Privacy Policy

Information on the nature, scope and purpose of the processing of personal data by PENSAKI GmbH under the GDPR.

Convenience translation only

This page contains an English convenience translation of the German Privacy Policy, “Datenschutzerklärung”, of Pensaki GmbH.

This translation is provided solely for the convenience of English speaking users. In the event of any discrepancy, inconsistency, ambiguity or conflict between this English translation and the German version, only the German version shall prevail.

The German version is the sole legally binding and controlling version and shall be the only relevant version for interpretation and enforcement.

View the legally binding German version

1. Scope

This Privacy Policy informs users of pensaki.com about the nature, scope and purposes of the collection and use of personal data by Pensaki GmbH, Reilsheimer Strasse 15, 69245 Bammental, Germany, referred to as Pensaki. It applies to our online offering, associated websites, functions and content, and external online presences such as social media profiles. The terms personal data and processing are used as defined in Article 4 GDPR.

2. Principles and definitions

Pensaki collects and uses personal data only where required to provide and bill for pensaki.com or where another legal basis or consent applies. Personal data includes master data, contact data, content data, contract data, payment data, usage data, and meta and communication data. No special categories of data under Article 9(1) GDPR are processed. Data subjects include customers, prospective customers, suppliers, visitors and users. Processing purposes include providing the online offering, performing contracts, customer service, responding to enquiries, marketing, advertising, market research and security. During registration, Pensaki collects an email address and password as login data and company name, name, postal address and VAT number as billing data. Login data is transmitted using HTTPS encryption and passwords are stored in encrypted form. Server log files may contain IP address, referrer, date and time, requested file, transferred data volume, and browser information. These logs are used for security, troubleshooting and optimisation. Status: 1 May 2018.

1. Applicable legal bases

2. Changes and updates to the Privacy Policy

3. Security measures

4. Cooperation with processors and third parties

Where third parties process data under a data processing agreement, this is done in accordance with Article 28 GDPR.

5. Transfers to third countries

6. Rights of data subjects

Under Articles 16 to 20 GDPR, data subjects may request correction, completion, deletion, restriction of processing and data portability. Under Article 77 GDPR, they may lodge a complaint with the competent supervisory authority.

7. Right to withdraw consent

8. Right to object

9. Cookies and objection to direct marketing

Users may object to cookies used for online marketing through aboutads.info or youronlinechoices.com and may disable cookies in browser settings. Some functions of the online offering may then be unavailable.

10. Deletion of data

Data is retained in accordance with statutory requirements, in particular for six years under section 257(1) of the German Commercial Code and for ten years under section 147(1) of the German Fiscal Code.

11. Performance of contractual services

All users must create a user account to use Pensaki.com. User accounts are not public and cannot be indexed by search engines. Following termination, account data is deleted unless commercial or tax law retention duties apply. During registration, login and use of online services, Pensaki stores IP addresses and timestamps to protect against misuse. Usage and content data may be processed for advertising purposes in user profiles. Retention needs are reviewed regularly and data is deleted after expiry of applicable statutory periods.

12. Contact

When users contact Pensaki through a contact form or by email, their information is processed under Article 6(1)(b) GDPR to handle the enquiry. Information may be stored in a CRM or comparable enquiry management system. Pensaki uses Zoho CRM on the basis of legitimate interests in efficient enquiry handling. Enquiries are deleted when no longer required, subject to statutory retention duties.

13. Comments and contributions

If users leave comments or other contributions, their IP addresses are stored for seven days on the basis of Article 6(1)(f) GDPR to protect Pensaki where unlawful content is posted.

14. Collection of access data and log files

On the basis of Article 6(1)(f) GDPR, Pensaki collects server log data including the requested page, file, date and time, transferred data volume, successful access status, browser, operating system, referrer URL, IP address and provider. Log information is stored for security purposes for up to seven days unless longer retention is required as evidence.

16. Cookies and audience measurement

Pensaki uses session cookies that are stored only for the current visit, for example to retain login status or enable the shopping cart. Session cookies are deleted when the user logs out or closes the browser. Cookies may be disabled or deleted in browser settings, although this may restrict functionality. Users may object to audience measurement and advertising cookies through industry opt out pages.

17. Google Analytics

Pensaki uses Google Analytics on the basis of legitimate interests under Article 6(1)(f) GDPR. Google uses cookies and may transmit usage information to servers in the United States. Google acts on Pensaki's behalf to evaluate use, compile reports and provide related services. Pseudonymous user profiles may be created. Pensaki uses IP anonymisation. Users may prevent cookie storage in browser settings and may use Google's browser opt out plugin.

18. Google marketing and remarketing services

Pensaki may use Google marketing and remarketing services on the basis of legitimate interests. These services may use cookies, marketing tags and web beacons to display more relevant advertising and measure conversions. Services may include Google Ads, DoubleClick, AdSense, Google Optimizer and Google Tag Manager. Further information and opt out settings are available from Google.

19. Facebook Custom Audiences and marketing services

Pensaki may use the Facebook Pixel on the basis of legitimate interests in analysis, optimisation and economic operation. The pixel may identify visitors as advertising audiences, create Custom Audiences and measure conversions. Users may manage advertising settings through Facebook and industry opt out pages.

20. Facebook social plugins

Pensaki may use Facebook social plugins on the basis of legitimate interests. A plugin can establish a direct connection between the user's device and Facebook servers. Facebook may receive information that a user accessed a page and may associate the visit with a Facebook account where the user is logged in. Users who do not want this association should log out and delete cookies before using the online offering.

22. Integration of third party services and content

Pensaki may integrate third party content and services, such as payment services, fonts, maps, videos, social media functions and JavaScript libraries, on the basis of legitimate interests. Third party providers may receive users' IP addresses and may use cookies or pixel tags. The German source text lists PayPal, Stripe, Google Fonts, Google Maps, YouTube, Vimeo, Google+, Instagram, LinkedIn, Pinterest, Twitter and jQuery together with links to their privacy information and opt out options.

23. Integration of Zoho SalesIQ

Zoho SalesIQ may collect anonymised usage data through cookies for statistical analysis, including referral source, visit frequency and duration. Tracking can be prevented through browser settings. IP addresses are shortened. Further information is available in Zoho's Privacy Policy and Cookie Policy.

This page is an English convenience translation of the German legal text. It does not replace the legally binding German version.