Privacy Policy

www.hagen.com

*Last updated: April 25, 2025

1. Basic Information

Caring for pets since 1955, Rolf C. Hagen Inc. (doing business as Hagen Group), is a family company founded by Rolf C. Hagen which has grown to become the world’s largest privately-owned, multi-national pet products manufacturer and distributor. Driven by a common bond of love and compassion for animals, we are dedicated to creating practical and innovative products that enhance the health and welfare of pets worldwide.

We are delighted to have you visit our website, and we would like to thank you for your interest. In the following, we would like to inform you about how we handle your personal data when you use our website. The following information also relates to the use of our websites on mobile devices, e.g. smartphones or tablets. Personal data includes all data which could be used to identify you personally, or which make you identifiable via a username or identification code, such as your IP address.

This Privacy Statement explains the legal basis and the purpose for this collection or processing of your data. We would like to inform you of your rights regarding the use of your personal data. If you have any questions regarding our use of your personal data, please contact us as the responsible entity — Controller under data protection law (for contact details see Clause 2).

For security reasons and to protect the transfer of personal data and other confidential information, these online services use SSL or TLS encryption. You can identify an encrypted connection by checking that the letters “https://” and a lock symbol appear in your browser address line.

2. Who we are (Controller for Data Privacy)

Hagen has appointed an individual responsible for Privacy and Data Privacy Matters. If you have any questions about your personal information, to make comments or to make a complaint, you may contact the person responsible for ensuring compliance with this Privacy Policy at data_priv@rchagen.com

Or write to:

Rolf C. Hagen Inc.,

20500 Trans-Canada Hwy

Baie d’Urfé, Québec

H9X 0A2

Canada

If you are from the EU or the EEA, the following applies:

-This company is the Controller for the processing of data on our online service pursuant to the General Data Protection Regulation (GDPR).

-Our EU representative pursuant to Art. 27 GDPR is: Kaschae Datenschutz & Compliance GmbH, An der Alster 62, 20099 Hamburg, mail@kaschae.de

Contact information for our company Data Protection Officer (DPO): datenschutzbeauftragter@rchagen.com

You can access the Data Subject Access Request Form here

3. Data collection when accessing our online services

Accessing our web pages (without registration) will result in the automatic anonymised collection of the following data on our servers:

masked IP address,
access date/ time/ time zone,
access status,
type of access,
type of protocol,
type and number of pages accessed on our site,
name and size of accessed files,
referring website,
web browser,
operating system.

The listed non-personal data is collected automatically as part of the normal operations of our internet services. The information gathered about the use of our pages is not combined with any personal information provided through the online registration form. We do not have any personal references in our usage data.

We use the above data for the purposes of troubleshooting, generating statistics and measuring website activity with the aim of improving the value and use of our services. As such, we have a legitimate interest to justify the data processing activity pursuant to Article 6 (1) (f) GDPR.

Within our company, our IT Administrator is the only person with access to this data for the purposes listed above.

The above data is only collected for the period of use; once the use has ended, the data shall be deleted without delay, after seven days at the latest.

We use cookies and tools to obtain information as soon as your web browser accesses our website. These identifiers enable a range of our website’s service functions and are automatically transferred to the hard drive of your computer or other mobile device via your browser. This function can be deactivated in the settings of your browser. Should cookies be disabled, personalised service will be unavailable. In this case, your anonymised IP address may be transferred to the USA. For more information on the cookies and tools we use, see the “Use of cookies and tools” section below.

4. Contact

On our pages, we have provided an online form which enables you to contact us electronically. The form requires your first name and family name, your email address and telephone number as well as a box for entering a message to us. We need this data to process your request. You can also choose to provide us with your postal address. Additionally, you can contact us at any time via email. Contacting us is always voluntary.

This data is solely used for the purpose of answering your request or responding to your request for contact, and the technical administration involved. This processing is lawful pursuant to Art. 6 (1) (b) GDPR, as we require the data listed above for the initiation, conduct or termination of a contractual relationship with you.

You request is handled by our internal customer service.

We do not pass on your requests to third-parties or to organisations outside of the EU.

After your request has been processed, we delete your contact information, at the latest, 72 hours after your request has been dealt with. This period of storage may be subject to statutory storage periods, for example, when your request is in connection with the processing of a contract or a warranty or guarantee. In this case, we store your request beyond 72 hours only for the purpose of complying with our legal obligations (Art. 6 (1) (c) GDPR). In this case, we delete your data on termination of the statutory storage period (Section 147 (3) Fiscal Code of Germany (Abgabeordnung – AO)), i.e. after a period of 10 years, beginning at the conclusion of the contract. We will delete your data at the end of this retention period without any request to do so on your part.

5. Hyperlinks and Third Parties

The website may contain sharing or publishing options or links to third-party websites or platforms. By using or activating these links or features, you leave our website, and your browsing becomes subject to the terms of use and privacy policies of those third parties. We have no control over these third-party platforms, and the fact that they are listed on our website does not imply any responsibility on our part.

With whom do we share your data and why?

We may disclose your Personal Information to the following categories of recipients: (a) to our group companies for purposes consistent with this Policy, and in particular, so that they may contact you regarding products and services that may be of interest to you where you have given your consent. (b) to our third-party vendors, service providers and partners who provide data processing services to us, or who otherwise process Personal Information for purposes that are described in this Policy or notified to you when we collect your Personal Information. We may use external companies and third parties to administer and provide related services, such as data processing and storage, payroll processing, group insurance management, etc. Our third-party vendors, service providers and partners include, without limitation: Sunlife, Dayforce, Inc., Collage HR, LinkedIn. In such cases, we take the necessary measures to ensure that these third parties have access only to the information necessary to carry out the agreed services, that they process your information solely for the purposes we have determined, and that they have in place privacy protection measures that comply with applicable laws and ensure the same conditions and level of protection as outlined in the Policy. We may also disclose the information to fulfil a legal obligation. The company is committed to not specifically selling or renting your personal information to any third party.

How long do we keep personal information?

Hagen Group retains collected data for different periods depending on their nature and usefulness to our activities. The retention period varies depending on the reason for collecting the information. Once the retention period expires, personal information is destroyed. Only statistics or reports containing depersonalized and anonymized data may be retained for extended periods.

Age of Consent

We do not knowingly collect information from children or other individuals under the age of 16. If you are a minor under the age of 16, please do not provide us with personal information without the express consent of a parent or guardian. If you are a parent or guardian and know that your children have provided us with personal information, please contact us. If we learn that we have collected personal information from minors without verifying parental consent, we will take steps to delete this information without delay.

Use of cookies and tools

What are cookies?

To improve the look of our website and to enable certain functions, we use cookies on various pages. Cookies are small text files that are stored on your device. These text files are used for the temporary storage of information. Your browser stores cookies in the form of a readable text file once you access our site. If you are registered with us, cookies help us to recognise you, your device (computer, tablet or smart phone) the next time you access one of our pages. Some cookies may contain personal data.

What cookies do we use?

According to function, we classify our cookies as Required, Functional, Analysis & Statistics, and Advertising & Marketing. Some of the cookies we use are required for you to use our web pages (so called session cookies). If you disable this cookie, our pages may not be accessed. The authentication cookie provides you with access to the log-in page. Without this cookie, you cannot register or access the log-in page. These session cookies will be deleted when you close your browser.

Other cookies remain on your device and allow us and our partner companies (third-party cookies) to recognise your browser on your next visit (persistent cookies). Persistent cookies are automatically deleted after a certain period of time, which differs from cookie to cookie. For advertising purposes, we use a retargeting cookie which allows us to show you interesting offers, even outside of our web pages. For more information, see the following overview of cookies used.

What is the purpose and the legal basis for using cookies?

Most of the cookies we use do not store any information that can identify you personally or that makes you identifiable. Rather, these cookies provide us with general and anonymised information regarding the use of our websites, the pages that are visited, the browsers and operating systems used and the cities our visitors are located. We only collect masked IP addresses which make it impossible to recognise individual users or be assigned to any one individual.

Some of these cookies make the ordering process easier, by saving specific website settings (e.g. noting the content(s) of a virtual shopping basket for a subsequent visit to the website). Where our cookies do process personal data, this processing is done in accordance with Art. 6 (1) (b) GDPR to fulfil our contract with you.

Any cookies we collect are for the purposes of gathering information for improving the functioning and content of our online services. These functional cookies serve a legitimate interest (Art. 6 (1) (f) GDPR) as they enable the technical adaptation of our service and make it easier for you to use our pages. We also use cookies to measure the success of our online marketing. Using statistical data, we can also identify disruptions and understand cost calculations for advertising media. We only understand this processing when you have granted us consent for the use of these cookies for analysis and statistics or for advertising and marketing (Art. 6 (1) (a) GDPR). You may withdraw your consent at any time with future effect. The processing of your data remains lawful until your consent is withdrawn.

How to disable cookies

You can set your browser to inform you about the setting of cookies and whether you wish to accept cookies individually, or to accept specific kinds of cookies, or to disable all cookies. Each browser is different in the way it administers its cookie settings. The Help menu of your browser provides information on how to change your cookie settings. You can find this information for your browser using the links below. When following some of these links, you must first select your browser version to see the specific instructions for changing your cookie settings

Internet Explorer: https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d (if you are still using Internet Explorer, we recommend switching to an up-to-date browser)
Edge: https://support.microsoft.com/en-gb/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
Firefox: https://support.mozilla.org/en-US/kb/trackers-and-scripts-firefox-blocks-enhanced-track
Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/12.0/mac/10.14 (via “Select version” you can request information for your operating system version)
Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Alternatively, the Digital Advertising Alliance provide information on cookies and settings at www.aboutads.info.

Do we use cookies from third parties?

We sometimes work with web partners who help us to make our web pages more interesting for you. For this purpose, when you access some of our pages online, cookies from our partner companies may also be stored in your device (Third-party Cookies). This section provides more information regarding the use of these kinds of cookies, their scope, and the data they collect.

We use some cookies or tools because they are necessary for us to provide you with our online services. In this case, the legal basis for the processing is the user agreement concluded with you (Art. 6 Para. 1 Letter b GDPR) or our legitimate interest, provided that no conflicting interests are discernible, and no contradiction exists (Art. 6 Para. 1 letter f GDPR). We use all other cookies exclusively on the basis of your consent (Art. 6 para. 1 letter a GDPR).

The third-party cookies used by us partially lead to data processing in the USA. In this case, too, we only use cookies with your consent (Art. 6 para. 1 letter a GDPR). The use of these providers from the USA is permitted under the EU Commission’s adequacy decision (Commission Implementing Decision (EU) 2023/1795 of 10 July 2023 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequacy of the level of protection of personal data under the EU-U.S. Data Protection Framework (pub-lished under file number C(2023) 4745)). These providers participate in the EU-U.S. Data Privacy Framework (DPF). The EU and the USA have concluded this agreement for the transfer of personal data from the EU and the EEA to organizations in the USA. To the extent that these US organizations participate in the DPF, the level of protection in the USA is considered adequate. Further information on participation in the EU-US data protection framework can be found on the website that the U.S. Department of Commerce has set up to implement the agreement: www.dataprivacyframework.gov.

Cookies Overview

Type of Cookie	Cookie Name	Tool/Vendor	Description	Storage Duration
Analytics & Statistics	_ga	Google Analytics	Used to distinguish users.	2 years
Analytics & Statistics	_ga_RF0YHETTG1	Google Analytics	Used for session state management.	2 years
Required Cookies	axeptio_all_vendors	Axeptio	Stores the full list of vendors for consent management.	1 year
Required Cookies	axeptio_authorized_vendors	Axeptio	Stores the user’s consent for specific vendors.	1 year
Required Cookies	axeptio_cookies	Axeptio	Stores the cookie consent choices and status.	1 year
Functional	wp-settings-4	WordPress	Stores user interface preferences (e.g., TinyMCE editor settings).	1 year
Functional	wp-settings-time-4	WordPress	Stores the time the wp-settings-4 was set to maintain UI preferences.	1 year
Functional	wp-wpml_current_language	WPML	Stores the selected language preference.	Session

Web analysis services

Google Analytics

We use online services provided by the web analysis service Google Analytics. Google Analytics is a service offered in the EU and EEA by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies that are stored on your computer to analyse the use of our online web presence.

The information collected by the cookie regarding your use of our online web presence (including your masked IP address) is transferred to and stored in a Google server in the USA. Google uses this information to evaluate the use of our website to prepare reports about the activities in our online presence and provide us with additional services associated with that use. The IP address provided by your browser as part of the Google Analytics service is not added to any other Google data.

We use Google Analytics in our online presence for web analysis purposes exclusively with an add-on that provides an “anonymise IP” function. This setting ensures that Google Analytics erases the last part of your IP address. This anonymisation of your IP address removes any direct trace of you personally. When using this feature, Google masks your IP address within the member states of the European Union or in other signatory states to the Agreement on the European Economic Area prior to transferring that information outside of the EU. The full IP address will only be sent to a Google server for masking in the USA in exceptional cases. In this way, we do not receive data that provides us with a way to identify you personally.

We also use the Universal Analytics function with Google Analytics. Universal Analytics allows us to analyse the use of our online services across devices (e.g. access via a laptop and then later from a tablet). As a user, you will be given a pseudonymous User ID on registration, when you access our site from another device. This is how the system recognises your User ID when you access our site from another device. We do not allocate any names to the User ID. We do not provide Google with any personal data. Privacy measures such as IP masking and Browser Add-ons are not restricted by the use of the Universal Analytics function.

You can prevent the installation of cookies using the settings in your browser software. You can also prevent the collection and processing of the data created by the use of cookies and related to your use of our online services (including your IP address) by Google by downloading and installing the browser plugin available at: https://support.google.com/analytics/answer/181881?hl=en

This will prevent all future collection of data by Google Analytics within our website. This opt-out cookie only works in this browser and only for this domain.

If you undertake any of the above cookie deactivation measures, you may not be able to use all the functions of our website to their full extent.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

For more information regarding how Google Analytics deals with user information, please refer to Google’s Privacy Statement: https://policies.google.com/privacy?hl=en

Retargeting / Remarketing / Referral Advertising

Facebook Custom Audience Pixels

We use a Custom Audience pixel provided by Facebook, a service provided by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland in the EU, the EEA, and Switzerland, as well as in the USA by Meta Platforms Inc., 1601 Willow Road, Menlo Park, California 94025. “Custom Audiences” refers to the creation of a “user-defined target group”. This is a piece of JavaScript code. JavaScript is a script language that evaluates user interaction in web browsers, apps, or other applications. The use of these pixels on our website allows us to mark and separate users for targeted messaging. This allows us to measure the success of our advertising campaigns, and to see who has clicked on an advertisement, and subsequently made a purchase. As soon as the retargeting pixel is loaded, it transfers anonymised data to Facebook regarding user behaviour, the pages accessed (URL) and any Facebook cookies that may be present. Tracking occurs via cookie, and not via pixel.

Facebook compares this data with all its registered users. If you are also registered to Facebook, Facebook will allocate this data to your Facebook User Profile. This data may be processed on servers in the USA. We have no influence over this data processing. The Facebook pixel collects the following data:

input into the browser (everything present in the web protocol, the “HTTP headers”), i.e., IP addresses, information about the web browser, the page location, the document, the sender, and the user
pixel-specific data, namely, the pixel ID and the Facebook cookie
button-click data, namely all buttons you have clicked as a visitor to the website, the names of those buttons, and all pages visited as a result of the button clicks
data to measure the success of an advertising campaign, namely, the conversion rate (clicks on displayed advertisements), type of page, purchase.
information pertaining to the purchase, such as email, address, amount

You can suppress or deactivate the JavaScript functions of the retargeting pixel in your web browser. You can change the settings for online-based advertising through Facebook yourself here: https://www.facebook.com/ads/settings

Pixels may only be used with your consent. We have concluded a contract with Facebook between our respective Controllers (Art. 26 GDPR). In it, we have committed ourselves to informing you accordingly.

Facebook only transfers user data to countries for which there is an adequacy decision by the European Commission in accordance with Art. 45 GDPR or on the basis of suitable guarantees in accordance with Art. 46 GDPR. Meta Platforms Inc. and all affiliated companies participate in the EU-US Data Privacy Framework: (https://www.dataprivacyframework.gov/).

We have concluded a joint controller agreement with Facebook (https://www.facebook.com/legal/terms/page_controller_addendum).

Google Ad Manager

Google Ad Manager is a platform for displaying all advertising formats. This service is operated in the EU, the EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4., Ireland and in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The Ad Manager uses cookies to show you advertising that may be relevant to you. It does this by assigning a pseudonymous identification number (ID) to your browser, to check which advertisements are being displayed in your browser, and which have been viewed. The cookies do not contain any personal information. The use of Ad Manager allows Google and its partner websites only to control the display of advertisements based on previous visits to our online product range or other websites on the internet.

Google Ad Manager allows us to design advertisements that are interactive, dynamic, and in a range of formats (e.g., video or individual), and to administer and evaluate them. Ad Manager cookies allow Google to recognise your browser. We receive the information that someone clicked on an advertisement and was sent to our site. For our part, we do not collect or process any personal data in those advertising measures. Google only provides us with statistical valuations on our campaigns. Using these valuations, we can see which of our advertising measures are the most successful. We do not receive any further data on the use of our advertising, and we are not able to identify the user on the basis of this information.

The information generated by the cookies is sent to a Google server in the USA and stored and used for evaluation. Google is only permitted to share this information with third parties when required by law or under the framework of a data processing commission. Google will not under any circumstances combine this data with other data collected by Google.

You can prevent Ad Manager from collecting data by:

You can prevent the installation of cookies using the settings in your browser software. More information is available at: https://support.google.com/ads/answer/7395996
You can also prevent the collection and processing of data by cookies by installing a browser plugin (https://support.google.com/ads/answer/7395996
You can also deactivate Google cookies on the Digital Advertising Alliance website at (http://optout.aboutads.info/?c=2#).

If you undertake any of the above cookie deactivation measures, you may not be able to use all the features of our website to their full extent.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

Google Tag Manager

We use Google Tag Manager in our online services for the purpose of providing a personalised, interesting, and locally relevant online advertising. This service is operated in the EU, the EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4., Ireland and in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Tag Manager allows us to administer website tags using a single interface. Although we use cookies for this, we do not collect any personal data. The Tag Manager was specially developed for retailers and is a system with which elements (tags) from Google and other providers can be marked and administered. In this way, data may be sent to cookies or other tools. Tags can be used for conversion tracking, web site analysis, and other purposes.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

More information on Google Tag Manager is available at: https://www.google.com/analytics/terms/tag-manager/

Further information and the Google Privacy Policy are available at: http://www.google.com/policies/technologies/ads/ and https://policies.google.com/privacy?gl=en&hl=en.

Google Ads Remarketing

Our online services use the Google Ads remarketing function, which allows to advertise our online services in Google search results and on third-party websites. This service is operated in the EU, the EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4., Ireland and in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We have embedded a pixel (a snippet of code, also known as a remarketing tag) in our online presence, which Google uses to set a cookie in the browser of your end device. This cookie allows us to show you advertising based on your interests. It does this by generating a pseudonymous cookie ID and analysing the website you have visited.

Further data processing only occurs if you have consented to Google linking your web and app browsing history with your Google account and using information from your Google account to personalise the advertisements you see on the internet. Information on the integration of user consent is available at: http://www.google.com/about/company/user-consent-policy.html

If you are logged into Google during a visit to our website, Google will use your data together with Google Analytics data to compile and define target group lists for cross-device remarketing. Google will temporarily link your personal data with data from Google Analytics to form target groups. More information is available at: https://policies.google.com/technologies/ads?hl=en und https://support.google.com/google-ads/answer/7664943?hl=en&ref_topic=3122875.

You can permanently deactivate cookies for interest-based advertising by downloading and installing the plugin for your browser available from https://support.google.com/ads/answer/7395996.

Alternatively, the Digital Advertising Alliance provide information on cookies and settings at www.aboutads.info. You can set your browser to inform you about the setting of cookies and whether you wish to accept cookies individually, or to accept specific kinds of cookies, or to disable all cookies. You can also set your browser to automatically delete cookies at the end of each session.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

Google Consent Mode

We use the Google Consent Mode. This is a service that is offered in the EU, EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland. In the USA, this service is offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (together “Google”).

Google Consent Mode introduces two new tag settings, namely: tags that trigger data transfer to Google when consent to advertising or analytics cookies has been given, and tags that prevent cookies when consent has been denied. Once you have given consent on a website, Google uses the consent mode to manage cookies from Google services for advertising and analysis purposes for all connected advertisers who use the global website tag or the Google Tag Manager. Consent mode is available in the following Google services: Google Tag Manager, Google Analytics, the Google Marketing Platform and Google Ads.

The purpose of the Google consent mode is that a technical interaction takes place between this mode and our cookie consent banner in order to obtain the consent of visitors to our website. We use Google Consent Mode v2 to respect users’ privacy choices and manage how Google services (like Analytics and Ads) behave based on consent. If you give your consent via our cookie consent banner for the Google services mentioned there, Google tags are loaded. Data will only be transmitted to Google on the basis of your consent. The consent status is transmitted to Google via the Google tags as “default status” or “updated status”. This status is retained on all websites that you visit or access after visiting our website. Once consent has been given, Google dynamically adjusts the behavior of its own tools (e.g. Analytics, Google Ads and third-party tags).

If you do not give your consent to the Google services, the Google tags are blocked and no data is transmitted to Google, not even the consent status. Instead, the consent status and user activity are sent to the Google server using tags by sending pings without cookies. Pings are used in Google products to model measurement values in the analysis tools used and thereby close gaps in data collection. Pings are used to request the consent status of other websites that you have visited and on which the Google consent mode is used. If you have given your consent in the cookie consent banner on one of these websites, the consent status for you also changes from “refused” to “granted” for our website. Pings with information on a conversion (information on purchases) can also be transmitted. Google collects the following data:

Function-related information (timestamp, user agent (only web – visit to our website), referrer URL (websites from which our website was accessed).

Summarized (aggregated), non-personal data: References to information about an ad click in the URL of a visited website.

Boolean information on consent status (mathematical algebraic structure that generalizes the properties of the logical operators AND, OR, NOT).

Random number generated each time a page is loaded.

Information about the consent management platform used by the website owner.

IP addresses are used to derive the IP country. However, they are not logged by Google Ads and Floodlight systems but are deleted immediately after collection. In Google Analytics, IP addresses are recorded as part of normal internet communication but can be masked here (https://support.google.com/analytics/answer/2763052).

We use the Google consent mode for the purpose of checking and optimizing the Google advertising systems we use. This involves assigning purchase processes to specific advertising campaigns in order to measure the success of the advertising campaigns. Insofar as this assignment is personalized, e.g. by assigning the purchases you have made to specific advertising campaigns, the legal basis for this is the consent you have expressly given. Consent is given via the cookie consent banner and is voluntary. You can withdraw your consent at any time with effect for the future. This does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

If you do not give your consent, the allocation of the visiting of a landing page to specific advertising campaigns will take place without the use of personal data. In this case, we measure the success of our advertising campaign without cookies or identifiers, using estimates and aggregated data on visiting a landing page. We can use this data, for example, to optimize our landing pages, advertising texts or advertising budgets in order to promote our campaigns. The legal basis for this is our legitimate interest in assigning purchase processes to specific advertising campaigns (so-called conversion modelling) and thus being able to measure the success of our advertising campaigns in order to continuously improve our offer (Art. 6 para. 1 letter f GDPR). We assume that your interest does not conflict with this because no personal or personally identifiable data is collected. You can object to such use of your data for the purpose of the aforementioned statistical analysis at any time by notifying us.

It cannot be ruled out that the aforementioned data will be transmitted to Google LLC in the USA. Google participates in the EU-US data privacy framework: https://www.dataprivacyframework.gov. We have concluded a contract with Google in accordance with the EU standard contractual clauses.

You can obtain further information about Google’s data protection provisions regarding Google Consent Mode at the following Internet address: https://support.google.com/google-ads/answer/10031513

Google Ads Conversion Tracking

Our online services use the online advertising program “Google Ads” and the conversion tracking it provides. Conversion tracking is a free tool from Google which measures interaction or transactions related to our advertising. For example, using the tool, we can evaluate whether users subscribe to our newsletter or how often clicks on our advertisements have led to activity on our website (e.g., registration). That way, we can identify which actions should be evaluated (i.e., conversions).

Technically, conversion tracking works via the conversion tracking code (the “tag”) integrated into our online services. Click rate data for our advertisements is collected using cookies.

Conversion tracking is set as a cookie when you, as a user, click on an advertisement displayed on Google. Normally, this cookie becomes invalid after 30 days, and is only used for anonymised identification. If you visit specific pages within our online presence as a user before the cookie becomes invalid, we and Google can tell that you originally clicked on an advertisement and were thus re-directed to our online services.

Google shares specific (customer specific) cookies with us as an Ads customer. As an Ads customer, we cannot track individuals using the cookies on our website. Instead, we receive statistical analyses from Google on the information that Google collected using the conversion cookies. This only tells us the number of users who clicked on our Ads advertisements and who were directed to our pages marked with conversion tracking tags. This statistical analysis does not contain any information that could identify you as an individual.

If you do not wish to participate in conversion tracking or wish to permanently disable personalisation cookies, you can use the settings in your internet browser. Alternatively, you can also download and install the plug-in for your browser available at: http://www.google.com/settings/ads/plugin?hl=en. Your user behaviour will then not be recorded in the conversion tracking statistics. Deactivating conversion tracking or cookies for personalised advertising may result however in limitations to the functioning of our online services.

Use of conversion tracking may result in Google processing your data on servers located in the USA.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

More information on Google’s privacy terms and conditions are available at: https://policies.google.com/privacy?hl-en-US

Other Tools and Services

Google Maps

This website uses Google Maps to display interactive maps and to provide directions. Google Maps is a mapping service operated in the EU and EEA by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). You will only be shown the embedded Google Map after you have given your consent (Art. 6 (1) (a) GDPR).

On our website you will first only see an initial box with a reference to Google Maps. No data is transferred to Google until you activate the box on the screen and agree to the use of Google Maps.

Activation of the use of Google Maps via our website may result in information being sent to Google in the USA for processing regarding the use of the website, including your IP address, device information (operating system), your location, and any start and destination information you input into the route planner function. Google may also pass on this information to third parties, insofar as this is legally permitted or where those third parties process the data for Google. We have no influence over the scope of data collected by Google in this way. We as a company do not collect any personal data in connection with the use of Google Maps.

The best of our knowledge, at least the following data is included:

data and time of the visit to our website
internet address or URL of website accessed
IP address,
location information
a start and destination location where the route planner is used.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

More information is available in the Google Privacy Policy at: https://policies.google.com/privacy?hl=en. Use of Google Maps is governed by the Terms of Use at https://policies.google.com/terms?hl=en&gl=en and the Terms and Conditions https://www.google.com/intl/en_en/help/terms_maps/.

Salesforce: Customer Journey

We use the “Journey Builder” app, which is part of the Marketing Cloud of the service provider Salesforce Canada Corporation, 10 Bay Street, Suite 400, Toronto, ON, M5J 2R8, Canada (hereinafter referred to as “Salesforce”) for the development of customer journeys and for customer journey mapping. Customer journey is a marketing term and describes the path of your interaction with our brands and products before you decide to make a purchase. All touchpoints between you and our brands and products are analyzed. A customer journey map is a visual representation of your interactions with our brands.

If you give us your consent, the Salesforce Customer Journey enables us to send you reminder emails if there are still products in your shopping cart, to suggest suitable accessories after you have purchased a certain product and to send you further information (e.g. in the form of videos) about your new product.

We have concluded a data processing agreement with Salesforce. Salesforce acts on our behalf strictly in accordance with our instructions.

The legal basis for this data processing is your consent (Art. 6 para. 1 letter a GDPR, § 25 para. 1 TTDSG). You can withdraw your consent at any time with effect for the future. The lawfulness of the processing carried out on the basis of the consent until revocation remains unaffected.

Data processing generally takes place on Salesforce servers in Canada. This data transfer is justified by the EU Commission’s adequacy decision for Canada. It cannot be ruled out that data may also be transferred to Salesforce, Inc. in the USA. Salesforce, Inc. participates in the EU-US data privacy framework: https://www.dataprivacyframework.gov/

In addition, Salesforce has binding internal data protection regulations or Binding Corporate Rules (BCR) in accordance with Art. 47 GDPR. Salesforce’s EU Binding Corporate Rules (“Salesforce EU Processor BCR”) were approved by the European data protection authorities in 2015 and the UK Binding Corporate Rules (“Salesforce UK Processor BCR”) were approved by the Information Commissioner’s Office (IOC) in 2023.

Users can find more information in the Salesforce privacy policy: https://www.salesforce.com/company/privacy/.

10. Use of your data for advertising purposes (product recommendations to existing customers/ newsletter subscription)

Recommending products to existing customers

If you have ordered products from us and provided your email address, we allow ourselves under the law to send you product recommendations for similar products which could be of interest to you, where you have not objected this use during the purchase process. This form of contact will only occur for the purpose of sending product recommendations via email to you as an existing customer. In this, we are pursuing our legitimate interest in sending personalised direct advertising to existing customers. This is consistent with our legitimate interest in direct advertising to existing customers under Art. 6 (1) (f) GDPR in conjunction with Section 7 (3) German Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb – UWG). If you have initially objected to this use of your email address, we will not send this information to you via email. You may withdraw your consent to the use of your email address to receive such messages from us at any time and with future effect. After receipt of your withdrawal of consent, we will cease the use of your email address for this purpose without delay.

Newsletter subscription

You can register for our email newsletter on our website. Our newsletter provides regular updates on new items, interesting offers and new promotions and campaigns. To receive our newsletter, you must only provide your email address. You may also choose to provide your name, to allow us to address you personally. We use the double opt-in process for our newsletter subscription. For this purpose, we will send you a confirmation email after we have received your consent to a newsletter subscription. In this email, we will ask you to confirm your subscription via a provided link. You will only receive our newsletter after this (second) activation of the service.

Consent to newsletter subscription

The address you provided for our newsletter subscription and any other data you provided such as your name will solely be used for the purposes of sending advertisements to you via electronic mail. This sending of electronic advertising is lawful pursuant to Art. 6 (1) (a) GDPR.

You can withdraw your consent to the use of your email to receive newsletters at any time with future effect by sending an email or using our online contact form, or the link provided in the email. After cancellation of this service, we will delete your email address without delay from our distribution list, unless you have expressly consented to another use of your data, or we reserve the right to use your data for lawful purposes and of which you have been informed appropriately.

Your declaration of consent will be recorded electronically for the purposes of verification. You can see your declarations of consent at any time online in your account. On registration for the newsletter, we also store the IP address provided by your Internet Service Provider (ISP) as well as the date and time of your subscription to trace any potential misuse of your email address at a later date.

If you have not consented to the newsletter subscription or withdrawn said consent, you will only receive electronic mail from us in connection with the processing of orders you have placed with us.

Service providers for sending electronic advertising

We use the Email Studio software, which is part of the Marketing Cloud of the service provider Salesforce Canada Corporation, 10 Bay Street, Suite 400, Toronto, ON, M5J 2R8, Canada(hereinafter referred to as “Salesforce”), to send the aforementioned product recommendations and newsletters by electronic mail. This service provider acts on our behalf strictly in accordance with our instructions and obtains knowledge of your email address and, if applicable, your name for this purpose.

We have concluded a data processing agreement with Salesforce. Data processing generally takes place on Salesforce servers in Canada. This data transfer is justified by the EU Commission’s adequacy decision for Canada. It cannot be ruled out that data may also be transferred to Salesforce, Inc. in the USA. This data transfer is permitted by the adequacy decision of the EU Commission for the USA. Salesforce, Inc. participates in the EU-US data privacy framework: https://www.dataprivacyframework.gov/

Further information on data processing in the Salesforce Marketing Cloud can be found here: https://help.salesforce.com/s/articleView?id=sf.mc_overview_data_protection_privacy.htm&type=5. You can view Salesforce’s privacy policy here https://www.salesforce.com/company/privacy/.

If you have given us your consent to receive newsletters and to evaluate the interaction with our newsletters (so-called conversion tracking) (Article 6 (1) (a) GDPR, Section 25 (1) TTDSG), Salesforce uses this information on our behalf to send and statistically evaluate the newsletters. For the evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. This enables us to determine whether you have opened a newsletter message, and which links you may have clicked on. With the help of conversion tracking, we can also analyze whether a certain action (e.g. the purchase of a product on our online pages), which we have determined in advance, has taken place after clicking on the link in the newsletter. In addition, we collect further technical information, namely the time of access, the shortened IP address, browser type and operating system. We only collect this technical data in pseudonymized form and do not link it to your personal data or your customer account. We therefore exclude the possibility of the data being directly linked to a person. We use this data exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses enable us to better adapt future newsletter offers to the interests of our customers.

The legal basis for this data processing is your consent (Art. 6 para. 1 letter a GDPR, § 25 TTDSG). You can withdraw your consent at any time with effect for the future. The lawfulness of the processing carried out on the basis of the consent until revocation remains unaffected.

We will store your email address, your name (if applicable) and the consent you have given for sending the newsletter and conversion tracking for the duration of the newsletter subscription or until you withdraw your consent (unsubscribe from the newsletter). Any other data collected in the course of sending the newsletter will be deleted after seven days.

Consent to newsletter tracking

In addition to sending newsletters, it is also possible to evaluate your interaction with the newsletter. This involves the evaluation of delivery, engagement and contact history. We gain insight into whether the newsletter was read/opened (including times of opening), clicks (including visits to our websites, links called up and other web interactions) and undeliverability processes. If you follow a link, we can clearly attribute it to you. The newsletter and contact IDs are logged in the newsletter tool we use. This enables us to create target group profiles and constantly improve the effectiveness of our newsletters.

In order to be able to analyze these interactions, a unique web beacon is integrated into each newsletter. Web beacons are a technique for carrying out the aforementioned analyses incon-spicuously (usually invisible to you). Our web beacons are small digital image files that are embedded in the e-mail newsletter. They are the size of a few pixels and can have the same color as the background or be transparent. As the recipient, you activate the web beacon by loading the images and thus start the analysis.

We only use this technology if you have given us your prior consent to tracking (Art. 7 GDPR). When you subscribe to the newsletter, we ask you separately for your consent to newsletter tracking. You can revoke this consent to newsletter tracking at any time with effect for the future by sending us an email or using our online contact form or the corresponding link in the newsletter. After such a cancellation, we will immediately tag your e-mail address in our newsletter distribution list so that no newsletter tracking takes place in the future.

However, you also have the option of preventing newsletter tracking to a certain extent: you can configure your email reading software to prevent access to remote images. Another option is to disconnect from the Internet before reading the newsletter after you have download-ed it. However, this requires that you use an e-mail reader on your computer and download all e-mails from the server to your own computer. The web beacons contained cannot then trigger any requests to the host server and tracking is prevented. If you delete the messages, the web beacons are also deleted, which means that they cannot perform any activities. It is also possible to filter out web beacons completely at server level.

We have set up the data processing in the newsletter tool we use in such a way that tracking of newsletter interaction is kept to a minimum.

11. Automated decision-making and profiling

We do not use automated decision-making. Profiling only takes place in the cases described in this privacy policy if you have given us your consent to do so. You may revoke your consent at any time with future effect. Processing of your data which occurred prior to the withdrawal of consent is not affected. No further profiling will take place.

12. Tools and Services we use

This will prevent all future collection of data by Google Analytics within our website. This opt-out cookie only works in this browser and only for this domain.

If you undertake any of the above cookie deactivation measures, you may not be able to use all the functions of our website to their full extent.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

For more information regarding how Google Analytics deals with user information, please refer to Google’s Privacy Statement: https://policies.google.com/privacy?hl=en

Google Ad Manager

You can prevent Ad Manager from collecting data by:

You can prevent the installation of cookies using the settings in your browser software. More information is available at: https://support.google.com/ads/answer/7395996
You can also prevent the collection and processing of data by cookies by installing a browser plugin (https://support.google.com/ads/answer/7395996
You can also deactivate Google cookies on the Digital Advertising Alliance website at (http://optout.aboutads.info/?c=2#).

If you undertake any of the above cookie deactivation measures, you may not be able to use all the features of our website to their full extent.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

Google Tag Manager

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

More information on Google Tag Manager is available at: https://www.google.com/analytics/terms/tag-manager/

Further information and the Google Privacy Policy are available at: http://www.google.com/policies/technologies/ads/ and https://policies.google.com/privacy?gl=en&hl=en.

Google Ads Remarketing

You can permanently deactivate cookies for interest-based advertising by downloading and installing the plugin for your browser available from https://support.google.com/ads/answer/7395996.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

Use of Google Ads Conversion Tracking

Technically, conversion tracking works via the conversion tracking code (the “tag”) integrated into our online services. Click rate data for our advertisements is collected using cookies.

Conversion tracking is set as a cookie when you, as a user, click on an advertisement displayed on Google. Normally, this cookie becomes invalid after 30 days and is only used for anonymised identification. If you visit specific pages within our online presence as a user before the cookie becomes invalid, we and Google can tell that you originally clicked on an advertisement and were thus re-directed to our online services.

Use of conversion tracking may result in Google processing your data on servers located in the USA.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses.

More information on Google’s privacy terms and conditions are available at: https://policies.google.com/privacy?hl-en-US

Salesforce: Customer Journey

We have concluded a data processing agreement with Salesforce. Salesforce acts on our behalf strictly in accordance with our instructions.

Users can find more information in the Salesforce privacy policy: https://www.salesforce.com/company/privacy/.

13. Integration of social media

On our website we refer to our accounts in social networks. The use of these providers from the USA is permitted on the basis of the EU Commission’s adequacy decision. The providers referred to by us participate in the EU-U.S. Data Privacy Framework (DPF). The EU and the USA have concluded this agreement for the transfer of personal data from the EU and the EEA to organizations in the USA. Insofar as these US organizations participate in the DPF, the level of protection in the USA is deemed adequate. Further information on participation in the EU-US data privacy framework can be found on the website that the U.S. Department of Commerce has set up to implement the agreement: www.dataprivacyframework.gov.

Integration of YouTube videos

We have integrated YouTube videos into our website that can be played on YouTube directly from our website. This uses the “expanded privacy mode” which only allows YouTube access to your data when you play the video. The transmission of your data to YouTube will therefore only take place with your consent (Art. 6 para. 1 letter a GDPR).

YouTube is a service operated in the EU, the EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4., Ireland and in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

We have used the privacy-enhanced mode to integrate YouTube videos into our site. Opening one of our pages which include YouTube videos, and clicking on a video, does not result in your data being provided to Google. Your consent will be sought before such data provision takes place, using the consent declaration that we have provided.

Once you have given your consent, or if you have browsed to a video on YouTube itself (e.g., in our YouTube channel), your data may be sent to a Google server in the USA and stored there. Google uses this data to evaluate your use of our videos on YouTube, to create anonymised reports about the videos watched and to offer video-use related services to us.

Google participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov/

We have concluded a contract with Google in accordance with the EU’s standard contractual clauses. More information on YouTube’s processing of data can be found here: https://www.youtube.com/t/terms_dataprocessing

More information on data protection for the Google service “YouTube” is available in the provider’s Privacy Statement at: https://policies.google.com/privacy?hl=en&gl=en

Social media presence and use of social media icons on our website

We do not use social plug-ins as active buttons on our website. We only use icons to refer to our presence in the following social networks:

Facebook: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland;
Instagram: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland;
Twitter / X: International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland;
Pinterest: Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland;
YouTube: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

We only display the social media icons on our website, and they are not activated. To ensure your privacy, we have implemented a solution which only sends the address of our servers to these services and not your IP address should you click and activate a social media plug-in.

If you click on an icon on our website, this indicates your consent to connect with these third parties via a separate tab in your browser and allows these third parties to follow your visit to our website. If you are a member of a social network, you can share the content of our website with other members of that social media network by clicking the button.

Your data may be processed outside of the EU if you are a member of a social network or when you visit or access one of our social media accounts. This may carry risks, for example, by making it harder for you to enforce your rights.

When you access a social work, cookies are generally set to collect data on your user behaviour which is then stored in your end device. As long as you have a user account on any network, and are logged in, your user behaviour can be saved to your user account. The social networks may use this user behaviour information for market research and advertising purposes. This may result in your being advertisements both inside and outside of your social networks. We have no influence over this.

We have no influence over the personal data collected and stored by social networks. We receive evaluations of user behaviour from the social media sites listed above and may use this to send relevant advertising to users. If users interact with our social media accounts and are logged into a user account, we can also recognise the user profile and see the content of comments or postings on our website. The processing of this data is carried out in joint responsibility with the provider of the social network in question. We have concluded an agreement with the individual providers of our social media pages on joint responsibility for the evaluation of data collected in connection with our social media pages (Art. 26 GDPR). In it, we have committed ourselves to providing you with this privacy information. More information is available from the privacy policies of the individual social networks. You may also exercise the rights to which you are entitled against us. However, as the social network provider stores and evaluates your data, they are able to more comprehensively fulfil your rights.

Instagram

We operate a social media presence on Instagram, which we use to present photographs and posts related to our company, provide information on our services, and to communicate with customers. When using and accessing our Instagram account, your user data is processed by both the Ireland based company, Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin, as well as the USA based Meta Platforms Inc., 1601 Willow Road, Menlo Park, California 94025 (hereinafter referred to as “Facebook”). Facebook uses Instagram to enable a system (among other things) that distributes advertising across its network.

We analyse all access and interactions on our Instagram account. Facebook creates user profiles for this purpose but only provides us with anonymised data in this regard. This involves aggregate data which provides us with insights of how users interact with our Instagram account. The resulting statistics are only provided to us in anonymised form. We have no access to the underlying data. We process your data in conjunction with Facebook to provide this insight service. For this reason, we have concluded an agreement with Facebook between our respective Controllers.

Our Instagram account can be accessed whether or not you have an Instagram user account. We only process personal data when you interact with our Instagram account, e.g. if you leave a comment, click a Like button or send us a message. We do not provide this data to third parties. The Instagram Terms of Use are available at: https://help.instagram.com/519522125107875

This use is lawful pursuant to either your consent (Art. 6 (1) (a) GDPR) or due to our legitimate interest in providing tailored marketing to our customers (Art. 6 (1) (f) GDPR). Instagram users may withdraw consent on publishing their comment or Like at any time with future effect by deleting the comment or content in question. The legality of any processing that has occurred prior to the revocation of that consent remains unaffected.

Facebook offers you the opportunity to object to certain data processing; the relevant information and possibilities to opt-out can be found at https://www.facebook.com/policies/cookies/ and for registered users at https://www.facebook.com/settings?tab=ads.

Instagram users can influence the extent to which their user behaviour may be recorded on our Instagram account at https://www.facebook.com/help/109378269482053. Alternatively, the relevant settings can be changed at https://www.facebook.com/settings and https://www.instagram.com/accounts/login/?next=/accounts/privacy_and_security/ or you can reject the processing of your data at: https://www.facebook.com/help/contact/367438723733209.

You can also use the settings in your browser to prevent the processing your data using Facebook cookies.

Facebook only transfers user data to countries which have been granted an Adequacy Deci-sion by the European Commission pursuant to Art. 45 GDPR or based on guarantees offered pursuant to Art. 46 GDPR. Meta Platforms Inc. and all its affiliated companies participate in the EU-US Data Privacy Framework (https://www.dataprivacyframework.gov/).

Facebook

In addition to our company website, we also have a Facebook page (“Fanpage”). We use this page to introduce our company, provide information on our products and services, and to communicate with customers and interested parties.

We only process personal data when you interact with our Facebook page, e.g. if you leave a comment, click a Like button or send us a message. This use is lawful pursuant to either your consent (Art. 6 (1) (a) GDPR) or due to our legitimate interest in providing tailored marketing to our customers (Art. 6 (1) (f) GDPR). This includes for example, showing our current range, you send us a query in relation to a contract, or if you like or comment on one of our posts, or if you upload content to our Facebook page.

We analyse all access and interactions on our Facebook page. Facebook creates user profiles for this purpose but only provides us with anonymised data in this regard. This involves aggregate data which provides us with insights of how users interact with our Facebook page.

When using and accessing our Facebook page, your personal data is processed by both the Ireland based company, Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin, as well as the USA based Meta Platforms Inc., 1601 Willow Road, Menlo Park, California 94025 (hereinafter referred to as “Facebook”). In addition to the processing described above, Facebook processes your personal data for analysis and advertising purposes, including personalised advertising. To the extent of our knowledge, Facebook also uses cookies that are stored in your end device (also across end devices). This allows Facebook to use targeted advertising within its own platform, as well as on third-party sites. Facebook creates identifiable user profiles on the basis of valid consent pursuant to Art. 6 (1) (a) GDPR. For more information, see the Facebook privacy policy: https://www.facebook.com/about/privacy/.

You may revoke your consent at any time with future effect. The legality of any processing that has occurred prior to the revocation of your consent remains unaffected. You may delete a comment or uploaded material yourself at any time.

We operate a social media presence on Pinterest, which we use to present pins (photographs, links, and text) provide information on our services, and to communicate with customers. Pinterest is a service operated in the EU by Pinterest Europe Ldt., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland, in the USA by Pinterest Inc., 505 Brannan Street, Suite 900, San Francisco, CA 94107, USA (hereinafter referred to as “Pinterest”). Pinterest also offers a system for distributing advertising on Pinterest at https://ads.pinterest.com/.

We analyse all access and interactions on our Pinterest page. Pinterest creates user profiles for this purpose but only provides us with anonymised data in this regard under https://analytics.pinterest.com/, known as Audience Insights. This involves aggregate data which provides us with insights of how users interact with our Pinterest page. The resulting statistics are only provided to us in anonymised form. We have no access to the underlying data. We process your data in conjunction with Pinterest to provide this Audience Insights service. For this reason, we have concluded an agreement between our respective Controllers.

Our Pinterest page can be accessed whether or not you have a Pinterest user account. We only process personal data when you interact with our Pinterest page, e.g. if you leave a comment, click a Like button, re-pin our pin, or send us a message. We do not provide these data to third parties. The Pinterest data protection provisions apply: https://policy.pinterest.com/privacy-policy.

Within the EU, this data processing is lawful as per your consent (Art. 6 (1) (a) GDPR). Pin-terest users may withdraw consent on publishing their comment, Like, or pin at any time with future effect by deleting the comment or content in question. The legality of any processing that has occurred prior to the revocation of that consent remains unaffected.

Pinterest offers you the opportunity to object to certain data processing; the relevant infor-mation and possibilities to opt-out can be found at https://www.pinterest.com/settings/privacy/

Pinterest users can influence the extent to which their user behaviour on our Pinterest page may be recorded at https://www.pinterest.com/settings/privacy/.

You can also use the settings in your browser to prevent the processing of your data using Pinterest cookies.

Twitter

We maintain a social media presence on twitter, which we use to present photographs and posts related to our company, provide information on our services, and to communicate with customers. When using and accessing our Twitter page, user data is also processed by the Irish-based company International Unlimited Company, One Cumberland Place, Fenian Street, Dublin (hereinafter referred to as “Twitter / X”) and X Corp. based in the USA, 1355 Market Street, Suite 900, San Francisco, CA 94103.

Twitter also offers a system for distributing advertising on Twitter at https://ads.twitter.com/.

We analyse all access and interactions on our Twitter page. Twitter creates user profiles for this purpose but only provides us with anonymised data under https://analytics.twitter.com/. This involves aggregate data which provides us with insights of how users interact with our Twitter page. The resulting statistics are only provided to us in anonymised form. We have no access to the underlying data. We process your data in conjunction with Twitter to provide this insight service. For this reason, we have concluded an agreement between our respective Controllers.

Our Twitter page can be accessed whether or not you have a Twitter user account. We only process personal data when you interact with our Twitter page, e.g. if you leave a comment, click a Like button or send us a message. We do not provide these data to third parties. More information on privacy and data protection at Twitter: https://twitter.com/privacy.

Within the EU, this data processing is lawful as per your consent (Art. 6 (1) (a) GDPR). Twitter users may withdraw consent for publishing their comment or Like at any time with future effect by deleting the comment or content in question. The legality of any processing that has occurred prior to the revocation of that consent remains unaffected.

Twitter offers you the opportunity to object to certain data processing; the relevant information and possibilities to opt-out can be found at https://twitter.com/personalization.

Twitter users can influence the extent to which their user behaviour may be recorded on our Twitter page at https://twitter.com/personalization. You can also personalise the relevant settings.

You can also use the settings in your browser to prevent the processing of your data using Twitter cookies.

Twitter participates in the EU-US Data Privacy Framework: https://www.dataprivacyframework.gov.

We have concluded a contract with Twitter / X Corp. in accordance with the standard data protection clauses of the EU.

14. Your rights as a data subject as enforceable in the EU

Please read the following information about your rights as a data subject regarding the processing of your personal data.

The right of access

You have the right to request a confirmation whether your personal data is being processed. Should this be the case, you have the right to be informed of the personal data that has been collected, stored or processed, as well as to the following information:

the processing purpose,
the recipients or categories of recipients to whom this data has been disclosed or will be disclosed,
if possible, the intended duration of storage of your personal data or if this is not possible the criteria for determining that duration,
your additional rights (see below),
if the personal data has not been collected from you, all available information regarding its source,
the existence of automated decision-making, including profiling, and where existent, further relevant information.

You have the right to be informed of the appropriate safeguards available pursuant to Art. 46 GDPR against the transfer of your data to a third country or international organisation.

The right to rectification

You have the right to request the correction without delay of incorrect or incomplete personal data.

Right to erasure (right to be forgotten)

You have the right to request that we delete the personal data concerning you without delay. We are obliged to delete your personal data without delay where one of the following grounds applies:

Your personal data are no longer required for the purpose for which they were collected or otherwise processed.
You are withdrawing your consent and there are no other legal grounds for processing that data.
You are filing an objection (see below) to the data processing.
Your personal data were unlawfully processed.
The deletion of your personal data is necessary to fulfil an obligation under EU law or the law of the Member States.
A child has provided consent to the collection of personal data.

Right to restriction of processing:

You have the right to request a restriction of our data processing when one of the following conditions is met:

you are contesting the accuracy of the personal data,
the data processing is unlawful, but you do not agree to the deletion of the personal data, instead requesting a restriction of its use,
we no longer need the personal data for the purposes of processing, but you need the data to establish, exercise or defend legal claims; or
you have objected to processing (see below) and it is not yet clear whether our legitimate interest will prevail.

Right to notification

If you have exercised your right to rectification, erasure or restriction of processing against us, we are obliged to inform all recipients to whom personal data concerning you has been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed of those recipients.

Right to data portability

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without interference on our part provided that:

the processing is based on consent granted 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 our using automated methods.

In exercising this right, you may request that personal data related to you be transferred directly from us to another controller insofar as this is technically feasible and does not infringe on the freedoms and rights of any other person. The right to data portability does not apply to the processing of personal data required for fulfilling a task carried out in the public interest or in the exercise of an official authority invested in the controller.

Right to object

You have the right, based on grounds relating to your particular personal situation to object at any time to the processing of your personal data, unless it is based on one of the following grounds:

the processing of your personal data by us is required for the fulfilment of a task that lies in the public interest or in the exercise of public authority that has been delegated to us; or
the processing is necessary to safeguard our legitimate interest or the legitimate interest of a third-party, in so far as your interests or basic rights require that protection of your personal data prevail.

The right to object also applies to profiling based on these processes.

If the personal data that concerns you is being processed for direct marketing purposes, you have the right to object to the processing of your personal data for such marketing purposes. This also applies to profiling insofar as it is associated with such direct marketing.

You also have the right, on grounds arising from your particular personal situation to object to the processing of your personal data undertaken by us for scientific or historical research purposes or for statistical purposes, unless such processing is necessary for the performance of a task in the public interest.

Right to withdraw consent and data protection law

You may revoke your consent at any time with future effect. The revocation may be simply sent to us at any time, e.g., an informal email. Processing of your data which occurred prior to the withdrawal of consent is not affected.

Right of appeal to the supervisory authority

Do you think that the processing of your personal data was illegal? Then you have the right to lodge a complaint with a supervisory authority, particularly in your country of residence or country of work, or at the location the alleged breach took place. If you are in doubt, contact the agency responsible for us at Marit Hansen, ULD – Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein, (E-Mail: mail@datenschutzzentrum.de, Holstenstraße 98, 24103 Kiel, telephone: 0431 988-1200, fax: 0431 988-1223). Other administrative or judicial remedies are not affected by the exercise of these rights.

Recruitment Notice

About this Notice

This Recruitment Privacy Notice (“Notice”) explains how HAGEN GROUP (“HAGEN GROUP”, “we” and “our”) collects, uses, and discloses any information that, alone or in combination with other information, in relation to individuals (“Personal Information”) who apply for a job on our website (“Applicants”, “you” and “your”).

This Notice also sets out the rights that you have in relation to the Personal Information that we have about you and how you can exercise them.

HAGEN GROUP treats the protection of your privacy seriously. This is why we have developed this Notice, which describes the standards that HAGEN GROUP applies to protect Personal Information.

For the purposes of this Notice, HAGEN GROUP headquartered at 20500 aut. Transcanadienne Baie-D’Urfė (Quėbec) H9X 0A2, Canada, is the data controller for the Applicant’s Personal Information. As a data controller, HAGEN GROUP is responsible for ensuring that the processing of Personal Information complies with applicable privacy laws.

Please take the time to read this Notice carefully. If you have any questions or comments, please contact at data_priv@rchagen.com

What Personal Information does HAGEN GROUP collect and why?

The types of Personal Information that we may collect about you, and the reasons why we process it, include:

Types of Personal

Information

Why we collect it

Legal basis

Retention

period

Name

Surname

E-mail address

Home address

Phone number

Curriculum Vitae

Information about whether you are legally authorized to work in

Canada/US/E-U

City, State, Country

Education details

Work History

To enable you to contact us or enable us to respond and provide feedback in the context of recruitment.

To evaluate and select job applicants including for example setting up and conducting interviews.

To evaluate and assess the results thereto and as is otherwise needed in the recruitment process including the final recruitment.

To communicate with you during the

recruitment process.

To put in place necessary arrangements for future employment

Contractual necessity to carry out recruitment, manage the hiring process, and improve our hiring process.

Two (2) years following our last contact with you.

Bank account details

To reimburse any expenses incurred by you during the recruitment process (e.g. traveling).

Contractual necessity to facilitate the recruitment process for all Applicants and your legitimate interest to obtain reimbursement for any expenses incurred during recruitment process.

For the time needed to process the reimbursement and then this data is deleted.

We may collect information regarding your gender, racial or ethnic origin and sexual orientation to ensure that our candidates are representative of the population, to the extent permitted by applicable laws. We may also have knowledge of some sensitive data (e.g. religion) if you voluntarily provide it to us in your CV.

If we ask you to provide any other Personal Information not described above, then the Personal Information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect that Personal Information.

Who does HAGEN GROUP share your Personal Information with?

We may disclose your Personal Information to the following categories of recipients:

-to our group companies for purposes consistent with this Notice. We take precautions to allow access to your Personal Information only to those of our employees who have a legitimate business need for access and with a contractual prohibition of using the Personal Information for any other purpose.

-to our third-party vendors, services providers and partners who provide data processing services to us, or who otherwise process Personal Information for purposes that are described in this Notice or notified to you when we collect your Personal Information. This may include disclosures to third party vendors and other service providers we use in connection with the services they provide to us, including to support us in areas such as managing résumé/CV information, IT platform management or support services, infrastructure and application services, data analytics. Our third-party vendors, services providers and partners include, without limitation: PwC, SmartRecruiters, LinkedIn.

-to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

-to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Information for any other purpose.

-to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Information only for the purposes disclosed in this Notice.

-to any other person if you have provided your prior consent to the disclosure.

How we protect your privacy

We will handle Personal Information in accordance with the following principles:

(a) Accountability: An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.

(b) Identifying Purposes: The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.

(c) Consent: The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except when inappropriate.

(d) Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

(e) Limiting Use, Disclosure and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfilment of those purposes.

(f) Accuracy: Personal information shall be as accurate, complete and up to date as is necessary for the purposes for which it is to be used.

(g) Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

(h) Openness: An organization shall make readily available to individuals’ specific information about its policies and practices relating to the management of personal information.

(i) Individual Access: Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

(j) Challenging Compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.

Data storage, retention and deletion

The Personal Information we collect from you is stored in our servers located in Canada.

We retain Personal Information for as long as necessary to fulfil our contractual and legal obligations (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When it is no longer necessary to retain your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

If you are not retained following the recruitment process, HAGEN GROUP will keep your application form on file for future job openings no longer than two years. If you are successful and offered a job at HAGEN GROUP, your Personal Information will be used to complete your hiring process by our HR department.

Transfers of Personal Information

Your Personal Information may be transferred to, and processed in, countries/provinces other than the country/province in which you are a resident. These countries/provinces may have privacy laws that are different to the laws applicable in your place of residence.

Site hosting is provided by SiteGround (https://world.siteground.com/).

Specifically, our Website servers are located in Iowa, USA, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your Personal Information, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Policy. We only transfer or make your Personal Information available to other entities of the HAGEN GROUP group or to our third-party services providers in third countries/provinces where such transfer is necessary for the performance of a contract between you and HAGEN GROUP or the implementation of pre-contractual measures.

Your privacy rights

You have the following privacy rights:

If you wish to request access, correction, update or deletion of your Personal Information, you can do so at any time by contacting us. Please note that requests are subject to certain limitations, for example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

If you have a complaint or concern about how we are processing your Personal Information, then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a privacy authority about our collection and use of your Personal Information.

Updates to this Notice

We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Notice changes if and where this is required by applicable privacy laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Notice.

How to contact us

Or write to:

Rolf C. Hagen Inc.,

20500 Trans-Canada Hwy

Baie d’Urfé, Québec

H9X 0A2

Canada

If you are from the EU or the EEA, the following applies:

-This company is the Controller for the processing of data on our online service pursuant to the General Data Protection Regulation (GDPR).

-Our EU representative pursuant to Art. 27 GDPR is: Kaschae Datenschutz & Compliance GmbH, An der Alster 62, 20099 Hamburg, mail@kaschae.de

Contact information for our company Data Protection Officer (DPO): datenschutzbeauftragter@rchagen.com

Manage Cookies

Privacy Policy

www.hagen.com

1. Basic Information

2. Who we are (Controller for Data Privacy)

3. Data collection when accessing our online services

4. Contact

5. Hyperlinks and Third Parties

10. Use of your data for advertising purposes (product recommendations to existing customers/ newsletter subscription)

Recommending products to existing customers

Newsletter subscription

Consent to newsletter subscription

Service providers for sending electronic advertising

Consent to newsletter tracking

11. Automated decision-making and profiling

12. Tools and Services we use

13. Integration of social media

Integration of YouTube videos

Social media presence and use of social media icons on our website

Instagram

Facebook

Pinterest

Twitter

14. Your rights as a data subject as enforceable in the EU

The right of access

The right to rectification

Right to erasure (right to be forgotten)

Right to restriction of processing:

Right to notification

Right to data portability

Right to object

Right to withdraw consent and data protection law

Right of appeal to the supervisory authority

About Us

Careers

Our Brands

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