Privacy Staement (last updated: 11/05/2018) Effective as of: 25/05/2018

1. Data protection in our company
We are highly committed to the protection of your personal data. We value your privacy. We process your personal data for the purposes stated below in accordance with the applicable statutory data protection requirements. Personal data for the purposes of this data protection information are all data relating to your person. Relevant personal data are in particular your personal details (e.g. name, address, contact data, date of birth), your billing data, advertising and sales data (i.e. findings derived from customer data analyses). You can visit and search our website www.etu-software.com at any time without disclosing any personal data. However, we will save the IP address that you have transmitted to us.

2. Data controller and contact details
The controller responsible for the processing of your personal data is

Herr Karl Heinz Hottgenroth
ETU Software GmbH
ISO 9001 certified
Von Hünefeld-Straße 3
50829 Köln
Phone: +49 221 70993300
Fax: +49 221 70993301
Internet: www.etu-software.com

3. Purposes for which your data are collected and processed, and their legal bases
3a. Execution of contract
ETU Software GmbH processes your personal data to fulfil the contract concluded with you. The specific processing depends on the products and services that you procure from ETU Software GmbH. It includes in particular invoicing the contractually agreed services, the dispatch of invoices and if necessary dunning notes, as well as communications with you. The legal basis for the data processing described above is the fulfilment and execution of the contract. Without this data processing, we are not able to execute and fulfil the contract. For the purposes of contractual fulfilment, e.g. invoicing, processing of payments and dispatching of letters and goods, we transmit your personal data and your billing data to third parties and processors (e.g. shipping and collection agents).

3b. Advertising
ETU Software GmbH uses your name and address to provide you with product information on our product range. To provide you with product information on goods or services from ETU Software GmbH that are similar to those that you have obtained or procured as an existing customer of ETU Software GmbH, ETU Software GmbH also uses the email address provided by you, unless you have objected to its use. To send advertising to you, we transmit, where appropriate, your name and address to third parties and processors (e.g. shipping agents).
This processing of your aforementioned data is necessary to pursue the legitimate interests of ETU Software GmbH and is justified by a balancing of interests to the benefit of ETU Software GmbH. Without the use of these data, ETU Software GmbH is not able to display any direct marketing to you. Furthermore, ETU Software GmbH pursues a legitimate interest in processing your data as part of direct marketing to provide you with customised offers from ETU Software GmbH, namely to promote the sale of its own products. Your legitimate interest in not having your aforementioned data used for this purpose does not prevail over this legitimate interest of ETU Software GmbH, since ETU Software GmbH uses these data in a manner appropriate for the described processing purpose and, moreover, does not use any sensitive data derived from the customer relationship between ETU Software GmbH and you. The use of your data for advertising is, moreover, a type of processing, which you should expect as part of existing contractual relations or after the expression of interest in the products or services of ETU Software GmbH in the form of offers or services or even based on the undisputed receipt of direct marketing information over a lengthy period of time; hence, this direct marketing is not presumed to be a nuisance. In addition, ETU Software GmbH uses your aforementioned data for direct marketing for products of ETU Software GmbH only if you have not objected to this use.
ETU Software GmbH also ensures the least intrusive disruption for you through the selection of communication channels for advertising (post or email).
ETU Software GmbH uses your data for any promotional contacts other than by post only based on the consent you have expressed by agreeing to this Privacy Policy.

3c. Advertising for and through third parties
As part of promotional contacts by ETU Software GmbH, ETU Software GmbH also uses your name and address to be able to provide you with product information about products and services of third parties (e.g. entities of the Hottgenroth Group, business partners which offer similar products).
This processing is justified by the prevailing interests of ETU Software GmbH. As outlined above, ETU Software GmbH has a legitimate interest in providing you with direct marketing. This also includes direct marketing for products and services from third parties. Firstly, your interest in the products or third parties can be enhanced by the transmission of advertising by third parties in conjunction with advertising from ETU Software GmbH, which leads to an increased turnover for ETU Software GmbH and for the third party.
Secondly, ETU Software GmbH has a financial interest in providing third parties with this opportunity to share advertising. As in the case of direct marketing for products by ETU Software GmbH, your interest in not having your data used for these thirdparty marketing purposes is subordinate, in particular in the light of the low level of nuisance caused by postal and email advertising and your right to object to this use of your data.
Based on your consent to this Privacy Policy, third parties (corporate entities of the Hottgenroth Group) will also directly offer you their own products and services. In this case, ETU Software GmbH discloses your data covered by this consent (e.g. your contact data) to third parties to allow them to send you information about complementary products.

3d. Information collected by the website
On some pages of www.etu-software.com, e.g. in the contact form, you are requested to voluntarily provide us with personal data. As a rule, this information is requested if you are interested in information in connection with our company.
Cookies are small bits of information saved on the hard drive of your computer. We use cookies to be able to provide you with a more personalised service. Most internet browsers accept cookies automatically, but you can also change the settings of your browser if you do not want to save the information for later use. We only save cookies on our webpages with your prior consent. The personal data which you provide voluntarily are used to process your request, to discharge your order and to maintain our relationships with customers or prospective customers. To this end it may be necessary to transmit your personal data to business partners of www.etu-software.com, which have confirmed their compliance with the General Data Protection Regulation to us.
Privacy Policy for the use of Facebook plugins
Plugins of the Facebook social network, 1601 South California Avenue, Palo Alto, CA 94304, USA, are integrated in our website. Facebook plugins are identified by the Facebook logo or the ‘Like’ button on our webpage. For an overview of the Facebook plugins, please see: http://developers.facebook.com/docs/plugins/. If you visit our website, a direct connection will be established between your browser and the Facebook server through the plugin. As a result, Facebook obtains the information that you visited our web page with your IP address. If you click on the ‘Like’ button while logged into your Facebook account, you can link the content of our website with your Facebook profile. Thus, Facebook is able to associate the visit to our website with your user account.
We would like to make you aware that we as providers of the website do not obtain any information about the content of the transmitted data or of their user from Facebook. For further information in this regard, please see Facebook’s Privacy Policy: http://de-de.facebook.com/policy.php. If you do not want Facebook to be able to associate your visit to our website with your Facebook user account, please log out from your Facebook user account.
Privacy Policy for the use of Google plugins
Plugins of the Google Inc. network, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States integrated in our website. Google plugins are identified by the Google logo or the Google+1 button on our website. For an overview of the Google plugins, please see: https://policies.google.com/privacy?hl=en&fg=1#intro. If you visit our website, a direct connection will be established between your browser and the Google server through the plugin. As a result, Google obtains the information that you visited our website with your IP address. If you click on the Google button while logged into your Google account, you can link the content of our website with your Google profile. Thus, Google is able to associate the visit to our website with your user account. We would like to make you aware that we as providers of the website do not obtain any information about the content of the transmitted data or of their user from Google.
For further information in this regard, please see the Google Privacy Policy: https://policies.google.com/privacy?hl=en&fg=1#intro.
If you do not want Google to be able to associate your visit with our website with your Google user account, please log out from your Google user account.

3e. Other purposes
If any other purposes for the use of your data arise in addition to these existing purposes, we will check if these other purposes are compatible with the original collection purposes and are thus consistent with such use. If this is not the case, ETU Software GmbH will inform you about such a change of purpose. If no other legal basis exists for the further use of the data, ETU Software GmbH will not use your data without your consent.

4. Recipient of your personal data
Your personal data are also used by other companies which act on behalf of ETU Software GmbH (‘processors’) or as part of business partnerships with ETU Software GmbH (‘third parties’).
These may be either corporate entities of the Hottgenroth Group (e.g. ETU Software GmbH, ETU Nord GmbH, TACOS GmbH, Hottscan GmbH) or external companies and partners (‘ETU Software GmbH partner’). Potential recipients of your data are billing service providers, mailing service providers, collection agencies, shipping service providers, social media companies, IT service providers, consultants or consulting firms, as well as other service and cooperation partners. For further details, please see the descriptions of data processing in paras. 3a – 3d.

5. Data storage and deletion
Apart from the exceptions stated below, we will delete your sensitive personal data when the contractual relationship with you has ended, when all mutual claims have been satisfied and no other statutory retention obligations or statutory justifications for storing the data apply. We will continue to use your name and postal address after the contractual relationship has ended. This processing is justified by the legitimate pursuit of our interests. We have a legitimate interest in persuading you to use our products and services again through advertisingbased reacquisition attempts. In line with the pursuit of our legitimate interests through direct marketing in the course of our business relations, our interests also prevail in regard to the use of your data for this post-contractual advertising purpose. By raising an objection, you are able to prevent this processing at any time. ETU Software GmbH uses these data appropriately in accordance with the indicated processing purpose and does not use any sensitive data from your customer relations with ETU Software GmbH.
By accepting this Privacy Policy and with your declaration of consent, you agree to be contacted for promotional purposes by email or telephone. We use your personal data for promotional contacts for a period of not more than 12 months after the granting of your consent, irrespective of the duration of the contractual relationship. Subsequent use beyond this period will only take place if you do not object to being contacted for promotional purposes.

6. Your rights
6a. Information, rectification, deletion, etc.
We will gladly inform you as to whether and which personal data concerning you we have saved, and if applicable, to whom we have transmitted these data. In accordance with statutory provisions, you can also exercise the following additional rights: rectification, deletion, restriction of processing (blocking for certain purposes).

6b. Right to object
You have the right to object at any time to the processing of your data for advertising purposes. If we process data based on a balancing of interests, as described in detail in this Privacy Policy (see paras. 3b to 3d and para. 5), you have the right to object at any time to this processing for reasons relating to your specific situation. Such reasons apply in particular if they accord special significance to your interests, thus causing them to prevail over the interests of ETU Software GmbH; this applies in particular if these reasons are not known to ETU Software GmbH and have thus not been taken into account by the latter in pursuit of its interests.

6c. Right of withdrawal
Once you have consented to the processing of your personal data, you can inform us at any time that you withdraw your consent. A withdrawal does not affect the lawfulness of the processing of your data prior to the withdrawal.

6d. Questions or complaints
If you have any questions or wish to lodge a complaint, you have the right to contact the State Commissioner for Data Protection - Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Postfach 20 04 44, 40102 Düsseldorf.

6e. Right to data portability
You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format. You are entitled to transmit these data to another data controller. You are entitled to have the data transmitted directly from us to another data controller, where technically feasible. To exercise the rights stipulated in paras. 6a. to 6e., you can contact ETU Software GmbH, using any of the contact details provided in para. 2.