Privacy Policy

PRIVACY POLICY

The protection of your personal data is of the utmost importance to us. We therefore operate our website in compliance with the applicable laws on data protection and data security.
 

1. Contact Details of the Controller

The controllers within the meaning of the General Data Protection Regulation (GDPR), other national data protection laws of the Member States and other applicable data protection provisions are:

Hetzel Horses GmbH
Buschstrasse 21
47574 Goch
Germany

Hetzel Trading GmbH
Buschstraße 21
47574 Goch
Germany

No Data Protection Officer has been appointed by the controllers, as this is not required under the applicable legal provisions.

2. General Information on Data Processing

We process our users’ personal data insofar as this is necessary to provide a functional website as well as our content and services.

In addition, we process data (e.g. name, address, date of birth, bank details, payment history) relating to our customers, prospective customers and business partners for the purpose of providing contractual services, customer service and customer care, marketing, advertising and market research.

2.1 Legal Basis for the Processing of Personal Data

Where we obtain the consent of the data subject for the processing of personal data, Article 6(1)(a) GDPR serves as the legal basis.

Where the processing of personal data is necessary for the performance of a contract to which the data subject is party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations necessary in order to take steps prior to entering into a contract.

Where processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, and where such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Article 6(1)(f) GDPR serves as the legal basis for the processing.

2.2 Erasure of Data and Storage Period

The personal data of the data subject will be erased or blocked as soon as the purpose for which they were stored no longer applies.

Data may be stored for a longer period if this is provided for by European or national legislators in EU regulations, laws or other provisions to which the controller is subject.

Data will also be blocked or erased when a storage period prescribed by the aforementioned provisions expires, unless further storage of the data is necessary for the conclusion or performance of a contract.

3. Provision of the Website and Creation of Log Files

Each time our website is accessed, our system automatically collects data and information from the computer system of the device accessing the website.

The following data are collected:

  1. Information about the browser type and version used
  2. The user’s operating system
  3. The user’s internet service provider
  4. The user’s IP address, i.e. the hostname of the accessing computer
  5. Date and time of access
  6. Websites from which the user’s system accesses our website
  7. Websites accessed by the user’s system via our website

These data are also stored in our system’s log files. These data are not stored together with other personal data relating to the user.

3.1 Legal Basis for Data Processing

The legal basis for the temporary storage of the data and log files is Article 6(1)(f) GDPR.

3.2 Purpose of Data Processing

Temporary storage of the IP address by the system is necessary in order to deliver the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

The data are stored in log files to ensure the functionality of the website. In addition, the data help us to ensure the security of our information technology systems.

The data are not evaluated for marketing purposes in this context.

These purposes also constitute our legitimate interest in data processing pursuant to Article 6(1)(f) GDPR.

3.3 Storage Period

The data will be erased as soon as they are no longer required for the purpose for which they were collected.

Server log files are automatically erased seven days after the website is accessed.

4. Use of Cookies

Our website uses cookies. Cookies are text files that are stored in or by the internet browser on the user’s computer system.

When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is accessed again.

We store the following information:

  1. Login information
  2. Session ID
  3. The website the user last visited

4.1 Legal Basis for Data Processing

The legal basis for the processing of personal data using cookies is Article 6(1)(f) GDPR.

4.2 Purpose of Data Processing

The purpose of using technically necessary cookies is to make websites easier for users to use. Some functions of our website cannot be provided without the use of cookies. For these functions, the browser must be recognised even after the user changes pages.

4.3 Storage Period, Right to Object and Removal Options

Cookies are stored on the user’s computer and transmitted from there to our website. Users therefore have control over the use of cookies.

By changing the settings in their internet browser, users can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically.

If cookies are disabled for our website, it may no longer be possible to use all functions of the website to their full extent.

5. Website Analysis Using Google Analytics

5.1 Description

We use Google Analytics (Google Analytics, Google Tag Manager, Optimize, etc.), i.e. web analytics services provided by Google Inc. (“Google”).

These services are provided by:

Google Ireland Limited
Gordon House
Barrow Street
Dublin 4
Ireland

Google has undertaken to comply with the EU-US Privacy Shield Framework published by the US Department of Commerce regarding the collection, use and storage of personal data from EU Member States.

Google, including Google Inc. and its wholly owned subsidiaries in the United States, has certified that it complies with the relevant Privacy Shield principles.

However, the transfer of your data to the United States cannot be ruled out.

Google uses cookies. The information generated by the cookie regarding users’ use of the online service is generally transmitted to and stored on a Google server in the United States.

Google will use this information on our behalf to evaluate users’ use of our online services, compile reports on activities within these online services and provide us with other services relating to the use of these online services and the internet.

Pseudonymous user profiles may be created from the data processed.

For further information, please refer to Google’s Privacy Policy.

5.2 Legal Basis

The legal basis for the processing of users’ personal data is Article 6(1)(f) GDPR.

5.3 Purpose of Data Processing

This information is used to automatically recognise users when they next visit our websites and to facilitate navigation.

Cookies enable us, for example, to tailor a website to users’ interests or save their password so that they do not have to enter it each time.

Users can, of course, also view our websites without cookies.

The processing of users’ personal data enables us to analyse their browsing behaviour. By evaluating the data obtained, we are able to compile information regarding the use of the individual components of our website.

This helps us to continuously improve our website and its user-friendliness.

By pseudonymising the IP address, users’ interests in the protection of their personal data are adequately taken into account.

5.4 Storage Period

The data will be erased as soon as they are no longer required for our recording purposes.

5.5 Right to Object and Removal Options

Users can prevent cookies from being stored by selecting the appropriate settings in their browser software.

Users can also prevent Google from collecting the data generated by the cookie relating to their use of the online service and from processing these data by downloading and installing the browser plug-in available from Google.

Google Analytics can be disabled in the browser versions Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari and Opera.

Users can also prevent tracking (opt-out) using the corresponding Google Analytics opt-out function.

6. Integration of Social Media

6.1 Facebook

This website uses social plugins (“plugins”) from the social network Facebook, operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).

The plugins can be recognised by one of the Facebook logos (a white “f” on a blue tile, the terms “Like” or “Gefällt mir”, or a “thumbs up” symbol) or are identified by the wording “Facebook Social Plugin”.

When a user accesses a page of this website containing such a plugin, the user’s browser establishes a direct connection to Facebook’s servers. The content of the plugin is transmitted directly by Facebook to the user’s browser and integrated into the website.

(1) Legal Basis

The legal basis for the processing of users’ personal data is Article 6(1)(f) GDPR.

(2) Collection, Processing and Storage of Data by Facebook and Users’ Rights

We have no influence over the scope of the data collected by Facebook through these plugins and therefore inform users according to our current level of knowledge:

By integrating the plugins, Facebook receives information that a user has accessed the corresponding page of the website.

If the user is logged into Facebook, Facebook may associate the visit with the user’s Facebook account.

If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted directly from their browser to Facebook and stored there.

Even if a user is not a Facebook member, Facebook may still obtain and store the user’s IP address. According to Facebook, only an anonymised IP address is stored in Germany.

Users can find information regarding the purpose and scope of data collection and the further processing and use of data by Facebook, as well as their rights and settings options for protecting their privacy, in Facebook’s privacy information.

We have no influence over the duration for which Facebook stores these data.

If a user is a Facebook member and does not want Facebook to collect data about them via this website and link these data to their Facebook membership data, the user must log out of Facebook before visiting our website.

Further settings and objections regarding the use of data for advertising purposes can be made within the Facebook profile settings.

6.2 YouTube

Our website uses YouTube buttons.

YouTube is operated by YouTube LLC, headquartered at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc., headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

When users visit a page of our online service that contains a YouTube button, a connection to YouTube’s servers is established. The YouTube server is informed which specific page of our website the user has visited.

If the user is logged into their YouTube account, YouTube may associate their browsing behaviour directly with their personal profile. Users can prevent this by logging out beforehand.

Further information regarding data collection and use is available from YouTube.

(1) Legal Basis

The legal basis for the processing of users’ personal data is Article 6(1)(f) GDPR.

(2) Collection, Processing and Storage of Data by YouTube and Users’ Rights

When a user accesses a page of this website containing a YouTube button, the user’s browser establishes a direct connection to YouTube’s servers.

The content of the YouTube buttons is transmitted directly by YouTube to the user’s browser.

The provider therefore has no influence over the scope of the data collected by YouTube through this plugin and provides users with information according to its current level of knowledge.

The duration of storage is not known to us.

If users do not want YouTube to directly associate the data collected via our website with their YouTube account, they must log out of YouTube before visiting our website.

7. Leaflet Maps

Leaflet is a JavaScript library developed by CloudMade for displaying maps on websites.

Leaflet is a modern open-source JavaScript library for creating interactive web maps and is also optimised for mobile applications.

Despite its small size, it contains all essential functionality required to create online maps.

Leaflet was developed to create simple, high-performance and efficient applications. The library can be used with all major desktop and mobile platforms and takes advantage of HTML5 and CSS3.

Leaflet can be extended using various plugins and has extensive documentation.

Leaflet does not collect or transmit personal data.

8. Online Auctions

On our websites, we offer users the opportunity to participate in online auctions organised by Hetzel Trading GmbH.

For the registration required for this purpose and for processing purchases, personal data are collected, including first name, surname, email address, date of birth, address and telephone number.

Passwords provided by users are stored in encrypted form. All connections are encrypted via SSD.

8.1 Legal Basis for Data Processing

Where the user has given consent, the legal basis for processing the data is Article 6(1) GDPR and Recital 47.

8.2 Purpose of Data Processing

Personal data are collected for participation in the auctions. These data are used, in the event of a successful bid, to inform the bidder, organise the provision of the auctioned horse and process payment and, where applicable, transport of the horse.

Upon registration, you select an individual username that allows you to place bids and follow the development of the bidding process.

During registration, you may be asked to provide additional information.

Answering questions marked as “voluntary” enables us to simplify the auction process and facilitate the processing of a purchase, unless you have consented to additional use of the data.

Providing this information is entirely voluntary.

8.3 Storage Period

We store personal registration data until registered users request deletion of their registration, unless statutory retention obligations prevent us from doing so (for example, if you have participated in online auctions).

To cancel your registration, please send an email to info@holger-hetzel.de.

8.4 Right to Withdraw Consent and Removal Options

Until the online auction has ended, participants may withdraw their consent to storage pursuant to Article 21(2) to (4) GDPR at any time by sending an email to info@holger-hetzel.de, thereby withdrawing from participation in the auction.

9. Contact by Email

You can contact us using the email address provided on our website or via a contact form, where available.

If you contact us via the contact form, your first name, surname and email address will in all cases be transmitted to us. The user’s IP address and the date and time will also be stored.

As part of the submission process, your consent to the processing of the data will be obtained and reference will be made to this Privacy Policy.

If you contact us by email, your email address and your message will be transmitted to us and stored.

9.1 Legal Basis for Data Processing

Where the user has given consent, the legal basis for processing the data is Article 6(1)(a) GDPR.

The legal basis for processing data transmitted in the course of sending an email is Article 6(1)(f) GDPR.

If the purpose of the email contact is to conclude a contract, Article 6(1)(b) GDPR additionally serves as the legal basis for processing.

9.2 Purpose of Data Processing

Personal data entered into the contact form are processed solely for the purpose of handling the enquiry.

In the event of contact by email, this also constitutes the necessary legitimate interest in processing the data.

9.3 Storage Period

The data will be erased once your enquiry has been dealt with and answered, unless the enquiry has resulted in a contractual relationship.

9.4 Right to Object and Removal Options

Users may withdraw their consent to the processing of personal data at any time.

Consent may be withdrawn by sending an email to info@holger-hetzel.de.

All personal data stored in connection with the contact will be erased if you request this by email.

10. Advertising

Our advertising partners are listed on our website under the “Partners” section.

10.1 Legal Basis for the Processing of Personal Data

Where the user has given consent, the legal basis for processing the data is Article 6(1) GDPR.

10.2 Purpose of Data Processing

When an advertisement is commissioned, all personal data necessary for the commercial processing of the advertising order are collected.

10.3 Storage Period, Right to Object and Removal Options

The duration of storage and the options available to advertising partners to object to processing and have data removed are set out in the privacy policies forming part of the respective agreements.

11. Rights of the Data Subject

If your personal data are processed, you are a data subject within the meaning of the GDPR and have the following rights vis-à-vis us as the controller:

11.1 Right of Access

You may request confirmation from the controller as to whether personal data concerning you are being processed by us.

Where such processing takes place, you may request the following information from the controller:

  1. the purposes for which the personal data are processed;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  4. the envisaged period for which the personal data concerning you will be stored or, if specific information is not possible, the criteria used to determine that period;
  5. the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
  6. the existence of a right to lodge a complaint with a supervisory authority;
  7. any available information as to the source of the data where the personal data are not collected from the data subject;
  8. the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) GDPR and, at least in such cases, meaningful information regarding the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

You have the right to request information as to whether personal data concerning you are transferred to a third country or to an international organisation.

In this context, you may request to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

11.2 Right to Rectification

You have the right to obtain rectification and/or completion from the controller if the personal data concerning you that are being processed are inaccurate or incomplete.

The controller must carry out the rectification without undue delay.

11.3 Right to Erasure

You may request that the controller erase personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay where one of the following grounds applies:

  • The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • You withdraw your consent on which the processing is based pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR and there is no other legal ground for the processing.
  • You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.
  • The personal data concerning you have been unlawfully processed.
  • The personal data concerning you must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject.
  • The personal data concerning you have been collected in relation to the offer of information society services pursuant to Article 8(1) GDPR.

Where the controller has made the personal data concerning you public and is obliged pursuant to Article 17(1) GDPR to erase them, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that you, as the data subject, have requested the erasure of any links to, or copies or replications of, those personal data.

The right to erasure shall not apply to the extent that processing is necessary:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, insofar as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  • for the establishment, exercise or defence of legal claims.

11.4 Right to Restriction of Processing

You may request restriction of the processing of personal data concerning you where one of the following conditions applies:

  • you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defence of legal claims; or
  • you have objected to processing pursuant to Article 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.

Where processing of personal data concerning you has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or a Member State.

If processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction of processing is lifted.

11.5 Right to Notification

If you have exercised your right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to communicate such rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort.

You have the right to be informed by the controller about those recipients.

11.6 Right to Data Portability

You have the right to receive the personal data concerning you which you have provided to the controller in a structured, commonly used and machine-readable format.

You also have the right to transmit those data to another controller without hindrance from the controller to which the personal data were provided, where:

  • the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR; and
  • the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible.

The rights and freedoms of others must not be adversely affected by this.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

11.7 Right to Object

You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions.

Following an objection, the controller will no longer process the personal data concerning you unless the controller can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.

Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

11.8 Right to Withdraw Consent under Data Protection Law

You have the right to withdraw your consent under data protection law at any time.

The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

11.9 Automated Individual Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

This shall not apply if the decision:

  • is necessary for entering into or performance of a contract between you and the controller;
  • is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  • is based on your explicit consent.

However, such decisions must not be based on special categories of personal data referred to in Article 9(1) GDPR unless Article 9(2)(a) or (g) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to above, the controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

11.10 Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the progress and outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 GDPR.

Hetzel Horses GmbH
Holger Hetzel
Managing Director

Hetzel Trading GmbH
Holger Hetzel
Managing Director