DATA PROTECTION AND PRIVACY STATEMENT
1. Controller
The controller for the collection, processing, and use of personal data within the meaning of the German Federal Data Protection Act (BDSG) is
G. Pohl-Boskamp GmbH & Co. KG
Kieler Str. 11
25551 Hohenlockstedt, Germany
Tel.: +49 (0)4826 59 0
e-mail: datenschutz-info@pohl-boskamp.de
The operators of these pages take protecting your personal data very seriously. We treat your personal data confidentially and in accordance with the applicable statutory data protection provisions and this data protection and privacy statement. This data protection and privacy statement provides information on the collection, processing, and use of personal data.
2. COLLECTION, PROCESSING, AND USE OF PERSONAL DATA
a. If you use the website purely for informational purposes, meaning if you do not register or otherwise transmit information to us, we collect only those personal data that your browser transfers to our server. If you wish to view our website, we collect the following information, which we require in technical terms in order to display our website to you and ensure its stability and security (the legal basis is Article 6(1) (p.1 f) of the EU General Data Protection Regulation (GDPR)).
- IP address
- Date and time of query
- Time difference to Greenwich Mean Time (GMT)
- Content of request (specific page)
- Access status/HTTP status code
- Volume of data transferred in each case
- Requesting website
- Browser
- Operating system and interface
- Browser software language and version
b. If you contact us by e-mail or using a contact form, we store the information you provide (your e-mail address, possibly your name and phone number) in order to answer your questions. We delete the data collected in this context once it is no longer necessary to store them or restrict the processing thereof if we are under a statutory obligation to store the data.
3. USE OF PERSONAL DATA FOR ADVERTISING AND MARKET RESEARCH PURPOSES
If you consent to the use of personal data for advertising and market research purposes, we will also use your data for the specific purposes covered by your consent (e.g. for newsletters) unless and until you withdraw your consent. This means that we are permitted to contact you via the channels indicated in the declaration of consent (e.g. e-mail, phone, mail) and to send you information and individualized advertising about our products based on an analysis of your clicking behavior on our websites. We will ultimately also use your data to analyze and improve the effectiveness of our websites. Consent to the use of your personal data for advertising and market research purposes is given expressly, for example by checking the appropriate box. If you no longer wish us to use your personal data for advertising and/or market research purposes, you can object thereto at any time.
4. DISCLOSURE OF DATA FOR PROCESSING ON OUR BEHALF
In some cases, we may use the services of specialized service providers to process your data. We select our service providers carefully and check them regularly. They process personal data only on our behalf and strictly according to our instructions, on the basis of corresponding processing agreements.
5. USE OF COOKIES
Our website uses “cookies.” This section provides information on the use of cookies and similar storage technologies (“cookies”).
a. What are cookies?
Cookies are small text files placed on your device by your browser in order to store specific information. The next time you use the same device to access our website, the information stored in cookies is subsequently returned either to our website (first-party cookie) or to another website to which the cookie belongs (third-party cookies).
The website uses the stored and returned information to determine that you have accessed and visited the site with your device’s browser in the past. We use this information in order to be able to design and display the website optimally for you according to your preferences. The only thing on your device that is identified in the process is the cookie itself. Storage of personal data beyond that takes place only after you have given your express consent or if this is absolutely necessary in order to be able to use the service that is offered and accessed by you accordingly.
b. Consent to the use of cookies
If you are visiting our website for the first time, you will see a banner requesting your consent to the use of cookies. If you give your consent, we store a cookie on your computer, and the banner will not be displayed again during the cookie’s life span. After that, or if you actively erase this cookie beforehand, the banner will be displayed again the next time you visit our website in order to obtain your consent again.
c. Categories of cookies
We divide cookies into the following categories, depending on the intended use and function:
(i) REQUIRED COOKIES
Required cookies ensure functions without which you are unable to use our website or services as intended. These cookies are used exclusively by us, so they are first-party cookies. This means that all information stored in the cookies is returned to our website.
Required cookies serve, for example, to ensure that if you are a registered user, you remain logged in at all times when accessing different subpages of our site, so you do not have to re-enter your login credentials every time you access a new page.
These cookies do not identify you as an individual. If you do not accept these cookies, this may adversely affect the performance of the website or portions thereof. The legal basis for the processing of personal data is Article 6(1)(b) GDPR. The use of required cookies on our website is possible without your consent. However, you do have the option of deactivating cookies in general in your browser at any time.
Our website uses the following required cookies:
| Cookie name | Description / Term | Term |
| cookie-agreed | This cookie stores the information that the user has viewed the cookie banner. | 100 days |
| has_js | This cookie traces whether JavaScript is activated or deactivated. | Session |
| PHPSESSID | This cookie is used to store the user’s preferred settings so that they can be provided right away the next time the user visits the site. This might include language settings or other preferences. It is also used to facilitate filling out of forms. | Session |
(ii) FUNCTIONAL AND PERFORMANCE COOKIES
Functional cookies allow our website to store information that has already been provided (such as the registered name or language selection) and offer you improved and more personal functions on this basis.
Performance cookies collect information on how our website is used in order to consequently improve its attractiveness, content, and functionality. These cookies help us, for example, to determine whether subpages of our website are visited, and if so which ones, and which content is especially interesting to users. Specifically, we collect information in particular on the number of times a page is accessed, the number of subpages accessed, the time spent on our website, the order in which pages are visited, which search terms brought you to us, the country, region, and possibly the city from which the access takes place, and the percentage of the devices accessing our website that are mobile devices. We also collect information on movements, clicks, and mouse scrolling in order to understand which areas of our website are especially interesting to users. Doing this allows us to tailor the content of our website more specifically to the needs and requirements of our users and to optimize our offerings. The IP address of your computer, which is transferred for technical reasons, is automatically anonymized and does not allow us to identify individual users.
We process all of the data collected by us in aggregated form only. The legal basis for the processing of personal data is Article 6(1)(f) GDPR. Our legitimate interest in this context is in optimizing and improving our website.
Our website uses the following functional and performance cookies:
GOOGLE ANALYTICS AS ANALYSIS TOOL
This website uses functions of the Web analytics service Google Analytics. The provider is Google Inc.,1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies that are stored on your computer and enable analysis of your use of the website. The information on your use of this website that is generated by the cookie is typically transferred to a Google server in the United States and stored there.
IP ANONYMIZATION
We have activated the IP anonymization function on this website. This means your IP address is truncated (shortened) by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area before being transferred to the United States. Only in isolated cases is the full IP address transferred to a Google server in the United States and truncated there. Google will use this information on behalf of the operator of this website in order to analyze your use of the website, compile reports on website activity, and perform further services for the website operator in connection with website use and Internet use. The IP address transferred by your browser within the scope of Google Analytics is not combined with other Google data.
BROWSER PLUGIN
You can prevent cookies from being stored by adjusting your browser software settings accordingly; please note, however, that if you do so, you may not be able to use all of the functions of this website in full. You can also prevent the collection of the data generated by the cookie concerning your use of the website (including your IP address) and provision thereof to Google and the processing of these data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
OBJECTION TO COLLECTION OF DATA
You can prevent the collection of your data by Google Analytics by clicking the following link. This will place an opt-out cookie that prevents the collection of your data when you visit this website in the future: deactivate Google Analytics For more information on how user data are used in the case of Google Analytics, please see the Google privacy policy: https://support.google.com/analytics/answer/6004245?hl=d
DEMOGRAPHICS IN THE CASE OF GOOGLE ANALYTICS
This website uses the “demographics” function of Google Analytics. This makes it possible to prepare reports containing information on the age, sex, and interests of visitors to the site. These data come from interest-related advertising of Google and from visitor data of third-party providers. The data cannot be associated with a specific person. You can deactivate this function at any time by adjusting the ad settings in your Google account or prohibit the collection of your data by Google Analytics in general as described in the section titled “Objection to collection of data.”
CONTRACT DATA PROCESSING
We have entered into an agreement for data processing with Google and comply in full with the stringent specifications set by the German data protection authorities in our use of Google Analytics.
Google Analytics places the following cookies:
| Cookie Name | Description / purpose | Term |
| __utmx | This cookie is used for Google Analytics in order to include users within the scope of content experiments. | 18 months |
| __utmxx | This cookie is used for Google Analytics to log the time when an experiment into which the user was integrated ends. | 18 months |
| __utma
__utmt __utmb __utmc __utmz |
These cookies serve to collect information on how users use our local websites. We use this information to prepare reports and improve our local Internet sites. These cookies collect information anonymously, including the number of visitors to a page, from where the visitors reached the local website, and what page they visited. | 2 years 10 minutes 30 minutes Session 6 months |
| url_landing_page | Aufzeichnung der Einstiegsseite/Landingpage des Users | 30 Minuten |
Administration and erasure of all cookies
You can adjust your browser settings so that you are informed every time a cookie is placed and agree to cookies in individual cases only or rule out acceptance of cookies in certain cases or in general, and so that cookies are automatically erased when you close your browser. If you deactivate cookies, the functionality of this website may be restricted. For specific information on how all of this works, please see your browser’s help function. A written explanation with illustrations is available at the following link for the Internet browsers Firefox, Microsoft Internet Explorer, and Google Chrome:
http://www.meine-cookies.org/cookies_verwalten/index.html.
6. USE OF GOOGLE WEB FONTS
This page uses Web fonts provided by Google to ensure that fonts are displayed uniformly. When you access a page, your browser loads the necessary Web fonts to your browser cache in order to display text and fonts correctly. If your browser does not support Web fonts, your computer uses a standard font.
Further information on Google Web fonts is available at https://developers.google.com/fonts/faq and in the Google privacy policy: https://www.google.com/policies/privacy/.
7. USE OF GOOGLE MAPS
This website uses Google Maps, a product of Google Inc. By using this website, you consent to the collection, processing, and use of the automatically collected data by Google Inc., its representatives, and third parties. The terms of use for Google Maps are available at https://www.google.com/intl/de_de/help/terms_maps.html.
8. USE OF GOOGLE RECAPTCHA
The reCAPTCHA service of Google Inc. (Google) is used to protect your orders via Internet form. Requesting this information serves to determine whether the entry was made by a human or made abusively by automated, mechanical processing. The query includes transmitting the IP address and any other data that may be needed by Google for the reCAPTCHA service to Google. To this end, your entry is transferred to Google and used further there. By using reCaptcha, you consent to the recognition you have performed being included in the digitization of old works. If IP anonymization is activated on this website, however, your IP address will be truncated (shortened) by Google beforehand within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in isolated cases is the full IP address transferred to a Google server in the United States and truncated there. Google will use this information on behalf of the operator of this website to analyze your use of this service. The IP address transferred by your browser within the scope of reCaptcha is not combined with other Google data. These data are subject to the data protection provisions of the company Google, which deviate from the foregoing. Further information on Google’s data protection and privacy guidelines is available at https://www.google.com/intl/de/policies/privacy/.
9. USE OF THE CONTACT FORM
If you send us inquiries via the contact form, the information you have provided in the inquiry form, including the contact data you have stated there, will be stored at our end for the purpose of processing your inquiry and in the event of any follow-up questions. The legal basis for the processing of your personal data is Article 6(1)(b) GDPR.
10. REQUESTS FOR SERVICE PACKAGES / INFORMATIONAL MATERIALS
If you request service packages regarding our medical products (such as the NYDA service package and/or GeloRevoice informational material), the information you have provided in the inquiry form, including the contact data you have stated there, will be stored at our end for the purpose of processing your inquiry and in the event of any follow-up questions. The legal basis for the processing of your data is Article 6(1)(b) GDPR.
11. USE OF THE NEWSLETTER
This section provides information on the content of our newsletter and the process used for subscription, sending, and statistical analysis as well as your rights to object. By subscribing to our newsletter, you consent to receive the newsletter and to the processes described.
a. Content of the newsletter
We transmit newsletters, e-mails, and other electronic messages containing marketing information (“newsletters”) only with the consent of the recipients or where the law allows us to do so. Where a specific description of the newsletter content is provided within the scope of subscribing to the newsletter, this content is the operative factor with regard to the consent of the users. Our newsletters also contain information on Pohl-Boskamp products.
b. Double opt-in and logging
Subscriptions to our newsletter are handled using a “double opt-in” procedure. This means that after you register, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary in order to ensure that no one can register using an e-mail address that is not their own. Subscriptions to the newsletter are logged in order to be able to provide documentation of the subscription process in accordance with the legal requirements. This includes storing the time of registration and confirmation and the IP address. Any changes in your data that are stored with this provider of transmission services are also logged. The transmission of the newsletter and the measuring of success that takes place associated therewith take place on the basis of the recipient’s consent pursuant to Article 6(1)(a) and Article 7 GDPR in conjunction with Sec. 7 (2) No. 3 of the German Act against Unfair Competition (UWG) or on the basis of the statutory permission granted pursuant to Sec. 7 (3) UWG. The logging of the registration process takes place on the basis of our legitimate interests pursuant to Article 6(1)(f) GDPR. Our interest is geared toward the use of a user-friendly and secure newsletter system that not only serves our business interests, but also meets the expectations of users while moreover permitting us to demonstrate the consent we have obtained.
c. Termination; withdrawal
You can stop receiving our newsletter, meaning withdrawing your consent, at any time. A link to unsubscribe from the newsletter is found at the end of each newsletter. We may store the unsubscribed e-mail address for up to three years based on our legitimate interests before erasing it for the purpose of sending out the newsletter. This is done in order to be able to demonstrate that consent had been given in the past. The processing of these data is restricted to the purpose of possibly defending against claims. An individual request for erasure is possible at any time provided that the former existence of consent is confirmed at the same time.
d. Service providers used for transmission
This website uses CleverReach to send out newsletters. The provider is CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany. CleverReach is a service that can be used to organize and analyze the transmission of newsletters. The data you enter for the purpose of subscribing to the newsletter (such as your e-mail address) are stored on the servers of CleverReach in Germany or Ireland. Our newsletters sent out with CleverReach allow us to analyze the behavior of newsletter recipients. Factors that may be analyzed in the process include how many recipients have opened the newsletter message and how often which links in the newsletter have been clicked. “Conversion tracking” may also be used to analyze whether a predefined action (such as purchasing a product on our website) has taken place after the link is clicked in the newsletter. Further information on the analysis of data through CleverReach newsletters is available at https://www.cleverreach.com/de/funktionen/reporting-und-tracking/.
The processing of data takes place on the basis of your consent (Article 6(1)(a) GDPR). You can withdraw this consent at any time by unsubscribing from the newsletter. The legality of the data processing procedures that have taken place up until then is not affected by the withdrawal. If you do not wish any analysis to be performed by CleverReach, you need to unsubscribe from the newsletter. We provide a link for this purpose in each newsletter message. You can also unsubscribe from the newsletter directly on the website. We will store the data we have on file regarding you for the purpose of receiving the newsletter until you are removed from the list of recipients of the newsletter. After you unsubscribe from the newsletter, these data will be erased both from our servers and from those of CleverReach. Data that we have stored for other purposes (such as e-mail addresses for the member section) will not be affected by this. For further details, please see the data protection and privacy policy of CleverReach at https://www.cleverreach.com/de/datenschutz/.
e. Measurement of success
The newsletters contain what is known as a Web beacon, a pixel-sized file that is retrieved by our server (or, if we use a service provider to transmit the newsletter, by that provider’s server) when the newsletter is opened. This retrieval initially collects technical information, such as information on the browser and your system, along with your IP address and the time of retrieval. This information is used to improve the services in technical terms based on the technical data or target groups and their reading behavior based on the retrieval locations (which can be determined using the IP address) or access times. The statistical information collected also includes a determination of whether the newsletters are opened, if so, when, and what links are clicked. For technical reasons, it is possible to associate this information with individual newsletter recipients. However, it is not our intent, or that of any service provider we may use to transmit the newsletter, to observe individual users. Instead, these analyses allow us to identify our users’ reading habits and adjust our content to those habits or to transmit different content in line with our users’ interests.
12. SSL ENCRYPTION
This site uses SSL encryption for security reasons and to protect the transmission of confidential content, such as the inquiries that you send to us as the site operator. You can see when a connection is encrypted from the fact that the browser’s address line shifts from "http://” to "https://” and from the lock symbol that appears in your browser. If SSL encryption is activated, the data you transfer to us cannot be observed by third parties.
13. INFORMATION ON SIDE EFFECTS; QUALITY COMPLAINTS
If you wish to report undesirable side effects, lack of efficacy of a drug, medication errors, gray market products/counterfeits, improper use or use that exceeds approval (“off label”), or if you have a quality complaint and/or wish to report other aspects relating to the safety and quality of a Pohl-Boskamp product, please use our website or contact your healthcare provider (such as your doctor or pharmacist) or the relevant authority directly (https://nebenwirkungen.bund.de/SiteGlobals/Forms/nebenwirkungen/01-person/person-node.html). If you notify us of undesirable side effects or other aspects relating to the safety or quality of drugs or medicinal products, we are legally obligated to store and process your report. For this purpose, we may also contact you to clarify questions. After that, we may be required to communicate the reports we have received from you to the relevant health authorities. If so, we will disclose your information in pseudonymous form only, so no information that can be used to identify you directly is disclosed. We may also be required to disclose these pseudonymous reports to our other affiliates and cooperation partners to the extent that these entities are, for their own part, obligated to report to the health authorities that have jurisdiction over them.
14. RIGHTS OF DATA SUBJECTS
a. You have the following rights toward us with regard to the personal data concerning you:
- Right to information
- Right to rectification or erasure
- Right to restriction of processing
- Right to object to processing
- Right to data portability
If you wish to learn which personal data concerning you we have stored, what the origin of these data is, and/or how they are used or wish to object to the processing thereof, please contact our data protection officer by phone (+49 (0)4826 59 0), fax (+49 (0)4826 59 109), e-mail (datenschutz-info@pohl-boskamp.de) or mail (G. Pohl-Boskamp GmbH & Co. KG, Kieler Str. 11, 25551 Hohenlockstedt, Germany).
b. You also have the right to complain to a data protection supervisory authority regarding our processing of your personal data.
c. If you have given us your express consent to the use of your personal data for marketing purposes, we will use your data for these purposes unless and until you withdraw your consent. You can withdraw your consent, once granted, at any time with effect for the future.
15. ADJUSTMENT OF THE DATA PROTECTION AND PRIVACY STATEMENT
We may amend or update portions of the data protection and privacy statement without notifying you beforehand. Please review the data protection and privacy statement in each case before using our site in order to stay up to date with regard to possible changes or updates.
Effective: 05/2018