Privacy Policy

This data protection declaration informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content connected to it, as well as external online presences, such as our social media profiles (hereinafter jointly referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Data Protection Officer

B. Sc. Dominik Scharnagl

Traeger GmbH Industry Components
Söllnerstr. 9
DE-92637 Weiden i.d. OPf
Germany

privacy@traeger.de

Types of data processed

• Inventory data (e.g. names, addresses)
• Contact data (e.g. e-mail, telephone numbers)
• Content data (e.g. text input, photographs, videos)
• Usage data (e.g. websites visited, content, access times)
• Meta/communication data (e.g. device information, IP addresses)

Categories of persons concerned

Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as "users").

Purpose of the processing

• Provision of the online offer, its functions and content
• Answering contact requests and communication with users
• Security measures
• Reach measurement/marketing

Terminology used

"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 (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

"Pseudonymisation" means the processing of personal data in such a way 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 are not attributed to an identified or identifiable natural person.

"Profiling" means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects of that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

"Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 DSGVO, we inform you of the legal basis for our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is Art. 6(1)(b) DSGVO, the legal basis for processing in order to fulfil our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing in order to protect our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO serves as the legal basis.

Security measures

We shall take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account in the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 DSGVO).

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6 para. 1 lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called "data processing contract", this is done on the basis of Art. 28 DSGVO.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the processing of data in a third country if the special requirements of Art. 44 ff. DSGVO are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "Standard Contractual Clauses").

Rights of the data subjects

You have the right to request confirmation as to whether data in question is being processed and to be informed about this data and to receive further information and a copy of the data in accordance with Art. 15 DSGVO.

You have according to. You have the right to request that data concerning you be completed or that inaccurate data concerning you be corrected in accordance with Article 16 of the Regulation.
In accordance with Art. 17 DSGVO, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with Art. 18 DSGVO, to demand restriction of the processing of the data.

You have the right to obtain the data concerning you that you have provided to us in accordance with Art. 20 of the GDPR and to request that it be transferred to other data controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.

Right of Revocation

You have the right to revoke consent granted in accordance with Art. 7 (3) DSGVO with effect for the future.

Right of Objection

You may object to the future processing of data concerning you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against processing for direct marketing purposes.

Cookies and right to object to direct advertising

"Cookies" are small files that are stored on the user's computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or "Session cookies" or "transient cookies" are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie can, for example, store the contents of a shopping basket in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be saved if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as "first-party cookies").
We may use temporary and permanent cookies and will explain this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US-American site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that not all functions of this online offer can then be used.

Data Deletion

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

According to legal requirements in Germany, data is stored for 10 years in accordance with §§ 147 Para. 1 AO, 257 Para. 1 No. 1 and 4, Para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 Para. 1 No. 2 and 3, Para. 4 HGB (commercial letters).
According to legal requirements in Austria, retention is in particular for 7 years pursuant to § 132 para. 1 BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with real property and for 10 years for records in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is claimed.

Business related processing

In addition, we process

• Contract data (e.g., subject matter of the contract, term, customer category)
• Payment data (e.g., bank details, payment history)
  of our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user's details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) lit. b) DSGVO. The user's details may be stored in a customer relationship management system ("CRM System") or comparable enquiry organisation.

We delete the enquiries if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.

Hosting

The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating this online offer.

In this context, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of a contract). Art. 28 DSGVO (conclusion of order processing agreement).

Collection of access data and log files

We, or rather our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.

Google Tag Manager

Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offer). The tag manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users' personal data, please refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html

Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC ("Google"), on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. DSGVO). DSGVO) Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with IP anonymisation activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de

For more information about Google's use of data, settings and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

The users' personal data is deleted or anonymised after 14 months.

Google Universal Analytics

We use Google Analytics in the form of "Universal Analytics" (https://support.google.com/analytics/answer/2790010?hl=de&ref_topic=6010376). "Universal Analytics" refers to a Google Analytics procedure in which the user analysis is carried out on the basis of a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called "cross-device tracking").

Google AdWords and conversion measurement

We use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 9.0.USA ("Google") on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO). DSGVO) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google").

Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing tool Google "AdWords" to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to better target ads for and within our online offering to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she has shown interest on other online offers, this is referred to as "remarketing". For these purposes, when our website and other websites on which the Google advertising network is active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as "web beacons") are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). This file records which web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring web pages, time of visit and other information on the use of the online offer.
Furthermore, we receive an individual "conversion cookie". The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that personally identifies users.

User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process, for example, the name or email address of the user, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. This means that from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google's servers in the USA.

For more information on Google's use of data, settings and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Integration of third-party services and content

We use content or service offers of third party providers within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service offers from third party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is thus necessary for the display of this content. We endeavour to use only such content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

Youtube

We integrate the videos of the platform "YouTube" of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Fonts

We integrate the fonts ("Google Fonts") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google ReCaptcha

We integrate the function for the recognition of bots, e.g. when entering data in online forms ("ReCaptcha") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Maps

We integrate the maps of the service "Google Maps" of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed within the framework of the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Newsletter with Mailchimp

The newsletter is sent using the dispatch service provider "MailChimp", a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the mailing service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO and an order processing agreement pursuant to Art. 28 para. 3 p. 1 DSGVO.

The dispatch service provider may use the recipients' data in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

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