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This privacy policy sets out how ERP Recycling uses and protects any information that you give us when you use this website.
Privacy Policy
Data protection and the security of your personal data are important to us and we implement appropriate technical and organisational measures to protect personal data that is subject to our access.
We, the Controller, (also referred to as “[Controller]”; “we”; “us”; or “our”), would like to inform you below about the type and extent of the processing of personal data when you visit and use our website.
This Policy also contains information about your data protection rights, including a right to object to some of the processing which Landbell carries out. More information about your rights, and how to exercise them, is set out in the “Your Rights” section.
1. Controller (the responsible person)
ERP SAS
62 Rue St Lazare
75009 Paris
France
Telephone: +33 (0)1 71 32 39 40
E-mail: info@erp-recycling.org; dataprivacy@landbellgroup.com
If you have any questions regarding data protection, or want to exercise one of your rights (see clause 5 hereafter) or to lodge a complaint, our data protection officer (DPO) will be happy to assist you: datenschutz@landbell.de
2. Data we collect and process via this website, the purposes of processing and legal bases
Only by using our website
Your visit to our website will be logged. Initially, the following automatic logging data, which your browser transmits to us, is mainly recorded:
- the IP address currently used by your PC or router
- date and time of request (including Time zone difference to Greenwich Mean Time (GMT))
- browser type, version and language
- operating system of your PC
- the pages you are viewing
- Access status/HTTP status code
- name and size of the requested file(s)
- and, if applicable, the URL of the referring web page.
This data is only collected for data security purposes, to improve our website and for error analysis. As we pursue our legitimate business interests when processing your personal data for these purposes, we rely based on Art. 6 par. 1 lit f) GDPR for doing this.
If you are submitting any job applications
Please refer to the Applicants Privacy Notice available here.
If you are using our Contact Form
Personal data (e.g. your name, address data or contact data) that you voluntarily provide to us, e.g. in the context of an enquiry by e-mail to the contact persons named on our homepage, are stored with us and processed only for correspondence with you and only for the purpose for which you have made these data available to us. Therefore, we may use your information to provide products and services you have requested, if any, (Art. 6 par. 1 lit. b) GDPR). We may also process your data for responding to any comments or complaints you may send us or send you information on products and services provided by us, our affiliates and carefully selected partners. As all this is required by us to conduct our business and pursue our legitimate interest, we base the respective processing’s on Art. 6 par. 1 lit f) GDPR. In respect to the sending of direct marketing communication, you have the right to object to such processing. Please find further information on this right in the “Your rights” section below.
If you give us your consent, we may process your data based on Art 6 par. 1 lit a) GDPR for performing direct marketing via email or telephone in relation to our relevant products and services, or other products and services provided by us or our affiliates.
If you are registering on our website
You can register on our website to use additional features on the site. We only use the data entered for the purpose of using the respective offer or service for which you have registered. The mandatory information requested during registration is marked with an asterisk under the data field and must be given in full. Otherwise, we will reject the registration. For important changes, such as the scope of the offer or for technical changes, we use the e-mail address specified during registration to inform you in this way. The processing of the data entered during registration takes place based on Art. 6 par. 1 lit. f) GDPR, as the processing is necessary for pursuing our legitimate business interest in providing the additional services available for our registered users.
If you are subscribing to our Newsletter
We offer you the possibility to subscribe to our newsletter via our homepage. We will only send you our newsletter if you consent us to do so, the respective data processing is based on Art. 6 par. 1 a) GDPR. To subscribe we need at least your e-mail address. To ensure that the Newsletter was requested by you or from your e-mail address, you will first receive a confirmation e-mail. Only when you click on the activation link will you be added to our e-mail distribution list and receive the newsletter. The subscription to the newsletter is logged for verification purposes (IP address, date, time). You can unsubscribe from the newsletter at any time by contacting us directly or by notifying us using the link at the end of each newsletter.
Google Analytics
We use Google Analytics on our website. This is a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
The Google Analytics service is used to analyze how our website is used. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.
Usage and user-related information, such as IP address, place, time, or frequency of your visits to our website will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function, whereby Google truncates the IP address within the EU or the EEA before it is transmitted to the US.
The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. This data can also be used to provide other services related to the use of our website and of the internet in general.
Google states that it will not connect your IP address to other data. In addition, Google provides further information with regard to its data protection practices at
https://www.google.com/intl/de/policies/privacy/partners,
including options you can exercise to prevent such use of your data.
In addition, Google offers an opt-out add-on at
https://tools.google.com/dlpage/gaoptout?hl=en
in addition with further information. This add-on can be installed on the most popular browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs Google Analytics’ JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services we may use as detailed herein.
Google reCAPTCHA
Our website uses Google reCAPTCHA to check and prevent automated servers (“bots”) from accessing and interacting with our website. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
This service allows Google to determine from which website your request has been sent and from which IP address the reCAPTCHA input box has been used. In addition to your IP address, Google may collect other information necessary to provide and guarantee this service.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the security of our website and in the prevention of unwanted, automated access in the form of spam or similar.
Google offers detailed information at
https://policies.google.com/privacy
concerning the general handling of your user data.
Google Fonts
Our website uses Google Fonts to display external fonts. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
To enable the display of certain fonts on our website, a connection to the Google server in the USA is established whenever our website is accessed.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the optimization and economic operation of our site.
When you access our site, a connection to Google is established from which Google can identify the site from which your request has been sent and to which IP address the fonts are being transmitted for display.
Google offers detailed information at
https://adssettings.google.com/authenticated
https://policies.google.com/privacy
on options for preventing the use of data.
Facebook plug-in
Our website uses the plug-in of the Facebook social network. Facebook.com is a service provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. In the EU, this service is also operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, hereinafter both referred to as “Facebook.”
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
Facebook guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in improving the quality of our website.
Further information about the possible plug-ins and their respective functions is available from Facebook at
https://developers.facebook.com/docs/plugins/
If the plug-in is stored on one of the pages you visit on our website, your browser will download an icon for the plug-in from Facebook’s servers in the USA. For technical reasons, it is necessary for Facebook to process your IP address. In addition, the date and time of your visit to our website will also be recorded.
If you are logged in to Facebook while visiting one of our plugged-in websites, the information collected by the plug-in from your specific visit will be recognized by Facebook. The information collected may then be assigned to your personal account at Facebook. If, for example, you use the Facebook Like button, this information will be stored in your Facebook account and published on the Facebook platform. If you want to prevent this, you must either log out of Facebook before visiting our website or use an add-on for your browser to prevent the Facebook plug-in from loading.
Further information about the collection and use of data as well as your rights and protection options in Facebook’s privacy policy found at
https://www.facebook.com/policy.php
Google+ plug-in
We use the plug-in of the Google+ social network on our website. Google+ is an online service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in improving the quality of our website.
Further information about the possible plug-ins and their respective functions is available from Google at
https://developers.google.com/+/web/
If the plug-in is stored on one of the pages you visit on our website, your browser will download an icon for the plug-in from Google’s servers in the USA. For technical reasons, it is necessary for Google to process your IP address. In addition, the date and time of your visit to our website will also be recorded.
If you are logged in to Google while visiting one of our plugged-in websites, the information collected by the plug-in from your specific visit will be recognized by Google. The information collected may then be assigned to your personal account at Google. If, for example, you use the +1 button, this information will be stored in your Google Account and may be published on the Google platform. To prevent this, you must either log out of Google before visiting our site or make the appropriate settings in your Google account.
Further information about the collection and use of data as well as your rights and protection options in Google’s privacy policy found at
https://policies.google.com/privacy
Twitter plug-in
Our website uses the plug-in of the Twitter social network. The Twitter service is operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”).
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active
Twitter guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in improving the quality of our website.
If the plug-in is stored on one of the pages you visit on our website, your browser will download an icon for the plug-in from Twitter’s servers in the USA. For technical reasons, it is necessary for Twitter to process your IP address. In addition, the date and time of your visit to our website will also be recorded.
If you are logged in to Twitter while visiting one of our plugged-in websites, the information collected by the plug-in from your specific visit will be recognized by Twitter. The information collected may then be assigned to your personal account at Twitter. If, for example, you use the Twitter Tweet button, this information will be stored in your Twitter account and may be published on the Twitter platform. To prevent this, you must either log out of Twitter before visiting our site or make the appropriate settings in your Twitter account.
Further information about the collection and use of data as well as your rights and protection options in Twitter’s privacy policy found at
YouTube
We use YouTube on our website. This is a video portal operated by YouTube LLC, 901 Cherry Ave, 94066 San Bruno, CA, USA, hereinafter referred to as “YouTube”.
YouTube is a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter referred to as “Google”.
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google and its subsidiary YouTube guarantee that they will follow the EU’s data protection regulations when processing data in the United States.
We use YouTube in its advanced privacy mode to show you videos. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in improving the quality of our website. According to YouTube, the advanced privacy mode means that the data specified below will only be transmitted to the YouTube server if you start a video.
Without this mode, a connection to the YouTube server in the USA will be established as soon as you access any of our webpages on which a YouTube video is embedded.
This connection is required in order to be able to display the respective video on our website within your browser. YouTube will record and process at a minimum your IP address, the date and time the video was displayed, as well as the website you visited. In addition, a connection to the DoubleClick advertising network of Google is established.
If you are logged in to YouTube when you access our site, YouTube will assign the connection information to your YouTube account. To prevent this, you must either log out of YouTube before visiting our site or make the appropriate settings in your YouTube account.
For the purpose of functionality and analysis of usage behavior, YouTube permanently stores cookies on your device via your browser. If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Further details can be found in the section about cookies above.
Further information about the collection and use of data as well as your rights and protection options in Google’s privacy policy found at
https://policies.google.com/privacy
Vimeo
We use Vimeo to display videos on our website. This is a service of Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA, hereinafter referred to as “Vimeo.”
Some of the user data is processed on Vimeo servers in the USA. Through certification according to the EU-US Privacy Shield
(https://www.privacyshield.gov/participant?id=a2zt00000008V77AAE&status=Active)
Vimeo guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
The legal basis for collecting and processing this information is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in improving the quality of our website.
When you access a page on our website that has Vimeo embedded in it, a connection to Vimeo’s servers in the USA is established. For technical reasons, it is necessary for Vimeo to process your IP address. In addition, the date and time of your visit to our website will also be recorded.
If you are logged into Vimeo while visiting one of our webpages containing a Vimeo video, Vimeo will associate information about your interaction with our site to your Vimeo account. If you wish to prevent this, you must either log out of Vimeo before visiting our website or configure your Vimeo user account accordingly.
For the purpose of functionality and usage analysis, Vimeo uses Google Analytics. Google Analytics stores cookies on your terminal device via your browser and transmits information about the use of those websites in which a Vimeo video is embedded to Google. It is possible that Google will process this information in the USA.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Further details can be found in the section about cookies above.
The legal basis for collecting and processing this information is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in improving the quality of our website and in Vimeo’s legitimate interest in statistically analyzing user behavior for optimization and marketing purposes.
Vimeo offers further information about its data collection and processing as well your rights and your options for protecting your privacy at this link:
Google AdWords with Conversion Tracking
Our website uses Google AdWords and conversion tracking. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
We use conversion tracking to provide targeted promotion of our site. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.
If you click on an ad placed by Google, the conversion tracking we use stores a cookie on your device. These so-called conversion cookies expire after 30 days and do not otherwise identify you personally.
If the cookie is still valid and you visit a specific page of our website, both we and Google can evaluate that you clicked on one of our ads placed on Google and that you were then forwarded to our website.
The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. In addition, we receive information about the number of users who clicked on our advertisement(s) as well as about the pages on our site that are subsequently visited. Neither we nor third parties who also use Google AdWords will be able to identify you from this conversion tracking.
You can also prevent or restrict the installation of cookies by making the appropriate settings in your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support.
In addition, Google provides further information about its data protection practices at
https://services.google.com/sitestats/de.html
http://www.google.com/policies/technologies/ads/
http://www.google.de/policies/privacy/
information on how you can prevent the use of your data.
Google Remarketing
We use the remarketing function on our website. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).
Through certification according to the EU-US Privacy Shield
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google guarantees that it will follow the EU’s data protection regulations when processing data in the United States.
We use this feature to deliver interest-based, personalized advertising on third-party websites that also participate in Google’s advertising network.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.
To allow this advertising service to function, Google stores a cookie with a sequence of numbers on your device via your browser when you visit our website. This cookie records both your visit and the use of our website in anonymous form. However, personal data will not be passed on. If you subsequently visit a third-party website that also uses the Google advertising network, advertising may appear that refers to our website or our offers there.
To permanently disable this feature, Google provides a browser plugin for most common browsers at
https://www.google.com/settings/ads/plugin?hl=de
Likewise, the use of cookies from certain providers, e.g. via
http://www.youronlinechoices.com/uk/your-ad-choices/
or
http://www.networkadvertising.org/choices/
can be deactivated by opt-out.
Cross-device marketing allows Google to track your usage patterns across multiple devices, so you may see interest-based, personalized advertising even when you switch devices. However, this requires that you have agreed to link your browsing history to your existing Google account.
Google offers more information about Google Remarketing at
http://www.google.com/privacy/ads/
3. Cookies
We also use so-called cookies in our internet offer (which may also be provided by third parties). Cookies are small text files that are saved by your browser and stored on your computer. The use of cookies serves to make the website more user-friendly. For example, it is possible to recognize the user for the duration of the session without having to constantly enter a new user name and password. The cookies do not cause any damage to your computer and are generally deleted at the end of your session, unless they are so called permanent cookies.
To find out more about the different kinds of cookies we use, the legal bases we rely in such use and the different ways you can deactivate cookies, please refer to our Cookie Policy.
4. Recipients of personal data
Your personal data may be shared with other entities of the Landbell Group when insofar as answering your question or providing you the service you requested requires the involvement of other group entities. Except from the Landbell Group, we will only be passed on to third parties if it is necessary for the execution of a contract and/or its technical processing, which regarding the website, includes our suppliers in charge of processing your data for the dispatch of the newsletter and for the hosting and maintenance of our website. When we subcontract such activities, we make sure your data is managed in compliance with the GDPR rules and this includes, where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, that data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield (https://www.privacyshield.gov/welcome) certification or a vendor’s Processor Binding Corporate Rules.
5. Your rights
According to Art. 15-21 GDPR you can assert the following rights about the personal data processed by us if the conditions described there are met.
5.1 Right to access (Art. 15 GDPR). You have the right to be informed about the personal data concerning you that is processed by us and be provided with a copy of your personal data we hold about you.
5.2 Right to rectification (Art. 16 GDPR). You may request the rectification of inaccurate personal data, or to complete personal data when it is incomplete.
5.3 Right to erasure (Art. 17 GDPR). You may be entitled to ask for the deletion of personal data concerning you, if one of the following reasons exists:
- Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
- You revoke your consent on which the processing of your data is based.
- You have asserted a right to object to the processing and there are no overriding legitimate grounds for the processing, or you asserted your right to object where your personal data is processed for direct marketing purposes.
- Your data has been processed unlawfully.
However, the right to deletion does not exist if this conflicts with the legitimate interests of the responsible party. These could be e.g.:
- if personal data is required to assert, exercise or defend legal claims.
- if deletion is not possible due to storage obligations.
If data cannot be deleted, however, there may be a right to restrict processing (see below).
5.4 Right to restriction of processing (Art. 18 GDPR). You have the right to request us to restrict the processing of your personal data under following circumstances:
- you contest the accuracy of your personal data and we therefore verify the accuracy of your personal data for a period,
- the processing is unlawful, and you oppose the erasure of your personal data and instead request the restriction of their use,
- we no longer need the data, but you do need it to establish, exercise or defend legal claims,
- you have objected to the processing of your data pursuant to Art. 21 par. 1 GDPR and it is not yet clear whether our legitimate grounds override those of yours.
5.5 Right to data portability (Art. 20 GDPR). You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controller without our interference, provided that the processing is based on your consent (e.g. Art. 6 par. 1 lit a) GDPR)) or a contract (Art. 6 par. 1 lit b) GDPR) and the processing is carried out by us with the help of automated means.
5.6 Right to object (Art. 21 GDPR). You have the right to object at any time to the processing of personal data relating to you based on Art. 6 par. 1 e) or f) GDPR for reasons arising from his situation, including profiling based on those provisions. Where your personal data is processed for direct marketing purposes without your consent and based on our legitimate interests, you have the absolute right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing (Art. 21 par. 2 GDPR). The respective personal data will no longer be processed for direct marketing purposes then.
5.7 Right to revoke consent (Art. 7 par. 3 GDPR). If you have consented to the processing of your personal data by us, you have the right to revoke your consent at any time. The legality of processing your personal data before revocation remains unaffected. We may further process such data pursuant to another applicable legal basis, e.g. for the fulfilment of our legal obligations.
5.8 Right to lodge a complaint with a supervisory authority (Art. 77 GDPR). If you have not received an answer after a reasonable period of time from the DPO, or have received an answer which is incomplete or unsatisfactory in your view, you shall have the right to lodge a complaint with a supervisory authority, in accordance with Art. 77 GDPR, if you consider that the processing of personal data relating to you infringes the GDPR. Such complaint may be lodged with the supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement.
Questions and how to assert your rights. If you have any questions regarding data protection, or want to exercise one of your rights or to lodge a complaint we will be happy to assist you: dataprivacy@landbellgroup.com
6. Standard periods for the deletion of data
6.1 If a legal regulation for the retention of data does not exist, the data will be deleted or destroyed if they are no longer necessary to achieve the above described purposes of data processing’s. Different periods apply to the storage of personal data, for instance due to tax law or according to some commercial law regulations. Finally, the storage period can also be based on the statutory limitation periods according to the respective applicable national laws.
6.2 The data collected during registration will be stored by us if you are registered on our website and will subsequently be deleted 3 years after this, beginning with end of the respective year.
6.3 Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
6.4 Where we process personal data for site security purposes, we retain it for 12 months.
6.5 Where we process personal data in connection with performing a contract, we keep the data as required according to the statutory retention period.
7. Changes to this Data Privacy Statement
We reserve the right to modify and amend this Privacy Policy from time to time to reflect current circumstances. We therefore recommend that you review this Privacy Policy / Data Privacy Statement regularly to keep up to date. Where required by law, we may also inform you about modifications/amendments of this Privacy Policy. This Data Privacy Statement was last updated on April 2, 2019.
