Privacy Policy What tool are you? Competition

Introduction

In this document, we inform you about the processing of personal data for participation in the competition as part of the What tool are you? action. For more details on the processing of personal data by Hager Group, please also consult our data protection resource center and the data protection information note for the Facebook fan page and Instagram account.

If you have any questions that have not been answered in this data protection statement, or if you would like more detailed information on a particular point, please contact the Hager Group data protection officer at the e-mail address: dsb.hagergroup@verimax.de.   

The Data Protection Officer is independent in his or her function and will treat your inquiries as confidential.

Contents

1. Your rights as a data subject and how to exercise them 2
2. What data we process as personal data 2
3. The personal data we collect and process 3
4. How we use your personal data 3
a. The role of Hager Vertriebsgesellschaft mbH & Co. KG in processing 3
b. Purposes of processing 3
c. Legal basis for processing 3
d. Transfer of your data 4
e. Retention of your data 4
5. Protection of your personal data 4
6. Minors 5
7. Data protection officers 5

In addition to our explanations, we will provide you with the appropriate reference to the GDPR. Local data protection laws may also apply, but are not directly mentioned.

1. Your rights as a data subject and how you can exercise them

In order for you to feel secure when your personal data is processed by the Hager Group or its subsidiaries, we inform you of the personal data that the Hager Group or its subsidiaries process about you within their retention period (GDPR art. 15 (1)). In addition, we will inform you on request of the processes in which your data is involved. You also have the right to request the erasure and restriction of the processing of your personal data (RGPD art. 17 & 18).

Nevertheless, we may need to retain or use your data to comply with legal obligations, even if you have exercised one of the aforementioned rights (RGPD art. 17 (3) (b)). We may also use the data collected for legal actions. (RGPD Art. 17 (3) (e)). 

You can have your personal data rectified at any time (RGPD Art. 16).

Your contact details to participate in the competition as part of the What tool are you? action are transmitted to us by Meta Platforms Ireland Ltd. Your personal data may be transmitted to or accessed by this business partner in a third country. On request, we will inform you of the security measures taken to protect your data (RGPD, art. 15 (2)). In addition, you will also find information on the protection of your personal data in this document.
Please use this link if you have any questions or wishes regarding this processing or this data protection declaration, if you wish to express concerns or exercise your rights. The Hager Group or its subsidiaries will ensure that all your rights are implemented on request, without undue delay.

Complaints against the Hager Group or its subsidiaries regarding your personal data may be filed with the supervisory authority:

Unabhängiges Datenschutzzentrum Saarland (Independent Data Protection Centre Saarland)
Fritz-Dobisch-Straße 12
66111 Saarbrücken
Tel: (0681) 94781-0
Email: poststelle@datenschutz.saarland.de

2. What data we process as personal data

The Hager Group and its subsidiaries consider all data that identifies you or can be used to identify you as personal data (GDPR art. 4 (1)). Therefore, we will process such data with the security measures and practices described in our privacy statement. 
Contact data collected in the context of participation in the competition game is therefore personal data.

3. Personal data we collect and process

To take part in the What tool are you? competition, you need to provide us with your contact details. To participate, we collect your account name. People who have won a prize in the competition are invited to share it with us via Instagram or Facebook: 
- First and last name 
- Telephone number
- Street address 
- Age (above 18 years)

The information that may be obtained through the use of Facebook and Instagram is not accessible to Hager and is not processed for the competition. Please also see the data protection information for the Hager Group Facebook fan page and Instagram account.

4. Use of your personal data

Your personal data will be used exclusively for the organization of the What tool are you? competition.

a. The role of Hager Vertriebsgesellschaft mbH & Co. KG in data processing

The competition is organized by Hager Vertriebsgesellschaft mbH & Co. KG, Zum Gunterstal, 66440 Blieskastel, HRA10002. Hager Vertriebsgesellschaft mbH & Co. KG is responsible (RGPD art. 4 (7)) for processing personal data in connection with the competition. (RGPD art. 24)

b. Purposes of processing

We collect your personal data to take part in the competition as part of the What tool are you? action. We need your profile name for the organization of the contest and to inform you, if applicable, of the result of the prize draw via Instagram or Facebook Messenger. We need your contact details, telephone number and address so that we can send you your prize if applicable.

c. Legal basis for processing

We process your personal data in order to perform the contract with you (see conditions of participation in the competition) (GDPR art. 6 (1) (b)) or in the event of a legal obligation (GDPR art. 6 (1) (c)). 

d. Transmission of your data

Personal data for the competition is collected via Facebook or Instagram, depending on which social media platform you use to participate in the competition. Meta Platforms Ireland Ltd (4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland), operator of Instagram and Facebook, processes personal data independently of Hager Group. Please refer to the relevant data protection declarations. As their contact details are sent via Facebook or Instagram, Meta Platforms Ireland Ltd may have access to this personal data. In addition, they need a user account with Meta Platforms Ireland Ltd. in order to interact with our competition publication. The processing of personal data for the operation and functions of such a user account is the sole responsibility of Meta Platforms Ireland Ltd. The liability of Hager Vertriebsgesellschaft mbH & Co KG does not extend beyond the fulfilment of obligations arising from the conditions of participation. 

By running the competition on Facebook and Instagram, Meta Platforms Ireland Ltd. may have access to your personal data outside the EEA, as it is an international group of companies. Access from the USA by Meta Platforms Inc (USA), as part of the Meta group, is covered by the Data Privacy Framework. This guarantees an adequate level of protection for the transfer or access to your personal data from the USA.

For prize delivery, your name and address will be forwarded to a supplier for postal delivery. Please also read the data protection information for the Hager Group Facebook fan page and Instagram account.

e. Retention of your data

We retain your personal data for as long as we need it to perform the contract (RGPD art. 17 (1) (a)). In addition, you can make use of your rights as a data subject see 1. Your rights as a data subject (GDPR art. 17 (1) (c)). After the prizes have been sent, the personal data collected in connection with the competition will be deleted within 6 weeks.

5. Protection of your personal data

Your personal data is encrypted, and technical and organizational measures are taken to protect your data. Your data is only transmitted within the EU or to partners that fall under the EU-U.S. Privacy Shield framework or comply with other adequate security measures (GDPR art. 28 (1)). In addition, access to your personal data is restricted to the competent personnel of the Hager Group (RGPD art. 5 (1) (f)). Please note that we cannot provide information on security measures for processing under the responsibility of Meta Platforms Ireland Ltd. 

6. Minors

Minors are not allowed to participate in the competition. 

7. Delegates for data protection

Martina Renner 
Verimax GmbH
Warndtstraße 115, 66127 Saarbrücken
dsb.hagergroup@verimax.de