HAGEN GROUP PRIVACY POLICY

Adopted on April 6, 2024

1. Basic information

We are pleased that you are visiting our website and thank you for your interest. In the following, we will inform you about how we handle your personal data when you use our online services, such as our website and our online shop. The following information also relates to the use of our website with mobile devices, e.g. smartphones or tablets. Personal data is all data with which you can be personally identified or which makes you identifiable via an identifier, for example via your IP address or credit card number.

This privacy policy explains the legal basis and purpose for this. We also inform you about your rights with regard to the use of personal data. If you have any questions regarding the use of your personal data by us, please contact us as the responsible body (contact under point

This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or enquiries to the controller). You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser line.

2. Who we are (responsible for data protection)

The controller for data processing on our online offering within the meaning of the General Data Protection Regulation (GDPR) is:

KG HAGEN Deutschland GmbH & Co,

represented by the personally liable partners of Hagen Deutschland GmbH,

represented by the managing directors Rolf Horst Hagen, Christian Parbs,

Lehmweg 99-105, 25488 Holm

E-mail: customer.service-de@rchagen.com.

Telephone: +49 41 03 – 960 – 2000

Contact details of our company data protection officer: datenschutzbeauftrag-ter@rchagen.com.

3. Data collection when visiting our online offer

Visiting our website (without registration) automatically leads to the anonymized collection of the following data on our server:

– abbreviated IP address,

– Date/time/time zone of access,

– access status,

– type of access,

– protocol type,

– Type and number of pages accessed,

– Name and size of the files accessed,

– source website,

– Web browser used,

– operating system used.

The aforementioned non-personal information is collected automatically by the normal operation of our Internet services. This usage data about the visit to our pages is not combined with the personal data provided via the registration form. For us, any personal reference to the usage data is excluded.

We use the aforementioned data for the purpose of troubleshooting, to compile statistics and to measure the activities on the website with the aim of increasing the usefulness of our offer for you. This also constitutes a legitimate interest (Art. 6(1)(f) GDPR).

Only our IT administrator has internal access to this data for the above-mentioned purposes.

We only collect the above-mentioned data for the period of use; once use has ended, the data is deleted immediately, but after 7 days at the latest.

We receive information via cookies and tools as soon as your web browser opens our website. These identifiers support various service functions of our website and are automatically transferred to the hard drive of your computer or other mobile device via your web browser. You can prevent this function by setting your browser accordingly. In this case, however, a personalized service is not possible. In these cases, your anonymized IP address may also be transmitted to the USA. More information on the cookies and tools we use can be found below under the heading “Use of cookies and tools”.

4. Contacting us

We have provided an online form on our website that you can use to contact us electronically. The form requires your first name and surname, your e-mail address and telephone number (optional) as well as a field for the subject and for your message to us. We require this data in order to process your enquiry. You can also provide us with your postal address on a voluntary basis. You can also contact us by e-mail at any time. Contacting us is always voluntary.
We process this data exclusively for the purpose of responding to your enquiry or for the desired contact with you and the associated technical administration (Art. 6(1)(b) GDPR).
Your enquiry will be received by our internal customer service.
We do not transfer your enquiries to third countries or organizations outside the EU.
After processing your enquiry, we will delete the data relating to your contact immediately, but no later than 72 hours after the enquiry has been dealt with. This storage period may conflict with statutory retention periods, e.g. if your enquiry is related to a contract or warranty or guarantee processing. In this case, we will only store your enquiry beyond the expiry of seven days for the purpose of fulfilling the statutory retention obligations (Art. 6 (1) (c) GDPR). In this case, we will delete your data at the latest upon expiry of the statutory retention period, i.e. after 10 years, beginning with the conclusion of the contract. Upon expiry of this retention period, we will delete this data immediately without you having to request us to do so.

5. Use of your data for advertising purposes (product recommendations to existing customers/newsletter subscription)

5.1 Product recommendations to existing customers
If you have ordered products from us and have provided your e-mail address, we allow ourselves to send you product recommendations for our own similar products within the framework of the legal requirements if we have pointed this out to you when the contract was concluded and you have not objected to this. This type of contact takes place exclusively for the purpose of sending the product recommendation by electronic mail to you as an existing customer. In doing so, we are pursuing our legitimate interest in the personalized direct advertising of existing customers (Art. 6 (1) (f) GDPR). If you have initially objected to the use of your email address for this purpose, we will not send you the aforementioned information by email. You are entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying us. Upon receipt of your objection, the use of your e-mail address for the aforementioned advertising purpose will be discontinued immediately.

5.2 Newsletter subscription
You can subscribe to our e-mail newsletter on our website. Our newsletter provides regular information about news, interesting offers, new promotions and campaigns. The only mandatory information required to receive our newsletter is your e-mail address. Optionally, you can enter your name so that we can address you personally. We use the so-called double opt-in procedure for the newsletter subscription. For this purpose, we will send you a confirmation e-mail after you have given your consent to subscribe to the newsletter. In this e-mail, we ask you to confirm the link contained therein in order to confirm the newsletter subscription. You will only receive our newsletter after this (second) activation.

5.3 Consent for newsletter subscription
We will only use the email address provided with your consent to subscribe to the newsletter and, if applicable, your name details to send you advertising by email. This transmission of electronic advertising is justified on the basis of your consent (Art. 6(1)(a) GDPR).

You can revoke your consent to receive newsletters by e-mail for the aforementioned purpose at any time with effect for the future by e-mail or via our online contact form or the corresponding link in the newsletter. After such cancellation, we will immediately delete your e-mail address from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

We record your declaration of consent electronically for the purpose of verifiability. You can view your declaration of consent online in your Ac-count at any time. When you register for the newsletter, we also store your IP address entered by the Internet Service Provider (ISP) as well as the date and time of the newsletter subscription in order to be able to trace any possible misuse of your e-mail address at a later date.

If you have not given us your consent for the newsletter subscription or have revoked it, you will only receive electronic mail from us in connection with the processing of orders that you have placed with us.

5.4 Service provider for sending electronic advertising
We use the Email Studio software, which is part of the Marketing Cloud of the service provider Salesforce Germany GmbH, Erika-Mann-Str. 31, 80636 Munich (hereinafter referred to as “Salesforce”), to send the aforementioned product recommendations and newsletters by electronic mail. This service provider acts on our behalf strictly in accordance with our instructions and obtains knowledge of your email address and, if applicable, your name for this purpose.

We have concluded an order processing contract with Salesforce. Salesforce acts on our behalf strictly in accordance with our instructions. Data processing generally takes place on Salesforce servers in the EU. It cannot be ruled out that data may also be transferred to Salesforce, Inc. in the USA. This data transfer is justified by the EU Commission’s adequacy decision for the USA. Salesforce, Inc. participates in the EU-US data protection framework: https://www.dataprivacyframework.gov/

In addition, Salesforce has binding internal data protection regulations and Binding Corporate Rules (BCR, Art. 47 GDPR). Salesforce’s EU Binding Corporate Rules (“Salesforce EU Processor BCR”) were approved by the European data protection authorities in 2015 and the UK Binding Corporate Rules (“Salesforce UK Processor BCR”) were approved by the Information Commissioner’s Office in the UK in 2023.

Further information on data processing in the Salesforce Marketing Cloud can be found here: https://help.salesforce.com/s/articleView?id=sf.mc_overview_data_protection_privacy.htm&type=5. You can view Salesforce’s privacy policy here https://www.salesforce.com/de/company/privacy/.

If you have given us your consent to receive newsletters and to analyze the interaction with our newsletters (so-called conversion tracking) (Article 6(1)(a) GDPR), Salesforce uses this information on our behalf to send and statistically analyze the newsletters. For the analysis, the emails sent contain so-called web beacons or tracking pixels, which are one-pixel image files that are stored on our website. This enables us to determine whether you have opened a newsletter message and which links you may have clicked on. With the help of conversion tracking, we can also analyze whether a certain action (e.g. the purchase of a product on our online pages), which we have determined in advance, has taken place after clicking on the link in the newsletter. In addition, we collect further technical information, namely the time of access, the shortened IP address, browser type and operating system. We only collect this technical data in pseudonymised form and do not link it to your personal data or your customer account. In this way, we exclude the possibility of the data being directly linked to a person. We use this data exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses enable us to better adapt future newsletter offers to the interests of our customers.

The legal basis for this data processing is your consent (Art. 6 (1) (a) GDPR). You can withdraw your consent at any time with effect for the future. This does not affect the lawfulness of the processing carried out on the basis of your consent prior to its withdrawal.

We store your email address, your name (if applicable) and the consent you have given for sending the newsletter and conversion tracking for the duration of the newsletter subscription or until you withdraw your consent (cancellation of the newsletter). Any other data collected in the course of sending the newsletter will be deleted after seven days.

6. Automated decision-making and profiling

We do not use automated decision-making. Profiling only takes place in the cases described in this privacy policy if you have given us your consent to do so. You can revoke your consent at any time with effect for the future. The legality of the processing carried out on the basis of your consent up to the time of revocation remains unaffected. The revocation is possible informally, e.g. by e-mail to privacy@bionicdogtoys.com. No profiling will take place beyond this.

7. Information on the use of cookies and tools

7.1 What are cookies?
We use cookies on various pages to make your visit to our website more attractive and to enable the use of certain functions. These are small text files that are stored on your end device. These text files are used to archive information for a limited period of time. Your browser saves the cookies in the form of a readable text file as soon as you visit our website. If you are registered with us, the cookies help us to recognize your end device (computer, tab-let or smartphone) the next time you visit our online offering. Certain cookies may contain personal data.

7.2 Which cookies do we use?
We categorize the cookies we use into the following categories: necessary cookies, functional cookies, analysis & statistics cookies and advertising & marketing cookies. Necessary cookies enable you to use our online services (so-called session cookies). If this cookie is deactivated, you will not be able to access our website. The authentication cookie gives you access to the log-in area. Without this cookie, neither registration nor access to the log-in area is possible. These session cookies are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies).
Other cookies remain on your end device and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. We use a so-called retargeting cookie for advertising purposes. This enables us to display advertising offers that may be of interest to you outside of our offers on the Internet. You can find more detailed information in the following overview of the cookies used.

7.3 For what purposes and on what legal basis do we use cookies?
Most of the cookies we use do not store any information that identifies you as a person or makes you identifiable. Rather, these cookies provide us with general and anonymised information about the visitors to our online services, the services accessed, the browsers and operating systems used and the cities from which our visitors come. We only record the IP address in abbreviated form and in such a way that it is not possible to recognize and assign it to individuals.

In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the contents of a virtual shopping basket for a later visit to the website). If personal data is also processed by individual cookies used by us, the processing is carried out to fulfil the contract with you (Art. 6(1)(b) GDPR).

Insofar as we collect data using cookies, this is done on the one hand to gain insights for optimizing the functionalities and content of our online offering. We pursue a legitimate interest with such functional cookies (Art. 6(1)(f) GDPR) because they allow us to customize our offering technically and make it easier for you to access our pages. On the other hand, we use cookies to measure how successful our online advertising measures are. We can also use statistical data to recognize disruptions and track the calculation of advertising costs to us. We only carry out this processing if you have given us your consent to the use of these cookies for analysis & statistics or for advertising & marketing (Art. 6 para. 1 letter a GDPR). Once you have given your consent, you can withdraw it at any time with effect for the future. Data processing remains authorized until you withdraw your consent.

7.4 How can you switch off cookies?
You can set your browser so that you are informed about the setting of cookies and can decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. These can be found for the respective browsers under the following links. For some of these links, you must first select your browser version in order to see the specific instructions for changing your cookie settings
– Internet Explorer: https://support.microsoft.com/de-de/windows/l%C3%B6schen-und-verwalten-von-cookies-168dab11-0753-043d-7c16-ede5947fc64d (if you are still using Internet Explorer, we recommend switching to an up-to-date browser)

– Edge: https://support.microsoft.com/de-de/help/4027947/microsoft-edge-delete-cookies
– Firefox: https://support.mozilla.org/de/kb/verbesserter-schutz-blockiert-tracker-und-skripte
– Chrome: http://support.google.com/chrome/bin/answer.py?hl=de&hlrm=en&answer=95647
– Safari: https://support.apple.com/de-de/guide/safari/sfri11471/16.1/mac (you can query information for your operating system version via “Select version”)
– Opera: https://help.opera.com/de/latest/web-preferences/#cookies

Alternatively, you can obtain information from the Digital Advertising Alliance at the Internet address www.aboutads.info about the setting of cookies and make settings for this.

7.5 Do we use cookies from third-party providers?
We sometimes work together with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies may also be stored on your end device when you visit our online services (third-party cookies). The information on the use of such cookies and the scope of the data collected in each case is explained in more detail below. We use some cookies or tools because they are necessary for us to provide you with our online services. In this case, the legal basis for the processing is the user contract concluded with you (Art. 6 para. 1 letter b GDPR) or our legitimate interest, provided that no conflicting interests are recognizable and there is no objection (Art. 6 para. 1 letter f GDPR). We use all other cookies exclusively on the basis of your consent (Art. 6 (1) (a) GDPR).

Some of the cookies we use from third-party providers lead to data processing in the USA. In this case, too, we only use the cookies with your consent (Art. 6 (1) (a) GDPR).
Some of the cookies we use from third-party providers lead to data processing in the USA. In this case, too, we only use the cookies with your consent (Art. 6 (1) (a) GDPR).

The use of these providers from the USA is permitted on the basis of the EU Commission’s adequacy decision. These providers participate in the EU-U.S. Data Privacy Framework (DPF). The EU and the USA have concluded this agreement for the transfer of personal data from the EU and the EEA to organizations in the USA. Insofar as these US organizations participate in the DPF, the level of protection in the USA is deemed adequate. Further information on participation in the EU-US data protection framework can be found on the website that the U.S. Department of Commerce has set up to implement the agreement: www.dataprivacyframework.gov.

7.6 Overview of cookies used
In order to allow the user of our website to choose which cookies are stored on their device when using the website, our website uses a so-called cookie consent tool, which is displayed when our website is accessed for the first time.

The user has the option of selecting whether cookies may be set for the categories of statistics, marketing and external media. Required cookies are necessary for the functionality of the website and the storage of consent and cannot be deactivated.

Here is an overview of the cookies we use:
Necessary cookies enable basic technical functions and are required for the proper functioning of the website and cannot be blocked. In addition to the cookies listed under point 11.2, the cookies listed here are particularly relevant.

To save these consents (opt-in), it is necessary for a separate cookie to be set. If a user deletes their browser cache, our website will request the cookie consent again.

Type of Cookie	Cookie Name	Description	Duration
Required Cookies
	borlabs-cookie	Saves the settings of visitors selected in the Cookie Box of Borlabs Cookie.	1 year

The following cookies are used as standard on our website to ensure the functionality of certain contents (e.g. shopping cart, web shop, secure login to customer account):

Type of Cookie	Cookie Name	Description	Duration
Function
	pll_language	Used to identify the language of a website visitor	1 day
	catit_store	This cookie stores information on which store the visitor prefers (US, UK, CA etc).	1 year

Type of Cookie	Cookie Name	Description	Duration
Analysis & Statistics		Statistics Cookies collect information about the behaviour of visitors to our website. This information helps us to understand how our visitors use and navigate our website.
	_ga, _gid, _ga_xxx, uetvid, _gcl_au	Cookie from Google for website analysis. Generates statistical data about how visitors use the website.	1 minute, 1 day, 2 years
	_hjFirstSeen	This is set to identify a new user’s first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by Recording filters to identify new user sessions.	Session
	_hjAbsoluteSessionInProgress	This cookie is used to detect the first pageview session of a user. This is a True/False flag set by the cookie.	30 minutes
	hjIncludedInPageviewSample	This cookie is set to let Hotjar know whether that user is included in the data sampling defined by your site’s pageview limit.	30 minutes
	_hjid, _hjSessionUser_xxx	Hotjar cookie that is set when a user first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.	1 year
	_hjIncludedInSessionSample	This cookie is set to let Hotjar know whether that user is included in the data sampling defined by your site’s daily session limit.	30 minutes
	_hjSession_xxx	A cookie that holds the current session data. This ensures that subsequent requests within the session window will be attributed to the same Hotjar session.	30 minutes

Type of Cookie	Cookie Name	Description	Duration
External media		External media integrated on our website, such as content from video platforms and social media platforms, are blocked by default. If cookies from external media are accepted, access to this content no longer requires manual consent.
	Youtube	Is used to unlock Youtube content.	6 months

7.7 Google Analytics web analysis service
We use the web analytics service Google Analytics in our online offering with your consent. In the EU, EEA and Switzerland, this service is provided by Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland, and in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies, which are stored on your computer and enable us to analyze the use of our online services.

The information generated by the cookie about your use of our website (including your shortened IP address) is transmitted to a Google server in the USA and stored there. In this way, Google analyses your use of our online offering in order to compile statistical reports for us about the activities on our online offering and to provide us with other services related to the use of our online offering. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.
We use Google Analytics in our online offering exclusively with the addition of the “anonymize IP” function for the purpose of web analysis. This setting ensures that Google Analytics deletes the last part of your IP address. This anonymisation of your IP address means that it cannot be directly linked to you personally. By extension, your IP address will be shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and only shortened there. This means that we do not receive any data that would allow us to draw conclusions about your person.

With Google Analytics, we also use the Universal Analytics functions. Universal Analytics allows us to analyze the activities on our online offers across devices (e.g. when accessing via notebook and later via a tablet). As a user, you will be assigned a pseudonymised user ID when you register on our website. The system uses this to recognize your user ID when you visit our site with another device. However, we do not assign any names to the pseudonymous user ID. We also do not transmit any personal data to Google. Data protection measures such as IP masking or the browser add-on are not restricted by the Universal Analytics function.

You can prevent the installation of cookies by selecting the appropriate settings in your browser software. You can also prevent Google from collecting the data generated by the cookie and relating to your use of our online offer (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: https://support.google.com/analytics/answer/181881?hl=de
This will prevent Google Analytics from collecting data within our online offering in the future. This opt-out cookie only works in this browser and only for this domain.
If you have made one of the above deactivations, you may not be able to use all the functions of our website to their full extent.

The transfer of data to Google is justified by the adequacy decision of the EU Commission. Google participates in the EU-US data protection framework: https://www.dataprivacyframework.gov/
We have concluded a contract with Google in accordance with the standard data protection clauses of the EU.

You can find more information on how Google Analytics handles user data in Google’s privacy policy: https://policies.google.com/privacy?hl=de

7.8 Retargeting / remarketing / referral advertising

7.8.1 Google Ad Manager (Ad Manager)
Google Ad Manager is a platform for all ad formats. This service is operated in the EU, EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland, in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). The ad manager uses cookies to present you with adverts that are relevant to you. A pseudonymous identification number (ID) is assigned to your browser in order to check which adverts have been displayed in your browser and which adverts have been viewed. The cookies do not contain any personal information. The use of the ad manager only enables Google and its partner websites to display adverts on the basis of previous visits to our online offering or other websites on the Internet.

With the Google Ads Manager, we can design adverts interactively and dynamically in various formats (e.g. video or individual). We can also manage and analyze our ads. The ad manager cookies enable Google to recognize your browser. This provides us with the information that someone has clicked on an advert and has been redirected to our site. We ourselves do not collect and process any personal data in the aforementioned advertising measures. We only receive statistical analyses of our campaigns from Google. These analyses enable us to recognize which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users on the basis of this information.

The information generated by the cookies is transmitted by Google to a server in the USA for analysis and stored there. A transfer of data by Google to third parties only takes place on the basis of legal regulations or in the context of commissioned data processing. Under no circumstances will Google combine your data with other data collected by Google.

You can prevent data collection by the Google Ads Manager as follows:
– You can prevent the storage of cookies by selecting the appropriate settings in your browser software. You can find information on this here: https://support.google.com/ads/answer/7395996
– You can also prevent the collection and processing of data by cookies by installing a browser plugin (https://support.google.com/ads/answer/7395996).

– Alternatively, you can deactivate Google cookies on the Digital Advertising Alliance website by clicking on the following link (http://optout.aboutads.info/?c=2#!/).
If you have deactivated one of the above options, you may not be able to use all the functions of our website to their full extent.

Google participates in the EU-US data protection framework: https://www.dataprivacyframework.gov/
We have concluded a contract with Google in accordance with the standard data protection clauses of the EU.

7.8.2 Google Ads Remarketing
Our online offering uses the remarketing functions of Google Ads, which we use to advertise our online offering in Google search results and on third-party websites. The provider in the EU, EEA and Switzerland is operated by Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland, in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). For this purpose, we have embedded a pixel (a code snippet, so-called remarketing tag) in our online offer, with the help of which Google sets a cookie in the browser of your end device. This cookie enables us to show you interest-based advertising. For this purpose, a pseudonymous cookie ID is generated and the websites you have visited are analyzed.

Any further data processing will only take place if you have consented to Google linking your internet and app browsing history to your Google account and using information from your Google account to personalize ads that you view on the internet. You can find information on the integration of user consent here: http://www.google.com/about/company/user-consent-policy.html

In this case, if you are logged in to Google while visiting our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, Google temporarily links your personal data with Google Analytics data to create target groups. You can find more information about this here: https://policies.google.com/technologies/ads?hl=de and https://support.google.com/google-ads/answer/7664943?hl=de&ref_topic=3122875.

You can permanently deactivate the setting of cookies for ad preferences by downloading and installing the browser plug-in available at the following link: https://support.google.com/ads/answer/7395996.
Alternatively, you can obtain information from the Digital Advertising Alliance at the Internet address www.aboutads.info about the setting of cookies and make settings for this. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If you do not accept cookies, the functionality of our website may be limited.

7.8.3 Use of Google Ads conversion tracking
Our online offering uses the online advertising program “Google Ads” and conversion tracking as part of Google Ads. Conversion tracking is a free tool from Google that can be used to measure interactions or transactions related to our adverts. We can use the tool to analyze, for example, whether users subscribe to our newsletter or how often clicks on our ads lead to activities on our online offering (e.g. registrations). In doing so, we can determine the usage actions that are to be analyzed (so-called conversions).

Conversion tracking works technically via the conversion tracking code (so-called “tag”), which is integrated into our online offering. The data on ad clicks is collected using cookies.
Conversion tracking is set as a cookie when you as a user click on an Ads advert placed on Google. This cookie generally loses its validity after 30 days and is used for non-personal (anonymised) identification. If you as a user visit certain pages of our online offering before the cookie has expired, Google and we can recognize that you originally clicked on the ad and were redirected from there to our online offering.

Google assigns certain (customized) cookies to us as Ads customers. As an Ads customer, we cannot track the cookies via our online offering on a personalized basis. Instead, we receive statistical analyses from Google of the information that Google has collected using the conversion cookie. We only find out the total number of users who have clicked on our adverts and have been forwarded to our online offer with the conversion tracking tag. However, these statistical analyses do not contain any information that can be used to personally identify you as a user.

If you do not wish to participate in conversion tracking or permanently deactivate cookies for ad preferences, you can deactivate this use in the user settings of your Internet browser. Alternatively, you can download and install the browser plug-in available at the following link: http://www.google.com/settings/ads/plugin?hl=de. In this case, your user behavior will not be recorded by the conversion tracking statistics. However, deactivating conversion tracking or cookies for ad preferences may lead to restrictions in the functions of our online offering.

Google may process your data on servers in the USA when using conversion tracking. Google participates in the EU-US data protection framework: https://www.dataprivacyframework.gov/
We have concluded a contract with Google in accordance with the standard data protection clauses of the EU.

You can obtain further information about Google’s data protection provisions at the following Internet address: http://www.google.de/policies/privacy/

8. Integration of social media and other services

We link to our profiles in social networks in our online offering. The use of these providers from the USA is permitted on the basis of the EU Commission’s adequacy decision. The providers we link to participate in the EU-U.S. Data Privacy Framework (DPF). The EU and the USA have concluded this agreement for the transfer of personal data from the EU and the EEA to organizations in the USA. Insofar as these US organizations participate in the DPF, the level of protection in the USA is considered adequate. Further information on participation in the EU-US data protection framework can be found on the website that the U.S. Department of Commerce has set up to implement the agreement: www.dataprivacyframework.gov.

8.1 Google ReCAPTCHA
If you have given us your consent when visiting the website, we use the “reCAPTCHA” service to protect input forms on our site. The provider is operated in the EU, EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland, in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

By using this service, a distinction can be made as to whether the corresponding input is of human origin or is misused by automated machine processing. For this purpose, a JavaScript element is integrated into the website, which analyses the user behavior of the user. From this data, reCAPTCHA calculates a so-called CAPTCHA score, which indicates the probability of whether the user is a natural person or a bot.
We use this information on our website for registration, filling out forms and shopping in our online shop.

To our knowledge, Google uses the reCAPTCHA software to collect the referrer URL (address of the website from which the visitor comes), the IP address, the behavior of the website visitor, information about the operating system, browser and length of visit, cookies, display instructions and scripts, the user’s input behavior and mouse movements in the “reCAPTCHA” checkbox area.
IP addresses are generally truncated within the member states of the EU/EEA before the data is transferred to the servers in the USA and stored there. Google does not clarify where exactly this data is stored.

The IP address transmitted as part of “reCAPTCHA” will not be merged with other Google data unless you are logged into your Google account at the time you use the “reCAPTCHA” plug-in. If you want to prevent this transmission and storage of data about you and your behavior on our website by “Google”, you must log out of “Google” before you visit our site or use the reCAPTCHA plug-in.

Google uses and analyses this data before you click on the “I am not a robot” checkbox. With the Invisible reCAPTCHA version, there is no need to tick the box and the entire recognition process runs in the background. Google does not tell you in detail exactly how much and what data it stores. For more information on how Google handles personal data:
https://www.google.com/intl/de/policies/privacy/.

If you have given us your consent to data processing, the data will be processed with the Google tool reCAPTCHA on the basis of Art. 6 (1) (a), (f) GDPR. Your consent to data processing can be revoked at any time with effect for the future. To do this, you can change your settings via the cookie consent platform available on the website. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

If you do not want your personal data to be transmitted to Google, you should not give us your consent to the use of Google reCAPTCHA. Alternatively, you can log out completely before visiting our website and delete all Google cookies; you can find more information on this at: https://support.google.com/?hl=de&tid=331618988690.

Google participates in the EU-US data protection framework: https://www.dataprivacyframework.gov/
You can obtain further information about Google’s data protection provisions at the following Internet address: http://www.google.de/policies/privacy/

8.2 Google Maps
This website uses Google Maps to display interactive maps and to provide directions. In the EU and EEA, Google Maps is a map service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). The integrated map from Google Maps will only be displayed to you after you have given your consent (Art. 6 (1) (a) GDPR).

On our website, you will first see an upstream field with a reference to Google Maps. No data is yet transferred to Google. Data will only be transferred to Google once you have activated the pre-switched field and consented to the use of Google Maps.

If Google Maps is activated and used via our website, information about the use of this website, including your IP address, device information (operating system), your location and the start and destination addresses entered as part of the route planner function, may be transferred to Google in the USA and stored there. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. We have no influence on the scope of the data collected by Google in this way. We ourselves do not collect any personal data in connection with the use of Google Maps.

To the best of our knowledge, this is at least the following data:

Date and time of the visit to our website,
Internet address or URL of the website accessed,
IP address,
location data
start and destination address entered as part of route planning.

Google participates in the EU-US data protection framework: https://www.dataprivacyframework.gov/
Further information can be found in Google’s privacy policy at: https://policies.google.com/privacy?hl=de. Google Maps is used in accordance with Google’s terms of use at https://policies.google.com/terms?hl=de&gl=de and the terms and conditions at https://www.google.com/intl/de_de/help/terms_maps/.

8.3 Integration of YouTube videos
We have integrated YouTube videos into our online offering so that YouTube videos can be played directly on our pages. The “extended data protection mode” applies here, so that YouTube only collects data about you if you consent to this. The transmission of your data to YouTube therefore only takes place with your consent (Art. 6 para. 1 letter a GDPR).

YouTube is a service offered in the EU, EEA and Switzerland by Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland, and in the USA by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

We have integrated the YouTube videos into our website in such a way that an extended data protection mode applies (so-called privacy-enhanced mode). Calling up one of our pages containing YouTube videos and clicking on these videos does not result in your data being transmitted to Google. Before this happens, you will be asked to give your consent. We have provided a corresponding declaration of consent for this purpose.

If you have given this consent or view a video directly on YouTube (e.g. on our YouTube channel), your data may be transferred to a Google server in the USA and stored there. In this way, Google evaluates your use of our video offer on YouTube in order to compile anonymized reports on video views for us and to provide us with other services related to video usage.

YouTube and Google participate in the EU-US data protection framework: https://www.dataprivacyframework.gov/

We have concluded the contract offered by Google with Google in accordance with the standard data protection clauses of the EU. You can find Google’s order processing conditions here: https://www.youtube.com/t/terms_dataprocessing

Further information on data protection at the Google service “YouTube” can be found in the provider’s privacy policy at: https://policies.google.com/privacy?hl=de&gl=de

9. Social media appearances and use of social icons on our pages

We do not use any social plug-ins as active buttons on our website. We only use icons to refer to our offer in the following social networks:
– Facebook: Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland;
– Instagram: Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland;
– Twitter: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland;

– YouTube: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

We only display the social media icons on our website. They are designed as inactive icons. To ensure data protection, we use a solution that only transmits the address of our server to these services and not your IP address if you have activated a social media icon by clicking on it.

If you click on such a social media icon on our site, it will be activated with your consent and a connection to these third-party providers will be established via your web browser in a separate tab (tab card). These third-party providers can then track your visit to our website. If you are a member of one of the social networks, you can share the content of our site with other members of your social network by activating the button.

Through your participation in social networks or by visiting or accessing our social media sites, your data may be processed outside the EU. This may give rise to risks, e.g. because it may be more difficult to enforce your rights.

When you access a social network, cookies are usually stored on your end device to record user behavior. If you have a user account on the respective network and are logged in there, your user behavior can be saved to your user account. The social networks can analyze user behavior and use it for market research and advertising purposes. This may result in you being shown adverts within and outside the social networks. We have no influence on this.

We have no influence on the personal data collected and stored by the social networks. We receive analyses of user data via our above-mentioned social media sites and can target users with interest-based advertising. If users interact with our social media presence and are logged in with a user account, we can generally also recognize the user profile and see the content of comments or postings on our presence. This data processing is therefore carried out in joint responsibility with the respective provider of the social network. We have therefore concluded a joint responsibility agreement with the providers for the analysis of data in connection with our social media presence (Art. 26 GDPR). In this agreement, we have undertaken to provide you with this information on data protection. Further information can be found in the privacy policies of the respective social networks. You can also assert the rights to which you are entitled against us. However, the provider of the social network can fulfil your rights more comprehensively because the data for use and analysis is also stored there.

9.1 Instagram
We operate a social media presence at https://www.instagram.com/fluvalaquatics, which we use to present photos and posts about our company, provide information about our services and communicate with customers. When using and accessing our Instagram page, user data is also processed by the Irish-based company Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbor, Dublin and the US-based company Meta Platforms Inc, 1601 Willow Road, Menlo Park, California 94025 (hereinafter referred to as “Facebook”). Via Instagram, Facebook enables, among other things, a system in which Facebook distributes adverts via its network.

We analyze the views and interactions on our Instagram page. For this purpose, Facebook creates user profiles, but only provides us with anonymous data in this regard, so-called Page Insights. This is summarized data that provides us with information about how users interact with our Instagram page. The statistics generated are only transmitted to us in anonymized form. We do not have access to the underlying data. With regard to this Insight service, we process your personal data together with Facebook. For this reason, we have concluded the contract between joint controllers.

You can access our Instagram page regardless of whether you have a user account with Instagram or not. We process your personal data when you interact with our Instagram page, e.g. when you leave a comment, click a Like button or send us a message. We do not pass the data on to third parties. The Facebook terms of use are also applicable at: https://help.instagram.com/519522125107875

Depending on the nature of your activity, the legal basis for this data processing is your consent (Article 6(1)(a) GDPR) or our legitimate interest (Article 6(1)(f) GDPR) in customized marketing. Instagram users can revoke their consent to the publication of their comment or like at any time with effect for the future by deleting the comment or the content in question. A revocation does not affect the legality of the processing carried out on the basis of the consent until the revocation.

Facebook offers the option of objecting to certain data processing; relevant information and opt-out options can be found at https://www.facebook.com/policies/cookies/ and for logged-in users at https://www.facebook.com/settings?tab=ads.

Instagram users can influence the extent to which their usage behavior may be recorded when visiting our Instagram page at https://www.facebook.com/ads/preferences. In addition, corresponding settings can be made at https://www.facebook.com/settings and https://www.instagram.com/accounts/login/?next=/accounts/privacy_and_security/ or data processing can be objected to at: https://www.facebook.com/help/contact/367438723733209.

Data processing via cookies used by Facebook can also be prevented by settings in the browser.

Facebook only transfers user data to countries for which there is an adequacy decision by the European Commission in accordance with Art. 45 GDPR or on the basis of suitable guarantees in accordance with Art. 46 GDPR. Meta Platforms Inc. participates in the EU-US data protection framework: (https://www.dataprivacyframework.gov/).

We have concluded a contract with Facebook in accordance with the EU standard data protection clauses for joint controllers (https://de-de.facebook.com/legal/controller_addendum).

9.2 Facebook
In addition to our company’s own website, we also operate a Facebook page (so-called fan page). This can be found at https://www.facebook.com/fluval. We use it to present our company, provide information about our goods and services and communicate with customers and interested parties.

We only process personal data when you interact with our Facebook page, e.g. when you leave a comment, click a Like button or send us a message. The legal basis for this data processing is your consent (Art. 6 (1) (a) GDPR) or our legitimate interest in marketing and dialogue with our customers (Art. 6 (1) (f) GDPR). This includes, for example, that we can show our current offers, you can send us a contract-relevant enquiry or “like” a post from us, comment on it or upload content to our Facebook page.

We can analyze the views and interactions on our Facebook page. Facebook creates user profiles for this purpose, but only provides us with anonymous data, so-called Page Insights. This is summarized data that provides us with information about how users interact with our Facebook page.

When you use and access our Facebook page, your personal data will also be processed by the Irish-based company Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbor, Dublin and the US-based company Facebook, Inc, 1601 Willow Road, Menlo Park, California 94025 (hereinafter referred to as “Facebook”). In addition to the processing described above, Facebook also processes your data for analysis and advertising purposes or personalized advertising. To the best of our knowledge, Facebook also uses cookies that store your usage behavior (also across different end devices). This enables Facebook to display targeted advertising on its own platform and on third-party sites. Facebook creates the personal user profiles on the basis of effective consent in accordance with Art. 6 (1) (a) GDPR. Further information can be found in Facebook’s privacy policy, which is available here: https://www.facebook.com/about/privacy/.

We have concluded a contract with Facebook for joint controllers (https://de-de.facebook.com/legal/controller_addendum). You can revoke your consent at any time with effect for the future. The legality of the processing carried out on the basis of the consent until the revocation remains unaffected. You can delete a comment or uploaded content yourself at any time.

9.3 Twitter
We operate a social media presence at https://www.facebook.com/fluval, which we use to display photos and posts about our company, provide information about our services and communicate with customers. When using and accessing our Twitter page, user data is also processed by the US-based company X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (hereinafter referred to as “Twitter”). Twitter bases this data processing on the standard data protection clauses of the EU.

Twitter also offers a system for the distribution of advertising on Twitter at https://ads.twitter.com/.

We analyze the views and interactions on our Twitter page. Twitter creates user profiles for this purpose, but only provides us with anonymous data in this regard at https://analytics.twitter.com/. This is summarized data that provides us with information about how users interact with our Twitter page. The statistics compiled are only transmitted to us in anonymized form. We do not have access to the underlying data. With regard to this analysis service, we process your personal data together with Twitter. For this reason, we have concluded the contract between joint controllers.

You can access our Twitter page regardless of whether you have a Twitter user account or not. We process your personal data when you interact with our Twitter page, e.g. by posting a reply, clicking a Like button or sending us a direct message. We do not pass the data on to third parties. Information on data protection at Twitter can be found at: https://twitter.com/de/privacy.

Within the EU, the legal basis for this data processing is your consent (Art. 6 (1) (a) GDPR). Twitter users can revoke their consent to the publication of their reply or likes at any time with effect for the future by deleting the reply or the content in question. A revocation does not affect the legality of the processing carried out on the basis of the consent until the revocation.

Twitter offers the option of objecting to certain data processing; information and opt-out options in this regard can be found at https://twitter.com/personalization.

Twitter users can influence the extent to which their usage behavior may be recorded when visiting our Twitter page at https://twitter.com/personalization. Corresponding settings can also be made.

Data processing via cookies used by Twitter can also be prevented by settings in the browser.

9.4 LinkedIn
In our online services, we refer to our profiles on the social network LinkedIn. We operate a social media presence on LinkedIn, which we use to display photos and posts about our company, provide information about our services, publish job advertisements and communicate with customers. When you use and access our LinkedIn page, your data is processed by the Irish-based company LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland and the US-based LinkedIn Corporation, 1000 W Maude Ave, Sunnyvale, CA 94085 (hereinafter referred to as “LinkedIn”). Among other things, LinkedIn enables a system in which LinkedIn distributes advertising via its network.

If you access our LinkedIn profile, your data will be transmitted to LinkedIn in the USA. This data transfer is justified by the adequacy decision of the EU Commission. The LinkedIn Corporation participates in the DPF (https://www.dataprivacyframework.gov/).

We analyze the views and interactions on our LinkedIn page. For this purpose, LinkedIn creates user profiles, but only provides us with anonymous data, so-called page analyses. This is summarized data that provides us with information about how users interact with our LinkedIn page. The statistics compiled are only transmitted to us in anonymized form. We do not have access to the underlying data. With regard to this analysis service, we process your personal data together with LinkedIn. For this reason, we have concluded a joint controller agreement with LinkedIn (Art. 26 GDPR, https://legal.linkedin.com/pages-joint-controller-addendum).

You can access our LinkedIn page regardless of whether you have a LinkedIn user account or not. We process your personal data when you interact with our LinkedIn page, e.g. by posting a comment, clicking a Like button or sending us a message. We do not pass the data on to other third parties. The LinkedIn terms of use also apply: https://ch.linkedin.com/legal/user-agreement?trk=hb_ft_userag.

The legal basis for this data processing is our legitimate interest in customer loyalty and the presentation of our services (Art. 6 (1) (f) GDPR). LinkedIn users can assert their own rights with LinkedIn, e.g. revoke or delete a comment or a like.

LinkedIn offers the possibility to object to certain data processing; relevant information and opt-out options can be found at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out?trk=microsites-frontend_legal_cookie-policy.

LinkedIn users can influence the extent to which their usage behavior may be recorded when they visit our LinkedIn page at https://www.linkedin.com/psettings/advertising.

Data processing via cookies used by LinkedIn can also be prevented by browser settings.

LinkedIn only transfers user data to countries for which there is an adequacy decision by the European Commission in accordance with Art. 45 GDPR or on the basis of suitable guarantees in accordance with Art. 46 GDPR. For this purpose, the conclusion of the EU standard data protection clauses is intended

10 Your rights as a data subject

We are pleased to inform you below about the rights that you have as a data subject with regard to the processing of your personal data by us.

10.1 The right to information
You have the right to request confirmation from us as to whether your personal data is being processed. If this is the case, you have the right to obtain information about the personal data collected, stored or used about you and the following information:

The purposes of processing;
the recipients or categories of recipients to whom we have disclosed or will disclose the personal data
if possible, the planned duration for which we will store the personal data or, if this is not possible, the criteria for determining this duration;
the existence of other rights (see below);
if the personal data is not collected from you, all available information about its origin;
– the existence of automated decision-making, including profiling, and, where applicable, further information on this.
You have the right to be informed of the appropriate safeguards pursuant to Art. 46 GDPR if your data is transferred to a third country or an international organization.

10.2 Right to rectification
You have the right to obtain from us without undue delay the rectification of inaccurate or incomplete personal data concerning you.

10.3 Right to erasure
You can request that we delete the personal data concerning you immediately. To request the erasure of personal data, you can send an email to privacy@bionicdogtoys.com. We are obliged to delete your personal data immediately if one of the following reasons applies:

– Your personal data are no longer necessary for the purposes for which we collected or otherwise processed them.

– You withdraw your consent and there is no other legal basis for the processing.

– You object to the processing (see below).

– Your personal data has been processed unlawfully.

– The deletion of your personal data is necessary for us to fulfil a legal obligation under Union law or the law of the member states.

– We have collected the personal data on the basis of a child’s consent.

10.4 Right to restriction of processing
You have the right to demand that we restrict processing if one of the following conditions is met:

You contest the accuracy of the personal data.
The processing of the data is unlawful and you oppose the erasure of the personal data and request the restriction of the use of the personal data instead.
We no longer need the personal data for the purposes of the processing, but you require the data for the establishment, exercise or defense of legal claims; or
You have objected to the processing (see below) and it is not yet clear whether our legitimate grounds override yours.

10.5 Right to information
If you have asserted the right to rectification, erasure or restriction of processing against us, we are obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right vis-à-vis us to be informed about these recipients.

10.6 Right to data portability
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. You also have the right to transmit this data to another controller without hindrance from us, provided that

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

In exercising this right, you may request that the personal data concerning you be transmitted directly by us to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this. The right to data portability does not apply to the 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.

10.7 Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on one of the following grounds

the processing of your personal data by us is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental freedoms which require protection of your personal data.

You also have the right to object to pro-filing based on this processing.

If we process your personal data for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing. This also applies to profiling insofar as it is associated with such direct advertising.

You also have the right to object, on grounds relating to your particular situation, to processing of personal data concerning you which we process for scientific or historical research purposes or statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

10.8 Right to withdraw consent under data protection law
You can revoke your consent to us at any time with effect for the future. You can withdraw your consent informally at any time, e.g. by sending us an e-mail. However, this does not affect the lawfulness of the processing carried out up to the time of revocation.

10.9 Right to lodge a complaint with the supervisory authority
Do you believe that the processing of your personal data violates applicable law? Then you have the right to lodge a complaint with a supervisory authority, in particular in your country of residence or place of work or the place of the alleged infringement. If you have any doubts, you can contact Marit Hansen, ULD – Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein, (e-mail: mail@datenschutzzentrum.de, Holstenstraße 98, 24103 Kiel, phone: 0431 988-1200, fax: 0431 988-1223), who is responsible for us. In addition to exercising this right, any other administrative or judicial remedy remains unaffected.

Status: May 2024

KG Hagen Deutschland GmbH & Co.