Privacy Policy

Last updated: 15 October 2026

We are very pleased about your interest in our company. Data protection is of particular importance to the management of Horst Bode Import-Export GmbH. The use of the websites of Horst Bode Import-Export GmbH is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company via our website, the processing of personal data may become necessary. Where the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, for example the name, address, e-mail address or telephone number of a data subject, always takes place in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to Horst Bode Import-Export GmbH. By means of this privacy policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.

As the controller, Horst Bode Import-Export GmbH has implemented numerous technical and organisational measures to ensure the most complete protection possible for the personal data processed via this website. Nevertheless, internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The privacy policy of Horst Bode Import-Export GmbH is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand, both for the public and for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this privacy policy, we use the following terms, among others:

  • a)    Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • b)    Data subject

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

  • c)    Processing

Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • d)    Restriction of processing

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

  • e)    Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

  • f)     Pseudonymisation

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

  • g)    Controller or controller responsible for the processing

The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

  • h)    Processor

A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  • i)      Recipient

A recipient is a natural or legal person, public authority, agency or other body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

  • j)      Third party

A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

  • k)    Consent

Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller

The controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

Horst Bode Import-Export GmbH

Havighorster Weg 6

21031 Hamburg

Germany

Tel.: 040 7393320

E-mail: info@bode.bio

Website: www.bode.bio

3. Name and address of the data protection officer

The data protection officer of the controller is:

Rebecca Wiemer

Wiemer & Arndt

Marienstraße 25

10117 Berlin

Germany

Tel.: +49 (0)30 403 649 831

E-mail: rebecca.wiemer@wiemer-arndt.de

Website: www.wiemer-arndt.de

Any data subject may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

 4. Cookies

The Internet pages of the Horst Bode Import-Export GmbH use cookies. Cookies are text files that are stored in a computer system via an Internet browser. 

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID. 

Through the use of cookies, the Horst Bode Import-Export GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. 

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie. 

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable. 

When you visit our website you will see a banner below where you can agree to the cookies. The second option is "no marketing / statistics tracking". If you choose this, the cookies will remain, but the data will no longer be tracked.

Cookie consent management (consentmanager)

We use the consent management tool “consentmanager” provided by consentmanager AB, Haltegelvägen 1b, S-72348 Vasteras, on this website in order to obtain, manage and document your consent to the use of cookies and similar technologies. When you visit our shop, a banner is displayed in which you can decide which categories of cookies and services you consent to. You can change or withdraw your choice at any time with effect for the future by opening the privacy settings at the bottom left of any page.

The tool is integrated into our website via Google Tag Manager. Google Tag Manager serves solely to deliver the consentmanager code; it does not itself process any content of your consent. Further information on Google Tag Manager can be found in the corresponding section of this privacy policy. When you access our website, a connection to the consentmanager servers is established. In particular, the following data is processed: IP address (shortened), consent decision. In addition, a cookie is stored in your browser so that your choice is taken into account on your next visit. The storage period of this cookie is [e.g. 12 months]. We store the records of consent for [e.g. 3 years].

Processing is based on our legal obligation to be able to prove consent (Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR). Access to your device is strictly necessary for this purpose and is based on Section 25(2) No. 2 TDDDG.

We have concluded a data processing agreement (Art. 28 GDPR) with the provider. According to the provider, the consent data is stored in data centres within the EU.

Google Tag Manager

We use Google Tag Manager on this website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Tag Manager is a tool for managing website tags (e.g. code snippets from third-party providers). The Tag Manager itself does not set any cookies and does not access the content of the tags delivered through it. We use it to integrate the consent management tool “consentmanager” as well as other services loaded via GTM, e.g. Google Analytics, Google Ads, Microsoft Ads, Consent Mode and website trackers. These services are only loaded if you have previously given your consent in the cookie banner. Which services these are in detail can be found in the respective sections of this privacy policy.

When you access our website, a connection to Google’s servers is established in order to load the Tag Manager. In the process, your IP address is transmitted to Google. It cannot be ruled out that data is thereby transferred to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework, so that an adequacy decision of the EU Commission exists for the transfer (Art. 45 GDPR). [If standard contractual clauses have also been agreed: In addition, we have concluded standard contractual clauses pursuant to Art. 46 GDPR with Google.]

Processing is based on our legitimate interest in the efficient and lawful management of the services on our website, in particular in obtaining your consent (Art. 6(1)(f) GDPR). Access to your device is strictly necessary for this purpose and is based on Section 25(2) No. 2 TDDDG.

We have concluded a data processing agreement (Art. 28 GDPR) with Google. Further information can be found in the terms of use of Google Tag Manager (https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/) and in Google’s privacy policy (https://policies.google.com/privacy?hl=de).

 5. Collection of general data and information

Each time the website of Horst Bode Import-Export GmbH is accessed by a data subject or an automated system, it collects a range of general data and information. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using this general data and information, Horst Bode Import-Export GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Horst Bode Import-Export GmbH, on the one hand, statistically and, on the other hand, with the aim of increasing data protection and data security in our company, in order ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.

6. Registration on our website

The data subject has the possibility to register on the website of the controller by providing personal data. Which personal data is transmitted to the controller in the process is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller’s own purposes. The controller may arrange for the data to be passed on to one or more processors, for example a parcel service provider, which likewise uses the personal data exclusively for internal use attributable to the controller.

By registering on the website of the controller, the IP address assigned by the data subject’s internet service provider (ISP) and the date and time of registration are also stored. This data is stored because this is the only way to prevent misuse of our services and, if necessary, to enable the investigation of criminal offences committed. In this respect, the storage of this data is necessary to safeguard the controller. As a matter of principle, this data is not passed on to third parties unless there is a legal obligation to do so or the disclosure serves criminal prosecution.

The registration of the data subject, with the voluntary provision of personal data, enables the controller to offer the data subject content or services which, by their nature, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it deleted completely from the controller’s database.

The controller shall provide information to any data subject at any time upon request as to which personal data relating to the data subject is stored. Furthermore, the controller shall correct or delete personal data at the request or notification of the data subject, insofar as this does not conflict with statutory retention obligations. A data protection officer named in this privacy policy and all employees of the controller are available to the data subject as contact persons in this context.

7. Subscription to our newsletter

On the website of Horst Bode Import-Export GmbH, users are given the opportunity to subscribe to our company’s newsletter. Which personal data is transmitted to the controller when ordering the newsletter is determined by the input mask used for this purpose.

Horst Bode Import-Export GmbH informs its customers and business partners at regular intervals by means of a newsletter about the company’s offers. As a general rule, our company’s newsletter can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter. For legal reasons, a confirmation e-mail using the double opt-in procedure is sent to the e-mail address first entered by a data subject for the newsletter mailing. This confirmation e-mail serves to verify whether the owner of the e-mail address, as the data subject, has authorised the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject’s e-mail address at a later point in time and therefore serves to provide legal protection for the controller.

The personal data collected when registering for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail where this is necessary for the operation of the newsletter service or for a related registration, as could be the case in the event of changes to the newsletter offering or changes in technical circumstances. The data subject can cancel the subscription to our newsletter at any time.

The consent to the storage of personal data that the data subject has given us for sending the newsletter can be revoked at any time. For the purpose of revoking consent, each newsletter contains a corresponding link. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to notify the controller of this in another way.

8. Newsletter tracking

The newsletters of Horst Bode Import-Export GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in e-mails sent in HTML format to enable log file recording and log file analysis. This makes it possible to carry out a statistical evaluation of the success or failure of online marketing campaigns. Using the embedded tracking pixel, Horst Bode Import-Export GmbH can recognise whether and when an e-mail was opened by a data subject and which links in the e-mail were accessed by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters is stored and evaluated by the controller in order to optimise the sending of the newsletter and to adapt the content of future newsletters even better to the interests of the data subject. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. Following a revocation, this personal data will be deleted by the controller. Horst Bode Import-Export GmbH automatically interprets an unsubscription from receiving the newsletter as a revocation.

CleverReach is used as newsletter software. Your data is transmitted to CleverReach GmbH & Co. KG, which is prohibited from selling your data and from using it for purposes other than sending newsletters. CleverReach GmbH & Co. KG is a German, certified provider that was selected in accordance with the requirements of the General Data Protection Regulation and the Federal Data Protection Act. Further information can be found here:

https://de.sendinblue.com/informationen-newsletter-empfaenger/

https://www.cleverreach.com/de-de/datenschutz/

8.1 Terms of participation for prize draws via newsletter

  • The contact person and controller is solely Horst Bode Import-Export GmbH. The winners are determined by random draw and notified by e-mail.
  • Eligibility: This prize draw is only open to persons aged 18 or over who reside in Germany and who have consented to receiving the newsletter. Participants can revoke this consent at any time by letter, fax or e-mail.
  • Employees of Horst Bode Import-Export GmbH and their relatives and family members are excluded from participating in the prize draw.
  • For the start and end of the prize draw, the exact description of the prize and the date of the prize draw, please refer to the newsletter.
  • There is no obligation to accept the prize. The prize will be sent to the winner’s address stored in our merchandise management system. A cash payout of the prize is not possible. Recourse to the courts is excluded.
  • Participation in the prize draws/competitions is free of charge. If prize draws/competitions are offered online, however, the participant must have an internet connection in order to receive and send an e-mail; the participant bears the costs incurred for this themselves.
  • This promotion is in no way sponsored, endorsed or administered by the newsletter tool provider and is not associated with the newsletter provider. The provider is therefore released from any liability towards all participants.

 

8.2 Participation in customer surveys

We use the tool “Umfrage Online” to conduct customer surveys.

Your answers and the survey results are made available to us by the provider on the basis of a service contract. Processing in Switzerland is permitted in accordance with the adequacy decision that exists for Switzerland.

Participation in a customer survey is possible without providing your personal data. For the purpose of conducting the survey, only your IP address is recorded, which does not allow any direct conclusions to be drawn about you as a natural person.

The purpose of the customer survey is to analyse customers’ opinions of our offering and service. The aim of the survey is to continuously improve our processes and products and thereby further increase customer satisfaction.

The legal basis for the invitation to participate in the customer survey is your consent to receiving the newsletter and thus Art. 6(1)(a) GDPR. 

Consent to the collection and processing of the data is irrevocable, because, owing to the anonymised form of the customer survey, no deletion relating to individual participants can be carried out.

In addition, further data (IP address) is processed pursuant to Art. 6(1)(f) GDPR (legitimate interest). Your IP address is used to ensure that the survey cannot be completed more than once, in order to prevent the result from being distorted.

The responses to the customer survey (in pseudonymised form) and the results derived from them are retained and stored for the purpose of evaluating the results. The data is retained for 1 year after the end of the customer survey and then deleted.    

If you would like to take part in our prize draw following the customer survey, we need your e-mail address.

The e-mail address collected from you is never merged with your answers from the customer survey.

The legal basis for this type of processing is Art. 6(1)(f) GDPR (legitimate interest). The controller has a legitimate interest in giving survey participants a token of thanks in the form of a prize draw.

The provision of your personal data in this context is voluntary.

If consent is objected to, participation in the prize draw is no longer possible.

Your personal data will be retained for a period of 5 years and then deleted.

9. Contact options via the website

Due to statutory provisions, the website of Horst Bode Import-Export GmbH contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purposes of processing the enquiry or contacting the data subject. This personal data is not passed on to third parties.

10. Use of the Certiflow document management platform for suppliers

As an importer and trader of organic raw materials, we hold multiple certifications. In the context of fulfilling purchasing and quality assurance criteria and the annual inspections by the certification bodies, we are required to provide evidence that the goods and our suppliers also hold the corresponding certifications. In order to manage the large volume of documents, we use the supplier management platform “Certiflow” from Cedgetec, Schönhorst 41, 21509 Glinde, Germany. In addition, “Certiflow” also serves as a communication tool and works like e-mail. When communication data is exchanged between you and us, it is stored, similar to an e-mail, in the outboxes and inboxes. Your personal data, such as salutation, surname, first name and your communication data, is transferred to “Certiflow” via an interface and processed by further service providers (e-mail providers); in this context, processing of this data outside the EEA cannot be ruled out. Please note that no data flows to Cedgetec GmbH and that all documents and information about your company are stored exclusively on Bode Naturkost’s own servers in Germany. We have concluded a data processing agreement with Cedgetec; however, Cedgetec is not directly involved in the data processing, and contact may only occur in the context of support.

The legal basis for the use of the document management platform is our legitimate interest pursuant to Art. 6(1)(f) GDPR. Our legitimate interest lies in keeping the time and personnel effort required to manage the necessary documentation as low as possible.

The data is stored for the duration of the contractual relationship with you; after the contractual relationship ends, the data is blocked from further processing for the statutory retention period. After the statutory retention period has expired, the data is deleted in compliance with data protection law.

11. Routine erasure and blocking of personal data

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage or where provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage ceases to apply, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with the statutory provisions.

12. Rights of the data subject

  • a)    Right to confirmation

Every data subject has the right, granted by the European legislator, to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to exercise this right to confirmation, he or she may contact our data protection officer or another employee of the controller at any time.

  • b)    Right of access

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

  • the purposes of the processing
  • the categories of personal data being processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  • the existence of the right to request from the controller rectification or erasure of personal data concerning him or her, or restriction of processing, or to object to such processing
  • the existence of the right to lodge a complaint with a supervisory authority
  • where the personal data are not collected from the data subject: any available information as to their source
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has a right to be informed whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, he or she may contact our data protection officer or another employee of the controller at any time.

  • c)    Right to rectification

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Furthermore, the data subject has the right, taking into account the purposes of the processing, to have incomplete personal data completed — including by means of a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may contact our data protection officer or another employee of the controller at any time.

  • d)    Right to erasure (right to be forgotten)

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller the erasure of personal data concerning him or her without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:

  • The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
  • The data subject withdraws consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
  • The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
  • The personal data has been unlawfully processed.
  • The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  • The personal data has been collected in relation to the offer of information society services pursuant to Art. 8(1) GDPR.

If one of the above-mentioned grounds applies and a data subject wishes to have personal data stored at Horst Bode Import-Export GmbH erased, he or she may contact our data protection officer or another employee of the controller at any time. The data protection officer of Horst Bode Import-Export GmbH or another employee will arrange for the erasure request to be complied with without undue delay.

Where the personal data has been made public by Horst Bode Import-Export GmbH and our company, as controller, is obliged to erase the personal data pursuant to Art. 17(1) GDPR, Horst Bode Import-Export GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested from those other controllers

the erasure of any links to, or copy or replication of, that personal data, insofar as the processing is not necessary. The data protection officer of Horst Bode Import-Export GmbH or another employee will arrange the necessary measures in each individual case.

  • e)    Right to restriction of processing

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
  • The controller no longer needs the personal data for the purposes of the processing, but the data subject requires them for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Art. 21(1) GDPR and it has not yet been verified whether the legitimate grounds of the controller override those of the data subject.

If one of the above-mentioned conditions is met and a data subject wishes to request the restriction of personal data stored at Horst Bode Import-Export GmbH, he or she may contact our data protection officer or another employee of the controller at any time. The data protection officer of Horst Bode Import-Export GmbH or another employee will arrange the restriction of processing.

  • f)     Right to data portability

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller by the data subject, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data was provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may contact the data protection officer appointed by Horst Bode Import-Export GmbH or another employee at any time.

  • g)    Right to object

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions.

In the event of an objection, Horst Bode Import-Export GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims.

Where Horst Bode Import-Export GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of the personal data for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Horst Bode Import-Export GmbH to processing for direct marketing purposes, Horst Bode Import-Export GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Horst Bode Import-Export GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact the data protection officer of Horst Bode Import-Export GmbH or another employee directly. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

  • h)    Automated individual decision-making, including profiling

Every data subject affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Horst Bode Import-Export GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise rights relating to automated decisions, he or she may contact our data protection officer or another employee of the controller at any time.

  • i)      Right to withdraw consent under data protection law

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may contact our data protection officer or another employee of the controller at any time.

13. Data protection in job applications and the application process

The controller processes personal data about you in the course of the application process, insofar as this is necessary for the decision on establishing an employment relationship. The legal basis for the processing is Section 26 of the German Federal Data Protection Act (BDSG) and Art. 88 GDPR.

If no employment relationship is established, the application documents will be deleted three months after notification of the decision to reject the application, provided that no other legitimate interests of the controller conflict with deletion. Another legitimate interest in this sense may be, for example, a duty to provide evidence in proceedings under the German General Equal Treatment Act (AGG).

13.1. Use of the Coveto Recruiting Portal

If you apply (register) with your profile via our recruiting portal, this information is collected, processed, used and stored only for the purpose of carrying out the application process (Art. 6 GDPR in conjunction with Section 26 BDSG-neu). This data is generally used for contacting you regarding your applications. 

Mandatory information about you is marked accordingly with an *; further information is optional and provided on a voluntary basis. As a matter of principle, we will not ask you to disclose so-called special categories of personal data within the meaning of Art. 9 GDPR (e.g. health data). However, if you voluntarily provide us with such information, you permit us to store it in the recruiting portal for the purpose of the application process. 

You can make changes to your (contact) data in the recruiting portal at any time. Please note that changes to your (contact) data update all of your applications — including multiple applications, where applicable. 

After the respective process has been completed, your data will be deleted in accordance with statutory provisions or anonymised for statistical purposes in such a way that no conclusions can be drawn about you any more.

If your data is to remain stored in our recruiting software beyond the statutory retention period, e.g. for later contact, this will be done on the basis of your consent (pursuant to Art. 6(1)(a) GDPR). 

You can find the privacy policy of the provider Coveto at https://www.coveto.de/datenschutz

14. Privacy provisions on the use and application of Google Analytics (with anonymisation function)

The controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites. A web analytics service collects, among other things, data on the website from which a data subject came to a website (so-called referrer), which sub-pages of the website were accessed, or how often and for what length of time a sub-page was viewed. Web analytics is mainly used to optimise a website and to carry out a cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

For web analytics via Google Analytics, the controller uses the add-on "_gat._anonymizeIp". By means of this add-on, the IP address of the data subject’s internet connection is shortened and anonymised by Google if access to our websites takes place from a Member State of the European Union or from another contracting state of the Agreement on the European Economic Area.

The purpose of the Google Analytics component is the analysis of visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our websites, and to provide further services connected with the use of our website.

Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By placing the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, is accessed, the internet browser on the data subject’s information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. In the course of this technical procedure, Google obtains knowledge of personal data, such as the data subject’s IP address, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission statements.

By means of the cookie, personal information, for example the access time, the place from which an access originated and the frequency of the data subject’s visits to our website, is stored. Each time our websites are visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may, under certain circumstances, pass on to third parties the personal data collected via the technical procedure.

As already described above, the data subject can prevent our website from placing cookies at any time by means of a corresponding setting in the internet browser used, and thereby permanently object to the placing of cookies. Such a setting of the internet browser used would also prevent Google from placing a cookie on the data subject’s information technology system. In addition, a cookie already placed by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility to object to, and prevent, the collection of the data generated by Google Analytics relating to the use of this website, as well as the processing of this data by Google. To do so, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information on website visits may be transmitted to Google Analytics. The installation of the browser add-on is regarded by Google as an objection. If the data subject’s information technology system is deleted, formatted or reinstalled at a later point in time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or by another person within his or her sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and the applicable privacy provisions of Google can be accessed at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

15. Privacy provisions on the use and application of Google Remarketing

This website uses the functions of Google Ads Remarketing. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With Google Ads Remarketing, we can assign people who interact with our online offering to certain target groups in order to subsequently display interest-based advertising to them in the Google advertising network (remarketing or retargeting).

Furthermore, the advertising target groups created with Google Ads Remarketing can be linked to Google’s cross-device functions. In this way, interest-based, personalised advertising messages that have been tailored to you depending on your previous usage and browsing behaviour on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).

If you have a Google account, you can object to personalised advertising at the following link: https://adssettings.google.com/anonymous?hl=de.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent can be revoked at any time.

Further information and the privacy provisions can be found in Google’s privacy policy at: https://policies.google.com/technologies/ads?hl=de.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further

information on this is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

16. Privacy provisions on the use and application of Google Ads

The website operator uses Google Ads. Google Ads is an online advertising programme of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Furthermore, targeted advertisements can be displayed on the basis of the user data available at Google (e.g. location data and interests) (target group targeting). As the website operator, we can evaluate this data quantitatively, for example by analysing which search terms led to our advertisements being displayed and how many advertisements led to corresponding clicks.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent can be revoked at any time.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

 

17. Privacy provisions on the use and application of Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that helps us integrate tracking or statistics tools and other technologies on our website. Google Tag Manager itself does not create user profiles, does not store cookies and does not carry out any independent analyses. It merely serves to manage and deliver the tools integrated via it. However, Google Tag Manager collects

your IP address, which may also be transmitted to Google’s parent company in the United States.

 

Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and management of various tools on its website. Where corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1)

TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further

information on this is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

 

18. Privacy provisions on the use and application of Microsoft Advertising

The website operator uses Microsoft Advertising. Microsoft Advertising is an online advertising programme of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

Microsoft Advertising enables us to display advertisements in the Bing search engine or on third-party websites when the user enters certain search terms on Bing (keyword targeting). Furthermore, targeted advertisements can be displayed on the basis of the user data available at Microsoft (e.g. location data and interests) (target group targeting). As the website operator, we can evaluate this data quantitatively, for example by analysing which search terms led to our advertisements being displayed and how many advertisements led to corresponding clicks.

On this site, we use Microsoft Advertising’s Universal Event Tracking (UET). In doing so, pseudonymised data is collected in order to track which actions you perform on our websites after you have clicked on an advertisement on Microsoft Advertising. UET collects your IP address (anonymised), device identifiers, information about device and browser settings, Microsoft Click ID (stored in a cookie), time spent on the website, which areas of the website were accessed, the advertisement through which you reached the website and the keyword clicked.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent can be revoked at any time.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://learn.microsoft.com/de-de/compliance/regulatory/offering-eu-model-clauses.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/6474.

19. Privacy provisions regarding our social media presences

Data processing by social networks

We maintain publicly accessible profiles on social networks. You can find the individual social networks we use further below.

Social networks such as Facebook, Twitter etc. can generally analyse your user behaviour comprehensively when you visit their website or a website with integrated social media content (e.g. like buttons or advertising banners). Visiting our social media presences triggers numerous processing operations relevant to data protection. In detail:

If you are logged in to your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. However, your personal data may under certain circumstances also be collected if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.

With the help of the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you within and outside the respective social media presence. If you have an account with the respective social network, the interest-based advertising can be displayed on all devices on which you are or have been logged in.

Please also note that we cannot trace all processing operations on the social media portals. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and privacy provisions of the respective social media portals.

Legal basis

Our social media presences are intended to ensure the most comprehensive possible presence on the internet. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which are to be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6(1)(a) GDPR).

Controller and assertion of rights

If you visit one of our social media presences (e.g. Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered during this visit. You can in principle assert your rights (access, rectification, erasure, restriction of processing, data portability and complaint) both against us and against the operator of the respective social media portal (e.g. against Facebook).

Please note that, despite the joint responsibility with the operators of the social media portals, we do not have full influence over the data processing operations of the social media portals. Our options are largely determined by the corporate policy of the respective provider.

Storage period

The data collected directly by us via the social media presence is deleted from our systems as soon as you request us to delete it, withdraw your consent to its storage or the purpose for the data storage ceases to apply. Stored cookies remain on your device until you delete them. Mandatory statutory provisions – in particular retention periods – remain unaffected.

We have no influence on the storage period of your data that is stored by the operators of the social networks for their own purposes. For details, please contact the operators of the social networks directly (e.g. see their privacy policy, below).

Social networks in detail

Facebook

We have a profile on Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. According to Facebook, the data collected is also transferred to the USA and to other third countries.

You can adjust your advertising settings yourself in your user account. To do so, click on the following link and log in: https://www.facebook.com/settings?tab=ads.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.

For details, please refer to Facebook’s privacy policy: https://www.facebook.com/about/privacy/.

Instagram

The controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform and allows users to share photos and videos and also to redistribute such data in other social networks.

The operating company of the Instagram services is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, USA.

Further information and the applicable privacy provisions of Instagram can be accessed at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

 

 

Terms of participation for prize draws on Instagram

·         The contact person and controller is solely Horst Bode Import-Export GmbH. The winners will be announced via the account @bodenaturkost on Instagram.

·         Eligibility: This prize draw is only open to persons aged 18 or over who reside in Germany. Employees of Horst Bode Import-Export GmbH and their relatives and family members are excluded from participating in the prize draw.

·         For the start and end of the prize draw, the exact description of the prize and the date of the prize draw, please refer to the Instagram post.

·         The winners will be notified by us via the Direct Message function on Instagram. Winners must send their contact and address details by Direct Message to the Bode Naturkost Instagram page within 5 working days (from the winner notification). If winners do not confirm acceptance of the prize within this time, their claim to the prize lapses without replacement. A substitute winner will then be determined following the same procedure. There is no obligation to accept the prize. The prize will be sent to the winner’s address provided. A cash payout of the prize is not possible. Recourse to the courts is excluded.

·         Participation in the prize draws/competitions is free of charge. If prize draws/competitions are offered online, however, the participant must have an internet connection in order to connect to our website; the participant bears the costs incurred for this themselves. If the participant withdraws their like or deletes their post, they will no longer take part in the prize draw.

·         Comments that violate Instagram’s guidelines will be removed without notice once we become aware of them. The participant is thereby excluded from the draw. The same applies to comments that do not comply with the law. The participant alone is responsible for this. The organiser is released from responsibility for any legal violations by participants.

·         This promotion is in no way sponsored, endorsed or administered by Instagram and is not associated with Instagram. Instagram is therefore released from any liability towards all participants.

·         The contact person and controller is solely Horst Bode Import-Export GmbH. The winners will be announced via the account @bodenaturkost on Instagram.

·         Insofar as personal data of participants is collected in the course of the prize draw, it is collected, processed and used by the organiser exclusively for the purpose of conducting the prize draw and deleted after the end of the prize draw. The participant expressly agrees to this. The participant can revoke this consent at any time by letter, fax or e-mail. The participant is themselves responsible for the correctness and completeness of the data they submit. Consent can be revoked at any time by deleting the corresponding post. In this case, the participant simultaneously declares that they no longer wish to take part in the prize draw.

 

19.a  Privacy provisions on the use and application of analytics tools and advertising

Meta Pixel (Facebook Pixel)

We use the Meta Pixel of Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, on our website. The Meta Pixel is used to analyse user behaviour, measure the success of advertising campaigns and create target groups for marketing measures. The Meta Pixel is activated exclusively after your express consent via our consent banner. Without your consent, the Meta Pixel is not loaded.

Legal basis
Processing is based on your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. You can revoke your consent at any time with effect for the future via the cookie settings.

Joint controllership
Insofar as event data is collected with the help of the Meta Pixel and transmitted to Meta, we and Meta Platforms Ireland Limited are jointly responsible for this data processing within the meaning of Art. 26 GDPR. The essential contents of the joint controllership agreement (“Controller Addendum”) are provided by Meta. Meta Controller Addendum

Third-country transfers
 In the context of using the Meta Pixel, personal data may be transferred to companies of the Meta group in the USA. The level of data protection in the USA is not fully identical to that of the European Union. According to its own statements, Meta uses appropriate safeguards for international data transfers. Nevertheless, there is a risk that US authorities may, under certain circumstances, access personal data without effective legal remedies being available against this.

Further information
For further information on data processing by Meta, please refer to Meta’s privacy information.

20. Legal basis of the processing

Art. 6(1)(a) GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, for processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his or her name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. The processing would then be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal bases, if the processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this regard, it took the view that a legitimate interest could be assumed where the data subject is a customer of the controller (Recital 47, second sentence, GDPR).

21. Legitimate interests in the processing pursued by the controller or a third party

Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.

22. Period for which the personal data will be stored

The criterion for the period of storage of personal data is the respective statutory retention period. After the period has expired, the corresponding data is routinely deleted, provided that it is no longer required for the performance or initiation of a contract.

21. Statutory or contractual requirements to provide personal data; necessity for entering into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We inform you that the provision of personal data is in part required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data, which subsequently has to be processed by us. For example, the data subject is obliged to provide us with personal data when our company enters into a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of failure to provide the personal data would be.

23. Existence of automated decision-making

As a responsible company, we refrain from automatic decision-making.

24. Payment services

We integrate payment services from third-party companies on our website. If you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) is processed by the payment service provider for the purpose of payment processing. The respective contractual and data protection provisions of the respective providers apply to these transactions. The payment service providers are used on the basis of Art. 6(1)(b) GDPR (contract performance) and in the interest of a payment process that is as smooth, convenient and secure as possible (Art. 6(1)(f) GDPR).

We currently use the following payment services / payment service providers:

PayPal
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”). The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full. For details, please refer to PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Klarna
The provider is Klarna AB, Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter “Klarna”). Klarna offers various payment options (e.g. instalment purchase). If you choose to pay with Klarna (Klarna Checkout solution), Klarna will collect various personal data from you. Klarna uses cookies to optimise the use of the Klarna Checkout solution. For details on the use of Klarna cookies, please refer to the following link: https://cdn.klarna.com/1.0/shared/content/policy/cookie/de_de/checkout.pdf. You can read more details on this in Klarna’s privacy policy at the following link: https://www.klarna.com/de/datenschutz/.

Apple Pay
The provider of the payment service Apple Pay is Apple Inc., Infinite Loop, Cupertino, CA 95014, USA. You can find Apple’s privacy policy at: https://www.apple.com/legal/privacy/de-ww/.

Billie.io
Billie GmbH, Charlottenstraße, 10969 Berlin, is responsible for the payment service provider Billie.io. If you select this payment method, the data required to process the payment is passed on to Billie.io. Billie.io’s privacy policy can be viewed here:
https://www.billie.io/datenschutz

25. Credit checks

For business customers: In certain cases where there is a legitimate interest, our company checks your creditworthiness. For this purpose, we work with Creditreform Hamburg von der Decken KG, Wandalenweg 8-10, 20097 Hamburg, from which we receive the data required for this. To this end, we transmit your name and contact details to Creditreform. Further information on data processing at Creditreform can be found in the detailed information sheet “Creditreform Information pursuant to Art. 14 EU GDPR” (see Annex 1) or at www.creditreform.de/hamburg/datenschutz

For private customers: Our company regularly checks your creditworthiness when contracts are concluded and, in certain cases where there is a legitimate interest, also for existing customers. For this purpose, we work with Creditreform Boniversum GmbH, Hammfelddamm 13, 41460 Neuss, from which we receive the data required for this. To this end, we transmit your name and contact details to Creditreform Boniversum GmbH. You can find the information pursuant to Art. 14 of the EU General Data Protection Regulation on the data processing carried out at Creditreform Boniversum GmbH here: https://www.boniversum.de/eu-dsgvo/informationen-nach-eu-dsgvo-fuer-verbraucher/

26. Links

Despite careful review of the content, we accept no liability
for the content of external links. The operators of the linked pages are
solely responsible for their content.

27. Competent supervisory authority


Data protection supervisory authority Hamburg

The Hamburg Commissioner for Data Protection and Freedom of Information

Klosterwall 6 (Block C)

20095 Hamburg

Tel. 040 42854 - 4040

E-mail: mailbox@datenschutz.hamburg.de

 

Our “Information obligations for data subjects pursuant to Article 13 GDPR” can be found here as pdf.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Privacy Policy

Data protection is of high priority for the management of the Horst Bode Import-Export GmbH. The use of the Internet pages of the Horst Bode Import-Export GmbH is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Horst Bode Import-Export GmbH. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, the Horst Bode Import-Export GmbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of the Horst Bode Import-Export GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

  • a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

  • c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

  • e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

  • f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

  • g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

  • h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  • i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which

may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

  • j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

  • k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Horst Bode Import-Export GmbH

Havighorster Weg 6

21031 Hamburg

Deutschland

Phone: 040 7393320

Email: info@bobe.bio

Website: www.bode.bio

3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Rebecca Wiemer

Wiemer & Arndt

Am Borsigturm 40

13507 Berlin

Deutschland

Tel.: +49 (0)30 403 649 831

E-Mail: rebecca.wiemer@wiemer-arndt.de

Website: www.wiemer-arndt.de

Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

4. Cookies

The Internet pages of the Horst Bode Import-Export GmbH use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, the Horst Bode Import-Export GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

When you visit our website you will see a banner below where you can agree to the cookies. The second option is "no marketing / statistics tracking". If you choose this, the cookies will remain, but the data will no longer be tracked.

a) Cookies used

On our homepage we use a total of 10 cookies.

Category: Necessary (2)
Necessary cookies help to make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website may not work properly without these cookies.

Cookie name: CookieConsent, PHPSESSID

Category: Statistics (3)
Statistics cookies help website owners understand how visitors interact with Web pages by collecting and reporting information anonymously.

Cookie name: _ga, _gat, _gid

Category: Marketing (5)
Marketing cookies are used to follow visitors to websites. The intent is to show ads that are relevant and appealing to the individual user and therefore more valuable to publishers and third-party advertisers.

Cookie name: ads / conversion / #, ads / ga-audiences, collect, IDE, test_cookie

5. Collection of general data and information

The website of the Horst Bode Import-Export GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Horst Bode Import-Export GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Horst Bode Import-Export GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

6. Registration on our website

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

7. Subscription to our newsletters

On the website of the Horst Bode Import-Export GmbH, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

The Horst Bode Import-Export GmbH informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

8. Newsletter-Tracking

The newsletter of the Horst Bode Import-Export GmbH contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Horst Bode Import-Export GmbH may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The Horst Bode Import-Export GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.

The newsletter software used is Sendinblue. Your data is transmitted to Sendinblue GmbH. Sendinblue is prohibited from selling your data and using it for any purpose other than sending newsletters. Sendinblue is a German, certified provider, which has been selected in accordance with the requirements of the Basic Data Protection Regulation and the Federal Data Protection Act. You can find further information here:

https://de.sendinblue.com/informationen-newsletter-empfaenger/

8.1 Conditions of participation in competitions via newsletter

  • The sole contact and person responsible is Horst Bode Import-Export GmbH. The winners will be determined by a draw and informed by e-mail.
  • Eligibility to participate: This competition is only open to persons aged 18 and over who are resident in Germany and who have agreed to receive the newsletter. Participants can revoke this consent at any time by letter, fax or e-mail. Employees and their relatives and family members of Horst Bode Import-Export GmbH are excluded from participation in the competition.
  • The start and end of the competition, the exact description of the prize and the date of the prize draw can be found in the newsletter.
  • There is no obligation to accept the prize. The prize will be sent to the winner's address stored in our merchandise management system. Payment of the prize is not possible. Legal recourse is excluded.
  • Participation in the competitions/competitions is free of charge. However, if competitions/competitions are offered online, the participant must have an Internet connection, to receive and send an e-mail; the costs incurred for this shall be borne by the participant.
  • This promotion is in no way sponsored, endorsed or administered by the newsletter tool provider and is in no way affiliated with the newsletter provider. Therefore, the newsletter provider is exempt from any liability towards all participants.

8.2 Participation in customer surveys

We use the "Survey Online" tool to conduct customer surveys.

Your answers and the survey results are made available to us by the provider on the basis of a service contract. Processing in Switzerland is permitted in accordance with the existing adequacy decision for Switzerland.

Participation in a customer survey is possible without providing your personal data. Only your IP address is recorded for the purpose of conducting the survey, which does not allow any direct conclusions to be drawn about you as a natural person.

The purpose of the customer survey is to analyse customer opinions about our offer and service. The aim of the survey is to continuously improve our processes and products and thus to further increase customer satisfaction.

The legal basis for the invitation to participate in the customer survey is your given consent to receive the newsletter and thus Art. 6 para. 1 a) DS-GVO.

The consent to the collection and processing of the data is irrevocable, as no participant-related deletion can be carried out due to the anonymised form of the customer survey.

In addition, further data (IP address) is processed in accordance with Art. 6 (1) f) DS-GVO (legitimate interest). Your IP address is used to ensure that the survey cannot be carried out twice in order to guarantee that the result is not falsified.

The retention and storage of the answers to the customer survey (in pseudonymised form) and the results derived from them is carried out to evaluate the results. The data is stored for 1 year after completion of the customer survey and then deleted.

If you would like to take part in our prize draw following the customer survey, we need your e-mail address. The email address collected from you will not be merged with your answers from the customer survey at any time.

The legal basis for this type of processing is Art. 6 (1) f) DS-GVO (legitimate interest). The controller has a legitimate interest in sending participants in the survey a thank-you gift in the form of a prize draw. The provision of your personal data in this context is voluntary. If consent is revoked, participation in the raffle is no longer possible. Your personal data will be stored for a period of 5 years and then deleted.

9. Contact possibility via the website

The website of the Horst Bode Import-Export GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

10. Use of the relatico document management platform for suppliers

As an importer and trader of organic raw materials, we are certified several times. As part of the fulfilment of the purchasing and quality assurance criteria as well as the annual inspections by the certification bodies, we are obliged to prove that the goods and our suppliers also have the corresponding certifications. In order to be able to manage the large amount of documents, we use the supplier management platform "relatico", from the company ecratum GmbH with headquarters in Warschauer Strasse 58A D-10243 Berlin - Germany. In addition, "relatico" also serves as a communication tool and functions like e-mail. When communication data is exchanged between you and us, it is stored in the outbox or inbox, similar to an e-mail. Your personal data, such as title, surname, first name as well as your communication data are transferred to "relatico" via interface and processed by further service providers (e-mail providers), in this case a processing of these data outside the EEA cannot be excluded. According to the provider, all documents and information about your company are stored exclusively on servers in Germany.

All detailed information on data processing by "relatico" can be found in the provider's data protection declaration: https://www.relatico.com/de/privacy-statement/. ?

The legal basis for the use of the document management platform is the legitimate interest according to Art. 6 para. 1f DSGVO. Our legitimate interest is to keep the time and personnel expenditure for the management of the required documentation as low as possible.

The data is stored for the period of the contractual relationship with you; after the end of the contractual relationship, the data is blocked for further processing for the period of the legally prescribed retention period. After expiry of the statutory retention period, the data will be deleted in accordance with data protection regulations.?

11. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

12. Rights of the data subject

  • a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

  • b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

  • c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

  • d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must 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 Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Horst Bode Import-Export GmbH, he or she may, at any time, contact any employee of the controller. An employee of Horst Bode Import-Export GmbH shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Horst Bode Import-Export GmbH will arrange the necessary measures in individual cases.

  • e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Horst Bode Import-Export GmbH, he or she may at any time contact any employee of the controller. The employee of the Horst Bode Import-Export GmbH will arrange the restriction of the processing.

  • f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the Horst Bode Import-Export GmbH.

  • g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Horst Bode Import-Export GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If the Horst Bode Import-Export GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Horst Bode Import-Export GmbH to the processing for direct marketing purposes, the Horst Bode Import-Export GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Horst Bode Import-Export GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of the Horst Bode Import-Export GmbH. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

  • h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Horst Bode Import-Export GmbH shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Horst Bode Import-Export GmbH.

  • i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Horst Bode Import-Export GmbH.

13. Data protection for applications and the application procedures

The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

14. Data protection provisions about the application and use of Google Analytics (with anonymization function)

On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

15. Data protection provisions about the application and use of Google Remarketing

On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who

have previously resided on the enterprise's Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.

The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.

Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

16. Data protection provisions about the application and use of Google-AdWords

On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google's search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

17. Data protection provisions about the application and use of Instagram

On this website, the controller has integrated components of the service Instagram. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos, as well as disseminate such data in other social networks.

The operating company of the services offered by Instagram is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, UNITED STATES.

Further information and the applicable data protection provisions of Instagram may be retrieved under https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

18. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

19. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

20. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

21. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

22. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making.

23. Credit check

For business customers: Our company checks your credit standing in certain cases where there is a legitimate interest. For this we cooperate with the Creditreform Creditreform Hamburg from Decken KG, Wandalenweg 8-10, 20097 Hamburg, from whom we receive the necessary data.
For this purpose, we will transfer your name and contact details to Creditreform. Further information on the data processing at Creditreform can be found in the detailed information sheet "Creditreform Information acc. Art. 14 EU-DSGVO (see Annex 1) or at www.creditreform.de/hamburg/datenschutz

For consumers: Our company regularly checks your creditworthiness when concluding contracts and, in certain cases where there is a legitimate interest, also for existing customers. For this purpose, we work together with Creditreform Boniversum GmbH, Hammfelddamm 13, 41460 Neuss, from whom we receive the data required for this purpose. For this purpose, we transmit your name and contact details to Creditreform Boniversum GmbH. You can find the information pursuant to Art. 14 of the EU General Data Protection Regulation on the data processing carried out at Creditreform Boniversum GmbH here: https://www.boniversum.de/eu-dsgvo/informationen-nach-eu-dsgvo-fuer-verbraucher/

24. Links

Despite careful content control, we assume no liability for the content of external links. For the content of the linked pages are only their operators responsible.

25. Supervisory authority

Datenschutz-Aufsichtsbehörde Hamburg

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit

Klosterwall 6 (Block C)

20095 Hamburg

Tel. 040 42854 - 4040

E-Mail: mailbox@datenschutz.hamburg.de


 

Our "obligation of information of affected persons according to aticle 13 General Data Protection Regulation (DSGVO) " you can find it here as a pdf.