Data Privacy Policy Primo

The protection of privacy is a very important concern for us. This data protection declaration provides information on the processing of your personal information in connection with the use of our website and the associated functionalities provided, such as for example the opportunity to make contact with us, to take part in a contest or in a competition (subsequently referred to collectively as “website”).

§ 1 Responsible party


Zott Polska Sp. Z o.o. (ZOTT)
Ul. Chłodnicza 6
45-315 Opole

§ 2 Personal data protection administrator

If you have any questions about the processing of your personal data by us, please contact us in writing or by e-mail:  [email protected].

§ 3 Automatic data processing when accessing the website WWW.ZOTT-PRIMO.COM

Personal data is processed as soon as you access the website. This happens automatically without you having to take any further action, such as filling in and sending a contact form.
These automated processing operations concern:

PROCESSING OF THE IP ADDRESS
1. Description and scope of data processing
When this page is accessed, requests are sent to the server, which it must respond to. For this purpose, your IP address must be collected and processed by the server so that the corresponding server requests can be answered.

2. Legal basis for data processing
The legal basis for the processing of this data is Art. 6 para. 1 lit. f) GDPR.

3. Purpose of the data processing
The purpose of processing your IP address is to establish and ensure the functionality of the website and to technically enable the website to be accessed.

4. Legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR
Zott has a legitimate interest considering the security of the website. The legitimate interest in the temporary storage of the IP address lies in the fact that the functionality and provision of the technical retrieval option of the website is not possible without this storage.

5. Duration of storage
The data will be deleted as soon as further storage is no longer necessary due to the fulfilment of the purpose. This is regularly the case after a period of 7 days.

6. Recipient of personal data
The IP address is processed by the following hosting provider on the basis of an order processing agreement in accordance with Art. 28 para. 2 - para. 4 GDPR:
˗    Medienpalast Allgäu GmbH & Co. KG, Memminger Straße 50, 87439 Kempten
7. Transfer to a third country
It is not intended to transfer the personal data to a third country or to an international organisation.

8. Necessity of the provision
The provision of the data is necessary because otherwise the website cannot be accessed.

9. Automated decision-making / profiling
No automated decision-making or profiling takes place.

PROCESSING OF SERVER LOG FILES
1. Description and scope of data processing
The IP addresses collected when this website is accessed are also stored in server log files in order to detect and rectify technical faults and/or attempts to manipulate or break into the server structure.
In addition, the hosting provider of this website automatically collects, stores and processes information in so-called server log files, which are automatically transmitted by your browser.
This information is
-    Browser type and browser version
-    Operating system used
-    Referrer URL
-    Host name of the accessing computer
-    Time of the server request
However, this information is not merged with other data sources.

2. Legal basis for data processing
The legal basis for the processing of this data is Art. 6 para. 1 lit. f) GDPR.

3. Purpose of the data processing
The purpose of processing your IP address and the above information is to detect malfunctions and intrusion attempts. This serves the security structure of the website and the system integrity of the servers.

4. Legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR
Zott has a legitimate interest in the security of the website.
The legitimate interest in the processing of the IP address and the above information is the provision of a functional and uncompromised technical website environment.

5. Duration of storage
The data will be deleted within 7 days.

6. Recipient of personal data
The IP address and the above-mentioned information are processed by the following hosting provider on the basis of an order processing agreement in accordance with Art. 28 para. 2 - 4 GDPR:
˗    Medienpalast Allgäu GmbH & Co. KG, Memminger Straße 50, 87439 Kempten

7. Transfer to a third country
It is not intended to transfer the personal data to a third country or to an international organisation.

8. Necessity of the provision
The provision of the data is necessary because otherwise the website cannot be accessed.

9. Automated decision-making / profiling
No automated decision-making or profiling takes place.

USE OF COOKIES
1. Description and scope of data processing
Cookies are text files that are stored in the memory and/or on a data carrier of your device used to visit the website and that are processed by your Internet browser in accordance with the settings stored there.

2. Legal basis for data processing
The legal basis for the processing is Art. 6 para. 1 lit. f) GDPR.

3. Purpose of the data processing
The session cookie contains session information about the current website visit.

4. Legitimate interest according to Art. 6 para. 1 lit. f) GDPR
The session cookie used only contains technical data. The use of these cookies is necessary in order to provide the user with the functionality of our website that meets their expectations.

5. Duration of storage as well as objection and removal options
"Session cookies" are automatically deleted from your computer's browser cache/memory at the end of your website visit and/or when you close your browser, provided you have activated this functionality in your browser.
Please check the settings of your internet browser (e.g. Firefox, Internet Explorer, Edge, Chrome, Opera, Safari). Your internet browser also gives you the option of regulating the handling of cookies or deactivating them completely. 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 the functions of the website to their full extent.

6. Transfer to a third country
It is not intended to transfer the personal data to a third country or to an international organisation.

7. Necessity of the provision
The provision of the data is necessary because otherwise the website cannot be accessed.

8. Automated decision-making / profiling
No automated decision-making or profiling takes place.

CLOUDFLARE
1. Description and scope of data processing
The website also uses the ‘Cloudflare’ service, a so-called content delivery network from the manufacturer Cloudflare Inc, 101 Townsend St. San Francisco, CA 94107, USA (‘Cloudflare’). With this service, larger media files in particular (e.g. graphics, page content or scripts) can be delivered through a network of regionally distributed servers connected via the Internet. This optimises the website and improves the loading speed in particular. It also increases the security of competitions (by eliminating bots).

2. Legal basis for data processing
The legal basis for this is Art. 6 para. 1 lit. f) GDPR. The legitimate interest is a secure and efficient provision and improvement of the stability and functionality of the website.

3. Purpose of the data processing
The use of Cloudflare serves the efficient design and security of the website.

4. Legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR
The use of Cloudflare ensures the secure and efficient provision of the website.

5. Duration of storage as well as objection and removal options
The IP address is processed via Cloudflare, but is only stored for 24 hours and then deleted.

6. Recipients of personal data
An order processing contract has been concluded with Cloudflare in accordance with Art. 28 GDPR (Data Processing Addendum, www.cloudflare.com/media/pdf/cloudflare-customer-dpa.pdf). Cloudflare undertakes to protect the personal data of website visitors and not to pass it on to third parties. In addition, the standard contractual clauses have also been concluded with Cloudflare.

7. Transfer to a third country
For the transfer of data from the EU to the USA, Cloudflare relies on so-called standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection in the USA. Further information can be found in Cloudflare's privacy policy at: www.cloudflare.com/privacypolicy/.

8. Necessity of the provision
The provision of the data is necessary because otherwise the website cannot be accessed.

9. Automated decision-making / profiling
There is no automated decision-making or profiling.

§ 4 Sweepstakes

If you take part in a competition, ZOTT will only collect the personal data required for the specific competition, in compliance with the principle of data minimisation. As this varies depending on the competition, the specific data can be found in the respective conditions of participation, which are available on the website in due course.

§ 5 Contact forms

1. Description and scope of data processing
ZOTT uses the following categories of data when you contact us using the contact form provided on the website: First and last name, e-mail address and your request; if you provide us with your address, this will also be included.
We process the following personal data from you when you contact us via the complaint form: First and last name, address, email address and your request.
If you send us an email to [email protected] or [email protected], we will process the following data: First and last name, address, e-mail address and your request.

2. Legal basis for data processing
The legal basis for the processing of this data is Art. 6 para. 1 lit. a) and f) GDPR.

3. Purpose of the data processing
The purpose of the processing is to establish contact between Zott and the consumer or organizing and conducting the competition, considering complaints and delivering prizes to the winners.

4. Legitimate interest according to Art. 6 para. 1 lit. f) GDPR
Zott has a legitimate interest in being able to contact the consumer.

5. Duration of storage
Data collected in connection with a contact will be deleted after six months or in the event of receiving a prize in a competition, after the expiry of the limitation period of claims.

6. Recipients of personal data
Personal data will not be passed on to third parties.

7. Transfer to a third country
It is not intended to transfer the personal data to a third country or to an international organisation.

8. Necessity of the provision
The provision of the data is necessary, otherwise it will not be possible to communicate with the consumer.

9. Automated decision-making / profiling
There is no automated decision-making or profiling.

§ 6 Rights of the data subject

If your personal data is processed, you are the data subject within the meaning of the General Data Protection Regulation. You therefore have the following rights.
To exercise your data subject rights against us, please contact the following email address: [email protected]
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the information specified in Art. 15 GDPR.
The data subject has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her and, where applicable, the completion of incomplete personal data (Art. 16 GDPR).
The data subject has the right to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the grounds listed in Art. 17 GDPR applies, e.g. if the data are no longer necessary in relation to the purposes for which they were collected.
The data subject has the right to request the controller to restrict the processing.

RIGHT TO OBJECT - ART. 21 GDPR
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 point (e) or (f) of Article 6(1) GDPR, including 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 for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the option of exercising your right to object in connection with the use of information society services - notwithstanding Directive 2002/58/EC - by means of automated procedures that use technical specifications.

RIGHT TO REVOKE THE DECLARATION OF CONSENT UNDER DATA PROTECTION LAW
You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Without prejudice to any other administrative or judicial remedy, every data subject has the right to complain to a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes the GDPR (Art. 77 GDPR). The data subject may exercise this right before a supervisory authority in the Member State of his or her habitual residence, place of work or place of the alleged infringement.


This data protection notice is updated at regular intervals.