We are very pleased that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of AB-Tools GmbH. The use of the Internet pages of AB-Tools GmbH is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always in line with the General Data Protection Regulation and in accordance with the country-specific data protection provisions applicable to AB-Tools GmbH. By means of this privacy policy, our enterprise would like to inform the general public of the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of the rights to which they are entitled by means of this privacy policy.
As the controller, AB-Tools GmbH has implemented numerous technical and organisational measures to ensure the most complete protection of the personal data processed through this website. Nevertheless, Internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us by alternative means, for example by telephone.
1. Definitions
The privacy policy of AB-Tools GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be legible and understandable for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
In this privacy policy we use, among others, the following terms:
- a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “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 special characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. - b) Data subject
Data subject means any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing. - c) Processing
Processing means any operation or set of operations which is performed on 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. - d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting its processing in the future. - e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of that 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. - f) 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 which ensure that the personal data is not attributed to an identified or identifiable natural person. - g) Controller or controller responsible for the processing
Controller or controller responsible for the processing 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. - h) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. - i) 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 are not regarded as recipients. - j) Third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or processor, are authorised to process personal data. - k) Consent
Consent 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.
2. Name and address of the controller
The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
AB-Tools GmbH
Marsstraße 78
80335 Munich
Germany
Tel.: +49 89 38898588
E-mail: info@keynub.com
Website: https://www.keynub.com
3. Cookies
The Internet pages of AB-Tools GmbH use cookies. Cookies are text files that are stored and saved on a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows the visited Internet sites and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID.
Through the use of cookies, AB-Tools GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimised with the user in mind. As mentioned above, cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter access data each time the website is visited, because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping basket in an online shop. The online shop remembers the articles that a customer has placed in the virtual shopping basket via a cookie.
The data subject may prevent the setting of cookies through our website at any time by means of a corresponding setting of the Internet browser used, and may thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
4. Collection of general data and information
The website of AB-Tools GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using this general data and information, AB-Tools GmbH does not draw any conclusions about the data subject. Rather, this information is needed in order to (1) deliver the contents of our website correctly, (2) optimise the contents of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by AB-Tools GmbH both statistically and with the aim of increasing data protection and data security in our enterprise, in order ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.
5. Contact possibility via the website
The website of AB-Tools GmbH contains information that enables quick electronic contact with our enterprise as well as direct communication with us, as required by law, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purpose of processing the matter or of contacting the data subject. This personal data is not passed on to third parties.
6. Consent management (CookieYes)
On our website we use the consent management service CookieYes, operated by CookieYes Limited. CookieYes displays the cookie banner, asks for your decision on non-essential cookies, and records that decision so that you are not asked again on every page.
When a page is loaded, the CookieYes script is retrieved from the provider’s servers. Your IP address is necessarily transmitted in the process, because without it the script could not be delivered to your browser. In addition, your consent decision, the time it was given, and an identifier for it are stored so that we can demonstrate compliance with our documentation obligations.
The legal basis for the processing is Article 6(1)(c) GDPR, since we are legally obliged to obtain and document consent for non-essential cookies, and Article 6(1)(f) GDPR in respect of the secure and correct operation of the banner. You can change or withdraw your decision at any time via the cookie settings on our website.
7. Web analytics (Google Analytics 4)
On our website we use the web analytics service Google Analytics 4 (“GA4”). The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which processes the data concerned on our behalf and on our instructions only as our processor; we have concluded a data processing agreement with Google as required by Article 28 GDPR.
GA4 is used exclusively on the basis of your consent, which is requested via the CookieYes cookie banner described above; the legal basis is Article 6(1)(a) GDPR. We have also implemented Google Consent Mode: as long as you have not given consent, the consent state is set to “denied”, no analytics cookies are set and no analytics data is transmitted to Google. Only after you have given consent is GA4 activated.
If you consent, GA4 processes information about your use of our website, in particular the pages visited, the website from which you reached us (referrer), interactions such as clicks and downloads, approximate location information derived from the IP address, information about the browser, operating system and device used, and pseudonymous user and session identifiers stored in cookies. According to Google, GA4 does not log or store the IP address itself. We use this information solely for statistical analysis of the use of our website and to improve our website and offering.
In the course of the processing, personal data may also be transferred to Google LLC in the United States. This transfer is safeguarded by Google’s certification under the EU-U.S. Data Privacy Framework and by standard contractual clauses.
User-level data stored by GA4, including the identifiers mentioned above, is deleted after 14 months at the latest.
You can withdraw your consent at any time with effect for the future via the cookie settings link on our website, which reopens the CookieYes consent banner and allows you to change your decision. The lawfulness of the processing carried out on the basis of your consent until withdrawal remains unaffected.
8. Web fonts
Our website uses the “Poppins” typeface, which is retrieved from Google Fonts when a page is loaded. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
To deliver the font, your browser connects to Google’s servers, and your IP address is transmitted to Google in the process. This happens for the purpose of a consistent and legible presentation of our website; the legal basis is Article 6(1)(f) GDPR. We have no influence over any further processing by Google, and personal data may be transferred to the United States.
If you do not wish this to happen, you can prevent the font from being loaded using a browser add-on that blocks external font requests. Our website remains fully usable in that case and will simply be displayed in a substitute typeface.
9. Order processing and shipping
If you place an order in our online shop, we process the data you enter for that purpose — in particular your name, billing and delivery address, e-mail address, the items ordered and the payment method chosen. This data is required in order to conclude and perform the contract; the legal basis is Article 6(1)(b) GDPR.
For delivery we pass on the data required for shipment, in particular the recipient’s name and delivery address, to the shipping service provider commissioned in each case. This transfer takes place solely for the purpose of delivering the goods.
Order and invoice data is retained for as long as commercial and tax law requires us to retain it. The legal basis for that retention is Article 6(1)(c) GDPR.
Where an order is placed on behalf of a company, we also process the data of the person acting for that company — in particular their name, e-mail address and, where provided, telephone number — for the purpose of concluding and performing the contract.
Because we supply business customers only, we additionally record, together with the order, the declaration that the order is placed in the course of a trade, business or profession. We keep that declaration so that we can establish afterwards on what basis a given contract was concluded; the legal basis is Article 6(1)(f) GDPR, our legitimate interest being the ability to demonstrate which legal regime applies to an order.
10. Payment via PayPal
If you choose PayPal as the payment method, the payment is processed by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg.
In order to process the payment, the data required for that purpose — in particular the amount, the order reference and the data you enter during the payment process — is transmitted to PayPal. Your payment details, such as card or account data, are entered directly with PayPal; we do not receive them. The legal basis is Article 6(1)(b) GDPR, since the transfer is necessary for the performance of the contract, and, where you have consented within your PayPal account, Article 6(1)(a) GDPR.
PayPal processes this data as an independent controller. Details are set out in PayPal’s own privacy notice.
11. E-mail dispatch and logging
We send transactional e-mails, such as order confirmations and replies to enquiries, through an external mail dispatch service, so that these messages are delivered reliably rather than being classified as spam. The recipient address and the content of the message are processed for that purpose.
Copies of outgoing e-mails are also logged in our system so that we can establish afterwards whether a message was actually sent — for example when a customer states that they did not receive an order confirmation. These logs may therefore contain the personal data included in the message concerned, and are deleted once they are no longer needed for that purpose.
The legal basis is Article 6(1)(b) GDPR where the e-mail is connected with a contract or a pre-contractual enquiry, and otherwise Article 6(1)(f) GDPR, our legitimate interest being the verifiable delivery of our own business correspondence.
12. Hosting
Our website is not operated on our own hardware but with a hosting provider, who processes the data described in this privacy policy on our behalf and on our instructions only. That includes in particular the server log files described above.
We have concluded a data processing agreement with the provider as required by Article 28 GDPR. The legal basis for using a hosting provider is Article 6(1)(f) GDPR, our legitimate interest being the secure, stable and professional provision of our website.
13. Routine erasure and blocking of personal data
The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or where this has been provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.
If the purpose of storage ceases to apply, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with statutory requirements.
14. Rights of the data subject
- a) Right of confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether personal data concerning him or her is being processed. If a data subject wishes to make use of this right of confirmation, he or she may at any time contact an employee of the controller. - b) Right of access
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, free of charge, information about the personal data stored concerning him or her and a copy of that information. Furthermore, the European legislator has granted the data subject access to the following information:- the purposes of the processing
- the categories of personal data being processed
- the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations
- where possible, the envisaged period for which the personal data will be stored, or, if that is not possible, the criteria used to determine that period
- the existence of the right to rectification or erasure of personal data concerning him or her, or to restriction of processing by the controller, or a right to object to such processing
- the existence of the right to lodge a complaint with a supervisory authority
- where the personal data is not collected from the data subject: all available information as to the source of the data
- 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 envisaged consequences of such processing for the data subject
Furthermore, the data subject has a right to obtain information as to whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer.
If a data subject wishes to make use of this right of access, he or she may at any time contact an employee of the controller.
- c) Right to rectification
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain, without undue delay, the rectification of inaccurate personal data concerning him or her. Furthermore, the data subject has the right to have incomplete personal data completed — including by means of a supplementary statement — taking into account the purposes of the processing.If a data subject wishes to make use of this right to rectification, he or she may at any time contact an employee of the controller.
- d) Right to erasure (right to be forgotten)
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:- The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
- The data subject withdraws the consent on which the processing was based pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal basis for the processing.
- The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
- The personal data has been processed unlawfully.
- The erasure of the personal data is required for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data was collected in relation to information society services offered pursuant to Article 8(1) GDPR.
If one of the grounds referred to above applies and a data subject wishes to request the erasure of personal data stored by AB-Tools GmbH, he or she may at any time contact an employee of the controller. The employee of AB-Tools GmbH will arrange for the erasure request to be complied with without undue delay.
Where the personal data has been made public by AB-Tools GmbH and our enterprise, as controller, is obliged pursuant to Article 17(1) GDPR to erase the personal data, AB-Tools GmbH shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by those other controllers of any links to, or copies or replications of, that personal data, insofar as the processing is not required. The employee of AB-Tools GmbH will arrange for what is necessary in each individual case.
- e) Right of restriction of processing
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the restriction of processing where one of the following conditions applies:- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject opposes the erasure of the personal data and requests instead the restriction of its use.
- The controller no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise or defence of legal claims.
- The data subject has objected to the processing pursuant to Article 21(1) GDPR and it is not yet established whether the legitimate grounds of the controller override those of the data subject.
If one of the conditions referred to above is met and a data subject wishes to request the restriction of personal data stored by AB-Tools GmbH, he or she may at any time contact an employee of the controller. The employee of AB-Tools GmbH will arrange for the restriction of the processing.
- f) Right to data portability
Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which was provided to a controller by the data subject, in a structured, commonly used and machine-readable format. He or she also has the right to transmit that data to another controller without hindrance from the controller to which the personal data was provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where doing so does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may at any time contact an employee of AB-Tools GmbH.
- g) Right to object
Every data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to the processing of personal data concerning him or her which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.In the event of an objection, AB-Tools GmbH will no longer process the personal data, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims.
If AB-Tools GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for the purposes of such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to AB-Tools GmbH processing for direct marketing purposes, AB-Tools GmbH will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her which is carried out by AB-Tools GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.
To exercise the right to object, the data subject may contact any employee of AB-Tools GmbH directly. The data subject is furthermore free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.
- h) Automated individual decision-making, including profiling
Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, AB-Tools GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
If the data subject wishes to assert rights concerning automated decision-making, he or she may at any time contact an employee of the controller.
- i) Right to withdraw data protection consent
Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.If the data subject wishes to assert the right to withdraw consent, he or she may at any time contact an employee of the controller.
15. Legal basis for the processing
Article 6(1)(a) GDPR serves as the legal basis for our enterprise for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, for processing operations necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. If our enterprise is subject to a legal obligation which requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and, as a result, his or her name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. The processing would then be based on Article 6(1)(d) GDPR.
Finally, processing operations could be based on Article 6(1)(f) GDPR. Processing operations that are not covered by any of the above-mentioned legal bases are based on this legal basis if the processing is necessary for the purposes of a legitimate interest pursued by our enterprise or by a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overriding. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator, who took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, Sentence 2 GDPR).
16. Legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.
17. Period for which the personal data will be stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After that period expires, the corresponding data is routinely erased, provided that it is no longer necessary for the performance or initiation of a contract.
18. Statutory or contractual requirements to provide personal data; necessity for the conclusion of a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide it
We wish to make clear that the provision of personal data is partly required by law (for example tax regulations) and can also result from contractual provisions (for example information on the contractual partner).
Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data when our enterprise concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.
Before providing personal data, the data subject must contact one of our employees. Our employee will explain to the data subject, on a case-by-case basis, whether the provision of the personal data is required by law or by contract, or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of failure to provide it would be.
19. Existence of automated decision-making
As a responsible enterprise, we do not use automated decision-making or profiling.
