Protecting personal data is highly important to Knappe + Lehbrink Promotion GmbH. Because of this, Knappe + Lehbrink Promotion GmbH only processes personal data in accordance with applicable legal regulations, and ensures that we comply with data protection regulations on technical and organisational levels.
The following information provides an overview of how we handle data and of the rights of data subjects under the European General Data Protection Regulation (GDPR) as of 25/05/2018.
Information in accordance with Art. 13 (data collected directly from the data subject) and Art. 14 (data collected from third parties) under the General Data Protection Regulation (GDPR)
We collect personal data in the course of performing our service provider and within the framework of employment relationships required for this purpose. Please observe the following data protection provisions:
The controller responsible for data collection is:
Knappe + Lehbrink Promotion GmbH
49 5223 9270-0
2. Data Protection Officer
Our external Data Protection Officer can be contacted at:
Creditreform Compliance Services GmbH
Mrs Natalia Wozniak
Tel.: + 49 2131 109-1937
3. Supervisory authority
The supervisory authority responsible for data protection is:
State Officer of Data Protection and Freedom of Information
Tel.: +49 211 38424-0
Fax: +49 211 38424-10
4. Purpose and legal bases for processing
The legal bases for processing the data are:
- Processing to fulfil contracts concluded with Knappe + Lehbrink Promotion GmbH according to Art. 6 para. 1 letter b GDPR
- If personal data is collected and processes to carry out pre-contractual measures or based on a contract, this data will be used to conclude the contract, carry out the contractual relationship and, if necessary, in conjunction with the end of the contractual relationship.
- Processing based on a legitimate interest according to Art. 6 para. 1 letter F GDPR
- Data may be processed based on the legitimate corporate interests of Knappe + Lehbrink Promotion GmbH or of third parties. This may be necessary, for instance, to ensure IT security and IT operations, to prevent / clarify criminal or administrative offences, to ensure domiciliary rights, to offer our customers post-contractual services, or for the purpose of direct advertisement to our own customers if further requirements are fulfilled, etc.
- Processing based on consent, Art. 6 para. 1 letter a GDPR
- If the data subjects has granted their consent to data processing to Knappe + Lehbrink Promotion GmbH for specific purposes (such as posting birthday lists, sending newsletters), then this personal data may be legally used within the scope of their consent.
- Processing to fulfil legal obligations, Art. 6 para. 1 letter c GDPR
- Data processing may be necessary to fulfil legal obligations, in particular retention obligations under the Commercial Code and Tax Code
- If we process special categories of personal data, then the legal basis for this processing is Art. 9 para. 2 and 4 GDPR, in conjunction with Sec. 22 BDSG (Federal Data Protection Act) if applicable.
5. Data categories we collect from third parties
We process the following categories of personal data we receive from third parties:
- Contact information such as first and last names, company address, company telephone number, company cell phone number, company fax number and company e-mail address
- Credit information (when obtaining information through credit bureaus)
6. Sources (third parties) from which personal data may be obtained
Knappe + Lehbrink Promotion GmbH processes personal data insofar as this data is provided or transmitted by the data subjects themselves (such as customers, employees) or by third parties.
If Knappe + Lehbrink Promotion GmbH receives personal data from third parties, these include, in particular, the following entities:
- Credit agencies
- Commercial agents
- Business partners in the course of fulfilling contractual services
7. Recipients or categories of recipients for personal data
Personnel at Knappe + Lehbrink Promotion GmbH receive access to personal data if they require such access to legally fulfil their duties.
If commissioned external service providers receive personal data for these purposes, we ensure that suitable technical and organisational measures are taken, and necessary agreements are concluded so that processing conforms to valid data protection law regulations and so as to ensure the rights of data subjects are protected.
We may transmit personal data to other entities (recipients or categories of recipients for personal data), such as
- external service providers (such as IT service providers, computing centres, support by software providers, payroll processing service providers)
- Business partners to whom we must transmit the data so that they can carry out their duties, such as payment service providers/banking institutions, postal/package services, commercial agents, external advisers, etc.
- Any collection agencies to collect receivables
- Officials and companies in the course of updates or to fulfil statutory notification obligations (such as social security insurance companies, financial agencies, police and public prosecutors, supervisory authorities, traffic officials)
- Other third parties if the data subjects have granted their consent to transmit data to them, or if we have a legal authorisation to transmit the data (such as attorneys, insolvency administrators)
8. Intention to transmit data to a third country of international organisation
We do not transmit personal data to third countries (nations outside of the European Union or European Economic Area) or to international organisations.
9. Duration of storage or criteria for determining this duration
Personal data will only be stored for as long as permitted based on applicable legal bases. It will be stored, in particular, for as long as necessary to fulfil the contractual purposes for which the personal data was collected, as long as it must be stored to fulfil retention obligations or based on our overwhelming legitimate interest, or until the data subject revokes their consent upon which processing is based.
10. Rights of data subjects
You have the following rights with respect to the collection of your personal data:
- Right to information, Art. 15 GDPR: In accordance with Art. 15 para. 1 GDPR, data subjects have the right to request confirmation of whether their personal data is being processed. If this is the case, they furthermore have the right to receive information on this personal data and further information in accordance with Art. 15 para. 1 letters a to h GDPR.
- Right to rectification, Art. 16 GDPR: If personal data is incorrect or incomplete in consideration of the purpose of processing, then in accordance with Art. 16 GDPR data subjects have the right to request that their personal data be rectified or completed.
- Right to deletion, Art. 17 GDPR: In accordance with Art. 17 para. 1 GDPR, data subjects have the right to request that their personal data be deleted if the processing of their personal data is prohibited for one of the reasons indicated in these regulations. However, no request can be made to delete data if further processing is necessary in the cases covered by Art. 17 para. 3 GDPR, for instant to fulfil legal obligations.
- Right to restrict processing, Art. 18 GDPR: If the requirements of Art. 18 para. 1 letters a to d GDPR apply, then data subjects can request that processing be restricted (blocked).
- Right to data portability in accordance with Art. 20 GDPR: Data subjects have the right to receive their personal data that they have provided to Knappe + Lehbrink Promotion GmbH and that is processed by Knappe + Lehbrink Promotion GmbH based on their consent or a contract through automated means in a commonly used and machine-readable format. This right is conditional upon the availability of technical capabilities to provide such data.
- Right to object, Art. 21 GDPR: Data subjects have the right to submit objections against the processing of their personal data which is carried out based on a balancing of interests (Art. 6 para. 1 letter f GDPR), in consideration of the specifications of Art. 21 GDPR.
- If they are objecting to direct advertisement (with associated profiling, if applicable), then data will no longer be processed. In other cases, data may only continue to be processed despite the objection if there are essential, protected reasons for processing that outweigh the interests, rights and freedoms of the data subjects or if data is processed in order to assert, exercise or defend against legal claims.
11. Right to revoke consent
Furthermore, data subjects may amend or fully revoke any consent they have granted at any time and without providing grounds, with future effect. The revocation shall not affect the legality of any processing of their data carried out based on said consent up to that point.
You can send your revocation to Knappe + Lehbrink Promotion GmbH either by mail to Knappe + Lehbrink Promotion GmbH, Maschbruchstraße 22-28, 32257 Bünde, by e-mail to dsgvo(at)kl-promotion.de. You will not incur any costs besides the base tariffs.
12. Right to submit complaints to a supervisory authority
You have the right to submit complaints to a data protection supervisory authority. Contact information for our responsible supervisory authority is provided under point 3 of this document.
13. Obligation to provide personal data
Data subjects are obligated to provide certain personal data based on contracts that have been or are to be concluded, insofar as the contract cannot be carried out unless the data is provided. Furthermore, there may be statutory obligations requiring us to collect / process certain data.
If the information is required for a certain contract and it is not provided, then the contract cannot be concluded.
If data must be provided based on legal obligations, then the associated services cannot be performed unless it is provided.
14. Automated decision-making or profiling
Knappe + Lehbrink Promotion GmbH does not use any automated decision-making processes or profiling in accordance with Art. 22 GDPR.