Data Protection Guidelines for the Facebook Webpage of “Sales Unit Telemarketing GmbH”
As you perhaps already know, the Europäische Gerichtshof [European Court of Justice] (“EuGH”) recently ruled that Facebook and a Facebook webpage operator are jointly responsible under data protection law for the data processing (EuGH, ruling of 05/06/2018; you can find more information here: http://curia.europa.eu/juris/document/document.jsf?text=&docid=202543&pageIndex=0&doclang=DE&mode=req&dir=&occ=first&part=1&cid=298398).
Thus, insofar as this is possible for us, we wish to inform you through this Data Protection Declaration regarding the processing of personal data when using the Facebook webpage of “Sales Unit Telemarketing GmbH” (“Fan Page”).
§ 1 Responsible Party, Data Protection Officer
The following parties are jointly responsible in accordance with the General Data Protection Regulation (“GDPR”) for the data processing during the operation of the Fan Page:
Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour Dublin 2
Sales Unit Telemarketing GmbH
Telephone: 0621 122 84 850
(“Sales Unit Telemarketing GmbH” or “we”)
As the operator of our Fan Page, we have concluded contractual agreements with Facebook regarding the usage of a fan page. You can review the relevant “Usage Terms and Conditions” of Facebook here: https://www.facebook.com/legal/terms
§ 2 Contact to the Data Protection Officer
You can contact Facebook’s Data Protection Officer here: https://www.facebook.com/help/contact/540977946302970
You can find the contact data of Sales Unit Telemarketing GmbH’s Data Protection Officer here: https://www.sales-unit.de/datenschutz/
§ 3 Data Processing for the Operation of the Fan Page
As the operator of the Fan Page, we use the “Facebook Insights” function which is provided by Facebook. Via Facebook Insights, we receive statistical data from Facebook (e.g. total number of impressions, “likes” data, page activities, etc.). These statistical data are provided to us only in anonymised form, i.e. we can categorise these data to no specific visitor of our webpage. We also have no access to the underlying data for the statistics.
So that Facebook can provide these data to us, Facebook places cookies on your devices by means of which you access the Fan Page. These cookies are small text files which contain a transparent user code. The cookies are active for the timeframe of two years unless you delete them before this timeframe lapses. Insofar as we know, Facebook uses the data collected via the cookies in order to provide you with advertising and in order to enable this also via Facebook’s affiliated companies as well as its advertising partners.
You can find additional information regarding the usage of cookies by Facebook at: https://www.facebook.com/policies/cookies/.
You can review additional information regarding the data processing done by Facebook in its Data Protection Declaration: https://www.facebook.com/about/privacy/.
§ 4 Purposes of the Processing
We maintain this Fan Page in order to be able to increase the awareness of our products and in order to communicate with you. In this regard, we also use the data provided via the “Facebook Insights” function. These data help us to be able to better understand your interests and to better reach our target group. Thus, we are able to provide targeted, interest-based advertising and to provide more relevant contents on our Fan Page. You can find additional information about us as well as our products on the following website: www.sales-unit.de. You can find our Data Protection Declaration here: https://www.sales-unit.de/datenschutz/.
Moreover, Facebook uses the data that it collects for market research and advertising purposes–thus particularly in order to analyse your behaviour, to create user profiles and to provide personalised advertising (including by mandate from third-party companies).
You can utilise an “opt-out” option here and influence which advertising is displayed to you in the future as a user of the Facebook service: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com You can make additional setting changes here: https://www.facebook.com/help/contact/367438723733209
§ 5 Data Dissemination
We shall pass on no personal data. However, we cannot exclude the dissemination and additional processing of personal data by Facebook to Facebook Inc. with its commercial residence in the USA or to other companies outside the EU and the related risks for affected persons. Facebook Inc. is certified in accordance with the so-called “Privacy Shield” and is thus obliged to follow the European data protection directives. You can find information regarding the Privacy Shield status of Facebook here: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
§ 6 Legal Basis
We maintain this Fan Page in order to be able to increase the awareness of our products and to communicate with you. The processing of personal data is done upon the basis of our rightful interests in accordance with Art. 6 Para. 1 Clause 1 lit. f GDPR in effective communication and interaction with the users as well as an optimised presentation of our products and services.
§ 7 Your Rights
It is more purposeful and most effective to submit information requests and to assert additional affected person’s rights to Facebook as the provider of the platform. This is also stated in the contractual agreement that we have concluded with Facebook as well as owing to the circumstance that only Facebook has the direct information as well as the database from which the statistics are compiled which are provided to us. If our support should be required, you can contact us at any time in this regard.
You shall have the following rights:
(a) Right of Information
You shall have the right to at any time submit a request to receive information regarding your personal data that we have processed in the scope of Art. 15 GDPR. In order to do so, you can submit a request via the postal service or by e-mail to the address listed below.
(b) Right of Correction of Incorrect Data
You shall have the right to demand that we promptly correct your personal data insofar as they are discovered to be incorrect. In order to do so, please use the contact addresses listed below.
(c) Right of Deletion
You shall have the right to demand that we delete your personal data subject to the fulfilment of the requirements prescribed in Art. 17 GDPR. These requirements prescribe particularly a right of deletion if the personal data are no longer required for the purposes for which they were collected or otherwise processed as well as in cases of illegal processing, the submission of an objection or the valid existence of a deletion obligation in accordance with the law of the European Union or the law of the member country to which we are subject. In order to assert your right of deletion, please use the contact addresses listed below.
(d) Right of Restriction of the Processing
You shall have the right to demand that we restrict the processing in accordance with Art. 18 GDPR. This right shall be valid particularly if the correctness of the personal data is disputed between the user and us for the timeframe which is required for the determination of the correctness of the data as well as in the case that the user, while holding a valid right to deletion, nonetheless demands restricted processing instead of deletion; furthermore, in the case that the data are no longer required for the purposes that we have been pursuing, but the user nonetheless requires them for the assertion, exercising or warding-off of legal claims as well as if the successful exercising of an objection is still being disputed between us and the user. In order to assert your right to right the processing, please use the contact addresses listed below.
(e) Right of Data Portability
You shall have the right to receive the personal data from us that you have provided to us in a structured, standard, machine-readable format in accordance with Art. 20 GDPR. In order to assert your right of data portability, please contact the following contact addresses below.
(f) Right to Lodge an Objection
You shall have the right, for reasons based upon your special situation, to at any time lodge an objection in accordance with Art. 21 GDPR to the processing of your personal data which is done, among others, in accordance with Art. 6 Para. 1 lit. e) or f) GDPR. We shall discontinue the processing of your personal data unless we can document mandatory reasons worthy of protection for the processing which outweigh your interests, rights and freedoms or if the processing serves the purpose of the assertion, exercising or warding-off of legal claims.
(g) Right of Revocation (in the case that a consent has been granted)
You shall have the right to revoke any consents that have been granted in accordance with Art. 7 Para. 3 GDPR with effectiveness for the future. The revocation of the consent shall not affect the legality of the processing done based upon the consent until it was revoked.
(h) Right to Lodge a Complaint
Moreover, you shall have the right to lodge a complaint to the competent government supervisory agencies.