1) INFORMATION ON THE COLLECTION OF PERSONAL DATA AND CONTACT DETAILS OF THE CONTROLLER

1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is STEPCRAFT GmbH & Co. KG, An der Beile 2, 58708 Menden, Deutschland, Tel.: +49 (0) 23 73 – 179 11 60, Fax: +49 (0) 23 73 – 179 11 59, E-Mail: [email protected]. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) DATA COLLECTION WHEN YOU VISIT OUR WEBSITE

2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called „server log files“). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:

• Our visited website
• Date and time at the moment of access
• Amount of data sent in bytes
• Source/reference from which you came to the page
• Browser used
• Operating system used
• IP address used (if applicable: in anonymized form)

Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

3) HOSTING & CONTENT DELIVERY NETWORK

Cloudflare

We use a content delivery network offered by the following provider: Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA

This service enables us to deliver large media files such as graphics, page content or scripts faster via a network of regionally distributed servers. The processing is carried out to protect our legitimate interest in improving the stability and functionality of our website pursuant to Art. 6 (1) point f GDPR. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors‘ data and prohibiting unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

4) COOKIES

In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called „session cookies“), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called „persistent cookies“). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.

If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that the functionality of our website may be limited if cookies are not accepted.

5) CONTACTING US

When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.

The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.

6) REGISTRATION AT THE PORTAL OR FORUM

You can register on our website by entering your personal data. The personal data processed for registration is determined by the input mask used for registration. We use the so-called double opt-in procedure for registration, i.e. your registration is not complete until you have previously confirmed your registration via a confirmation e-mail sent to you for this purpose by clicking on the link contained therein. If you do not receive confirmation within 24 hours, your registration will automatically be deleted from our database. You are obliged to provide the aforementioned data; all further information can be provided voluntarily by using our portal.

If you use our portal, we store your data necessary for the fulfillment of the contract as well as, if necessary, information on the method of payment, until you finally delete your access. Furthermore, we store the data provided voluntarily by you for the duration of your use of the portal, unless you delete it beforehand. You can manage and change all information in the protected customer area. The legal basis can be found in Art. 6 (1) point f GDPR.

In addition, we store all content published by you (such as public contributions, bulletin board entries, guestbook entries, etc.) to operate the website. We have a legitimate interest in providing the website and the complete user-generated content. The legal basis can be found in Art. 6 (1) point f GDPR. If you delete your account, your public statements, especially in the forum, will remain visible to all readers. However, your account is no longer accessible. All other data will be deleted in this case.

7) WEB ANALYSIS SERVICES

7.1 Google Analytics 4

This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland („Google“), which can be used to analyze the use of websites.

When using Google Analytics 4, so-called „cookies“ are used as standard. Cookies are text files that are stored on your terminal device and enable an analysis of your use of a website. The information collected by cookies about your use of the website (including the IP address transmitted by your terminal device, shortened by the last digits, see below) is usually transmitted to a Google server and stored and processed there. This may also result in the transmission of information to the servers of Google LLC, a company based in the USA, where the information is further processed.

When using Google Analytics 4, the IP address transmitted by your terminal device when you use the website is always collected and processed by default and automatically only in an anonymized manner, so that a direct personal reference of the collected information is excluded. This automatic anonymization is carried out by shortening the IP address transmitted by your terminal device by Google within member states of the European Union (EU) or other contracting states of the Agreement on the European Economic Area (EEA) by the last digits.

On our behalf, Google uses this and other information to evaluate your use of the website, to compile reports (reports) on your website activities or your usage behavior and to provide us with other services related to your website usage and internet usage. In this context, the IP address transmitted and shortened by your terminal device within the scope of Google Analytics 4 will not be merged with other data from Google. The data collected in the context of the use of Google Analytics 4 will be retained for 2 months and then deleted.

Google Analytics 4 also enables the creation of statistics with statements about age, gender and interests of website users on the basis of an evaluation of interest-based advertising and with the involvement of third-party information via a special function, the so-called „demographic characteristics“. This makes it possible to determine and distinguish between groups of website users for the purpose of targeting marketing measures. However, data collected via the „demographic characteristics“ cannot be assigned to a specific person and thus not to you personally. This data collected via the „demographic characteristics“ function is retained for two months and then deleted.

All processing described above, in particular the setting of Google Analytics cookies for the storage and reading of information on the terminal device used by you for the use of the website, will only take place if you have given us your express consent for this in accordance with Art. 6 (1) lit. a GDPR. Without your consent, Google Analytics 4 will not be used during your use of the website.

You can revoke your consent once given at any time with effect for the future. To exercise your revocation, please deactivate this service via the „Cookie Consent Tool“ provided on the website.

Google Signals
On this website, the „Google Signals“ service can also be used as an extension of Google Analytics 4. With Google Signals, cross-device reports can be created by Google (so-called „cross-device tracking“). If you have activated „personalised ads“ in your Google account settings and you have linked your internet-enabled devices to your Google account, Google can analyse user behaviour across devices and create database models based on this, provided you have given your consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR (see above). The logins and device types of all page visitors who were logged into a Google account and performed a conversion are taken into account. The data shows, among other things, on which device you first clicked on an ad and on which device the associated conversion took place. Insofar as Google Signals is used, we do not receive any personal data from Google, but only statistics compiled on the basis of Google Signals. You have the option of deactivating the „personalised ads“ function in the settings of your Google account and thus turning off the cross-device analysis. To do this, follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=de
Further information can be found here: https://support.google.com/analytics/answer/7532985?hl=de

User IDs
As an extension of Google Analytics 4, the „UserIDs“ function can also be used on this website. By assigning individual UserIDs, we can have Google create cross-device reports (so-called „cross-device tracking“). This means that your usage behaviour can also be analysed across devices if you have given your corresponding consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR, if you have set up a personal account by registering on this website and are logged into your personal account on different end devices with your relevant login data. The data collected in this way shows, among other things, on which end device you clicked on an ad for the first time and on which end device the relevant conversion took place.

We have concluded a so-called data processing agreement with Google for our use of Google Analytics 4, by which Google is obliged to protect the data of our website users and not to pass it on to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

Further legal information on Google Analytics 4 can be found at the following link: https://policies.google.com/privacy?hl=en

Details on the processing triggered by Google Analytics 4 and Google’s handling of data from websites can be found here: https://policies.google.com/technologies/partner-sites

7.2 This website uses the „Google Tag Manager“, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: „Google“).

The Google Tag Manager provides a technical basis for bundling various web applications, including tracking and analysis services, and for calibrating, controlling and attaching conditions to them via a uniform user interface.
Google Tag Manager itself does not store any information on user end devices or read them. The service also does not perform any independent data analyses.
However, the Google Tag Manager transmits your IP address to Google when you visit a page and may store it there. Also a transmission to servers of Google LLC in the USA is possible.

All processing described above, in particular the reading or saving of information on the end device used, is only carried out if you have given us your express consent in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the „cookie consent tool“ provided on the website.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors‘ data and prohibits unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

8) RETARGETING/REMARKETING/ REFERRAL ADVERTISING

Google Ads Remarketing

This website uses the online advertising program „Google Ads“ and, within the scope of Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland („Google“). We use Google Ads to draw attention to our attractive offers on external websites with the help of advertising media (so-called Google Adwords). We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. In this way, we pursue the concern of showing you advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of the advertising costs incurred

The conversion tracking cookie is set when a user clicks on an ad placed by Google. Cookies are small text files that are stored on your terminal device. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize if the user has clicked on the ad and has been directed to this page. Each Google Ads customer receives a different cookie. Cookies therefore cannot be tracked across Google Ads customers’ websites. The information obtained using the conversion cookie is used to create conversion statistics for Google Ads customers who have chosen conversion tracking. Customers learn the total number of users who clicked on their ad and who were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. The use of Google Ads may also result in the transmission of personal data to the servers of Google LLC. in the USA.

Details on the processing operations initiated by Google Ads conversion tracking and on Google’s handling of data collected from websites can be found here: https://policies.google.com/technologies/partner-sites?hl=en
All processing described above, in particular the setting of cookies for the reading of information on the end device used, will only be carried out if you have given us your express consent to do so in accordance with Art. 6 (1) point a GDPR. Without this consent, Google Conversion Tracking will not be used during your visit to the website.

You can permanently disable the setting of cookies by Google Ads Conversion Tracking for advertising preferences. You may download and install the browser plug-in available at the following link: https://support.google.com/ads/answer/7395996?
Please note that certain functions of this website may not be available or may be restricted if you have deactivated the use of cookies.

Further information about Google’s privacy policy can be viewed at:
https://www.google.com/policies/technologies/ads/

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

9) SITE FUNCTIONALITIES

YouTube Videos

This website uses plugins to display and play videos from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland

Data may also be transmitted to: Google LLC., USA.

When you call up a page of our website that contains such a plugin, your browser establishes a direct connection to the provider’s servers to load the plugin. This involves certain information, including your IP address, being transmitted to the provider.

If the playback of embedded videos is started via the plugin, the provider also uses cookies to collect information about user behavior, to create playback statistics and to prevent abusive behavior.

If you are logged into a user account maintained by the provider during your visit to the site, your data will be directly assigned to your account when you click on a video. If you do not wish to have your data assigned to your account, you must log out before clicking on the play button.

All the above-mentioned processing, in particular the setting of cookies for reading out information on the end device used, only takes place if you have given us your express consent in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the „cookie consent tool“ provided on the website.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

10) TOOLS AND MISCELLANEOUS

10.1 This website uses a so-called „cookie consent tool“ to obtain effective user consent for cookies and cookie-based applications that require consent. The „cookie consent tool“ is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box. Through the use of the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.

Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.

Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

10.2 Cloudflare

For security purposes, this website uses the service of the following provider: Cloudflare, Inc, 101 Townsend St. San Francisco, CA 94107, USA

The provider protects the website and the associated IT infrastructure from unauthorised third-party access, cyber attacks and viruses and malware. The provider collects the IP addresses of users and, if necessary, further data on their behaviour on our website (in particular URLs accessed and header information) in order to detect and defend against illegitimate page accesses and dangers. In doing so, the collected IP address is compared with a list of known attackers. If the captured IP address is identified as a security risk, the provider can automatically block it from accessing the website. The information collected in this way is transferred to a server of the provider and stored there.

The described data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interests in protecting the website from harmful cyber attacks and in maintaining structural and data integrity and security.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors‘ data and prohibits unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

11) RIGHTS OF THE DATA SUBJECT

11.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:

• Right of access by the data subject pursuant to Art. 15 GDPR;
• Right to rectification pursuant to Art. 16 GDPR;
• Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
• Right to restriction of processing pursuant to Art. 18 GDPR;
• Right to be informed pursuant to Art. 19 GDPR;
• Right to data portability pursuant to Art. 20 GDPR;
• Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
• Right to lodge a complaint pursuant to Art. 77 GDPR.

11.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

12) DURATION OF STORAGE OF PERSONAL DATA

The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and – if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).

If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.

If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.

When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.

Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.