Data Privacy
I. Name and address of the person responsible
Front Panel Express LLC
1015 Central Avenue North
Kent, WA 98032
US
Tel: (206) 768-0602
E-Mail: Info@frontpanelexpress.com
Website: www.frontpanelexpress.com
II. General information on data processing
1. Scope of processing of personal data
We collect and use personal data from you as a user only to the extent necessary to provide a functional website as well as our content and services. Your personal data is only collected and used regularly with your consent. An exception applies in those cases where prior consent cannot be obtained for practical reasons and where processing of the data is permitted by law.
In accordance with point (1) of Article 4 of the General Data Protection Regulation (GDPR), personal data means any information relating to an identified or identifiable natural person. This includes, for example, name, e-mail address, postal address and telephone number. Information that cannot be attributed to a particular individual, such as the number of visitors to a website, does not constitute personal data.
2. Legal basis for the processing of personal data
Where we obtain your consent to process personal data, point (a) of Article 6(1) GDPR serves as the legal basis for the processing of personal data.
In the processing of personal data required for the performance of a contract to which you are a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures. Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis. In the event that vital interests on your part or on the part of another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
3. Data erasure and storage period
Your personal data will be erased or blocked as soon as the purpose of storage ceases to apply. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which we are subject. The data will also be blocked and erased if a storage period prescribed by the aforementioned standards expires, unless there is a requirement for the further storage of the data for the conclusion or fulfilment of a contract.
4. Protection of minors
Individuals under the age of 16 may not transfer personal data to us without the permission of a parent or legal guardian. Personal information may be provided to us by individuals under the age of 16 only with the express consent of a parent or legal guardian or by individuals aged 16 or over. This data is processed in accordance with this privacy statement.
III. Provision of the website and creation of log files
1. Description and scope of data processing
Every time you visit our website, our system automatically collects data and information from the computer system of the calling computer. The following data is collected:
(1) Information about the browser type and version used
(2) Your operating system
(3) Your Internet Service Provider
(4) Your IP address
(5) Date and time of access
(6) Websites from which your system reaches our website
(7) Websites accessed from your system through our website
The data is also stored in the log files of our system. This data is not stored together with other personal data.
2. Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.
3. Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable the website to be delivered to your computer. For this purpose, your IP address must remain stored for the duration of the session.
The data is stored in log files to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
If the data is stored in log files, this is the case after seven days at the latest. Further storage is possible. In this case, your IP address will be deleted or alienated so that it is no longer possible to assign it to you as the calling client.
5. Possibility of objection and elimination
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, you as a user have no right of objection.
6. Google Analytics
This website uses Google Analytics, a web analysis service of Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”, text files, which are stored on your computer and which enable an analysis of the use of the website by you. The information generated by the cookie about your use of this website is as a rule transmitted to a server of Google in the USA and is stored there. In the event of the activation of the IP anonymisation on this website, your IP address is however previously abbreviated by Google within member states of the European Union or in other contracting states of the Treaty on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a server of Google in the USA and will be abbreviated there. BY order of the operator of this website Google will use this information in order to evaluate your use of the website in order to compile reports about the website activities and in order to provide further services associated with the website use and the internet use towards the website operator. You can additionally prevent the entry of the data generated by the cookie and which refers to your use of the website (incl. your IP address) to Google as well as the processing of these data by Google by downloading and installing the browser plugin available under the following link -: tools.google.com/dlpage/gaoptout.
This website uses Google Analytics with the extension “_anonymizeIp()”. This way your IP addresses will be abbreviated and further processed, an ability to make reference to a person can thus be excluded. Insofar as the data collected in relation to you has a reference to a person, this will thus be excluded immediately, and the personal data will therefore be deleted immediately.
We use Google Analytics in order to be able to analyse and regularly improve the use of our website. Via the gained statistics we can improve our offer and design is more interesting for you as a user. For the exceptional cases, in which personal data are transmitted to the USA, Google has submitted itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 Para. 1 S. 1 lit. f GDPR.
7. Facebook
a) The Facebook pixel
Our website uses the Facebook pixel. This tool allows us to register clicks on the ads we’ve posted on Facebook as well as to track user actions on our website. Moreover, we can use this collected data to place interest-based advertising on Facebook using Facebook’s Custom Audiences feature.
b) Facebook Custom Audiences
Our website uses the Facebook Custom Audiences retargeting feature. In combination with the Facebook pixel, this tool allows Facebook to compare users of our website with Facebook account holders. This lets us present advertising in a targeted way on Facebook: exclusively to Facebook users who have already shown an interest in our products and services.
You can find further information on Facebook’s collection and usage of your data in the Facebook Privacy Policy: https://www.facebook.com/about/privacy/. You can deselect the Custom Audiences feature here (you need to be logged in to Facebook to do so): https://www.facebook.com/settings/?tab=ads.
8. Use of YouTube videos
This website uses the YouTube embedding function to display and play back videos from the provider YouTube, which is owned by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (‘Google’).
To this end, extended data protection mode is used to ensure, according to provider information, that user information is only stored once the playback of the video(s) is started. When playback of embedded YouTube videos is started, the provider sets YouTube cookies in order to collect information about user behaviour. According to indications from YouTube, the use of these cookies is intended, among other things, to record video statistics, to improve user-friendliness and to prevent improper action. If you are logged in to Google, your information will be directly associated with your account when you click a video. If you do not wish your usage to be associated with your profile on YouTube, you must log out before activating the button. Google saves your data (including for users who are not logged in) as usage profiles and evaluates them. Such evaluation is carried out in particular in accordance with point (f) of Article 6(1) GDPR on the basis of Google’s legitimate interests in the insertion of personalised advertising, market research and/or demand-oriented design of its website. You have the right to object to the creation of these user profiles. To exercise this right, you must contact YouTube. When you are using YouTube, personal data may also be transferred to the servers of Google LLC in the US.
Regardless of whether embedded videos are played back or not, a connection to the Google network is established every time this website is visited. This may trigger further data processing beyond our control.
For the event that personal data is transferred to Google LLC, based in the US, Google LLC is certified under the US-European data protection agreement ‘Privacy Shield’, which guarantees compliance with the data protection level applicable in the EU. A current certificate can be viewed here: https://www.privacyshield.gov/list
Use of YouTube is based on our interest in presenting our online content in an appealing manner. This constitutes a legitimate interest within the meaning of point (f) of Article 6(1) GDPR.
Further information on how user data is handled can be found in the YouTube privacy policy at: https://policies.google.com/privacy?hl=de&gl=de.
IV. Use of cookies
1. Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored on your computer system via an Internet browser. When you visit a website, a cookie may be stored on your operating system. This cookie contains a characteristic character string that enables a unique identification of the browser when the website is called up again.
By using cookies, we can provide you with more user-friendly services on our website that would not be possible without cookies. The data collected from you in this way is pseudonymised by means of technical measures. The data is not stored together with other personal data of yours.
2. Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.
3. Purpose of data processing
The purpose of using technically necessary cookies is to simplify the use of websites for you as a user. Some functions of our website cannot be offered without the use of cookies. For this it is necessary that the browser is recognized even after a page change. The user data collected by technically necessary cookies is not used to create user profiles.
4. Duration of storage, ability to opt out and to remove cookies
Cookies are stored on your computer and transmitted to our site. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.
V. Webshop
1. Data processing when a contract is entered into
If you register for one of our websites/applications and/or enter into another contract with us, we process the data necessary for entering into, performing or ending the contract with you. This includes:
(1) first name, surname, company name
(2) status as corporate or private customer
(3) billing and delivery address
(4) e-mail address
(5) billing and payment data
(6) parcel service account data
(7) telephone number
The legal basis for this is point (a) and point (b) of Article 6(1) GDPR, i.e., you provide this data to us on the basis of the respective contractual relationship in place between you and us (maintaining a customer/user account, performing an agreement to sell). We are also required to process your e-mail address in the event of a sale via our websites/applications because we are under a legal obligation imposed by the German Civil Code (BGB) to send out an electronic order confirmation (point (c) Article 6(1) GDPR).
We store data collected for the purpose of performing the contract for the term of the contract and until the statutory or, where applicable, contractual guarantee and warranty rights have expired. Upon expiry of this period, we retain the information required under commercial and tax law relating to the contractual relationship for the periods stipulated by law. During this period, the data is processed again solely for the purpose of inspection by the tax authorities.
In order to perform an agreement to sell via our websites/applications, the following data processing operations are also necessary:
2. Transfer of data to transport service providers
For the purpose of delivering items you have ordered, we work with logistics service providers/transport service companies and/or shipping partners. The following data can be transferred to these for the purpose of delivering items you have ordered or to provide notification of same: first name, surname, postal address.
To ensure that items are delivered in accordance with your wishes, we transfer your e-mail address and, where applicable, your telephone number to the logistics company and/or shipping partner we use to carry out the delivery.
The legal basis for processing in this respect is point (b) of Article 6(1) GDPR.
3. Payment collection agency
In the event of late payment, we also use the company Mediafinanz to collect outstanding amounts. For this purpose, the necessary data is shared with and used by Mediafinanz in compliance with all data privacy rules. Where ordered by a court of law, at the request of an investigative authority or for evidential purposes (e.g., in the event that our Terms & Conditions are breached), the data and information we store can be used within the limits set by law and disclosed to third parties, if this is necessary.
VI. Newsletter
1. Description and scope of data processing
You will be automatically signed up to our free newsletter when you purchase our goods and services. We use the e-mail address that you entered during the order process to send this newsletter.
The newsletter is sent out exclusively for the purposes of directly advertising our goods and services. Your data will not be shared with third parties within the context of the data processing required to send the newsletter.
2. Legal basis for data processing
The legal basis for sending the newsletter following the sale of goods is § 7 para. 3 Unfair Competition Act (UWG).
Article 6(1)(a) GDPR serves as the legal basis for data processing for the purposes of sending the newsletter.
3. Purpose of data processing
Collecting your e-mail address also serves the purposes of sending you the newsletter.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. Your email address will be stored as long as the registration as a customer is active.
5. Possibility of objection and elimination
You can unsubscribe from the newsletter at any time by revoking your consent to the use of your e-mail address. A link is provided in every newsletter for this purpose. We do not charge a fee for this service. The only fees that may be accrued are the data transmission costs (according to basic tariffs) that are required to unsubscribe from the newsletter.
VII. Online contact form
1. Description and scope of data processing
An online contact form is provided on our website, which can be used to contact us electronically. If you make use of this option, the data entered in the input screen is transferred to us and stored. This data is:
(1) Name
(2) email address
(3) subject
(4) message
Your consent will be obtained for the processing of the data as part of the sending process.
Alternatively, you can contact us using the email address provided. In this case, the personal data transmitted with your email address will be stored.
In this context, the data is not passed on to third parties. The data is used exclusively for processing the conversation.
2. Legal basis for data processing
If you have given your consent, the legal basis for processing the data is Art. 6 para. 1 lit. a GDPR.
The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 lit. f GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b GDPR.
3. Purpose of data processing
The processing of the personal data from the input mask is used solely for handling the establishment of contact. In the event of contact by email, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the sending process serves to prevent misuse of the forum and to ensure the security of our information technology systems.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. This applies to the personal data in the forum input mask and that sent by email once the conversation with you has ended. The conversation is deemed to have ended when it can be inferred from the circumstances that the relevant situation has been conclusively settled.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5. Possibility of objection and elimination
You have the possibility to revoke your consent to the processing of your personal data at any time. If you contact us by email, you can object to the storage of your personal data at any time. In such a case, the conversation cannot be continued.
All personal data stored in the course of contacting us will be deleted in this case.
VIII. Rights of the data subject
If your personal data are processed, you are affected within the meaning of the GDPR and you have the following rights vis-à-vis Front Panel Express:
1. Right to information
You can ask us to confirm whether personal data concerning you will be processed by us.
If such processing has taken place, you can request the following information from us:
(1) the purposes for which personal data are processed;
(2) the categories of personal data being processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed;
(4) the planned duration of the storage of the personal data concerning you, or, if specific information on this is not possible, criteria for determining the storage period.
(5) the existence of a right to rectification or deletion of personal data concerning you, a right to limitation of processing by us or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information about the origin of the data if the personal data is not collected from you as the data subject;
(8) the existence of automated decision-making, including profiling in accordance with Article 22 para. 1 and 4 GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for you as the data subject.
You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.
2. Right to rectification
You have a right of rectification and/or completion vis-à-vis us if the personal data processed concerning you is incorrect or incomplete. We shall make the correction without delay.
3. Right to limitation of processing
Under the following conditions, you may request that the processing of personal data concerning you be restricted:
(1) if you dispute the accuracy of the personal data concerning you for a period of time that enables us to verify the accuracy of the personal data;
(2) the processing is unlawful and you refuse a deletion of the personal data and instead request that the use of the personal data be restricted;
(3) we no longer need the personal data for the purposes of processing, but you do need them to assert, exercise or defend legal claims, or
(4) if you have filed an objection to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether our legitimate reasons outweigh your reasons.
If the processing of personal data concerning you has been restricted, such data may only be processed - apart from being stored - with your consent or for the purpose of asserting, exercising or defending legal rights or for protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.
If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by us before the restriction is lifted.
4. Right to erasure
a) Obligation to delete
You may request that the personal data relating to you be erased without delay and we are obliged to erase this data without delay if one of the following reasons applies.
(1) The personal data relating to you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You withdraw your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal ground for the processing.
(3) You object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR.
(4) The personal data relating to you have been processed unlawfully.
(5) The erasure of personal data relating to you is necessary to comply with a legal obligation in Union or Member State law to which we are subject.
(6) The personal data relating to you have been collected in relation to the offer of information society services referred to in Art. 8 para. 1 GDPR.
b) Information to third parties
If we have made the personal data relating to you public and are obliged to erase it pursuant to Art. 17 para. 1 GDPR, we will take reasonable steps, taking account of available technology and the cost of implementation, including technical measures, to inform those responsible for data processing who are processing the personal data that you as the data subject have requested the erasure of all links to this personal data or of copies or replications of this personal data.
c) Exceptions
The right to erasure does not apply to the extent that processing 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 we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
(3) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in a) 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 exercised your right to rectify, erase or restrict processing against us, we are obliged to inform all recipients to whom the personal data relating to you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves disproportionate effort.
You have the right to be notified by us about these recipients.
6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format. Furthermore, you have the right to transmit this data to another person responsible without any hindrance from us, provided that
(1) processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and
(2) processing is carried out by automated means.
In exercising this right, you also have the right to request that the personal data relating to you be transferred directly by us to another person responsible, insofar as this is technically feasible. The rights and freedoms of other persons shall not be adversely affected by this.
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 us.
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 Art. 6 para. 1 lit. e or f GDPR; this also includes profiling based on those provisions.
We will no longer process the personal data concerning you, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.
Where personal data concerning you are processed for direct marketing purposes, you shall 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.
Where you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
You may exercise your right to object to the use of information society services by automated means using technical specifications, notwithstanding Directive 2002/58/EC.
8. Right to withdraw the data protection declaration of consent
You have the right to withdraw your data protection declaration of consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
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 shall not apply if the decision
(1) is necessary for entering into or performing a contract between you and us,
(2) is authorized by Union or Member State law to which we are subject and which lays down suitable measures to safeguard your rights, freedoms and legitimate interests, or
(3) is based on your explicit consent.
However, these decisions shall not be based on special categories of personal data referred to in Article 9 para 1 GDPR, unless Article 9 para. 2 lit. a or g applies and suitable measures are in place to safeguard your rights and freedoms and your legitimate interests.
In the cases referred to in (1) and (3), we shall implement suitable measures to safeguard your rights, freedoms and legitimate interests, including at least the right of Front Panel Express to obtain human intervention to express its 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, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the 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.