Data Privacy Statement in accordance with the General Data Protection Regulation (GDPR)

of beyerdynamic GmbH & Co. KG, Theresienstraße 8, 74072 Heilbronn, Germany

We take data protection seriously and wish to ensure that your privacy is protected when you use our website. We have therefore created this Data Privacy Statement to explain how we handle your data.
We reserve the right to amend its contents from time to time. You are therefore advised to read and take note of this Data Privacy Statement regularly.

I. Definitions

The terms used in this Data Privacy Statement are as defined by European legislators in the General Data Protection Regulation (GDPR). Our Data Privacy Statement is intended to be easy to read for and understandable to the general public, as well as our customers and business partners. In order to ensure that, we would first like to explain the terms used.

The terms used in this Data Privacy Statement are as defined by European legislators in the General Data Protection Regulation (GDPR). Our Data Privacy Statement is intended to be easy to read for and understandable to the general public, as well as our customers and business partners. In order to ensure that, we would first like to explain the terms used.

The terms we use in this Data Privacy Statement include:

1. Personal data

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Data subject

A “data subject” is any identified or identifiable natural person whose personal data is processed by the controller.

3. Processing

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Restriction of processing

“Restriction of processing” means the marking of stored personal data with the aim of limiting its processing in the future.

5. Profiling

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

6. Pseudonymisation

“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

7. Controller

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

8. Processor

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

9. Recipient

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

10. Third-party

“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

11. Consent

“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

II. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other national data protection laws of the Member States and other data protection regulations is:

beyerdynamic GmbH & Co. KG
Theresienstraße 8
74072 Heilbronn
VAT ID: DE145795453
Managing Director: Edgar van Velzen
Phone: +49 (0)7131/617-0
Fax +49 (0)7131 617-224 

III. Name and address of the Data Protection Officer

The controller’s Data Protection Officer is:

Professor Wolf M. Nietzer MBA, LL.M.
beyerdynamic GmbH & Co. KG, Theresienstraße 8, 74072 Heilbronn, Germany 
Phone: +49 (0)7131/20391-0
E-mail: datenschutzbeauftragter@beyerdynamic.de

IV. General information on data processing

1. Scope of processing of personal data

In principle, we process our users’ personal data only insofar as that is required to provide a well-functioning website and our content and services. Personal data is usually processed only subject to the user’s prior consent. An exception to that is when such prior consent cannot be obtained for factual reasons and we are permitted by law to process the data. 

2. Legal grounds for processing of personal data

If we obtain consent from data subjects to process their personal data, the legal basis for that is laid down by Article 6 (1) point (a) of the EU General Data Protection Regulation (GDPR).
The legal basis for processing personal data required in order to perform a contract to which the data subject is a party is Article 6 (1) point (b) GDPR. That also applies to processing activities required to take steps prior to entering into a contract.
If processing of personal data is necessary for compliance with a legal obligation on the part of our company, the legal basis for that is Article 6 (1) point (c) GDPR.
If vital interests of the data subject or another natural person necessitate processing of personal data, the legal basis for that is Article 6 (1) point (d) GDPR.
If processing is necessary to safeguard legitimate interests of our company or a third party and the data subject’s interests, fundamental rights and freedoms do not override the interests of our company or the third party, the legal basis for that is Article 6 (1) point (f) GDPR. 

3. Erasure and length of storage of data

The data subject’s personal data shall be erased or blocked as soon as the purpose for which it has been stored no longer applies. The data can also be stored if this is envisaged by European or national legislators in EU regulations, laws or other provisions to which the controller is subject. The data shall also be blocked or erased when a period of time prescribed for its storage under the above legal provisions expires, unless it is necessary for the data to still be stored so that a contract can be concluded or performed.

V. Provision of the website and creation of log files

1. Description and scope of data processing

Whenever our website is called, our system automatically collects data and information from the computer system calling it. 
The following data is collected as part of that:

  • Information on the type of browser used and its version
  • The user’s operating system
  • The user’s IP address
  • The date and time the user accessed the site
  • Websites from which the user’s system accesses our website 
  • Websites the user’s system calls from our website

The data is likewise stored in our system’s log files. This data is not stored together with other personal data of the user.

2. Legal grounds for processing data

The legal basis for temporary storage of data and log files is Article 6 (1) point (f) GDPR.

3. Purpose of data processing

Temporary storage of the IP address by the system is necessary so that the website can be delivered to the user’s computer system. To enable that, the user’s IP address must be stored for the duration of the session. 
The data is stored in log files in order to ensure that the website functions properly. The data also helps us optimise the website and ensure the security of our IT systems. The data is not analysed for marketing purposes in this connection. 
These purposes also constitute our legitimate interest in processing data in accordance with Article 6 (1) point (f) GDPR.

4. Duration of storage

The data is erased as soon as it is no longer required for achieving the purpose for which it was collected. As regards data recorded to deliver the website, this is the case when the session in question is over. 
If the data is stored in log files, this is the case after seven days at the latest. The data can be stored above and beyond that. In that case, the IP addresses of users are erased or anonymised so that the client calling the website can no longer be identified.

5. Means of objection and rectification of data

Recording of data in order to deliver the website and storage of the data in log files are absolutely necessary for operating the Internet site. Consequently, users do not have the possibility of objecting and opting out. 

VI. Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in or by the web browser on the user’s computer system. If a user calls a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string that allows the browser to be identified unambiguously when the website is called again. 
We use cookies to make our website more user-friendly. Some elements of our Internet site require the browser calling it to be identified after the user moves to another page. 

The following data is stored and transmitted by the cookies:

  • Language settings
  • Articles in a shopping cart (shopping cart ID)
  • Log-in information

We also use cookies on our website to enable analysis of users’ surfing behaviour. 

The following data may be transmitted in this way:

  • The search terms entered
  • How often pages are called
  • Use of website functions

The user data collected in this way is pseudonymised using technical precautions. That means the data can no longer be used to identify the user calling the website. The data is not stored together with other personal data of users.
When users call our website, an info banner notifies them that cookies are used for analysis purposes and refers them to this Data Privacy Statement. In this connection, users are also informed about how they can prevent storage of cookies in their browser settings.

2. Legal grounds for processing data 

The legal basis for processing personal data using cookies is Article 6 (1) point (f) GDPR.

3. Purpose of data processing

The purpose of technically necessary cookies is to make it easier to use websites. Some functions of our Internet site cannot be offered without the use of cookies. It is necessary for these cookies to be recognised again by the browser when the user moves to another page.

We need cookies for the following applications:

  • Shopping cart
  • Adoption of language settings
  • Remembering search terms

The user data collected by technically necessary cookies is not used to create user profiles.
The analytics cookies are used to improve the quality and content of our website. These analytics cookies help us learn how the website is used so that we can keep on optimising our offering.

Publisher

Name of the cookie

Description and function

Google

IDE, _psegs, permutive-session, permutive-id

This cookie is used to record the user’s actions on a website after an ad has been displayed and clicked on. The purpose of that is to measure effectiveness so that targeted advertising can be displayed.

Google

DV

This cookie collects data for personalised advertising.

Google

CONSENT

This cookie stores whether Google cookies are permitted.

Google

_dc_gtm_UA-[id]-1, _dc_gtm_UA-[id]-19, _dc_gtm_UA-[id]-21, _dc_gtm_UA-[id]-32

The Google Analytics ID, which is integrated using Google Tag Manager, so that DoubleClick can obtain data to track the performance of advertising campaigns with Google Analytics. [id] corresponds to the Google Analytics ID.

Google

_ga

This cookie collects data for the Analytics Report of the site and generates a number for each unique user as a client identifier. This cookie also collects data to calculate user, session and campaign data.

Google

_gid

This cookie collects data for the Analytics Report of the site. It is session-dependent and collects data on the user’s journey over the website in each session. When the session changes, so too does the value of the cookie.

Google

NID

This cookie collects data on search queries, interaction with the website operator’s advertising, and visits to the website of advertisers, so that personalised advertising can be displayed.

Google

APISID, SAPISID, HSID, SID, SSID

This cookie is used by Google to save user settings and information of Google Maps.

Google

OGPIC

This cookie is used by Google to save user settings and information of Google Maps.

Google

SIDCC

This is a security cookie which protects user data against unauthorised access.

Microsoft

MUID, MUIDB

Microsoft Unique User Identifier: This cookie links data from the Bing Advertising Network with other actions on the website.

Microsoft

_uetsid

Microsoft Bing Ads Universal Event Tracking ID: This cookie tracks what happens when a user has clicked on an ad.

Facebook

fr

This cookie collects data so that advertising can be selectively displayed on Facebook on the visited site. It is used on all websites that have Facebook social plug-ins.

Beyerdynamic

cookieconsent_status

This cookie stores whether the cookie notification has already been closed.

Beyerdynamic

PHPSESSID

This cookie stores the user’s session ID in the PHP backend.

Zendesk

_help_center_session

This cookie retains the statuses of the user for all page requests.

Zendesk

_zendesk_shared_session

This cookie retains the statuses of the user for all page requests.

Swiftype

__cfduid

This cookie helps optimise searching on the page.

Swiftype

__st_user_uuid

This cookie helps optimise searching on the page.

Magento

mage-cache-sessid

This cookie enables caching of content in the browser so that pages can be loaded faster.

Magento

mage-cache-storage

This cookie enables caching of content in the browser so that pages can be loaded faster.

Magento

mage-cache-storage-section-invalidation

This cookie enables caching of content in the browser so that pages can be loaded faster.

Magento

mage-messages

This cookie is used for interaction with users (alerts, notifications, etc.).

Magento

mage-translation-file-version

This cookie enables translation of content into other languages.

Magento

mage-translation-storage

This cookie enables translation of content into other languages.

Magento

private_content_version

This cookie enables caching of content in the browser so that pages can be loaded faster.

Magento

product_data_storage

This cookie enables caching of content in the browser so that pages can be loaded faster.

Magento

recently_compared_product

This cookie stores recently compared products.

Magento

recently_compared_product_previous

This cookie stores recently compared products.

Magento

recently_viewed_product

This cookie stores recently viewed products.

Magento

recently_viewed_produt_previous

This cookie stores recently viewed products.

Magento

section_data_ids

This cookie enables caching of content in the browser so that pages can be loaded faster.

Magento

X-Magento-Vary

This cookie enables Magento 2 to notify the user that the version of the page the user is viewing has changed.

Magento

form_key

This cookie prevents CSRF (Cross-Site Request Forgery).

Magento

store

This cookie saves the currently selected store (DE/AT/CH, Global, Western Europe or North America) and the language in question.

 

These purposes also constitute our legitimate interests in processing personal data in accordance with Article 6 (1) point (f) GDPR. 

4. Duration of storage; means of objection and rectification of data

Cookies are stored on the user’s computer system and transferred from it to our site. That means that you, the user, have full control over the use of cookies. You can disable or restrict transfer of cookies by changing the settings in your web browser. Cookies that have already been stored can be deleted at any time. That can also be done automatically. If cookies are disabled for our website, all the website’s functions may no longer be able to be used in full.

You can find the “Do Not Track” feature in your browser’s Help function or under the following links:

There are also tools or browser add-ons that can prevent the use of pixels on our pages (such as the add-on “AdBlock”).
You can find further ways of opting out in the following information on the tracking and targeting measures we use.

VII. Newsletter

1. Description and scope of data processing

Users can subscribe to a free newsletter on our Internet site. The data provided in the input screen used in subscribing to the newsletter is sent to us.

  • E-mail address (mandatory)
  • Form of address (optional)
  • First name (optional)
  • Surname (optional)
  • Date of birth (optional)

The following data is also collected during the subscription process:

  • IP address of the computer system calling the site
  • The date and time of subscription

Your consent to processing of the data is obtained and your attention is drawn to this Data Privacy Statement during the subscription process.

If you purchase goods or services on our Internet site and store your e-mail address as part of that, we can subsequently use that address to send a newsletter. In such a case, only direct advertising for our own, similar goods or services is sent out using the newsletter.

No data is passed on to third parties in connection with the processing of data needed to send newsletters. The data is used solely for sending the newsletter.

We use optivo broadmail for sending newsletters. optivo broadmail is a service from optivo GmbH (Wallstraße 16, 10179 Berlin, Germany). 

We have concluded order processing agreements with optivo GmbH to ensure that your data is processed in compliance with data protection regulations. 

Links in our newsletters contain tracking information that lets us know what links were of particular interest to you and when you clicked on them. The following data is stored in optivo broadmail by means of the tracking link: E-mail address, newsletter, link, date and time the link was opened.

2. Legal grounds for processing data

The legal basis for processing data after the user has subscribed to the newsletter is Article 6 (1) point (a) GDPR if the user has given consent.

The legal basis for sending the newsletter as a consequence of goods or services being sold is Section 7 (3) of the German Act Against Unfair Competition (UWG).

3. Purpose of data processing

The user’s e-mail address is collected so that the newsletter can be delivered.  Other personal data is collected as part of the subscription process so as to prevent misuse of the services or the e-mail address used.

4. Duration of storage

Your personal data is stored until you cancel your subscription to the newsletter by clicking on the unsubscribe link you can find below every newsletter you receive from us. 

5. Means of objection and rectification of data

Users can cancel their subscription to the newsletter at any time. Every newsletter contains a link allowing them to do that. If you are a registered user with a customer account, you can also cancel your subscription to the newsletter in your profile.

That also withdraws your consent to storage of your personal data collected during the subscription process.

VIII. Registration

1. Description and scope of data processing

On our Internet site, we give users the possibility of registering using their personal data. The data is entered in an input screen, sent to us and stored. The data is not passed on to third parties. 

If you open a personal customer account, we store your e-mail address and password so as to identify you, as well as the address data you have disclosed, so that you do not have to enter your particulars again when you place another order.  You can also call the articles you have ordered on the page “My Account” / “My Orders” and order or cancel our newsletter. 

The following data is also stored at the time of registration:

  • The user’s IP address
  • The date and time of registration

The user’s consent to processing of this data is obtained as part of the registration process.

2. Legal grounds for processing data 

The legal basis for processing data is Article 6 (1) point (a) GDPR if the user has given consent.

If registration is carried out for the purpose of performing a contract to which the user is a party or performing steps prior to entering into a contract, the additional legal basis for processing data is Article 6 (1) point (b) GDPR.

3. Purpose of data processing

Registration by the user can help in performance of a contract and is also required so that certain content and services can be provided on our website.

We point out that we use your data – also repeatedly – for advertising and marketing purposes, where permissible under the law without your separate, explicit consent. Acceptance of this Data Privacy Statement does not constitute your consent to use of your data for marketing purposes.

The data is recorded automatically for the purpose of subsequent statistical analysis.

The recorded information is of a general and technical nature and cannot be used to identify you. This data is also created whenever the user accesses websites again. The recorded data may include the operating system you use, the type of web browser you use, the link that took you to the page, your Internet service provider, the name of the requested file and similar details on your visit to our pages.

This data is used to improve our offering and does not allow us to identify you. The data is only analysed in anonymous form (e.g.: Information xy was called by 45% of the site’s visitors). That enables us to tailor the information we offer to reader’s interests.

Where we obtain data that could theoretically allow you to be identified, such as your IP address, we truncate it to ensure that it cannot be used to identify you.

Users must register so that a contract with the user or steps prior to entering into a contract can be performed.

4. Duration of storage

The data is erased as soon as it is no longer required for achieving the purpose for which it was collected.

This is the case for data collected during registration when registration is cancelled or changed on our Internet site. 

This is necessary for data collected during registration so that a contract or steps prior to entering into a contract can be performed if the data is no longer required for performance of the contract. Personal data of the contractual partner may also need to be stored after the contract has been concluded so that contractual or statutory obligations can be fulfilled.

5. Means of objection and rectification of data

Users can cancel their registration at any time. You can have the data stored on you changed at any time. 

If you wish to delete your customer account entirely, you can request our customer service (info@beyerdynamic.de) to do so at any time. Your account is then deleted without undue delay. You can register again at any time after that. 

If you have any further questions on the collection, processing or use of personal data, or wish to obtain information on data or have it rectified, blocked or erased, simply contact our Data Protection Officer. 

If the data is required for the purpose of performing a contract or steps prior to entering into a contract, premature erasure of the data is possible only if there are no contractual or statutory obligations that prevent it from being erased. 

IX. Contact form and e-mail contact

1. Description and scope of data processing

Our website contains a form that can be used for contacting us electronically. If a user makes use of this option, the data entered in the input screen is sent to us and stored. This data is:

  • E-mail address
  • Form of address
  • First name
  • Surname
  • Company
  • Street and number 
  • Federal state/Canton
  • City
  • Country 

The following data is also stored at the time the message is sent:

  • The user’s IP address
  • The date and time of registration

Your consent to processing of the data is obtained and your attention is drawn to this Data Privacy Statement when you send your message.

Users may also contact us under the e-mail address provided. In this case, the user’s personal data sent with the e-mail is stored. 

The data is passed on to third parties only if the user consents to that by checking a checkbox. If the user does not check the checkbox, no data is passed on to third parties in this connection. The data is then used solely for processing the conversation.

2. Legal grounds for processing data 

The legal basis for processing data is Article 6 (1) point (a) GDPR if the user has given consent.

The legal basis for processing data sent with an e-mail is Article 6 (1) point (f) GDPR. If the purpose of the e-mail contact is to conclude a contract, the additional legal basis for processing of the data is Article 6 (1) point (b) GDPR.

3. Purpose of data processing

We process personal data from the input screen solely for handling contacts. If we are contacted by e-mail, that constitutes the legitimate interest required for processing the data.

The other personal data that is processed when data is sent helps prevent misuse of the contact form and ensure the security of our IT systems.

4. Duration of storage

The data is erased as soon as it is no longer required for achieving the purpose for which it was collected. As regards personal data from the contact form’s input screen and personal data sent by e-mail, this is the case when the particular conversation with the user is over. The conversation is over when it is clear from circumstances that the matter in question has been definitely resolved. 

The personal data additionally collected when data is sent is erased after no later than seven days.

5. Means of objection and rectification of data

Users can withdraw their consent to their personal data being processed at any time. If users contact us by e-mail, they can object to their personal data being stored at any time. That then means the conversation cannot be continued.

Please contact our Data Protection Officer in such cases.

All personal data stored as part of the contact is erased in this case. 

X. Use of Google Analytics

1. Scope of processing of personal data

We use Google Analytics, a web analytics service from Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. 

Google Analytics uses cookies, text files that are stored on your computer and enable analysis of how you use the website. The information on your use of this website generated using the cookies is usually transferred to and stored on a server operated by Google in the USA. However, if IP anonymisation is activated on this website, your IP address will be truncated by Google beforehand within the Member States of the European Union or in other countries that are party to the Agreement on the European Economic Area. The complete IP address is sent to a Google server in the USA and truncated there only in exceptional cases. 

The IP address sent from your browser as part of Google Analytics is not combined by Google with other data. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activities and to provide other services for the website operator relating to website and Internet use.

This website uses Google Analytics with the extension “_anonymizeIp()”. As a result, IP addresses are only processed further in truncated form, which prevents them being linked to a particular individual. If data collected about you can be assigned to you, such a link is therefore excluded immediately and the personal data is erased without undue delay.

2. Purpose of data processing

We use Google Analytics to analyse the use which is made of our website and to improve it on a regular basis. We can use the statistics we obtain to improve our offering and make it more interesting for you as a user. In exceptional cases in which personal data is transferred to the USA, Google is subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.

3. Legal grounds for processing of personal data

The legal basis for using Google Analytics is Section 15 (3) of the German Telemedia Act (TMG) and Article 6 (1) point (f) GDPR. 

4. Duration of storage

The data that we send and that is linked with cookies, user identifiers (e.g. a user ID) or advertising IDs is automatically erased after 14 months. Data whose retention period has ended is erased automatically once a month. 

5. Means of objection and rectification of data

You can prevent storage of the cookies by making the appropriate setting in your browser software; however, we point out that if you do so, you might not be able to use all the functions of this website in full. You can also prevent recording of the data relating to your use of the website and generated by the cookie (including your IP address) by Google and processing of this data by Google by downloading and installing the browser add-on available under the following link: tools.google.com/dlpage/gaoptout. Opt-out cookies prevent future recording of your data when you visit this website. 

In order to prevent your data being recorded by Universal Analytics across different devices, you have to opt out on each system you use. You can set the opt-out cookie by clicking here:

Disable Google Analytics

6. Information on the third-party provider

Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Service: www.google.com/analytics/terms/us.html, overview of data protection: support.google.com/analytics/answer/6004245, and the Privacy Policy: https://policies.google.com/privacy?hl=en&gl=de .

XI. DoubleClick by Google

1. Scope and purpose of processing of personal data

DoubleClick by Google is a service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). DoubleClick by Google uses cookies to present relevant ads for you. As part of that, your browser is assigned a pseudonymous identification number (ID) to review which ads were shown in your browser and which ads were clicked on. The cookies do not contain any personal information. The use of DoubleClick cookies only enables Google and its partner websites to display ads on the basis of previous visits to our or other websites in the Internet. The information created by the cookies is transferred by Google to a server in the United States for analysis and is stored there. Google will transfer the data to third parties only in compliance with statutory regulations or as part of data processing commissioned under an agreement. Google will never combine your data with other data it has recorded.

2. Legal grounds for processing of personal data

The legal basis for processing personal data using cookies is Article 6 (1) point (f) GDPR.

3. Means of objection and rectification of data

You can prevent storage of the cookies by making the appropriate setting in your browser software; however, we point out that if you do so, you might not be able to use all the functions of our web pages in full. You can find more information on data protection in relation to DoubleClick at: policies.google.com. You can also prevent recording of the data relating to your use of the website and generated by the cookie by Google and processing of this data by Google by downloading and installing the browser plug-in available under the following link support.google.com/ads/answer/7395996, (under “Save ad settings with browser plugin”, extension for DoubleClick deactivation).

XII. Google Tag Manager

Google Tag Manager is a service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) which can be used to create, update and manage tags. Tags are small code elements on our website which, among other things, help measure traffic and visitor behaviour, as well as record the impact of online advertising and social channels. 
When you visit our website, the current tag configuration is sent to your browser. It contains instructions on which tags are to be activated. The tool itself does not record any personal data. However, it causes other tags to be activated, which may in turn record data. 

You can find more information on how Google Tag Manager tags work at: support.google.com/tagmanager/answer/6102821 and in the Terms of Service: https://www.google.com/analytics/tag-manager/use-policy/ .

XIII. Use of Google Remarketing

This website uses the remarketing function of Google Inc. (“Google”). This function is used to present interest-based ads to website visitors as part of the Google advertising network. The browser of the website visitors stores cookies, text files that are stored on their computer and enable visitors to be recognised when they call websites that are part of the Google advertising network. Visitors can then be shown ads on these sites which relate to content they called previously on websites which use the Google remarketing function. According to its own statements, Google does not collect any personal data in this process.The legal basis for processing personal data using cookies is Article 6 (1) point (f) GDPR.If you nevertheless do not wish to use the Google remarketing function, you can disable it by making the relevant settings under www.google.com/settings/ads. Alternatively, you can disable the use of cookies for interest-based advertising via the Network Advertising Initiative by following the instructions at www.networkadvertising.org/managing/opt_out.asp. You can find more information on Google remarketing and Google’s Privacy Policy at: www.google.com/privacy/ads/ .

XIV. Use of Google AdWords conversion tracking

As a Google AdWords customer, we use Google conversion tracking, an analytics service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). If you access our website after clicking on a Google ad, Google AdWords places a cookie (“conversion cookie”) on your computer system. These cookies lose their validity after 30 days and are not used to identify users personally. If you visit specific pages of our website and if the cookie has not yet expired, we and Google will be able to tell that someone has clicked on the ad and so was forwarded to our page. Every AdWords customer receives a different cookie. That means cookies cannot be tracked via the websites of AdWords customers. The information collected by the conversion cookie is used to create conversion statistics for AdWords customers who have opted-in for conversion tracking. AdWords customers are informed about the total number of users who clicked on their ad and were forwarded to a page with a conversion tracking tag. However, they do not obtain any information enabling them to identify users personally.If you do not wish to participate in tracking, you can object to its use by preventing installation of the cookies by means of a setting in your browser software (deactivation option). You are then not included in the conversion tracking statistics.The legal basis for processing personal data using cookies is Article 6 (1) point (f) GDPR.You can find more information from Google at www.google.com/policies/technologies/ads/ and policies.google.com/privacy .

XV. Bing Universal Event Tracking (UET)

Bing Ads technologies are used on our website to collect and store data, from which user profiles are created using pseudonyms. This is a service from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. This service allows us to track the activities of users on our website if they have come to our website after clicking on Bing Ads. If you come to our website after clicking on such an ad, a cookie is placed on your computer. A Bing UET tag is integrated on our website. This is a code with which, in conjunction with the cookie, some non-personal data relating to use of the website is stored. That includes the dwell time on the website, what areas of the website were called and which ad took users to the website. Information on your identity is not recorded.The legal basis for processing personal data using cookies is Article 6 (1) point (f) GDPR.The recorded information is transferred to Microsoft servers in the USA and stored there for a maximum of 180 days. You can also prevent recording of the data relating to your use of the website and generated by the cookie and processing of this data by disabling placement of cookies. The functions of this website may be restricted as a result.Microsoft may also use cross-device tracking to track your behaviour across multiple electronic devices, enabling it to display personalised advertising on or in Microsoft websites and apps. You can deactivate that at choice.microsoft.com/de-de/opt-out.You can find more details on Bing’s analytics services on the Bing Ads website ( help.bingads.microsoft.com ). You can find more details on data protection at Microsoft and Bing in the Microsoft Privacy Statement ( privacy.microsoft.com/en-us/privacystatement).

XVI. Facebook, Custom Audiences and Facebook Marketing Services

1. Scope of data processing

In our online offering, we use the “Facebook pixel” from the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). Facebook is certified under the Privacy Shield Framework and so offers a safeguard that it complies with European data protection law. The Facebook pixel enables Facebook to define visitors to our online offering as a target group for advertising (“Facebook ads”). When our web pages are called, the Facebook pixel is directly integrated by Facebook and may store a cookie, a small file, on your device. When you then log on to Facebook or visit Facebook when you are logged on, your visit to our online offering is recorded in your profile. The data collected about you is anonymous to us and so we cannot use it to identify users. However, the data is stored and processed by Facebook, which means it can be associated with your profile and used by Facebook and for our own marketing research and advertising purposes. If we should transmit data to Facebook for the purpose of synchronisation, it is encrypted locally in the browser and only then sent to Facebook over a secure https connection. This is done solely to synchronise the data with the data likewise encrypted by Facebook. Facebook processes the data in accordance with its Data Policy. You can find general information on the display of Facebook ads in Facebook’s Data Policy. You can find specific information and details on the Facebook pixel and how it works in the Facebook Help.

2. Legal basis for data processing

The legal basis is our legitimate interest in analysing and optimising our online offering and operating it cost-effectively and for these purposes. The legal basis for processing personal data using the Facebook pixel is Article 6 (1) point (f) GDPR.

3. Purpose of data processing

We use the Facebook pixel to display ads we have placed only to those Facebook users who are also interested in our online offering or have the specific attributes (e.g. interest in specific topics or products as determined by the websites they visit), which we transmit to Facebook (“Custom Audiences”). By using the Facebook pixel, we also wish to ensure that our Facebook ads reflect users’ potential interest and are not felt to be a nuisance. We can also use the Facebook pixel to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users are forwarded to our website after clicking on a Facebook ad (termed “conversion”).

4. Duration of storage

According to its own statements, Facebook stores the data and time of your visit, the specific Internet address where the social plug-in is located, and other technical data, such as the IP address, the type of browser, the operating system, for a period of 90 days so as to further optimise Facebook’s services. When the 90-day period ends, the data is anonymised so that it can no longer be associated with you.

5. Withdrawal of consent and means of deactivation

You can object to recording of your data by the Facebook pixel and use of it to present Facebook ads. In order to define which types of ad are shown to you in Facebook, you can call the site set up by Facebook and follow the information there on Your ad preferences. The settings are platform-independent, i.e. they are adopted for all your devices, such as desktop computers or mobile devices. You can also opt out from using cookies that are used to measure reach and for advertising purposes on the deactivation site of the Network Advertising Initiative and also on the U.S. website or the European website.

 XVII. Sharing plug-ins (Facebook, Twitter and YouTube)

We have installed sharing plug-ins on our website. These are simple HTML links which initially do not link any information about your visit to our website with your data on use of the relevant social media platform, such as with a Facebook user, or transmit it to the platform. Such information is only sent when you click on the sharing plug-in. That calls a script. The same applies to the possibility of sending tweets to Twitter directly from our site. A script calls up information on how often a site has been shared or tweeted about. It establishes contact with the service in question is via the programming interfaces (APIs) of that service and retrieves the figures. That query is therefore carried out by the server; instead of the visitor’s IP address, only the server address is transferred to Facebook, Google and Twitter. As long as users do not click on the link to share content, they remain invisible, at least to the social media platforms. Please not that if you click on the link and your data is stored by service providers with registered offices that are not specified as being in an EU country, your data is often also stored by the service provider in non-EU countries and is subject to the regulations there. We point out that we, as the provider of our website, obtain no binding knowledge of how the data is used by the social media platforms. The sharing plug-ins are visibly indicated, such as by a logo (“f” for Facebook, “t” for Twitter, “YouTube” for YouTube and/or by an addendum referring to the service). You can find out which data Facebook collects for its own purposes in Facebook’s Data Policy, where you can also obtain further information on how data is collected and processed by Facebook and on your related rights. Facebook’s Data Policy can be called at www.facebook.com/policy.php and Facebook’s information on social plug-ins at on.fb.me/mAN33b. If you activate a sharing plug-in, such as by clicking on Facebook’s "f” button, or if you submit comments or use other functions offered by Facebook, the information in question is transmitted to Facebook, stored for your Facebook account for further use, and processed in accordance with Facebook’s regulations. For details of the purpose and scope of data collection, how the data is processed and used further by Facebook, your related rights and settings you can make to protect your privacy, please refer to: 

Facebook’s Data Policy
Twitter’s Privacy Policy
YouTube’s Privacy Policy

XVIII. Dealer search

1. Scope of processing of personal data

When they call this website for the first time, users can consent to use of the Geolocation API function. After they have consented, various items of geo-information (GPS data / data on the WLAN in which the device may be logged in / geo-information on the IP address used) of the device (computer, notebook, smartphone, tablet, etc.) is called by a client so as to ascertain the device’s location. 
Exactly what data is called depends, among other things, on the settings on your device. The position of your device is ascertained by the browser or operating system on your device itself; we do not do that as part of our data processing activities. 
The location data is used in real time to determine the current location of the nearest Beyerdynamic dealer and suggest it as the relevant store. 
Information of the store selected in this way is then stored in a persistent cookie on your device’s browser so that you are shown the local offerings of relevance to you when you visit our website in future.
You can change the store assigned to you manually at any time. 

2. Purpose of data processing

Our objective is to ensure that you are automatically shown the latest offerings and information for your region and your nearest Beyerdynamic dealer when you visit our website. That is why we use the Geolocation API function. 

3. Legal grounds for processing data

The legal basis for processing data after the user has consented is Article 6 (1) point (a) GDPR.

4. Duration of storage

The location data is erased as soon as it is no longer required for achieving the purpose for which it was collected. As regards data recorded to deliver the website, this is the case when the session is over.

5. Means of objection and rectification of data

Users can withdraw consent at any time by deleting the cookies we have stored on their device (see section VI. “Use of cookies” in this Data Privacy Statement. 

XIX. Rights of data subjects

If your personal data is processed, you are a data subject within the meaning of the General Data Protection Regulation (GDPR) and you have the following rights vis-à-vis the controller:

1. Right to access and obtain information

You can demand confirmation from the controller as to whether personal data concerning you is processed by us. 
If it is processed by us, you can demand the following information from the controller:

(1) the purposes for which the personal data is processed;
(2) the categories of personal data processed;
(3) the recipients or categories of recipients to whom the personal data concerning you has been or is to be disclosed;
(4) the planned length of time for which the personal data concerning you will be stored or, if concrete details of that are not possible, the criteria used to determine that length of time;
(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing of the data by the controller, or a right to object to such processing; 
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) all available information on the origin of the data if the personal data has not been collected from you;
(8) the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;

You have the right to demand information on whether the personal data concerning you is transferred to a third country or an international organisation. You can demand to be informed about the appropriate safeguards in accordance with Article 46 GDPR that have been provided in connection with such transfer of your data.

2. Right to rectification 

You have a right to demand that the controller rectify and/or complete processed personal data concerning you if it is incorrect or incomplete. The controller shall rectify the data without undue delay.

3. Right to restriction of processing
You can demand that processing of personal data concerning you be restricted under the following circumstances:

(1) if you contest the accuracy of the personal data concerning you, processing of the data will be restricted for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you oppose the erasure of the personal data and request restriction of its use instead;
(3) the controller no longer needs the personal data for the purposes of processing, but it is required by you for the establishment, exercise or defence of legal claims; or
(4) you have objected to processing pursuant to Article 21 (1) GDPR and it has yet to be verified whether the legitimate grounds of the controller override your grounds.
Where processing of personal data concerning you has been restricted, the data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
If processing of data has been restricted pursuant to the above circumstances, you will be informed by the controller before the restriction is lifted.

4. Right to erasure

a) Obligation to erase data

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller has the obligation to erase that data without undue delay where one of the following grounds applies:

(1) the personal data concerning you is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
(2) you withdraw consent on which the processing was based in accordance with Article 6 (1) point (a) or Article 9 (2) point (a) GDPR, and where there is no other legal ground for the processing; 
(3) you object to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 (2) GDPR; 
(4) the personal data concerning you has been unlawfully processed; 
(5) the personal data concerning you has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; 
(6) the personal data concerning you has been collected in relation to the offer of information society services referred to in Article 8 (1) GDPR.

b) Notification of third parties

Where the controller has made the personal data concerning you public and is obliged pursuant to Article 17 (1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, that personal data. 

c) Exceptions

You do not have a right to demand erasure of your data if processing of it is necessary
(1) for exercising the right of freedom of expression and information;
(2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the area of public health in accordance with Article 9 (2) points (h) and (i) and Article 9 (3) GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR insofar as the right referred to in a) above is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(5) for the establishment, exercise or defence of legal claims.

5. Right to notification

If you have asserted your right to rectification, erasure or restriction toward the controller, the controller must communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you has been disclosed, unless this proves impossible or involves disproportionate effort.
You have the right to be informed by the controller about who these recipients are.

6. Right to data portability

You have the right to receive the personal data concerning you which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, if

(1) processing of the data is based on consent in accordance with Article 6 (1) point (a) GDPR or Article 9 (2) point (a) GDPR or on a contract in accordance with Article 6 (1) point (b) GDPR and
(2) the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another controller, where technically feasible. This must not adversely affect the rights and freedoms of others.
The right to data portability shall not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 (1) point (e) or (f) GDPR, including profiling based on those provisions. 
The controller shall no longer process the personal data concerning you unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

8. Right to withdraw the declaration of consent under data protection law

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing based on your consent before you withdrew it.

9. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision 
(1) is necessary for entering into, or performance of, a contract between you and the controller;
(2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
(3) is based on your explicit consent.
However, these decisions must not be based on special categories of personal data referred to in Article 9 (1) GDPR, unless Article 9 (2) point (a) or (g) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.
In the cases referred to in (1) and (3), the controller will implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your own point of view and to contest the decision.

10. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the General Data Protection Regulation (GDPR). 
The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.
If you wish to exercise your right to lodge a complaint, you can do so with the following authority:
Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg 
(The Baden-Württemberg State Commissioner for Data Protection and Freedom of Information)

Postfach 10 29 32
70025 Stuttgart / Germany

or:

Königstraße 10a
70173 Stuttgart / Germany
Phone: +49 (0)7 11/61 55 41-0
Fax: +49 (0)7 11/61 55 41-15
E-mail: poststelle@lfdi.bwl.de
Homepage: http://www.baden-wuerttemberg.datenschutz.de

11. Exercise of rights by data subjects

If data subjects wish to exercise one or more of their above rights, they can contact our Data Protection Officer or another employee of the controller at any time.

XX. Distribution through Amazon

1. Scope of processing of personal data

You have already been informed in Amazon’s Privacy Notice (which can be called at:  www.amazon.de/gp/help/customer/display.html/ref=footer_privacy) about the fact that your personal data is collected and stored, as well as how and the purpose for which it is used. Amazon obtained your consent to that when you registered. We do not collect any further personal data above and beyond that recorded by Amazon. You have already consented to Amazon transmitting your personal data to us for the purpose of performing the contract. The personal data Amazon sends us is stored by us. 

We use this data
• to be able to identify you as our customer;
• to process, fulfil and handle your order;
• to correspond with you;
• to send invoices;
• to handle any warranty claims and to assert any claims against you.

Your consent to processing of this data is obtained when you register with Amazon and as part of order handling.

2. Legal grounds for processing data 

Data is processed in response to your order and is required pursuant to Article 6 (1) sentence 1 point (b) GDPR for the stated purposes so as to enable proper processing of your order and so that both parties fulfil their obligations under the purchase agreement.

3. Duration of storage

The personal data collected by Amazon for handling your order and transmitted to us is stored by us until the statutory period for retaining it expires and is then erased, unless we are required to store it for longer in accordance with Article 6 (1) sentence 1 (c) GDPR pursuant to retention and documentation obligations under fiscal and commercial law (such as the German Commercial Code (HGB), the German Penal Code (StGB) or the German Fiscal Code (AO)) or you have consented to further storage of it in accordance with Article 6 (1) sentence 1 point (a) GDPR. For further information on storage of your personal data by Amazon, please refer to Amazon’s Privacy Notice.

XXI. Disclosure of data to third parties

Your personal data is passed on to third parties if, in particular, that is permitted by law and is required pursuant to Article 6 (1) sentence 1 point (b) GDPR for handling contractual relationships with you.

1. For handling payments 

That includes passing on payment data to payment service providers or banks so that payment can be handled. As part of that, it may be necessary for us to pass on personal data collected in the payment process, such as your name, address, phone number, e-mail address, credit card or bank account data and transaction data, to the payment service provider. However, the payment service providers usually collect this data themselves. The third party may use the data given to it solely for the above purposes.
In order to perform contracts in accordance with Article 6 (1) sentence 1 point (b) GDPR, we use the following payment service providers to handle payments. 

a) Payments by credit card

If you pay by credit card (Visa/MASTER card), the payment data you enter in accordance with Article 6 (1) sentence 1 point (b) GDPR is recorded and stored by SIX Payment Services AG, Hardturmstrasse 201, 8005 Zurich, Switzerland, and BS PAYONE GmbH, Lyoner Straße 9, 60528 Frankfurt/Main, Germany and passed on solely to the companies involved in the payment process. When you pay by credit card, you accept the payment service provider’s general terms and conditions. We do not collect or store the payment data if this means of payment is used.
You can find more information in the privacy policy of your credit card company.

b) Payment by PayPal
We offer payment by means of the payment service provider 
PayPal, PayPal (Europe) S.à. r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg (“PayPal”).
 If you pay using your PayPal account, you are forwarded to the PayPal website. You can log on there using your account data and instruct payment. If you select the means of payment “direct debit,” “credit card” or “purchase on account,” you are likewise forwarded to the PayPal website. You can instruct payment there, whether you have or do not have a PayPal account, stating the payment information. We have no access to the personal data collected by PayPal. PayPal is responsible for processing it.
You can find more information on data protection in the PayPal Privacy Policy. 

2. For sending your order

So that we can send the order you placed in our shop (Article 6 (1) sentence 1 point (b) GDPR) and pursuant to our legitimate interest in making shipment of orders for you as uncomplicated as possible (Article 6 (1) sentence 1 point (f) GDPR), we transmit your data you give us as your delivery address to the shipping service providers tasked with conveying your consignment. This is done solely to ensure the goods you order are delivered and you are notified of when they are to be delivered. These service providers must comply with regulations on secrecy of mail.

3. For requesting customers to give ratings

a) Trusted Shops

As soon as you have placed an order in our online shop, we send your e-mail address to 
Trusted Shops GmbH, Subbelrather Str. 15c, 50823 Cologne, Germany (www.trustedshops.de),
so that you are, if applicable, reminded by Trusted Shops by e-mail to submit a rating. Your e-mail address is sent on the basis of our legitimate interest in accordance with Article 6 (1) sentence 1 point (f), namely to tailor the shopping experience we offer as best possible to our customers’ needs on the basis of your ratings. 

b) Google reviews

You can rate the purchase process on our website by using the survey from Google Customer Reviews. If you explicitly consent to participate (Article 6 (1) sentence 1 point (a) GDPR), you are sent a survey by Google after your order has been delivered. As part of that, we transmit the following information relating to your order

  • The order ID
  • Your e-mail address
  • The country to which the order is delivered
  • The date on which you order was delivered, and
  • The Global Trade Item Number for assigning the review data to one of our articles

to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) in the USA. Google complies with the data protection regulations of the EU-US and and Switzerland-U.S. Privacy Shield and is registered in the EU-US and Switzerland-U.S. Privacy Shield Framework of the U.S. Department of Commerce. You can withdraw your consent to processing of your data at any time by notifying us. As a consequence, we will no longer be allowed to continue processing the data on the basis of your prior consent with future effect.

4. For integrating the Trusted Shops Trustbadge

The Trusted Shops Trustbadge is integrated on this website to display our Trusted Shops seal of quality and the Trusted Shop products for buyers after an order.

This safeguards our overriding legitimate interest, based on a weighing of interests, in optimum marketing of our range of products and services (Article 6 (1) sentence 1 point (f) GDPR). The Trustbadge and services promoted by it are offered by

Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne, Germany.

When the Trustbadge is called, the web server automatically stores a server log file which contains, for example, your IP address, the date and time you called the Trustbadge, the volume of data transferred, and the provider that submitted the request (access data) and documents calling of the Trustbadge. This access data is not analysed and is automatically overwritten no later than seven days after your visit to the site. 

5. For other purposes

We also disclose your personal data to third parties only if:

  • you have given your explicit consent in accordance with Article 6 (1) sentence 1 point (a) GDPR,
  • if there is a legal obligation to disclose the data in accordance with Article 6 (1) sentence 1 point (c) GDPR, and
  • if it must be disclosed in accordance with Article 6 (1) sentence 1 point (f) GDPR to enable the establishment, exercise or defence of legal claims and there is no reason to assume that you have overriding legitimate interests in your data not being disclosed.