Klöckner Pentaplast companies' website privacy policy

Effective: May 2018

This notice describes in detail on the basis of the EU General Data Protection Regulation (GDPR) that KP Holding GmbH & Co. KG and its subsidiaries ("Klöckner Pentaplast Companies") have adopted in order to address our concerns about privacy, concerns we know you share ("Privacy Policy"). This Privacy Policy describes the types of information we collect on this website (the "Klöckner Pentaplast Website"), how and for which purpose that information may be used, and with whom that information may be shared. This Privacy Policy also describes the measures we take to protect the security of the information collected, and the choices you, as a user of the Klöckner Pentaplast Website, can make about how and for which purpose we use the information you provide to us. Finally, this Privacy Policy tells you how you can contact KP Holding GmbH & Co. KG, the administrator of the Klöckner Pentaplast Website, in the event that you have any questions or concerns about our Privacy Policy or any information which we have collected from you or that you have provided to us.

Content

  1. Responsible within the meaning of Art. 4 para. 7 GDPR
  2. Communication via contact form/telephone/email/post
  3. Data processing of contact persons
  4. Applications
  5. Data processing for marketing purposes
  6. Newsletter subscription
  7. Investor Portal
  8. Cookies and web beacons
  9. Encryption
  10. Your rights as a data subject
  11. No obligation to provide personal data
  12. Links to other sites
  13. Contact data of the Data Privacy Officer
Unless otherwise stated in the individual sections (highlighted by the headings) of this Privacy Policy, the…

KP Holding GmbH & Co. KG
P.O.Box 1165, 56401 Montabaur
Industriestraße 3-5
56412 Heiligenroth
Germany
Phone: +49 (0) 2602 915 0
Fax: +49 (0) 2602 915 297
Email: kpinfo@kpfilms.com

is the controller of the data within the meaning of Art. 4 para. 7 GDPR.
Purpose of data processing/legal basis:
Personal information that you provide to us when filling out contact forms, by telephone, e-mail, post or in direct contact, will of course be treated confidentially. We use your data exclusively for a specific purpose in order to process your enquiries. The legal basis for data processing is Art. 6 para. 1 f) GDPR. The justified interest on the part of KP arises from the interest in answering inquiries from customers and interested parties and thus to maintain and promote their satisfaction.

Recipients/categories of recipients:
As a matter of principle, we do not pass on the data to third parties outside the kp Group. Within the kp Group your data will be passed on for processing your inquiry, among other things. Exceptionally, data are processed by order processors on our behalf. These are carefully selected, audited by us and contractually bound by Art. 28 GDPR. An overview of all kp Group companies can be found here.

Storage duration/criteria for defining the storage duration:
All personal data that you provide us with enquiries will be deleted or anonymized by us at the latest 90 days after the final reply to you. The retention of 90 days is explained by the fact that it can happen in isolated cases that you as a customer or prospective customer must contact us again after an answer to the same thing and we must then be able to refer to the preliminary correspondence. Experience has shown that after 90 days there are usually no more questions about our response.
Purpose of data processing/legal basis:
Klöckner Pentaplast Group companies process contact information from customers, prospects, suppliers and other business partners for communication by e-mail, telephone, fax and mail. In addition, the contact details of the contact persons are also processed in the Finance section as part of the master data of business partners.
The legal basis for data processing is Art. 6 para. 1 f) GDPR. The legitimate interest on the part of kp arises from the interest to conduct or initiate the business relationship with customers, interested parties, suppliers and other business partners and to maintain personal contact with contact persons.

Recipients/categories of recipients:
As a matter of principle, we do not pass on the data to third parties outside the kp Group. Within the kp Group, your data will be passed on for the purpose of carrying out or initiating the business relationship, among other things. An overview of all kp Group companies can be found here. Exceptionally, data are processed by order processors on our behalf. These are carefully selected, audited by us and contractually bound by Art. 28 GDPR.

Storage duration/criteria for defining the storage duration:
Personal data will be stored for the purpose of conducting business relations for as long as there is a legitimate interest in doing so. Especially in the area of finance, contact details of contact persons may be subject to statutory retention periods and must be stored for the duration of these periods.
Klöckner Pentaplast Group companies are constantly on the lookout for qualified and motivated employees. Please note that applications that you send us by e-mail will be sent to us unencrypted. We therefore recommend the use of the online application program.

Purpose of data processing, legal basis and functioning:
All information and attachments that you save in your profile and send with an application will be processed by us exclusively for processing the application you submitted via the profile.

You can create a personal profile with a personal password on the KP Online Applicant Portal. The data of your profile can be viewed by us at any time. We use an encryption method for the online transmission of your applicant data in this system, so that your data is protected from unauthorized access.

As soon as you create a concrete application via your profile and send it to us, our recruiters will have the right of access to your application data.

The legal basis for the processing of data within the application process is in principle Art. 6 Para. 1 b) GDPR, or Art. 88 GDPR in conjunction with the National Data Protection Act applicable in your country provided that your country has made use of the opening clause in Art. 88 GDPR and has regulated the processing of data in the context of application and employment relationships nationally.

In Germany this is new in connection with § 26 Paragraph 1 Sentence 1 BDSG. Art. 88 GDPR.

The legal basis for a kp internal forwarding and processing of your application data for other positions or within the framework of an applicant pool is your consent pursuant to Art. 6 para. 1 a) GDPR. In addition, we will never pass on your application to third parties.
Purpose of the data processing/legal basis:
The companies in the Klöckner Pentaplast (kp) Group use personal data for marketing purposes, in particular for advertising by email, phone and post. The purpose of this data processing in a marketing context is to inform data subjects of products and services that are offered by the companies in the kp Group. The legal basis for sending advertising material by post is Art. 6 (1) (f) GDPR. In this connection, kp’s legitimate interest arises out of its interest in sending customers and interested parties information about products and services. The legal basis for marketing initiatives by email or phone is normally a declaration of consent provided by you. For marketing initiatives involving existing customers there are additional legal bases contained in special legislation based on DIRECTIVE 2002/58/EC .

You can refuse consent to receive future advertising at any time by fill out the form on this page.

Recipients/categories of recipient:
We unequivocally assure you that we do not pass on your data to third parties outside the kp Group. Within the kp Group your data are passed on for purposes including that of initiating or developing a business relationship with you. You will find an overview of all the companies in the kp Group here. In exceptional cases, data is processed by processors on our behalf. These are in every instance carefully selected, audited by us and under contractual obligation in accordance with Art. 28 GDPR.

Storage period/criteria for determining the storage period:
If you refuse your consent to receive advertising, we will immediately block access to your data and then erase it, provided that it is not required for other purposes.
Purpose of data processing/legal basis:
You have the opportunity to order the free kp Newsletter through this website and other channels (by phone, in person at trade fairs, etc.). The legal basis for data processing in the context of sending newsletters is your consent in accordance with Art. 6 para. 1 a) GDPR. Purpose of the data processing in the context of the order of the kp newsletter is the information of the newsletter subscribers to products and services of the enterprises of the kp group. The newsletter is sent irregularly, but usually not more than four times a year per division.

As far as you register for the free kp Newsletter, we need your email address as mandatory. If you voluntarily provide additional information about yourself (name, surname, last name, company, country, selection newsletter), we use this data only to offer the newsletter in your own language if possible and to address you personally. The specification of your company is for information purposes only.

After submitting the registration form you will receive an email with a confirmation link. If you click on the link contained in it, you are registered for the newsletter. This will be displayed by forwarding you to a confirmation page. By confirming the registration, you agree that you agree with the described processing of your e-mail address and any optional data provided.

The consent to order the newsletter can be withdrawn at any time with effect for the future, by pressing the corresponding unsubscribe link in one of the newsletters or write a message to newsletter@kpfilms.com.

Recipients/categories of recipients:
In principle, we do not disclose the data to third parties outside the kp Group. Within the kp Group, your data will be used i.a. to conduct or initiate the business relationship. An overview of all kp Group companies can be found here.
Insofar as external newsletter processors are used to carry out the newsletter, they are contractually obligated pursuant to Art. 28 GDPR and have accordingly been checked for provision of suitable organizational and technical security measures.

Storage duration/criteria for determining storage duration:
If you revoke your consent to receive the kp Newsletter, your data will be blocked immediately and then deleted. As a result, you will no longer receive the kp Newsletter.
Purpose of data processing/legal basis:
As an investor in the kp Group or as an interested party, you have the opportunity to register for the Investor Portal on this homepage. You can then retrieve current information in the portal on a regular basis, which is relevant in this regard. The storage of your data, which you must provide at registration, is based on your consent. You can revoke this consent at any time. We need your data to inform you about new figures and investor relations topics of the kp Group. In the case of a registration, you will be informed quarterly by email about the next investor call and investor related figures.

Recipients/categories of recipients:
Your data will only be managed by kp Group companies. An overview of all kp Group companies can be found here.

Storage duration/criteria for determining storage duration:
Your personal data will be stored as long as you are registered in the Investor Portal.
When you visit the Klöckner Pentaplast website, your browser automatically sends us certain Internet-related information (such as Internet Protocol or IP address of the computer you are using). The Klöckner Pentaplast website may also use cookies and web beacons in order to better understand how visitors use the Klöckner Pentaplast website so that they may improve your user experience. The cookies and web beacons will be deleted no later than after such statistical evaluation has been completed.

Cookies are small text files that websites often store on the computer hard drives of visitors to their sites. A cookie contains a unique code, which is used to recognize your computer when a user of your computer returns to a website that was visited previously. Web beacons are Internet tools that help us determine, for example, whether a website page has been viewed. The Klöckner Pentaplast website uses cookies and web beacons to enhance the online experience of our visitors and to better understand how the Klöckner Pentaplast website is used. Cookies and web beacons may indicate, for example, whether you have visited the Klöckner Pentaplast website before or whether you are a new visitor.

Cookies and web beacons on the Klöckner Pentaplast website cannot be used to run programs or deliver viruses to your computer. They are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie or web beacon to you and will solely be used for the purpose of call control/recognition in the event of the repeated use of the homepage. The Klöckner Pentaplast website does not match your personally identifiable information with the cookie or web beacon assigned to you. We will not share or sell non-aggregated information contained within cookies or web beacons with any third party. You have the ability to accept or decline cookies or web beacons. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies and Web beacons. The "help" button on the toolbar of most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. However, please note that if cookies and/or web beacons are disabled, you may not be able to use the full range of services or features of the website.


8.1 Usage data about your visit to our website

Purpose of data processing and legal basis
Information that arises during your use of our Internet pages (these are: the page from which the file was requested, the name of the file, the date and time of the query, the amount of data transferred, the access status such as "file transferred", "file not found", etc.), A description of the type of web browser used and an anonymous IP address - shortened by the last three digits by the Google Analytics program) are used by us for user guidance, for statistical evaluations, to adapt our web pages to your needs and to prevent irregular queries to our web offer. We use temporary and permanent cookies to control your connection to our websites during the session. No personal data will be stored or processed in any other way. The cookie only allows us to identify you as a unique but unknown user during your visit to the site.

Klöckner Pentaplast uses pseudonyms to create user profiles. The user profiles are not merged with the data of the bearer of the pseudonym. According to DIRECTIVE 2002/58/EG, you have the right to object to the creation of user profiles. You can exercise this right by sending us an e-mail to kpinfo@kpfilms.com In creating user profiles, the Klöckner Pentaplast Companies comply with the strictest applicable security standards.

Recipients/categories of recipients:
Access to the cookies stored in your system for these purposes is not given.

Storage duration/criteria for defining the storage duration:
We do not store your user data for longer than three months.


8.2 Web tracking using Google Analytics

Purpose of data processing/legal basis:
We create pseudonymous user profiles with the help of Google Analytics for the demand-oriented design of our website. Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, because we have activated IP anonymisation on this website, your IP address will first be reduced by Google within Member States of the European Union or in other states party 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. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing us with other services relating to website activity and internet usage.

You can object to the creation of pseudonymous user profiles at any time. There are several ways to do this:

  1. One way to object to web analysis by Google Analytics is to set an opt-out cookie that instructs Google not to store or use your data for web analysis purposes. Please note that with this solution the web analysis will only not take place as long as the opt-out cookie is stored by the browser. If you would like to set the opt-out cookie now, please click here.
  2. you can also prevent the storage of the cookies used to create your profile by adjusting your browser software accordingly.

Depending on the browser you are using, you may be able to install a browser plug-in that prevents tracking. Please click here and install the browser plugin available there.

The legal basis is your for this data processing is your consent according to art. 6 para. 1 lit.a) GDPR.

Recipients/categories of recipients:
Your data will only be processed by companies of the kp group and the service provider Google commissioned by us.

Storage duration/criteria for defining the storage duration:
Personal data is not stored by using Google Analytics.


8.3. Webtracking via Act-On beacon

Purpose of data processing / legal basis:
For the appropriate configuration of our website we create with your consent pseudonymous user profiles using act-on "beacons". A beacon is a pixel-sized file that is retrieved from the server of the software provider Act-On when you visit our website. Information is also captured when you visit custom landing pages built within the platform (those URL’s would start with “marketing.kpfilms.com”). Within the framework of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected. In addition, a distinction can be made between known and unknown visitors. If you have already filled out our contact form, you have already had e-mail contact with us or you have shared your contact information with us in some other way, we can recognise you and allocate the information. If you access our website from another technical device, this information will also be linked to allocate this information to you.

The information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined by means of the IP address) or the access times. Statistical surveys also include determining when a website was visited and which links were clicked. This information can be assigned to individual website visitors. The evaluations help us to better understand the customer behaviour of our users and to adapt our contents to them or to send different contents according to the interests of our users.

To do this, we use a system that alerts us when a certain level of activity is reached (e.g., certain pages are accessed more often, documents downloaded,…). If you have given your prior consent, we may contact you in this case to discuss products you may be interested in. Kindly note that the Klöckner Pentaplast Group is only providing B2B solutions and is not offering its products directly to consumers. It is also used to analyse website traffic and behaviour patterns, which in turn will help kp make the website more user-friendly.

The information generated by the beacon about your use of this website is generally transmitted to and stored on Act-On's server in Ireland. However, if it cannot be excluded that your data is transferred to third countries, we have concluded standard contractual clauses with our service provider. Act-On will use this information to evaluate your use of the website for us, to compile reports on website activity and to provide other services to us related to website and internet usage.

You can revoke your consent to the creation of the pseudonymous user profiles at any time. If you wish to revoke your consent to the web analysis by Act-On, please update your cookie preferences disabling the statistic cookies using this link. In any event an opt-out option will always be included in any e-mails generated using the Act-On web analysis tool that you would receive from us.

The legal basis for this data processing is your consent pursuant to Art. 6 para. 1 sentence 1 lit. a) DSGVO.

Recipients/ categories of recipients:
Your data collected here will only be processed by companies in the KP Group and by Act-On, the service provider commissioned by us.

The external processor has been contractually obliged by us in accordance with Art. 28 DSGVO and has been checked accordingly for the provision of suitable organisational and technical security measures.

Storage period/ Criteria for determining the storage period:
We will store your data for no longer than three (3) years after your last interaction with us. If you revoke your consent to data processing within the scope of the Act-On beacon, your data will be deleted immediately.

8.4. Webtracking via hotjar

Purpose of data processing / legal basis:
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
We take technical and organizational security measures to protect your data from unwanted access as comprehensively as possible. In addition to securing the operating environment, we also use encryption methods. The information you provide is transmitted in encrypted form using an SSL protocol (Secure Socket Layer) and authenticated to prevent misuse of the data by third parties. You can recognize this by the fact that the lock symbol is closed in the status bar of your browser and the address line is marked with "https" at the beginning.
The data subject has the right to request a statement from the data controller as to whether personal data relating to him or her is being processed; if this is the case, he or she has the right to be informed about this personal data and the right to the information referred to in detail in Art. 15 GDPR.

The data subject has the right to require that inaccurate personal data relating to him or her be immediately rectified by the data controller and, where applicable, that incomplete personal data be completed (Art. 16 GDPR).

The data subject has the right to request that personal data relating to him or her be immediately erased by the data controller where one of the grounds referred to in Art. 17 GDPR applies, for example when the data is no longer needed for the intended purposes (right to erasure).

The data subject has the right to request that the data controller restricts processing where one of the conditions referred to in Art. 18 GDPR applies, for example if the data subject has objected to processing, for a period enabling the controller to examine the matter.

The data subject has a right to data portability under the conditions of Art. 20 DSGVO

The data subject has the right, on grounds relating to his or her particular situation, to object at any time to the processing of personal data relating to him or her. The controller shall no longer process the personal data, unless he or she is able to demonstrate legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims (Art. 21 GDPR).

Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes the GDPR (Art. 77 GDPR). The data subject can exercise this right with a supervisory authority in the member state in which he or she resides or works or in which the alleged infringement took place.

In any of the above cases, or if you have an unresolved query or wish to make a complaint, please contact us in writing, or use the form on this page.
Apart from under the circumstances described in the previous sections, the provision of personal data is not required, either contractually or by law or for the conclusion of a contract. You are not under obligation to make personal data available unless information to the contrary has been provided beforehand. The non-provision of your personal data can, under certain circumstances, mean that we cannot answer your contact request or enter into a business relationship.
Occasionally we provide links to other websites for your convenience and information. These sites operate independently and are not under our control. These sites may have their own privacy policies in place, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites. We reserve the right to terminate any link at any time, and the inclusion of any link does not constitute or imply an endorsement, authorisation, sponsorship or affiliation by or between us and the linked website, or any of the products or services provided therein. If you access any of the websites linked to the Klöckner Pentaplast website, you do so entirely at your own risk.
You can contact the Data Protection Officer of the German KP companies under the following contact details:

Fieldfisher (Germany) LLP
Dr. Felix Wittern
Am Sandtorkai 68
20457 Hamburg
Germany
+49 (0)40 878 869 81 14
felix.wittern@fieldfisher.com