Privacy Policy of the
Otto Group Solution Provider (OSP) GmbH


Updated: 10/09/2020


As of 25 May 2018, the uniform requirements of the EU General Data Protection Regulation (GDPR) apply throughout Europe in the area of data protection. The Privacy Policy provides information regarding the processing of personal data by the Otto Group Solution Provider (OSP) GmbH, (“OSP“ and/or “we” and/or “controller") in accordance with the GDPR and the German Federal Data Protection Act (FDPA 2018).

Please read our Privacy Policy carefully. If you have any questions or comments regarding our Privacy Policy, please contact us at datenschutzbeauftragter@ottogroup.com.

Content

1. Controller's name and contact details
2. Data protection officer's contact details
3. Purposes of data processing, legal bases and legitimate interests
    3.1 Accessing our websites
        3.1.1 Log files
        3.1.2 Cookies, tracking, social media plugins
    3.2 Data processing for advertising purposes
        3.2.1 Newsletter
        3.2.2 Sweepstakes
4. Website and website optimisation (using cookies) including consent
    4.1 Cookies – general information and consent
    4.2 Intervention options / browser settings
    4.3 OneTrust consent management
    4.4 Consent to the use of individual online services / the collection of tracking data
        4.4.1 Consent for performance cookies
            4.4.1.1 Google Conversion Tracking
        4.4.2 Consent for targeting cookies 
            4.4.2.1 Consent for Google Remarketing
            4.4.2.2 Consent for Facebook Retargeting (Website Custom Audience)
            4.4.2.3 Consent for LinkedIn Ads / Retargeting
        4.4.3 Consent for social media plugins
            4.4.3.1 YouTube        
        4.4.4 Revocation of all consents
        4.4.5 Further processing of tracking data for legitimate interests
            4.4.5.1 Legitimate interests of OSP / balancing of interests
            4.4.5.2 Google Analytics (Basic version)
            4.4.5.3 Google reCAPTCHA
5. Contact
6. Recipients outside the EU
7. Your rights
    7.1 Overview
    7.2 Right to object
    7.3 Right of revocation

 

1. Controller’s name and contact details

This Privacy Policy applies to data processing by

Otto Group Solution Provider (OSP) GmbH
Freiberger Straße 35
01067 Dresden
Deutschland

Represented by the directors Dr. Stefan Borsutzky, Norbert Gödicke and Jens Gruhl

Tel.: +49 (0)351 4923 0
Email: info@osp.de
Website: www.osp.de

for the following website: www.osp.de

 

2. Data protection officer's contact details

The controller’s operational data protection officer can be reached at

Otto Group
Werner-Otto-Str. 1-7
22179 Hamburg
Deutschland

Email: datenschutzbeauftragter@ottogroup.com

 

3. Purposes of data processing, legal bases and legitimate interests pursued by the controller or a third party as well as categories of recipients

3.1 Accessing our websites

3.1.1 Log files

Every time you access www.osp.de, information is sent to the server of our website by the internet browser of your respective device and temporarily stored in log files. The records stored contain the following data, which are stored until automatic deletion: Date and time of retrieval, name of the page requested, IP address of the requesting device, referrer URL (origin URL from which you came to our web pages), the amount of data transferred, load time as well as product and version information of the respectively used browser and the name of your access provider.

The legal basis for processing the IP address is Art. 6 (1) lit f) GDPR. Our legitimate interest lies in

  • guaranteeing a trouble-free connection
  • guaranteeing comfortable use of our website,
  • evaluation of system security and stability.


It is not possible to directly infer your identity on the basis of the information, nor do we endeavour to do so.

The data is stored and automatically deleted after the accomplishing the aforementioned purposes. The standard deletion periods are determined according to necessity.

3.1.2 Cookies, tracking, social media plugins

We use cookies, tracking tools, targeting procedures and social media plugins for our website. The exact procedures and how your data is used for this purpose is explained in detail below.

3.2 Data processing for advertising purposes

3.2.1 Newsletter

On our website, we give you the option to subscribe to our newsletter. To ensure that no errors have occurred when entering an email address, we use the double-opt-in procedure (DOI procedure): After you have entered your email address in the registration field, we will send you a confirmation link to the address provided. Your email address will be only entered in our newsletter mailing list after you click on this confirmation link. The legal basis for this data processing is Art. 6 (1) lit. a) GDPR.

Information on the right of revocation
You can revoke your consent at any time with effect for the future by sending a mail to info@osp.de or by using the unsubscribe option at the end of each newsletter.

3.2.2 Sweepstakes

If you register for a lottery organised by us, we will use the data you provide at the time of registration for the purpose of concluding the participation contract, in particular to notify you of your winnings and, if applicable, to advertise our offers and services. Detailed information can be found in the conditions of participation for the respective lottery. The legal basis for this data processing is Art. 6 (1) lit. a) GDPR, Art. 6 (1) lit. b) GDPR and Art. 6 (1) lit. f) GDPR.

4. Website and website optimization (using cookies) including consent

Brief summary
As the operator of the website osp.de, OSP collects data on the behaviour of users on the aforementioned website (tracking data). This includes, among other things, which individual sub-pages were visited. For this purpose, OSP and/or partners of OSP may set cookies in the browser used by the respective user. The collection of tracking data is generally only permitted if you have previously consented to this. You can grant such consent by clicking the "OK" button in the "cookie banner" displayed at osp.de. However, consent is not required for the processing of such tracking data, which is necessary for using the osp.de website. OSP may use the information about your usage behaviour, among other things, to display offers at osp.de that may be of interest to you, or to advertise on other websites using personalised content (e.g. retargeting). Insofar as personal data about your usage behaviour at osp.de can also be used by other providers, e.g. for the purpose of "enriching their own information", such use will only occur in these cases if you have given your prior consent. Tracking data that OSP collects and stores itself are only processed by OSP in pseudonymised form. This prevents the data being linked to your person. If you wish to delete individual cookies set in your browser or find out which service providers / providers have set cookies in your browser, you can do so using a "preference manager". Such a preference manager is available, for example, at www.youronlinechoices.com. You also have the option of setting your browser in such a way that it prevents cookies from being set or only allows certain types of cookies to be set. Detailed information on how to change the settings in the most common browser types (including Google-Chrome, Firefox) can be found in section 4.2. of this Privacy Policy.

4.1    Cookies – general Information and consent

This website uses cookies. Cookies are small text files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.). Information arising in connection with the specific device used is stored in the cookie. However, this does not mean that we immediately become aware of your identity.

Some of the cookies we use are deleted after the end of the browser session (session cookies). Other cookies remain on your computer and allow us to recognise your computer the next time you visit (persistent or multi-session cookies). Among other things, these cookies serve, in particular, to make our offer more attractive.

According to legal requirements, the storage of information on end devices (desktops, cell phones, tablets or similar) - e.g. by setting cookies - and the retrieval of information from end devices (tracking) is only permitted if you have given your prior consent. However, consent does not have to be granted if such storage / retrieval is necessary for the services offered on the website (e.g. technically necessary cookies). Storage / Retrieval is considered necessary, for example, for ensuring the following functionalities / achieving the following purposes:
- Ensuring system security.

You have no right of objection with regard to the data processing necessary for the operation of the website. Therefore, the option "strictly necessary cookies" is always activated and cannot be deselected in the consent preferences in the content tool.

You can use the osp.de website without data being retrieved from or stored on your terminal device for purposes that are not necessary for the services offered on the osp.de website. For this reason, only basic tracking is activated when you use the osp.de website, unless you have given your further consent.

You can adjust your personal settings at any time using the cookie settings:

Cookie-Einstellungen

4.2 Intervention options / browser settings

Of course you can set your browser so that it does not store certain cookies on your terminal device. The Help menu on the menu bar of most web browsers tells you how to prevent your browser from accepting new cookies, how to make your browser inform you when you receive a new cookie, or how to delete all cookies you have already received and how you can block all others.

Please proceed as follows: 

In Internet Explorer

  1. In the “Tools” menu, select “Internet Options”.
  2. Click on the “Privacy” tab.
  3. Now you can configure the security settings for the internet zone. Here you can set whether and which cookies should be accepted or rejected.
  4. Confirm your settings by clicking “OK”.


In Firefox:

  1. Click on the triple bar icon in the top right of the browser and select Preferences.
  2. Click on “Privacy and Security”
  3. In the drop-down menu, select “Use custom settings for history”.
  4. Now you can set whether to accept cookies, how long you want to keep these cookies and add exceptions to which sites you always or never want to allow the use of cookies.
  5. Confirm your settings by clicking “OK”.


In Google Chrome:

  1. Click on the Chrome menu icon in the toolbar.
  2. Then select “Settings”
  3. At the bottom, click “Advanced”.
  4. Under “Privacy and security,” click "Content settings".
  5. Under “Cookies”, you can make the following settings for cookies
    • Delete cookies (See all cookies and site data -> Remove)
    • Block cookies by default
    • Delete cookies and webpage data by default after quitting the browser,
    • Allow exceptions to cookies from certain websites or domains


In Safari:


  1. Click on "Safari" in the menu bar.
  2. Now select "Preferences".

  3. Click on "Privacy".
  4. Here you can set the following preferences for cookies:
    • Delete Cookies
    • Block cookies and website data by default
    • Change which cookies and website data are allowed

If you wish to delete individual cookies set in your browser or find out which service providers / providers have set cookies in your browser, you can do so using a "preference manager". Such a preference manager is available, for example, at www.youronlinechoices.com.

4.3 OneTrust consent management

To manage your settings and document the consent of users of our services, we use a consent tool ("OneTrust") provided by OneTrust, LLC (UK headquarters: Cannon Green, 27 Bush Lane, London EC4R 0AA, UK and US headquarters: 1350 Spring Street NW, Suite 500, Atlanta, Georgia 30309, USA). OneTrust is used, among other things, to store the cookie settings for the entire website. OneTrust stores information about the categories of cookies used by the website and whether users have given or revoked their consent to use each category. This allows us to prevent cookies from being set in each category in the user's browser if consent is not given for individual categories. OneTrust uses cookies with a normal duration of one year for information storage, so that the settings of regular visitors are stored.

4.4 Consent to the use of individual online services / the collection of tracking data

As already stated in section 4.1 of this privacy policy, OSP collects and processes tracking data, in some cases on the basis of consent. You grant this consent by clicking on the "OK" button in a banner on the website osp.de that links to these consent texts. By clicking on the "OK" button, you consent to OSP storing data on your terminal device (e.g. by setting cookies) or retrieving data from your terminal device. Furthermore, by clicking on the "OK" button, you give your consent to the use of certain advertising functions, the use of which in itself requires consent. You also have the option of clicking on "Settings" in the banner and managing your consent preferences there. A distinction is made there between "performance cookies", "targeting cookies" and “social media cookies”. Data processing that takes place in connection with these advertising functions is described below (section 4.4.1 to section 4.4.3 of this Privacy Policy).

All data processing that is recorded on the basis of the consent given by you by clicking the "OK" button serves the same purpose, namely that of "advertising".

4.4.1 Consent for performance cookies
4.4.1.1 Google Conversion Tracking

On this website we use conversion tracking when using the Google Ads service. A conversion tracking cookie will be installed on your computer/device when you click on an ad placed by Google. These cookies expire after 30 days, do not contain any personal data and thus cannot be used for personal identification purposes. The information gathered using the conversion cookie is used to generate conversion statistics for Ads customers who have opted for conversion tracking.

The legal basis for this data processing is Art. 6 (1) lit. f) GDPR.

You can prevent cookies from being saved by configuring your browser software accordingly; however, we would like to point out that in this case you may not be able to use the full functionality of this website. In addition, you can deactivate interest-based ads on Google and interest-based Google ads on the web (within the Google display network) in your browser by activating the "Off" button at https://www.google.de/settings/ads or by deactivating them at https://optout.aboutads.info/. For more information about your options in this regard and Google's privacy policy, please visit: https://policies.google.com/privacy?hl=en

4.4.2 Consent for targeting cookies
4.4.2.1 Consent for Google Remarketing

This website uses Google's Remarketing service. Google Remarketing is an online advertising program provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). In this regard, we use the remarketing feature provided as part of the Google Ads service. The remarketing feature allows us to present ads based on your interests on other sites within the Google advertising network. In order to do this, we analyse your browsing behaviour on our website, e.g. which services you have viewed. This enables us to show you customised advertising on the online search engine Google itself, so-called "Google Ads", and on other websites even after your visit to our website. For this purpose, Google stores a cookie on your browser whenever you visit Google services or websites in the Google advertising network. This cookie is used to record your visits. The cookie is used to uniquely identify your web browser, not to identify you personally. It is possible that Google may use the data collected via the website osp.de about your usage behaviour for its own purposes or for the purposes of other Google customers (e.g. to display customised third-party ads). Any such further processing of the data as well as the processing of the data after its transmission by OSP to Google is carried out by Google as the sole data controller under data protection law. The legal basis for this data processing is Art. 6 (1) lit. a) GDPR (consent).


For more information about Google Remarketing and Google's privacy policy, please visit: www.google.com/privacy/ads/. Here you can also assert your rights as a data subject (e.g. right to deletion) with regard to the data that Google processes as the data controller under data protection law. You can revoke your consent granted for the use of Google Remarketing here or refuse to consent to the use of Google Remarketing.

4.4.2.2 Consent for Facebook Retargeting (Website Custom Audience)

A pixel of Facebook Ireland Limited is integrated in this website (Website Custom Audience pixel). This pixel collects information about the use of this website (e.g. information about pages acessed) by Otto Group Solution Provider (OSP) GmbH and Facebook Ireland Limited under joint responsibility and transmits it to Facebook Ireland Limited. This information can be attributed to you with the aid of other information that Facebook Ireland Limited has stored about you, for example because you have an account on the social network Facebook. The information collected by the pixel can be used to display interest-related ads about our offers in your Facebook account (retargeting). The information collected by the pixel can also be aggregated by Facebook Ireland Limited and the aggregated information can be used by Facebook Ireland Limited for its own and for third-party advertising purposes. Thus, for example, Facebook Ireland Limited may infer certain interests from your browsing behaviour on this website and may also use this information to promote third-party offers. Facebook Ireland Limited may also combine the information collected by the pixel with other information that Facebook Ireland Limited has collected about you via other websites and/or in connection with the use of the social network Facebook, so that a profile about you may be stored at Facebook Ireland Limited. This profile may be used for advertising purposes. Facebook Ireland Limited is solely responsible for the permanent storage and displayed further processing of tracking data collected via the website custom audience pixel used on this website. The legal basis for this data processing is Art. 6 (1) lit. a) GDPR (consent).


For more information on data protection at Facebook Ireland Limited, please click here: https://www.facebook.com/policy.php. Here you will also find the possibility of asserting your rights (e.g. right to deletion) against Facebook Ireland Limited.

You can withdraw your consent to the transfer to Facebook Ireland Limited by using the pixel on this website here or refuse to consent to the use of Facebook Retargeting.

4.4.2.3 Consent to LinkedIn Ads / Retargeting

We use the retargeting service and conversion tracking of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn").

For this purpose, our website includes the LinkedIn Insight Tag, which enables LinkedIn to collect statistical, pseudonymous information about your visit and use of our website and to provide us with aggregated statistics based on this information. As a rule, the following information is collected:

  • LinkedIn User ID (Cookie ID)
  • IP Address
  • Metadata of website visit, e.g. browser type, website visited


In addition, this information is used to provide you with offers and recommendations that are specific to your interests and relevant after you have informed yourself about certain services, information and offers on the website. This information is stored in a cookie. The legal basis for this data processing is Art. 6 (1) lit. a) GDPR (consent).

You can find more information about LinkedIn's privacy practices in the LinkedIn Privacy Policy here: https://www.linkedin.com/legal/privacy-policy

You may opt out of LinkedIn's analysis of your usage patterns and the display of interest-based recommendations here or refuse to consent to the use of LinkedIn Retargeting.

4.4.3 Consent for Social Media Plugins

On our website, we use Social Plug-ins of the social network YouTube on the basis of Art. 6 (1) lit. f) GDPR in order to make our company better known about this. The advertising purpose behind this is to be regarded as a legitimate interest within the meaning of the GDPR. The responsibility for the data protection-compliant operation is to be guaranteed by their provider.

The purpose and scope of the data collection and the further processing and use of the data by the provider as well as your related rights and setting options for the protection of your privacy can be found in the data protection information of the provider, which is linked below.

By previously logging out from the pages of social networks and deleting cookies, you can prevent social networks from assigning the information collected about you to your user account at the respective social network during your visit to osp.de. If you do not want social networks to associate the information collected through our website directly with your profile, you must log out of those social networks before visiting our website. You can also completely prevent the loading of plugins with add-ons for your browser, e.g. with the script blocker "NoScript", which can be found at: https://noscript.net/.

4.4.3.1 YouTube

This website uses the provider YouTube LLC , 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google")) for the integration of videos.

Normally, when you visit a page with embedded videos, your IP address is sent to YouTube and cookies are installed on your computer. However, we have integrated our YouTube videos with the enhanced data protection mode (in this case, YouTube still contacts Google's Double Click service, but according to Google's privacy policy, personal data is not evaluated). As a result, YouTube no longer stores information about visitors unless they watch the video. If you click on the video, your IP address will be transmitted to YouTube and YouTube will know that you viewed the video. If you are logged in to YouTube, this information is also associated with your user account (you can prevent this by logging out of YouTube before viewing the video). Otto Group Solution Provider (OSP) GmbH has no influence on the content of the plug-ins and the transmission of information.

Google provides detailed information on the scope, type, purpose and further processing of your data on its website. Here you will also find further information on your rights and setting options to protect your privacy.

Data protection references of Google: https://policies.google.com/privacy.

4.4.4 Revocation of all consents
You can revoke your consent, which you have given for the data processing described above, in full here.

4.4.5 Further processing of tracking data for legitimate interests
4.4.5.1 Legitimate interests of OSP / balancing of interests

OSP is entitled to further process tracking data collected after consent has been granted, based on legitimate interests. The legal basis for this further processing is Art. 6 (1) lit f) GDPR (balancing of interests). Insofar as OSP further processes tracking data on the legal basis of Art. 6 (1) lit f) GDPR, this is done exclusively for purposes in which OSP has a legitimate interest. In connection with the further processing of tracking data, OSP does not process any data that is classified as particularly sensitive by law in Art. 9 GDPR (e.g. health data). OSP does not use the tracking data to produce evaluation results which could be assigned to the specially protected areas under Art. 9 GDPR. Nor will OSP use the tracking data to make any automated decisions which would have legal consequences for you as a user of the osp.de website or which would significantly affect you in a similar way. In addition, depending on its scope and the risks arising from the processing of the tracking data for your rights to be safeguarded, OSP will pseudonymise the tracking data, which prevents the data from being assigned to you personally.

4.4.5.2 Google Analytics (Basic version)

For the purpose of designing osp.de to meet your needs and to enable its continuous optimisation, data collected on the basis of a granted consent will be further processed using the basic version of Google Analytics on the legal basis in Art. 6 (1) lit f) GDPR (legitimate interest). The basic version of Google Analytics is a web analytics service of Google Inc. (Google). Google Analytics uses cookies, text files which are stored on your computer and which enable analysis of your use of the website. Google will use this information on behalf of OSP to evaluate your use of the website and to compile reports on website activity. Google processes the data collected using the basic version of Google Analytics exclusively on OSP's instructions and for OSP's purposes.

You may object to the further processing of your data by Google Analytics at any time here. As a result of the objection, Google Analytics will no longer collect data on the terminal device used by you to visit osp.de when you submitted your objection.

4.4.5.3 Google reCAPTCHA

On our website, we use the reCaptcha service of Google Inc. ("Google"), 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, to protect us against spam and misuse. This service is used to distinguish whether input was made by a human or in an abusive manner by automated machine processing.

To determine this, when you use the reCaptcha service Google sets a cookie in your browser and collects and processes the following data:

  • Referrer URL (address of the page on which the CAPTCHA is used)
  • Browser, browser size and resolution, browser plug-ins, date, language setting
  • Mouse or touch events within the reCaptcha box
  • Assignment to a Google Account (if you are currently logged in to Google when using the reCaptcha service, this will be detected and assigned)


Your input behaviour (such as answering the reCAPTCHA question, input speed in the form fields, order of selection of input fields by the user) is processed to improve pattern recognition by Google.    

Furthermore, Google reads the cookies from other Google services such as Gmail, Search and Analytics. All listed data will be sent to Google in encrypted form. Google's subsequent evaluation decides on the form in which the CAPTCHA is displayed on the page - in the form of a checkbox or text input. Personal data is not read or stored from the input fields of the respective form. For more information about Google's privacy policy, visit https://policies.google.com/privacy?hl=en.

5. Contact

You have the option to contact us in several ways: via email, via contact form, over the phone, by post or per WhatsApp. When you contact us, we will use the personal information you voluntarily provide to us for the sole purpose of contacting you and processing your request.

The legal basis for this data processing is Art. 6 (1) lit. a), Art. 6 (1) lit. b), Art. 6 (1) lit. c) and Art. 6 (1) lit. f) GDPR.


6. Recipients outside the EU

With the exception of the above processing, we do not share your information with recipients located outside the European Union or the European Economic Area. The processing operations mentioned under 4. entail a data transfer to the servers of the providers of tracking or targeting technologies commissioned by us. These servers are located in the USA. Data is transferred on the basis of the EU Commission’s standard contractual clauses as well as in accordance with the principles of the Privacy Shield.

 

7. Your rights     

7.1. Overview

In addition to the right to revoke your consent granted to us, you are entitled to the following further rights if the relevant legal requirements apply:

  • the right to obtain information about your personal data stored by us (Art. 15 GDPR), in particular you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data was or is being disclosed, the planned storage period and the origin of your data, if it was not collected directly from you;
  • the right to rectify incorrect data or to complete correct data (Art. 16 GDPR),
  • the right to deletion of your data stored by us (Art. 17 GDPR), provided that we are not required to observe any statutory or contractual retention periods or other statutory obligations or rights concerning further storage,    
  • the right to demand the restriction of the processing of your personal data (Art. 18 GDPR), provided that the accuracy of the data is disputed by you, the processing is unlawful, you however refuse its deletion and the controller no longer needs the data, you however need the data to assert, exercise or defend legal claims or you have objected to processing pursuant to Art. 21 GDPR,
  • the right to data portability pursuant to Art. 20 GDPR, i.e. the right to transfer selected data stored by us in a common, machine-readable format, or to request transmission to another controller
  • the right to complain to a supervisory authority. You can generally contact the supervisory authority of your usual domicile, place of work or our head office.


You can assert the aforementioned rights that you have regarding us under info@osp.de or via our contact form. You can assert the right to data portability under info@osp.de or via our contact form.

7.2 Right to object

Under the requirements of Art. 21 (1) GDPR, data processing can be objected to for reasons arising from the data subject's particular situation.

The above general right of objection applies to all processing purposes described in this Privacy Policy that are processed on the basis of Art. 6 (1) lit. f) GDPR. Unlike the special right of objection to data processing for advertising purposes (see above 3.2), under the GDPR we are only obliged to implement such a general objection if you give us reasons of overriding importance (such as a possible danger to life or health).

7.3 Right of revocation

If we process data on the basis of your consent, you have the right to revoke your consent at any time. The revocation of consent does not mean that the data processing carried out on the basis of the consent until the time of revocation becomes ineffective.