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DATA PROTECTION DECLARATION




I. Who is responsible for the processing and who can I contact?

The controller for the processing of your personal data (hereinafter: data) is

Engelbert Strauss Ltd.
Unit 10
Ashburton Industrial Estate
Ross-On-Wye
HR9 7BW

You can find further contact details for the controller in the imprint.

If you have any questions, complaints or suggestions regarding data protection or if you want to obtain access to your personal data, please send an email to dataprotection@strauss.co.uk or a letter to the above address with the addition “Data Protection”.



II. Which data is processed?


1. Orders

We use data which you provide us with in the course of the order process (e.g. name, addresses, email addresses, bank details) to fulfil contracts or execute precontractual measures. We may also process the data you provide in order to inform you of other interesting products from our portfolio.

Why is this data processed?

Order processing: We process this data for purposes relating to accepting orders, shipping, billing, payment processing, customer service, debt collection and, where applicable, executing or defending against legal claims arising from the supply relationship. The legal basis is Article 6 (1)(b) GDPR. External service providers (call centre agencies) support us with order processing. These process your data exclusively according to our instructions and not for their own purposes. Should you fail to pay bills despite repeated reminders, we will, if necessary, transmit data to debt collection agencies for the purpose of fiduciary collection; the legal basis is also Article 6 (1)(f) GDPR.

Shipping of ordered goods: We cooperate with various transport companies in shipping the ordered goods. We forward the data required to deliver the ordered goods to these transport companies. If you order goods from third party vendors (additional purchase products), we may forward your data to these vendors for the purpose of direct shipping. Legal basis: Article 6 (1)(b) GDPR.

Credit check: We generally provide you with various payment options. If you choose an insecure payment method (e.g. purchase on account), we have a legitimate interest in protecting ourselves from possible defaults on payment. We may therefore obtain creditworthiness information from Experian, The Sir John Peace Building, Experian Way, NG2 Business Park, Nottingham NG80 1ZZ before allowing you to use these payment methods. For this purpose, we will transmit the personal data required for a credit assessment and use the information received on the statistical likelihood of a payment default for a balanced decision on the justification, execution or termination of the contractual relationship. The credit check may include probability values (score values) calculated on the basis of scientifically recognised mathematical and statistical procedures, taking address data, among other things, into account. Your interests worthy of protection will be taken into account in accordance with legal requirements. We will allow you to use your desired payment method regardless of your score value. Legal basis: Article 6 (1)(f) GDPR.

Fraud prevention: The personal data you submit may be used in order to verify particularly unusual order processes. We have a legitimate interest in doing this because we wish to avoid payment defaults and to protect customers from misuse of their personal data. We carry out fraud prevention ourselves or with the help of external service providers. The latter process your data exclusively according to our instructions and not for their own purposes. Legal basis: Article 6 (1)(f) GDPR.

Advertising: We process your data for the purposes of sending email advertising (this includes, among other things, news, promotions, offers and customer satisfaction surveys.), if you provided us with your email address when ordering, and print advertising. In this way, we make sure that you receive catalogues tailored to you in addition to the main catalogue. The legal basis is Article 6 (1)(f) GDPR. We have a legitimate interest in sending our customers direct advertising within the legally allowed scope.

Customer rating: In addition, we use the rating platform of Trustpilot Ltd. (Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark, hereinafter "Trustpilot"). If you, as a user, rate us or otherwise provide feedback via the rating platform or process, Trustpilot's General Terms and Conditions, Terms of Use and Privacy Notice will apply.
In order to verify that the rating persons have actually used our services, we transmit the necessary data from you (name, email address and order number or item number) to Trustpilot on the basis of our legitimate interest pursuant to Art. 6 (1) f) GDPR.
We have concluded an order processing contract with Trustpilot, which means that Trustpilot is not considered a third party.

You may object, free of charge, to the use of your data for direct marketing purposes without incurring transmission costs other than the basic tariffs. You can object by emailing dataprotection@strauss.co.uk or by post with the addition “Data protection” to Engelbert Strauss Ltd., Unit 10, Ashburton Industrial Estate, HR9 7BW Ross-On-Wye.

How long will this data be stored? Do I have to provide this data?

We may store your data for as long as this is necessary in order to fulfil the contract. We may store much of your data until the contract has been fulfilled and thereafter within the usual limitation period. We may store your data for the assertion of or defence against legal claims until the maximum limitation period has expired.



2. Newsletter

You have the option to subscribe to a free newsletter. When you register for our newsletter on our website, the email address you provide will be transmitted to us. You also have the option of receiving a tailored, personalised email newsletter from us. We produce the latter on the basis of the data you provide us for this purpose via the input form.

Why is my data processed?

We process your email address for the purpose of regularly sending our newsletter. After subscribing to the email newsletter, you will receive an email from us with a link to verify your email address. After confirming your email address you may provide more data via a separate input form. We process the data entered here for the purpose of producing a tailored, personalised and sector-specific newsletter.

The legal basis is your consent, which you gave us when subscribing to the newsletter or a personalised newsletter (Article 6 (1)(a) GDPR). The legal basis for sending the newsletter after you purchase goods or services is Article 6 (1)(f) GDPR.

How do I unsubscribe from the newsletter? How long will the data be stored?

If in the future you no longer wish to receive the newsletter, you may withdraw your consent to receive the newsletter at any time via the unsubscribe link in the newsletter or via our unsubcribe form in the online shop under “Newsletter” (for further information on the right of withdrawal see IV.).

The data you provided when subscribing to the newsletter will be promptly deleted after you withdraw your consent or unsubscribe from the newsletter. If you are also a customer of ours, the storage periods given above under II.1 will apply.

Do I have to provide this data?

Our newsletter is a voluntary offer. However, you must provide your email address in order to receive the newsletter. Additional data is required if you wish to receive a tailored, personalised newsletter (e.g. profession/sector for the production of a sector-specific newsletter, surname to address the newsletter to you personally and location for sector-specific campaigns in your geographical area).

3. Online shop

3.1. Website

When you visit this website (incl. help.strauss.co.uk), we process your IP address, the date and time of your visit, information on the browser you are using, including language setting, and possibly your operating system, the address of the website from which you visited our website (referrer URL) and information on the files you call up. Your browser automatically transmits this data to your Internet service provider and the latter transmits it to us.

Why is this data processed?

We process this data so that you can load our website, for the purposes of analysis and guaranteeing the security of our systems, to optimise our website, and for statistical purposes. This data cannot be assigned to a specific person. The legal basis is Article 6 (1)(f) GDPR. We have a legitimate interest in ensuring that our website is correctly displayed on your screen and that we can determine and rectify the causes of disruptions.

How long will this data be stored? Do I have to provide this data?

This data will be stored in log files for a maximum of thirty days. The provision of this data is not mandatory and is also not required in order to conclude a contract. It would, however, not be possible for technical reasons for you to visit our website without this data being processed.

Data Processing by Third Parties

On our website, we use a Content Delivery Network (CDN) provided by the service provider "Fastly" (Fastly Inc., 475 Brannan St., Suite 300, San Francisco, CA 94107, USA). The CDN helps us deliver content from our online platform, such as large media files, graphics, or program scripts, faster and more securely through regionally distributed servers connected via the Internet. Additionally, we employ a Web Application Firewall (WAF) from Fastly to swiftly identify and prevent attacks on our website.

In connection with the aforementioned purposes, technical connection data from server access (IP address, date, time, requested page, browser information) is processed. Storage is only carried out in individual cases and for a maximum duration of 30 days. The legal basis for processing is Art. 6(1)(f) GDPR. We have a legitimate interest in ensuring and improving the stability and functionality of our website.

The transfer of data to the USA is carried out based on the Standard Contractual Clauses of the European Commission. Furthermore, Fastly has joined the EU-US Data Privacy Framework, ensuring compliance with the European data protection standards for data transfers to the USA, according to the European Commission. Fastly processes the aforementioned data based on a data processing agreement, which is why Fastly is not considered a "third party."

For more information on data protection at Fastly, please refer to https://www.fastly.com/privacy.

In addition, we use the Eye-Able® software from Web Inclusion GmbH on our website to ensure reduced-barrier access to information on the internet. The necessary files, such as JavaScript, stylesheets, and images, are loaded locally from this website. When functions are activated, Eye-Able® uses the browser's local storage to save settings. All settings are stored locally and are not transmitted further.

The legal basis for processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in implementing accessibility requirements as effectively as possible. 

Further information about Eye-Able® can be found in the following privacy policy:https://eye-able.com/datenschutz/



3.2 Cookies

What are cookies?

Cookies are small files containing an identification number. Cookies are stored on your computer or mobile device when you call up our website (incl. help.strauss.co.uk). When you call up our website, your computer or mobile end device can be recognised using this identification number. Cookies cannot run programs or transfer viruses to your computer. They are designed to make our services more user-friendly and more effective.

Which type of cookies does Strauss use?

Cookies help us to design our website in a more user-friendly way. Some functions of our website (incl. help.strauss.co.uk) cannot be offered without the use of cookies. These services require the browser to be recognised again after a page change. These cookies store and transmit, data such as the following:

  • Language settings
  • Items in the basket
  • Login details

We also use cookies which allow us to analyse users’ surfing behaviour. The following data may be transmitted in this way:

  • search terms entered
  • frequency of page views
  • use of website functions
  • date and duration of the visit

The data collected from users in this way is pseudonymised by technological means. Therefore, assignment of the data to the requesting user is no longer possible. The data is not stored together with other data.

Why does Strauss use cookies?

We use cookies in order to make our website more attractive to visitors and to make it possible or easier to use certain functions. We also use cookies in order to statistically measure use of our website. Analytics cookies tell us how the website is used so we can continuously optimise it. The legal basis is Article 6 (1)(f) GDPR. We have a legitimate interest in making our website user-friendly for you and improving the quality and content of our website.

How long will this data be stored?

Some cookies are deleted after the browser session ends (so-called transient cookies, especially session cookies). Other cookies remain on your device and allow us to recognise your computer on your next visit (so-called permanent cookies). You can find out how long they are stored in your web browser’s cookie settings.

Do I have to provide this data? How can I prevent the use of cookies?

The use of cookies is not mandatory. The data subject can prevent our website using cookies at any time by correspondingly adjusting the settings in his or her internet browser and thus vetoing the use of cookies. These settings must be changed for each browser and each end device. In addition, cookies already set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. We wish, however, to point out that the functionality of our website may be restricted if you deactivate cookies.

Cookie settings



Piwik PRO

We use the web analysis service Piwik PRO from Piwik PRO GmbH, Kurfürstendamm 21, 10719 Berlin (hereinafter "Piwik PRO"). Cookies are used to analyse your user behaviour, among other things.

We use Piwik PRO to evaluate information about your visits to our website (e.g. sequence of subpages accessed) for analysis purposes in order to understand how visitors use our website. The purpose is to analyse the click behaviour of visitors to our website so that we can constantly adapt our website to your needs and improve it for you.

The data compiled by Piwik PRO is stored by us for a maximum of 25 months.

The provision of this data is not mandatory and is not required for the use of our website. You can deactivate the Piwik PRO web analysis service via the link below.

Further information on data protection at Piwik PRO can be found at https://piwik.pro/privacy-policy/.

A/B Testing

We use software from SAS AB Tasty, 3 impasse de la Planchette, 75003 Paris. This facilitates so-called A/B Tests and web personalisation. This allows us to analyse how users navigate our web pages. This allows us to regularly improve our offering and make it more interesting for you as a user.

We store cookies as well as tracking pixels (invisible graphics loaded when you call up the website) on your computer for this evaluation. Before carrying out analysis we further process the IP addresses in shortened form, which excludes the possibility of relating them directly to persons. We do not combine the IP address transmitted by your browser with other data we have collected.

Why is this data processed?

We process this data in order to optimise our website. The legal basis for A/B testing and downstream personalisation is Article 6 (1)(a) GDPR and Article 49 (1)(a) GDPR.

How long is this data saved? Do I have to provide this data?

The data is stored for a maximum of 13 months. Provision of this data is not mandatory and not necessary to enter into a contract with us. You can prevent analysis via the settings (see above, section II.3). If you prevent cookies being saved, we would like to point out that you may not be able to use all the functions of our website. You can also prevent cookies being saved via the browser settings.

You can deactivate the use of A/B testing via the following link:

Meta Pixel

We use the "Meta Pixel" service. The provider is Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4, Ireland (hereafter "Meta"). 

When using the Meta Pixel, cookies are set that allow us to identify visitors to our website as a target audience for displaying ads (so-called "ads") on social media channels like Facebook and/or Instagram. In this way, we aim to ensure that the Facebook or Instagram ads we place are only shown to users who are interested in our online offerings ("targeted advertising"). Additionally, the cookies allow us to measure and analyse which actions users of our website take ("measurements and analyses"). 

When using the services described above, information about actions and activities of visitors to our website is collected, such as searching for a product, viewing it, or purchasing it. 

All information collected via cookies is forwarded to Meta, allowing Meta alone to draw conclusions about the respective user behaviour. For instance, if you are registered on a Meta platform/service, Meta can associate this visit with your account(s). Even if you are not registered or logged in to a Meta platform/service, Meta may still receive and store your IP address and other identifying characteristics.

The data collected is anonymous to us, meaning we cannot draw any conclusions about the identity of users. However, the data is stored and processed by Meta, making it possible to link it to individual user profiles, which Meta may use for its own advertising purposes.

The processing is done for the purpose of optimising our advertising efforts. The legal basis is Art. 6 (1) sentence 1 a) GDPR. Processing only takes place if you have given your express consent. You can revoke your consent at any time with future effect by deactivating the services described above in the

Cookie settings

under "Personal Cookies" provided on the website.

If personal data is collected and then transferred to Meta during the use of the Meta Pixel service (as described above under "targeted advertising"), this is done under joint responsibility with Meta (Art. 26 GDPR) and complies with the usage conditions stipulated by Meta. The joint responsibility is limited solely to the collection of personal data and its transmission to Meta. The subsequent processing of this data by Meta is not part of the joint responsibility. We have no influence on this.

We have concluded an agreement with Meta to regulate the respective obligations under the joint responsibility framework. You can access the wording of this agreement here: https://www.facebook.com/legal/controller_addendum. The agreement specifically stipulates that Meta is responsible for data subject rights regarding the stored personal data. You can exercise your rights (e.g., requests for information) directly with Meta. Should you instead address these requests to us, we are obliged to forward them to Meta for further processing.

Concerning the measurement and analysis services described above, we have concluded a data processing agreement with Meta (Art. 28 GDPR). We are responsible for the aggregated evaluations provided by Meta. Meta processes this data on our behalf and is bound by our instructions. You can access the agreement via the following link: https://www.facebook.com/legal/terms/dataprocessing
Further information on data protection at Meta, as well as settings and opt-out options, can be found here: https://de-de.facebook.com/privacy/explanation

When using Meta Pixel, personal data may be transferred to Meta Platforms, Inc., One Hacker Way, Menlo Park, CA 94025, USA. On July 10, 2023, the EU Commission issued an adequacy decision for the USA, certifying a level of data protection equivalent to that of the EU, provided that the relevant American service providers have undergone a self-certification process. This applies to Meta Platforms, Inc.



3.4. Youtube

These videos are embedded in our homepage so that the setting of Youtube cookies is blocked until 'play' is actively clicked. By clicking the 'play' button, you grant consent for Youtube to set cookies on the end device you are using; these can also be used to analyse the usage behaviour for market research and marketing purposes.

YouTube is service of the company Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you call up a website with one of these plugins whilst visiting our online sites, a connection is made to the YouTube servers and the plugin is shown. As a result, the YouTube-server is informed that you have visited our website. If you are logged in as a YouTube member, YouTube will assign this information to your personal user account. If the plugin is used, e.g. by clicking the start button of a video, this information is also assigned to your user account. You can prevent this assignment if, before using our websites, you log out of your YouTube user account or any other accounts of the companies YouTube LLC und Google Inc. and also delete the respective cookies of these companies.

The data collected by cookies is usually sent to a server in the USA where it is saved. If data is transferred to the USA, the data transfer is based on standard contractual clauses.

For more information about data processing and information about data protection by YouTube (Google), please visit google.de/intl/de/policies/privacy/.

For more information about the use of cookies by Youtube, please refer to Google's cookie policy at policies.google.com/technologies/types.



3.5. Creating a customer account

You can create a customer account in our online shop for future orders (“register” - order and create account).

Why is this data processed?

Your customer data is processed here to simplify and accelerate future orders. You can log in with your login details in the online shop after registering. If you log in as a registered customer, your login details will be transmitted to us for the purpose of checking your identity. After you log in with your login details, the customer data we have stored on you will be transferred to any new orders. II.1. otherwise applies accordingly.

We may process the data you provide on registration on the basis of Article 6 (1)(b) GDPR, insofar as this is necessary for the fulfilment of a contract or to execute precontractual measures; clause II.1. applies here. We may also process data which you have voluntarily shared with us on registration according to Article 6 (1)(a) GDPR if you have consented to processing.

How long will this data be stored? Do I have to provide this data?

The data provided in the course of registration will be deleted as soon as you delete your customer account. If you have not logged in for more than two years since your last order, your registration will be deleted. We may be entitled to store it for longer according to II.1. The provision of personal data by registering is not legally or contractually required.


3.6. Contact form and email contact

We process data, which you have entered in our contact form or transmitted to us by email, to allow us to process and answer your query.

We may process data which you enter into our contact form according to Article 6 (1)(a) GDPR, provided that you have consented to processing. If you enter sensitive information into the “message” field containing particular categories of data (e.g. origin, political or religious convictions, union membership, health or sexual data), you also consent to the processing of this data. If you transmit data to us by email, the legal basis is Article (6)(1)(f) GDPR. If you are also a customer of ours, the legal basis is Article 6 (1)(b) GDPR.

This data will be deleted twelve months at the latest after we receive your query, unless we are entitled or obliged to store it for longer due to legal regulations in connection with Article 6 (1)(c) GDPR. If you are also a customer of ours, clause II.1. shall apply as regards storage periods.

The provision of this data is not mandatory and is not required in order to conclude a contract. The use of the contact form does require, however, that you provide an email address, because we cannot reply otherwise. If you provide further data, you do so voluntarily.



III. Is my data forwarded to third parties?

Some data may also be forwarded to the following recipients if this is necessary for the fulfilment of the contract (Article 6 (1)(b) GDPR), we are legally obliged to do so (Article 6 (1)(c) GDPR), or this is necessary in order to safeguard our legitimate interests (Article 6 (1)(f) GDPR):

  • Banks and payment service providers, for payment processing
  • Collection agencies
  • Manufacturers, for the purpose of processing warranty claims
  • Transport companies, postal service providers
  • Prosecution authorities, courts, arbitration boards, auditors, lawyers or tax advisers
  • Insurers, for processing any claims

We may use external service providers to process your data. We have chosen and commissioned these carefully, and they are bound by our instructions and are regularly checked. These service providers include call centre agencies, lettershops and printers, data collection and maintenance agencies, IT service providers and service providers for data carrier destruction. The legal basis is Article 28 GDPR where these service providers are order processors.



IV. Which rights do I have in relation to my data?

You may request information from us concerning whether and how we are processing your data under the conditions set down in Article 15 GDPR. You can demand that your data is corrected and perhaps completed according to Article 16 GDPR. You have the right to ask us to delete your data under the conditions set down in Article 17 GDPR or Article 18 GDPR. Article 20 GDPR gives you the right to receive your data transmitted on the basis of consent or a contract, if processing is taking place automatically. If you so wish and it is technically possible, we will transmit this data to a third party. Your rights may be restricted or excluded by law under particular conditions. You have the right to lodge a complaint with the competent data protection authority at any time.

If we are processing data to safeguard our interests exclusively on the basis of Article 6 (1)(f) GDPR, you have the right to object to the processing of your data for reasons relating to your particular situation. If you do object, we will no longer process the relevant data, unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or processing is intended for the execution of legal claims.

You may also object at any time to the processing of your data for advertising purposes without incurring any costs other than transmission costs according to the basic tariffs. You can object to the sending of advertising emails at any time without charge, e.g. by clicking on the unsubscribe link at the end of such an email. You can also object by emailing dataprotection@strauss.co.uk or by post with the addition “Data Protection” to the address given under I. above.

If you have consented to the processing of data, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the legality of the processing which took place prior to the withdrawal. You can object in an email to dataprotection@strauss.co.uk or by post with the addition of “Data Protection” to the address given under I. above. Data will no longer be processed after you have withdrawn your consent. This does not apply if we are legally entitled or obliged to process it.




Engelbert Strauss Ltd.

Phone
01252 607855
Fax
01252 607857
All prices plus VAT