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We take care of your data - Privacy Policy

(as of May 24, 2018)

Our website may be used without entering personal information. Different rules may apply to certain services on our site, however, and are explained separately below. We collect personal information from you (e.g. name, address, email address, telephone number, etc.) in accordance with the provisions of German data protection statutes. Information is considered personal if it can be associated exclusively to a specific natural person. The legal framework for data protection may be found in the German Federal Data Protection Act (BDSG) and the Telemedia Act (TMG). The provisions below serve to provide information as to the manner, extent and purpose for collecting, using and processing personal information by the provider.

netclusive GmbH, Robert-Bosch-Str. 10, Haus I, 56410 Montabaur, Telefon: +49 2602 94708-0?, E-Mail: info@netclusive.de

Please be aware that data transfer via the internet is subject to security risks and, therefore, complete protection against third-party access to transferred data cannot be ensured.

1. Person in Charge

Responsible in the sense of the basic data protection regulation:
Reelway GmbH
Stephan Schneider
161a Eupener Street
6th floor
50933 Cologne
Phone: +49 221 53418492
Fax: +49 221 53418494
E-mail: s.schneider@reelway.de

2. Data Protection Officer

Contact details of our data protection officer:
Reelway GmbH
Stephan Schneider
161a Eupener Street
6th floor
50933 Cologne
Phone: +49 221 53418492
Fax: +49 221 53418494
E-mail: s.schneider@reelway.de

3. Purposes and Legal Foundations of Data Processing

3.1 Informational Use of the Website
You can visit our website without providing any personal data. If you use our website for your information only, i.e. do not otherwise provide us with any personal data, we do not process any personal data, with the exception of the data that your browser transmits to enable you to visit the website and data that is transmitted to us in the context of cookies used for statistical analysis of the use of our website.

3.1.a. Technical Provision of the Website
For the purpose of technically providing the website, we may need to process certain automatically submitted information from you in order for your browser to display our website content and for you to use the website. This information is automatically collected each time you visit our website and stored in our server log files. These data refer to the computer system of the calling computer. The following information is collected:
  • IP address,
  • Browser type/ version (e.g. Firefox 59.0.2 (64 bit)),
  • Browser language (e.g. German),
  • Operating system used (e.g. Windows 10),
  • Internal resolution of the browser window,
  • Screen resolution,
  • Activation of Javascript,
  • Java On / Off,
  • Cookies on / off,
  • Color depth,
  • Date and time of access.
We also use cookies to make the use of our website convenient to you. Cookies are small text files that are stored in the Internet browser or by the Internet browser when you visit a website on your computer system. A cookie contains a characteristic string of characters that enables a unique identification of the browser when the website is called up again. We use these cookies exclusively to provide you with technical functions for our website. Some functions of our website cannot be offered without the use of cookies. The following information is stored in the cookies and transmitted to us:

Session ID
Your information, which we have collected through the cookies described above, will not be used by us to create user profiles or to evaluate your surfing behaviour.
We process your personal data for the technical provision of our website on the basis of the following legal basis:

to fulfil a contract or to carry out pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR, insofar as you visit our website to inform yourself about us and our offers and
to protect our legitimate interests pursuant to art. 6 para. 1 letter f of the GDPR in order to make the website technically available to you. Our legitimate interest is to provide you with an attractive, technically functioning and user-friendly website, to take measures to protect our website from security risks and to prevent our website from posing security risks to third parties.

3.1.b. Statistical Analysis of Website Usage and Range Extension
For the purpose of statistical analysis of the use of our website, we use Google Analytics and thus cookies, which enable an analysis of your surfing behaviour. This enables us to improve the quality of our website and its content. We learn how the website is used and can thus continuously optimize our offer.
The information obtained in the context of the statistical analysis of our website will not be merged with your other data collected in the context of the website.
We process your personal data for statistical analysis of the use of our website on the basis of the following legal basis:
your consent pursuant to Art. 6 para. 1 lit. a) GDPR.

3.1.b.1. Google Analytics
On our website we are using Google Analytics, a web analysis service of Google Inc. Google Analytics uses "cookies", which are text files placed on your computer's hard drive. This information is stored on your computer and allows you to analyze how you use the website. The information generated by the cookie
about your use of our website are usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated on our website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
On our website we use Google Analytics with the extension "_anonymizeIp()". As a result, IP addresses are further processed in abbreviated form, a direct
Personal relationship can thus be excluded.
We use Google Analytics exclusively with your consent. You can revoke a consent once given by prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of our website to their full extent;
download and install the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en or
To prevent future collection by Google Analytics on our website, you can click on the link below. An opt-out cookie is stored in your browser. Please note that you must activate the opt-out cookie in every browser you use on all your end devices and must also reactivate it if you delete all cookies in a browser once.
Click here to disable Google Analytics
For more information on Google Analytics' terms of use and data protection, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/

3.1.b.2. Use of Social Plugins (Like, Tweet, Google+, Youtube)
On our website we use social plugins from Facebook (Like), Twitter (Tweet), Youtube and Google (+1). In order to increase the protection of your data when you visit our website, these plugins are limited and integrated into the site using the 2-click solution. This ensures that when you visit our website, no connection is established with the providers' servers and that your data is not transmitted to them. Only when you activate the plugins by clicking on the buttons next to the respective button and thus give your consent to data transmission, your browser establishes a direct connection to the servers of the providers, where you can (if necessary after entering your login data) e.g. press the Like, Tweet or Share button.
Once you have left our website and are on the pages of the providers, we no longer have any control over data processing. You may use the information on the handling of your data by the respective provider, in particular for the purpose and scope of data processing, further processing and use of the data by the respective provider, your relevant rights and setting options to protect your privacy, please refer to the data protection information of the respective provider as follows:

Facebook: http://www.facebook.com/policy.php
Twitter: https://twitter.com/de/privacy
Google+: http://www.google.com/intl/de/+/policy/+1button.html
Youtube: https://www.youtube.com/static?template=privacy_guidelines

3.1.c. Social Links
The website includes links to services such as Facebook, Twitter, Google+ and YouTube. After clicking on the link you will be redirected to the page of the respective provider, i.e. only then will user information be transferred to the respective provider. For information on the handling of your data when using the websites of other providers, please refer to the respective data protection information of these providers.

3.2 Active Use of the Website
In addition to the purely informational use of our website, you can also actively use our website to register for our newsletter or to contact us. In addition to the above-mentioned processing of your personal data for purely informational purposes, we will then also process other personal data of yours that we require to process your order or to process and respond to your inquiry.

3.2.a. User Requests
In order to be able to process and answer your inquiries to us, e.g. via the contact form or to our e-mail address, we process your personal data provided by you in this context. In any case, this includes your name and e-mail address in order to send you an answer, as well as the other information that you send us in the context of your communication.
We process your personal data to answer user inquiries on the basis of the following legal basis:
to protect our legitimate interests pursuant to Art. 6 para. 1 letter f GDPR; our legitimate interest is to answer customer inquiries appropriately.

3.2.b Registration and User Account
You can create a user account to use the online shop ("editions"). To do this, you must register you. We process the data you enter into the registration form. You must provide your email address and a password of your choice. In addition, we process in particular your name, your address, your contact data and, if necessary, a different delivery address.
Mandatory data for the creation of a user account are marked with an asterisk ("*") in the registration form. We process your data for the above purposes on the basis of the following legal bases:
for the performance of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR, provided that you register to use the user account and the services offered there; and
to protect our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, in order to make the portal technically available to you. Our legitimate interest is to be able to provide you with an attractive, technically functioning and user-friendly portal.

3.2.c. Online Shop and Order Process
Within the online shop we enable you to order our online services ("editions") in the form of free or paid subscriptions.
We process your data for the above purpose on the basis of the following legal basis:
to fulfil a contract or to carry out pre-contractual measures in accordance with Art. 6 Para. 1 lit. b GDPR, insofar as you use our portal to inform yourself about our range of goods and place orders.
to protect our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, in order to make the portal technically available to you. Our legitimate interest is to be able to provide you with an attractive, technically functioning and user-friendly portal.

3.2.d. Payments
We use payment service providers  as well as online subscription management services to process and fulfill your orders.
We process your personal data for the processing of orders on our website on the basis of the following legal basis:
for the performance of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR.

3.2.e Order Processing
In order to be able to send you the ordered online services, we pass on your first and last name, contact data and, if necessary, a different delivery address to the delivery service commissioned by us.
We process your personal data on the basis of the following legal bases:
for the performance of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR.

3.2.f Compliance with Legal Regulations
We also process your personal data in order to fulfil other legal obligations that affect us in connection with the processing of the order. These include in particular retention periods under commercial, trade or tax law.
We process your personal data on the basis of the following legal bases:
to fulfil a legal obligation to which we are subject pursuant to Art. 6 para. 1 lit. c GDPR in connection with commercial, trade or tax law, insofar as we are obliged to record and store your data.

3.2.g Enforcement
We also process your personal data in order to assert our rights and assert our legal claims. We also process your personal data in order to be able to defend ourselves against legal claims. Finally, we process your personal data insofar as this is necessary to defend against or prosecute criminal offences.
We process your personal data for this purpose on the basis of the following legal bases:
to protect our legitimate interests pursuant to Art. 6 (1) (f) GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or we prevent or clarify criminal offences.

3.2.h Newsletter
With your consent we use your data for the transmission of our newsletter. We process mandatory information that you enter when registering for the newsletter, such as your e-mail address and your name:
If you have given us your consent by double opt-in procedure, pursuant to Art. 6 para. 1 lit. a GDPR.

4. Links

Some pages of our website contain links to the websites of third parties. These websites are subject to their own data protection principles. We are not responsible for their operation including data handling. If you send information to or about such third party sites, you should review the privacy statements of these sites before you provide them with information that may be personally identifiable.

5. Categories of Recipients

Initially, only our employees receive knowledge of your personal data. We may also share your personal information with other recipients who provide services to us in connection with our website, to the extent permitted or required by law. We limit the transfer of your personal data to what is necessary, especially to process your orders, complaints and support requests. In some cases, our service providers receive your personal data as contract processors and are then strictly bound by our instructions when handling your personal data. In some cases, the recipients act independently with your data, which we transmit to them.
Below we list the categories of recipients of your personal data:
subscription, payment service providers and banks, in the processing of subscriptions and payments,
Logistics service provider to deliver the goods to you,
IT service provider for the administration and hosting of our website and our online service platforms,
Collection agencies and legal advisors in asserting our claims.

6. Transfer to a Third Country

As part of the use of Google tools, subscription management and payment service providers, we transfer your shortened IP address to the USA. The data transfer is based on the EU Commission implementing Decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequacy of the protection provided by the EU-US data protection shield.
Furthermore, we do not transfer your personal data from our side to countries outside the EU or the EEA or to international organisations.

7. Archiving Period

7.1 Informational use of the website
When using our website for information purposes only, we store your personal data on our servers exclusively for the duration of the
visit our website. After you have left our website, your personal data will be deleted immediately.
Cookies installed by us are usually also deleted after leaving our website. However, this does not apply to Google Analytics cookies. These remain stored for a period of up to two years. You also have the option of deleting installed cookies yourself at any time.

7.2 Active Use of the Website
If you actively use our website, we will initially store your personal data for the duration of answering your inquiry or for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.
In addition, we will store your personal data until any legal claims arising from the relationship with you become statute-barred, in order to use them as evidence if necessary. The limitation period is generally between 12 and 36 months, but can also be up to 30 years.
Upon commencement of the limitation period, we delete your personal data, unless there is a legal obligation to store data, for example from the German Commercial Code (?º?º 238, 257 para. 4 HGB) or from the Tax Code (?º 147 para. 3, 4 AO). These retention obligations can amount to two to ten years.

8 Your Rights as a Data Subject

Under the legal requirements you are entitled to the following rights as the person concerned, which you can assert against us:

Right to information: You are entitled at any time within the scope of Art. 15 GDPR to request confirmation from us whether we are processing personal data concerning you; if this is the case, you are also entitled within the scope of Art. 15 GDPR to obtain information about such data and certain other information (including processing purposes, categories of personal data, categories of recipients, planned storage time, the origin of the data, the use of automated decision-making and, in the case of a transfer to a third country, the appropriate guarantees) and a copy of your data.
Right to correction: According to Art. 16 GDPR, you are entitled to demand that we correct the personal data stored about you if it is inaccurate or incorrect.
Right of deletion: You are entitled, under the conditions of Art. 17 GDPR, to request us to delete personal data relating to you without delay. Among other things, there is no right of deletion if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defence of legal claims.
Right to restrict processing: You are entitled to require us to restrict the processing of your personal data under the conditions of Art. 18 GDPR.
Right to data transferability: Under the conditions of Art. 20 GDPR, you are entitled to require us to provide you with the personal data that you have provided to us in a structured, common and machine-readable format.
Right of revocation: You have the right to revoke your consent to the processing of personal data at any time with effect for the future.
Right of objection: You are entitled to object to the processing of your personal data under the conditions of Art. 21 GDPR, so that we must stop the processing of your personal data. The right of objection exists only within the limits provided for in Art. 21 GDPR. In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your personal data despite your objection.
Right of appeal to a supervisory authority: You are entitled, under the conditions laid down in Article 77 GDPR, to lodge a complaint with a supervisory authority, in particular in the Member State where you are staying, working or suspected of having infringed the GDPR, if you believe that the processing of personal data concerning you is contrary to it. The right of appeal is without prejudice to any other administrative or judicial remedy.
The supervisory authority responsible for us is:

State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia
Kavalleriestr. 2-4
40213 D??sseldorf, Germany
Phone: 0211/38424-0
Fax: 0211/38424-10
E-mail: poststelle@ldi.nrw.de

We recommend that you always address a complaint to our data protection officer first.
If possible, your applications for the exercise of your rights should be addressed in writing to the above address or directly to our data protection officer.

9. Scope of Your Obligations to Provide Data

In principle, you are not obliged to provide us with your personal data. However, if you do not do so, we will not be able to provide you with our website, answer your questions and enter into a contract with you. Personal data which we do not necessarily require for the above-mentioned processing purposes are marked as voluntary data by a "possibly" or another symbol.

10. Automated Decision Making / Profiling

We do not use automated decision making or profiling (an automated analysis of your personal circumstances).
Information about your right of objection Art. 21 GDPR
You have the right to object at any time to the processing of your data on the basis of Art. 6 para. 1 f GDPR (data processing on the basis of a balance of interests) or Art. 6 para. 1 e GDPR (data processing in the public interest), if there are reasons for this arising from your particular situation. This also applies to profiling based on this provision within the meaning of Art. 4 No. 4 GDPR.
If you object, we will no longer process your personal data, unless we can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
The objection can be informal and should be addressed to:
Reelway GmbH
161a Eupener Street
50933 Cologne
E-mail: info@reelway.de
Phone: +49 221 53418492
Fax: +49 221 53418494

11. Changes

Reelway GmbH reserves the right to change this privacy policy at any time. Any changes will be announced by publishing the amended privacy policy on our website. Unless otherwise specified, such changes shall take effect immediately. Please check this privacy policy regularly to see the latest version.

Last Updated May 2018