is required for contractual purposes, for example, or on the basis of legitimate interests in the economic and effective operation of our business.
In the event that we employ subcontractors to provide our services, we take suitable legal precautions and appropriate technical and organisational measures to protect your personal data in accordance with the relevant statutory requirements.
Data transfer to a third country or an international organisation
Third countries mean countries where the GDPR is not directly applicable as law. This gener-ally means all countries outside the EU and the European Economic Area.
Data is transferred to a third country or an international organisation.
Since we use Google products (Analytics, Maps, ReCaptcha, Ads Conversion Tracking), YouTube/Vimeo videos, Freshchat and Facebook Pixel on our website, data is transferred to a third country (in this case the USA) or to an international organisation, provided that you have consented to this in accordance with Article 49 (1) a) GDPR. According to the current legal situation, the United States is considered a country with an inadequate level of data protection. There is a risk that your data will be processed by US authorities for surveillance and monitoring purposes. Currently, there is no legal remedy against these practices.
To revoke your consent, deactivate these services in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
Retention period for your personal data
We adhere to the principles of data minimisation and data avoidance. This means we only retain data for as long as necessary to fulfil the purposes above, or as determined by the various retention periods provided for by law. If the given purpose no longer applies, or after the given period elapses, your data are blocked or deleted as a matter of routine and in ac-cordance with legal regulations.
For this purpose, we have drawn up an internal procedure to ensure that this process is followed.
Contact
If you get in touch with us via the website, you agree to electronic communication. Personal data is processed as part of this electronic contact. The information you provide will be stored solely for the purpose of processing your enquiry and dealing with any follow-up questions.
The legal basis for this is provided below:
- Processing for the performance of our services and to implement contractual measures
Article 6 (1) b) GDPR
Please note that emails can be read or changed, unauthorised and unnoticed, during trans-mission. Please also note that we employ software to filter out unwanted emails (spam filter). The spam filter can reject emails if they are falsely identified as spam on the basis of certain criteria.
What rights do you have?
a) Right of access
You have the right to obtain information about your saved personal data at no charge. Upon request, we shall inform you in writing about which of your personal data we have retained. This also includes the origin and the recipients of your data as well as the purpose of the processing.
b) Right to rectification
You have the right to have your data stored with us rectified if it is inaccurate. In this context, you may have the processing restricted, for example in the case of disputes surrounding the accuracy of your personal data.
c) Right to block
You can also have your data blocked. To ensure your data can be blocked at any time, this data must be kept in a blocking file for monitoring purposes.
d) Right to erasure
You can request that your personal data be erased, unless there is a statutory obligation to retain it. If there is such an obligation, we will block your data on request. If the statutory requirements apply, we will also erase your personal data, even if you do not request us to.
e) Right to data portability
You are entitled to request that we provide the personal data supplied to us in a format enabling it to be transmitted elsewhere.
f) Right to lodge a complaint with a supervisory authority
You are entitled to lodge a complaint at a data protection supervisory authority.
Data Protection Authority for the German state of Bavaria (BayLDA)
Promenade 27, 91522 Ansbach, Germany
Telephone: +49 981 53-1300
Fax: +49 981 53-981300
The complaint form can be found at the following link: https://www.lda.bayern.de/de/beschwerde.html
Note: A complaint can also be lodged with any data protection supervisory authority in the EU.
g) Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your data based on Article 6 (1) (e) and (f) GDPR, including profiling based on those provisions.
Polytan GmbH will no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims.
If personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to such processing, we will no longer process your personal data for the purposes of direct marketing. It suffices to send us an email to this effect.
h) Right to withdraw
At any time, you may withdraw the consent you have provided to the processing of your data with effect for the future, without stating any reasons. You will not be disadvantaged in any way by such withdrawal of consent. It suffices to send us an email to this effect.
Such withdrawal, however, does not affect the lawfulness of processing before the withdrawal based on Article 6 (1) a) GDPR.
To enforce your rights as a data subject, send us an email to the following address: datenschutz@sportgroup-holding.com
Protection of your personal data
We have implemented state-of-the-art contractual, technical and organisational security measures to ensure data protection laws are upheld, and thus to protect processed data against accidental or intentional manipulation, loss, destruction or against unauthorised access by third parties.
These security measures include, in particular, the encrypted transmission of data between your browser and our server. For this, we use 256-bit-SSL (AES 256) encryption technology.
Your personal data is protected as per the following points (excerpt):
a) Protection of the confidentiality of your personal data
To protect the confidentiality of your data that we retain, we have taken various measures regarding entry and access controls.
b) Protection of the integrity of your personal data
To protect the integrity of the data that we retain, we have taken various measures regarding forwarding and input controls.
c) Protection of the availability of your personal data
To protect the availability of your data that we retain, we have taken various measures regarding ordering and availability controls.
The security measures in place are constantly improved as technology develops. Despite these precautions, given the uncertain nature of the internet, we cannot guarantee the safety of your data transfer to our website. Consequently, any data transfer takes place at your own risk.
Protection of minors
Personal information may only be provided to us by people under the age of 16 with the express consent of their parent/guardian. These data will be processed in line with this privacy policy.
Server log data
The provider of the web pages automatically collects and retains information in server log files that your browser transmits to us automatically. This includes:
- browser type and browser version
- operating system used referrer URL
- host name of accessing computer
- time of server request
IP address
These pieces of data are merged with other data sources for click numbers, impressions, etc., for the purpose of online reporting via Hubspot.
Cookies
Cookies are small text files saved locally in the cache of your web browser. Cookies enable browsers to be recognised again on the next visit, for example. The data is used to help the browser navigate through the website and make full use of all the functions.
CookieBot
This website uses the Cookie Consent Tool of Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (“CookieBot”), which deploys technically required cookies to save your cookie preferences. This processing is conducted in accordance with Article 6 (1) (f) GDPR on the basis of our legitimate interest in providing a cookie consent management service for website visitors.
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Hubspot
This website uses services (analysis tool, web beacon) from HubSpot, a software-based marketing service from HubSpot Germany GmbH (Am Postbahnhof 17, 10243 Berlin, Germany), its sub-processor Hubspot Inc. (25 First Street, 2nd Floor, Cambridge, MA 02141, USA) and Hubspot Ireland Ltd. (One Dockland Central, Dublin 1, Ireland).
Hubspot can be used to digitally synchronise and implement various customer services and customer management services via a central user interface. For example, HubSpot facilitates the generation of leads, central email and newsletter marketing, contact management in the form of user segmentation and CRM, and the management of contact forms.
To implement various functions, HubSpot uses cookies, which are small text files saved locally in the cache of your web browser on your device and enable us to analyse your use of the website. The cookies capture certain information, such as IP address, location, the time pages are viewed, etc. Information recorded by HubSpot is stored on HubSpot servers and evaluated on our behalf.
You can permanently object to HubSpot’s recording of data via cookies and the use of cookies by preventing cookies from being saved in your browser settings.
If legally required, we have obtained your consent to the processing of your data as described above in accordance with Article 6 (1) a GDPR. You may revoke your consent at any time with effect for the future. To revoke your consent, deactivate this service in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
We have entered into a processing agreement with HubSpot, in which HubSpot is obliged to protect the data of our clients and not forward them to third parties.
More information about HubSpot’s data protection provisions can be found at the following link: https://legal.hubspot.com/privacy-policy
Use of Google Analytics
If you have given your consent, Google Analytics, a web analytics service of Google LLC, is used on this website. The competent provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
Google Analytics uses “cookies”, which facilitate an analysis of how you use our website. The information captured by the cookies about your use of the website is generally transmitted to and stored by Google on a server in the USA.
We use the “anonymizeIP” function (known as IP masking): Based on the IP anonymisation activated on this website, your IP address will first be shortened by Google within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to and stored by Google on a server in the USA. The IP address transmitted by your browser as part of Google Analytics is not combined with other data by Google.
During your visit to the website, the following data is recorded:
- the pages you accessed, your “click path”
- achievement of “website targets” (conversions, e.g. newsletter subscriptions, downloads, purchases)
- your user behaviour (for example clicks, visit durations, bounce rates)
- your approximate location (region)
- your IP address (shortened)
- technical information on your browser and the end devices you used (e.g. language setting, display resolution)
- your internet provider
- the referrer URL (via which website/advertising medium did you access this website)
Google will use this information on behalf of the operator of this website to analyse your pseudonymised use of the website and compile reports on website activities. The reports generated by Google Analytics analyse the performance of our website and the success of our marketing campaigns.
The data is received by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland as the processor.
Google LLC is based in California, USA, which means US authorities may have access to data saved by Google. It cannot be ruled out that data may be transmitted to the USA. Google processes the data for its own purposes, which is why we and Google have joint responsibility in accordance with Article 26 GDPR. However, Google does not offer this contract.
The data sent by us and associated with cookies will automatically be erased after 14 months. Data, for which the retention period has expired, will be automatically erased once a month. Furthermore, you can prevent the capture by Google of data (including your IP address) generated by the cookie and related to your use of the website as well as the processing of this data by Google by
a. not giving your consent to the use of cookies, or
b. downloading and installing the browser add-on to deactivate Google Analytics HERE [https://tools.google.com/dlpage/gaoptout?hl=en-GB].
You can prevent the storage of cookies by selecting the corresponding settings in your browser software. By configuring your browser in a manner that rejects all the cookies, however, you may not be able to make full use of all the functions on this and other websites.
Your consent is needed for this processing, Article 6 (1) sentence 1 a GDPR. You may revoke your consent at any time with effect for the future. To revoke your consent, deactivate this service in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
Since we use Google Analytics on our website, data is transferred to a third country (in this case, the USA) or to an international organisation, provided you have consented to this in accordance with Article 49 (1) a) GDPR. According to the current legal situation, the United States is considered a country with an inadequate level of data protection. There is a risk that your data will be processed by US authorities for surveillance and monitoring purposes. Currently, there is no legal remedy against these practices.
You can find more information on the terms of use of Google Analytics and on Google data protection at https://www.google.com/analytics/terms/gb.html and at https://policies.google.com/?hl=gb.
Freshchat
This website uses the “FreshChat” live-chat system of Freshworks, Inc., 2950 S. Delaware Street, Suite 201, San Mateo, California 94403, USA. Anonymised data is collected and stored to operate this live-chat system and to respond to live support requests. A user profile under a pseudonym can be created from this anonymised data. Cookies can be employed for this. Cookies are small text files saved locally in the cache of the visitor’s web browser. Cookies enable browsers to be recognised again on the next visit.
If legally required, we have obtained your consent to the processing of your data as described above in accordance with Article 6 (1) a GDPR.
Data is transferred to a third country (in this case, the USA) or to an international organisation, provided that you have consented to this in accordance with Article 49 (1) a) GDPR. According to the current legal situation, the United States is considered a country with an inadequate level of data protection. There is a risk that your data will be processed by US authorities for surveillance and monitoring purposes. Currently, there is no legal remedy against these practices.
To revoke your consent, deactivate this service in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
Without consent obtained separately from the data subject, the data captured with the FreshChat technologies are not used to identify visitors to this website personally, and are not combined with personal data about the bearer of the pseudonym. To prevent cookies from being saved, you can configure your web browser so that cookies in future are no longer stored on your computer, and/or cookies already stored are deleted. However, turning off all cookies can mean that some functions on our web pages can no longer be used. You can object at any time with effect for the future to the recording and retaining of data for the purposes of creating a pseudonymised user profile, by sending us your objection informally by email to the email address indicated in the Legal Information.
Google reCAPTCHA
On this website, we use the reCAPTCHA function from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). This function primarily helps to decide whether the entry has been made by a natural person, or whether there has been misuse via automated machine processing. This service includes the sending of the IP address and any other data needed by Google for the reCAPTCHA service. The use of Google reCAPTCHA can result in the transfer of personal data to the servers of Google LLC in the USA.
If legally required, we have obtained your consent to the processing of your data as described above in accordance with Article 6 (1) a GDPR. You may revoke your consent at any time with effect for the future. To revoke your consent, deactivate this service in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
Since we use Google reCAPTCHA on our website, data is transferred to a third country (in this case, the USA) or to an international organisation, provided you have consented to this in accordance with Article 49 (1) a) GDPR. According to the current legal situation, the United States is considered a country with an inadequate level of data protection. There is a risk that your data will be processed by US authorities for surveillance and monitoring purposes. Currently, there is no legal remedy against these practices.
More information on Google reCAPTCHA and on Google’s privacy policy can be found at: https://policies.google.com/privacy?hl=gb
Use of Google Ads Conversion tracking
This website uses the online advertising programme “Google Ads”, and as part of Google Ads, the conversion tracking function of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). We use Google Ads to draw attention to our attractive services with the help of advertising tools on external websites (known as Google AdWords). We can use the data of the advertising campaigns to determine how successful the individual campaigns have been. Our aim in this context is to show you ads that are of interest to you, to make our website more interesting for you, and to make a fair calculation of the resulting advertising costs.
The conversion-tracking cookie is placed when a user clicks on an ad placed by Google. Cookies are small text files saved on your end device. These cookies generally become invalid after 30 days and are not used for personal identification. If a user visits certain pages of this website and the cookie is still valid, Google and we can see that the user has clicked on the ad and been brought to this web page. Every Google Ads customer receives a different cookie. Thus cookies cannot be tracked via the websites of Google Ads customers. Information collected by means of conversion cookies helps create conversion statistics for Google Ads customers that use the conversion tracking service. Customers learn how many users in total have clicked on their ad and been taken to a web page equipped with a conversion tracking tag. However, they receive no information enabling the user to be personally identified.
Details on processing triggered by Google Ads conversion tracking and on Google’s handling of website data can be found here: https://policies.google.com/technologies/partner-sites
If legally required, we have obtained your consent to the described processing of your data in accordance with Article 6 (1) a GDPR. You may revoke your consent at any time with effect for the future. To revoke your consent, deactivate this service in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
Since we use Google Ads Conversion on our website, data is transferred to a third country (in this case, the USA) or to an international organisation, provided that you have consented to this in accordance with Article 49 (1) a) GDPR. According to the current legal situation, the United States is considered a country with an inadequate level of data protection. There is a risk that your data will be processed by US authorities for surveillance and monitoring purposes. Currently, there is no legal remedy against these practices.
More information about Google’s data protection provisions can be found at the following link: https://policies.google.com/privacy?gl=gb
You can permanently reject the placement of cookies by Google Ads conversion tracking by downloading and installing Google’s browser plug-in at the following link: https://www.google.com/settings/ads/plugin?hl=de
Facebook Pixel for building custom audiences
As part of our online services we use the “Facebook Pixel” of the social network Facebook, which is operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”).
If a user clicks on an ad placed by us and played on Facebook, Facebook Pixel adds a suffix to the URL of our linked web page. Once our website allows data sharing with Facebook via Pixel, this URL parameter is added to the user’s browser by means of a cookie, which is set by our own linked website. This cookie is then read by Facebook Pixel and enables data to be transferred to Facebook.
The processing associated with the use of Facebook Pixel only takes place with your express consent in accordance with Article 6 (1) a GDPR.
Since we use Facebook Pixel on our website, data is transferred to a third country (in this case, the USA) or to an international organisation, provided that you have consented to this in accordance with Article 49 (1) a) GDPR. According to the current legal situation, the United States is considered a country with an inadequate level of data protection. There is a risk that your data will be processed by US authorities for surveillance and monitoring purposes. Currently, there is no legal remedy against these practices.
You may revoke your consent to the processing and to the data transfer at any time with effect for the future. To revoke your consent, deactivate this service in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
With the help of Facebook Pixel, Facebook can identify the visitors to our website as a target group for showing ads (“Facebook Ads”). Thus we use Facebook Pixel to only show our Facebook Ads to Facebook users that have also shown an interest in our online services, or who meet certain criteria (e.g. interest in certain topics or products determined on the basis of visited websites) that we communicate to Facebook (known as “custom audiences”). Using Facebook Pixel, we would also like to make sure that our Facebook Ads correspond to the potential interests of users and are not annoying. This allows us to assess the effectiveness of Facebook ads for the purposes of statistics and market research by understanding whether users were redirected to our site having clicked on a Facebook ad (“conversion”).
The data collected are anonymous for us, and thus give no indication as to the identity of the user. However, all data is stored and processed by Facebook, so it can be traced to a given user profile, and Facebook can use the data for its own advertising purposes in line with the Facebook guidelines on the use of data (https://www.facebook.com/about/privacy/). The data can allow Facebook and its partners to show ads on and off Facebook.
Use of YouTube videos
We use the YouTube Implementation function to display and play videos from the provider “YouTube”, which belongs to Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).
If legally required, we have obtained your consent to the processing of your data as described above in accordance with Article 6 (1) a GDPR.
Data is transferred to a third country (in this case, the USA) or to an international organisation, provided that you have consented to this in accordance with Article 49 (1) a) GDPR. According to the current legal situation, the United States is considered a country with an inadequate level of data protection. There is a risk that your data will be processed by US authorities for surveillance and monitoring purposes. Currently, there is no legal remedy against these practices.
You may revoke your consent at any time with effect for the future. To revoke your consent, deactivate this service in the “Cookie Consent Tool” provided on the website or in the privacy policy settings.
According to “YouTube”, this is used among other things to record video statistics for improving user friendliness and preventing misuse. If you are logged into Google, your data are assigned directly to your account when you click on a video. If you do not want to be associated with your YouTube profile, you need to log out before pressing the button.
Google saves your data (even for users not logged in) as a user profile, and evaluates it. You may object to the creation of this user profile, for which you must contact YouTube. Regardless of whether an embedded video is played, a connection to the Google network is established upon each visit to the website, which may trigger further processing operations without our influence. You can find further information on data protection at “YouTube” in the provider’s privacy policy: https://policies.google.com/privacy?hl=en&gl=en
Newsletter
If you subscribe to our email newsletter, we regularly send you information about our offers and services. To this end, personal data is recorded. Only your email address needs to be provided for us to send you the newsletter. The provision of any further data is voluntary, and is used to address you personally. We will use this data for our own advertising purposes in the form of the email newsletter, provided that you have expressly given your consent to this as follows:
“Yes, I would like to subscribe to the newsletter! I have read the privacy policy”
We use the “double opt-in” procedure to send the newsletter. This means that we only send you a newsletter by email if you expressly confirm that you consent to the sending of the newsletter. We then send you a confirmation email, asking you to click on the link to confirm that you want to receive the newsletter in the future.
By clicking on the confirmation link, you give us your consent to use your personal data in accordance with Article 6 (1) a) GDPR. When you subscribe to the newsletter, we save the IP address registered by your Internet Service Provider (ISP), and the date and time of the subscription, in order to be able to track any possible misuse of your email address at a later date.
You can unsubscribe from the newsletter at any time using the link provided in the newsletter or by sending us a message to this effect by email to marketing@polytan.com. Once unsubscribed, your email address is immediately deleted from our newsletter mailing system and included in a blocking file to ensure the cancellation.
Newsletter distribution via Hubspot
We send our newsletter via the technical provider Hubspot (EU) and/or Hubspot Germany GmbH, Am Postbahnhof 17, 10243 Berlin, Germany (“Hubspot”) and its sub-processor Hubspot Inc. (25 First Street, 2nd Floor, Cambridge, MA 02141, USA) and Hubspot Ireland Ltd. (One Dockland Central, Dublin 1, Ireland, to whom we transfer the data you have entered upon subscribing to the newsletter. This transfer is conducted in accordance with Article 6 (1) (f) GDPR and serves our legitimate interest in using a secure and user-friendly newsletter system that is effective for advertising. The data you provide (e.g. email address) is saved on the Hubspot servers in Germany and/or Ireland.
Hubspot uses this information to send newsletters and to conduct statistical evaluations on our behalf. For this evaluation, the sent emails contain web beacons and/or tracking pixels, which are 1×1 pixel graphics stored on our website. This means it can be determined whether a newsletter message has been opened and what links, if any, were clicked on.
By means of conversion tracking it can also be analysed whether clicking the link in the newsletter was followed by a pre-defined action. Technical information is also recorded (e.g. time of access, IP address, browser type and operating system). Data are only recorded once pseudonymised, and are not linked with any other personal data of yours. There can be no direct reference to a person. These data are only used for the statistical analysis of newsletter campaigns. The results of these analyses can be used to adapt future newsletters better to your interests.
If you object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.
We have entered into a processing agreement with HubSpot, in which HubSpot is obliged to protect the data of our clients and not forward such to third parties.
More information about HubSpot’s data protection provisions can be found at the following link: https://legal.hubspot.com/privacy-policy
Changes to our privacy policy
We reserve the right to change our privacy policy at short notice so that it always complies with the current legal requirements, or in order to implement changes to our services. This can mean the introduction of new services, for example. The new privacy policy will then apply for your next visit.
