Data protection

 Data protection

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Data Protection Declaration
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1) Information on the Collection of Personal Data and Contact Details of the

Controller
1.1 We are pleased that you are visiting our website and thank you for your

interest. In the following, we inform you about the handling of your personal data

when using our website. Personal data is all data with which you can be personally

identified.
1.2 The controller in charge for data processing on this website within the meaning

of the General Data Protection Regulation (GDPR) is Drawin Trading GmbH,

Zugspitzstr. 15, 82049 Pullach, Deutschland, Tel.: +49 89 74495191, E-Mail:

info@drawin-trading.com. The controller in charge of the processing of personal

data is the natural or legal person who alone or jointly with others determines the

purposes and means of the processing of personal data.
1.3 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

inquiries to the controller). You can recognize an encrypted connection by the

character string https:// and the lock symbol in your browser line.

2) Data Collection When You Visit Our Website
When using our website for information only, i.e. if you do not register or

otherwise provide us with information, we only collect data that your browser

transmits to our server (so-called "server log files"). When you visit our website,

we collect the following data that is technically necessary for us to display the

website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the

basis of our legitimate interest in improving the stability and functionality of

our website. The data will not be passed on or used in any other way. However, we

reserve the right to check the server log files subsequently, if there are any

concrete indications of illegal use.

3) Cookies
In order to make your visit to our website attractive and to enable the use of

certain functions, we use so-called cookies on various pages. These are small text

files that are stored on your end device. Some of the cookies we use are deleted

after the end of the browser session, i.e. after closing your browser (so-called

session cookies). Other cookies remain on your terminal and enable us or our

partner companies (third-party cookies) to recognize your browser on your next

visit (persistent cookies). If cookies are set, they collect and process specific

user information such as browser and location data as well as IP address values

according to individual requirements. Persistent cookies are automatically deleted

after a specified period, which may vary depending on the cookie.
If personal data are also processed by individual cookies set by us, the processing

is carried out in accordance with Art. 6 (1) point b GDPR either for the execution

of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our

legitimate interests in the best possible functionality of the website and a

customer-friendly and effective design of the page visit.
We work together with advertising partners who help us to make our website more

interesting for you. For this purpose, cookies from partner companies are also

stored on your hard drive when you visit our website (third-party cookies). You

will be informed individually and separately about the use of such cookies and the

scope of the information collected in each case within the following sections.
Please note that you can set your browser in such a way that you are informed about

the setting of cookies and you can decide individually about their acceptance or

exclude the acceptance of cookies for certain cases or generally. Each browser

differs in the way it manages the cookie settings. This is described in the help

menu of each browser, which explains how you can change your cookie settings. You

will find these for the respective browsers under the following links:
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-

internet-explorer-delete-manage-cookies
Firefox: https://www.mozilla.org/en-US/privacy/websites/#cookies
Google: https://support.google.com/accounts/answer/61416?co=GENIE.Platform

%3DDesktop&hl=en
Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-

data-sfri11471/mac
Opera: http://help.opera.com/Windows/10.20/en/cookies.html
Please note that the functionality of our website may be limited if cookies are not

accepted.

4) Contacting
In the context of contacting us (e.g. via contact form or e-mail), personal data is

collected. Which data is collected in the case of a contact form can be seen from

the respective contact form. These data are stored and used exclusively for the

purpose of responding to your request or for establishing contact and for the

associated technical administration. The legal basis for processing data is our

legitimate interest in responding to your request in accordance with Art. 6 (1)

point f GDPR. If your contact is aimed at concluding a contract, the additional

legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be

deleted after final processing of your enquiry; this is the case if it can be

inferred from the circumstances that the facts in question have been finally

clarified, provided that there are no legal storage obligations to the contrary.

5) Use of Your Data for Direct Advertising
If you subscribe to our e-mail newsletter, we will send you regular information

about our offers. The only mandatory information for sending the newsletter is your

e-mail address. The indication of additional possible data is voluntary and is used

to be able to address you personally. We use the so-called double opt-in procedure

for sending the newsletter. This means that we will not send you an e-mail

newsletter, unless you have expressly confirmed to us that you agree to the sending

of the newsletter. We will then send you a confirmation e-mail asking you to

confirm that you wish to receive future newsletters by clicking on an appropriate

link.
By activating the confirmation link, you give us your consent to the use of your

personal data in accordance with Art. 6 (1) point a GDPR. When you register for the

newsletter, we store your IP address entered by the Internet Service Provider (ISP)

as well as the date and time of registration so that we can trace any possible

misuse of your e-mail address at a later time. The data collected by us when

registering for the newsletter will be used exclusively for the purpose of

advertising by means of the newsletter. You can unsubscribe from the newsletter at

any time via the link provided in the newsletter or by sending a message to the

responsible person named above. After your cancellation, your e-mail address will

immediately be deleted from our newsletter distribution list, unless you have

expressly consented to further use of your data or we reserve the right to use data

in excess thereof, which is permitted by law and about which we inform you in this

declaration.

6) Tools and Miscellaneous
6.1 On this website we also use the reCAPTCHA function of Google LLC, 1600

Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). This function is

mainly used to distinguish whether an entry is made by a natural person or misused

by automatic and automated processing. The service includes the sending of the IP

address and possibly other data required by Google for the reCAPTCHA service to

Google and is carried out in accordance with Art. 6 (1) point f GDPR on the basis

of our legitimate interest in determining the individual willingness of actions on

the Internet and avoiding misuse and spam.
Google LLC, based in the United States, is certified for the US-European data

protection agreement "Privacy Shield", which guarantees compliance with the data

protection level applicable in the EU.
Further information about Google reCAPTCHA and Google's privacy policy can be found

at: https://policies.google.com/privacy?hl=en-GB
6.2 Google Maps
Our website uses Google Maps (AP’I) of Google LLC., 1600 Amphitheatre Parkway,

Mountain View, CA 94043, USA (“Google”). Google Maps is a web service for

displaying interactive (country) maps in order to display geographical information

visually. Using this service will show you our location and will make it easier for

you to find us.
When you access the sub-pages that contain the Google Maps map, information about

your use of our website (such as your IP address) is transmitted to and stored by

Google on servers in the United States. This is regardless of whether Google

provides a user account that you are logged in with or whether no user account

exists. If you are logged in to Google, your information will be directly

associated with your account. If you do not wish to be associated with your profile

on Google, you must log out before activating the button. Google saves your data

(even for users who are not logged in) as usage profiles and evaluates them. Such

an evaluation takes place according to Art. 6 (1) point f GDPR on the basis of the

legitimate interests of Google in the insertion of personalized advertising, market

research and/or demand-oriented design of its website. You have the right to object

to the creation of these user profiles. If you want to do so, you must contact

Google to exercise this right.
Google LLC, based in the United States, is certified for the US-European data

protection agreement "Privacy Shield", which guarantees compliance with the data

protection level applicable in the EU.
If you do not agree to the future transmission of your data to Google in the

context of using Google Maps, you may completely deactivate the Google Maps web

service by switching off the JavaScript application in your browser. In this case,

Google Maps as well as the map display on this website cannot be used.
The Google terms of use can be found at: https://policies.google.com/terms?hl=en.

The additional terms of use can be found at: https://www.google.com/intl/en-

US_US/help/terms_maps.html.
You can find detailed information on data protection in connection with the use of

Google Maps on Google's website ("Google Privacy Policy") at:

https://policies.google.com/privacy?hl=en.

7) Rights of the Data Subject
7.1 The applicable data protection law grants you comprehensive rights of data

subjects (rights of information and intervention) vis-à-vis the data controller

with regard to the processing of your personal data, about which we inform you

below :
- Right of access by the data subject pursuant to Art. 15 GDPR
- Right to rectification pursuant to Art. 16 GDPR
- Right to erase (“right to be forgotten”) pursuant to Art. 17 GDPR
- Right to restriction of processing pursuant to Art. 18 GDPR
- Right to be informed pursuant to Art. 19 GDPR
- Right to data portability pursuant to Art. 20 GDPR
- Right to withdraw a given consent pursuant to Art. 7 (3) GDPR
- Right to lodge a complaint pursuant to Art. 77 GDPR
7.2 RIGHT TO OBJECT
IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL

DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY

TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT

ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED.

HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING

REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS,

FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR

DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT

TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR

DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED

FOR DIRECT ADVERTISING PURPOSES.

8) Duration of Storage of Personal Data
The duration of the storage of personal data is determined by the respective legal

retention period (e.g. commercial and tax retention periods). After expiry of this

period, the corresponding data will be routinely deleted, provided they are no

longer necessary for the performance or initiation of the contract and/or there is

no longer any legitimate interest on our part in the further storage.
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