Privacy Policy

Alps Alpine Europe GmbH (hereinafter referred to as "we“ or "ALPS ALPINE“) takes your privacy seriously. This Privacy Policy ("Policy") sets forth how we collect, gather, share and protect personal information.

Personal data is any information relating to an identified or identifiable natural person.

Alps Alpine is committed to ensuring that your privacy is protected. If we ask you to provide certain information by which you can be identified when using this website, you can rest assured that it will only be used in accordance with this policy.

A. The data controller

within the meaning of the General Data Protection Regulation ("GDPR") is

Alps Alpine Europe GmbH
Ohmstr. 4
85716 Unterschleißheim
Germany

B. Contact information of data protection officer

You can contact our data protection officer via mail to

Ohmstr. 4
85716 Unterschleißheim

and by email to datenschutz.eu@alpsalpine.com .

 

C. Type, purpose and storage period of the data

In the following, we inform you about the types of data, the different purposes for which it is collected, the intended storage period and the legal regulation on which the processing is based.

1. General visit to our website

In addition to general log files, we have a legitimate interest in storing the IP address of your end device with which you access the website in order to enable the website to be displayed (Article 6 (1) f) GDPR). This will be deleted again after you leave the website.

If you do not use any other functions of the website (e.g. registration, contact form, optional cookies, etc.) and do not voluntarily provide further data, we will not process any further data from you.

2. Registration

You can register to our website. For this purpose, we obtain your consent by using a double opt-in procedure (Art. 6 (1) a) GDPR) in order to collect the following data: (1) First/last name, (2) e-mail address, (3) password, and (4) a photo if you post it yourself. We will of course delete this registration-relevant data as soon as you withdraw your consent or unsubscribe from our portal.

Since we have a legitimate interest in being able to prove your consent for legal protection, an e-mail will be sent to you in the double opt-in process to the e-mail address you provided with a request for confirmation of your consent (Art. 6 (1) f) GDPR). We store the IP address, date and time of sending the web form as well as the IP address, date and time of confirmation of the double opt-in e-mail for at least 4 years, and only if this is necessary for the defence against potential claims.

By registering, you are given the opportunity to write your own posts, write comments on posts and rate posts. In doing so, we have a legitimate interest to store this contribution-relevant data as long as the contributions are relevant for our visitors and are therefore retained (Art. 6 (1) f) GDPR).

The images you voluntarily provide by uploading will be deleted as soon as you withdraw your consent or deregister from our portal and we do not invoke any other legal basis.  

We reserve the right to moderate comments, images and posts before they are published, i.e. so that we can insert our own clarifications and assistance, as well as make deletions, if any content violates our terms of use.

3. Newsletter

You can also subscribe to a newsletter in which we would like to inform you about various topics relating to motor homes, our company and our products.

The data you provide for this purpose in the course of a double opt-in procedure, such as (1) first/last name and (2) e-mail address, will be used by us exclusively for the purpose of providing this service within the scope of your consent (Art. 6 (1) a) GDPR).

Since we have a legitimate interest in being able to prove your consent for legal protection, an e-mail will be sent to the e-mail address you have provided in the double opt-in process with a request for confirmation of your consent (Art. 6 (1) f) GDPR). We store the IP address, date and time of sending the web form as well as the IP address, date and time of confirmation of the double opt-in e-mail for at least 4 years, and only if this is necessary for the defence against potential claims. 

Your consent can be revoked at any time with effect for the future, without incurring any transmission costs other than the basic rates (e.g. the costs of your Internet provider), e.g. via the „Unsubscribe" link contained in every e-mail.

For more information on how to assert your rights, please fere to the "Your rights“ section of this Privacy Policy. With regard to your objection or any requests for deletion, we refer you to our information on „Advertising objections“.

The newsletter is sent by DGTLS GmbH, which acts as the processor for ALPS ALPINE. The data processed for contractual purposes is also secured by pseudonymising the data. 

 

4. Advertising objections

Insofar as you object to the sending of newsletters, thereby revoking your consent to their use in the future, we reserve the right to include the data provided by you in a blocking list with the help of which we can ensure that we no longer send you any unsolicited advertising. In doing so, we have a legitimate interest in keeping this blocking list to preserve your rights and comply with data protection regulations until you expressly withdraw the advertising objection in writing (Article 6 (1) f) GDPR).

5. Competitions

We also offer registered customers the opportunity to participate in competitions.

The data you provide for this purpose in the course of a double opt-in procedure, such as (1) first/last name, (2) e-mail address, (3) postal address and (4) competition-relevant entries, will be used by us exclusively for the purpose of conducting the competition within the framework of your consent (Art. 6 (1) a) GDPR). In particular, we only need your postal address to send you physical prizes in case you have won. Of course, we will delete this data, with the exception of competition-relevant entries, as soon as you withdraw your consent or unsubscribe from our portal.

Since we have a legitimate interest in being able to prove your consent for legal protection, an e-mail will be sent to the e-mail address you have provided in the double opt-in process with a request to confirm your consent (Art. 6 (1) f) GDPR). We store the IP address, date and time of sending the web form as well as the IP address, date and time of confirmation of the double opt-in e-mail for at least 4 years, and only if this is necessary for the defence against potential claims. 

We also reserve the right to publish the competition-relevant entries you have posted on our website for as long as we have a legitimate interest in this, which may be rooted in particular in the interest of other site visitors and upholding the attractiveness of the website (Art. 6 (1) f) GDPR).

6. Contact form or e-mail

In order to enable quick contact with us and to be able to process your requests quickly, we provide you with a contact form. By entering your data and clicking the "send" field, you allow us to collect the following data to process your request and store it for as long as it is necessary for this purpose (Art. 6 (1) a) GDPR).

(1) Name, (2) e-mail address, (3) telephone number, (4) content of the message.

The same applies, of course, to all data that you voluntarily provide to us when you send us an e-mail.

However, we would like to ask you to address all data protection concerns directly to our Data Protection Officer in order to ensure the fastest possible processing.


7. Embedded content and transfer of personal data to thirdparties

7.1 General

In order to improve the attractiveness of our website and to be able to offer you a comprehensive range of services and information on the subject of motorhomes, we embed third-party content on our website and pass on your IP address to them for this purpose (Article 6 (1) f) GDPR). If you have accounts with the individual providers, it is possible that they can draw a connection directly to your account. 

7.2 Embedded maps and videos

The following links can be used to find out about the privacy policies of individual third-party providers.

a. Mapbox maps: Mapbox maps are offered via the "Embed" function in the Internet service in order to be able to locate content and events.
    Mapbox privacy policy: https://www.mapbox.com/privacy/.

b. YouTube content: With the YouTube player, we integrate videos from its YouTube channels or videos from other providers into the Internet offer.
    To Google's privacy policy: https://support.google.com/youtube/answer/2801895?hl=en

 

8. Processors for hosting, platform security, administrative, troubleshooting and support services

We have a legitimate interest in using the following processors to ensure the functionality of our website (Art. 6 Para. 1 f) GDPR).

8.1 Creation and maintenance

We use DGTLS GmbH, Implerstraße 24, 81371 Munich, whose server is located within the EU, to create and maintain the website.

In principle, personal data will not be accessed or stored by them. This only happens in exceptional cases, for example if this is necessary in the context of resolving technical problems. In these cases, storage only takes place to the extent and for the duration required.

Of course, we have concluded a data processing agreement with them in accordance with Art. 28 GDPR.


8.2. Hosting

Our website is hosted by Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, so that personal data stored on our platforms is transmitted to this processor or its servers. The server is located within the EU.

Of course, we have concluded a data processing agreement with them in accordance with Art. 28 GDPR.


9. Cookies

We use cookies. Cookies are small text files that are temporarily stored on the user's hard drive when a website is accessed by the Internet browser. These cookies contain a characteristic string of characters that enables the Internet browser to be unambiguously identified when the website is accessed again.

9.1 Functional cookies

We have a legitimate interest in the use of functional cookies in order to provide you with convenient access to our website and to make it more user-friendly (Art. 6 (1) f) GDPR).

The cookies store and transmit settings (e.g. volume, subtitle, display size) and user login information. 


10. Web analysis by Matomo (formerly PIWIK) 

10.1 Type and scope of processing personal data

Our website uses the open source software tool Matomo (formerly PIWIK) to analyse the surfing behaviour of our users. For this purpose, the software sets a cookie on the user’s computer. If individual pages of the website are called up, we store the following data:

a.       the anonymised IP-address of the user's system
b.       the web page called up
c.       the website from which the user accessed the website (referrer)
d.       the sub-pages accessed from the accessed website
e.       the length of time spent on the respective web page
f.        the number of times a web page is accessed
g.       browser information, such as type of browser, version number and resolution.

The software that stores this data runs exclusively on the servers of our website. Accordingly, personal user data is only stored there. This data is not passed on to third parties.

As mentioned above, IP-addresses are stored anonymously, i.e. 2 bytes of the IP-address are made unrecognisable (e.g. 192.168.XXX.XXX). This ensures that no correlation is possible between the IP-address and the user's system.

 10.2 Legal basis for the processing of personal data

The legal basis for the processing of the users' personal data is Art. 6 para. 1 lit. f DSGVO.

10.3 Purpose of data processing

We process the personal data of website users in order to analyse the surfing behaviour and the use of individual elements of the website. The results of these analyses help us to continuously improve our website and increase user-friendliness. These purposes are the basis for our legitimate interest in processing the data in accordance with Art. 6 Para. 1 lit. f DSGVO. We do sufficient justice to the interest of our users in the protection of their personal data by anonymising the IP-addresses.

10.4 Duration of storage

The recorded data is deleted as soon as it is no longer required for our evaluation purposes. We delete the data after 5 years, as we measure the results of improvements on our website in the long term.

For more information on the privacy settings of the Matomo software, please see the following link: https://matomo.org/docs/privacy/.

 

11. Your rights

11.1 Right to information (Art. 15 GDPR)

If you so wish, we are happy to inform you to what extent we process your personal data. Should processing take place by us, we can provide you with the following information on request:

- the purposes for which the personal data is processed;
- the categories of personal data that is processed;
- the recipients or categories of recipients to whom your personal data has been or will be disclosed;
- the planned duration of the storage of the personal data or, if specific information is not possible, criteria for determining the storage period;
- the existence of a right to rectification or erasure of your personal data, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right to lodge a complaint with a supervisory authority;
- all available information on the origin of the data, if the personal data is not collected from the data subject;
- the existence of automated decision-making including profiling in accordance with Article 22 (1) and (4) GDPR and - at least in these cases – meaningful information about the logic involved as well as the scope and intended effects of such processing on the data subject.

You have the right to request information about whether your personal data is transferred to a third country or to an international organisation and to what extent suitable guarantees for security are in place in accordance with Art. 46 GDPR.

You have the right to receive a copy of the personal data subject to processing. For any further copies you request, we may request reasonable remuneration based on administrative costs. If the application is submitted electronically, the information must be provided in a common electronic format, unless otherwise stated.

The right to receive the copy may not affect the rights and freedoms of other persons and the right to information does not exist insofar as the information would disclose information that must be kept secret according to a legal provision or its nature, in particular due to the predominant legitimate interests of a third party.

11.2 Right to rectification (Art. 16, 19 GDPR)

Upon your request, we will rectify and complete the personal data stored by us immediately if it is incomplete.

We will forward your request to any recipient to whom the personal data has been disclosed, unless this proves impossible or requires disproportionate effort and will inform you of these recipients upon request.

11.3 Right to erasure ("right to be forgotten") (Art. 17, 19 GDPR)

You can request that we erase your personal data immediately and we are obliged to erase this data immediately if one of the following reasons applies:

- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- You withdraw your consent on which the processing was based pursuant to Art. 6 (1) a) GDPR or Art. 9 (2) a) GDPR, and there is no other legal basis for processing.
- You object to the processing according to Art. 21 (1) GDPR, and there are no overriding legitimate reasons for the processing, or you object to the processing pursuant to Article 21 (2) GDPR.
- We have processed your personal data unlawfully.
- The erasure of your personal data is necessary in order to fulfil a legal obligation under European Union or Member State law to which we are subject.
- Your personal data has been collected in relation to information society services offered in accordance with Article 8 (1) GDPR.

We will forward your request to any recipient to whom the personal data has been disclosed, unless this proves impossible or requires disproportionate effort and will inform you of these recipients at your request.

Please note that there is no right to erasure insofar as we are legally obliged to process it or we require the processing of personal data for the establishment, exercise or defence of legal claims against us.

11.4 Right to restriction of processing (Art. 18, 19 GDPR)

Furthermore, you can request the restriction of processing of your personal data under the following conditions:

- in case you dispute the accuracy of the personal data, for a period that enables us to verify the accuracy of the personal data;

- the processing is unlawful and you object to the erasure of the personal data and instead request the restriction of the use of the personal data;

- we no longer need the personal data for the purposes of processing, but you need it for the establishment, exercise or defence of legal claims, or

- if you have filed an objection to processing pursuant to Article 21 (1) GDPR and it has not yet been established whether our legitimate reasons outweigh your reasons.

If the processing of your personal data has been restricted, this data may only be processed - except for its storage – with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

If the processing has been restricted in accordance with the aforementioned conditions, we will inform you before the restriction is lifted.

We will forward your request to any recipient to whom the personal data has been disclosed, unless this proves impossible or requires disproportionate effort, and will inform you of these recipients at your request.

11.5 Right to data portability (Article 20 GDPR)

At your request and under the conditions of Article 20 (1) GDPR, that

- 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 Art. 6 (1) b) GDPR and
- the processing is carried out by automated means, and
- the freedoms and rights of other persons may not be affected by this,

we will transfer your personal data to you or another controller (insofar as technically possible) in a structured, commonly used and machine-readable format.

11.6 Right to object (Art. 21 GDPR)

If the processing is based on Art. 6 (1) e) or f) GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation.

This also applies to profiling based on these legal grounds. We will then no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising. This also applies to profiling insofar as this is connected with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes. Notwithstanding Directive 2002/58/EC, you have the possibility of exercising your right to object in connection with the use of information society services by means of automated procedures using technical specifications. You also have the right to object, for reasons arising from your particular situation, to the processing of your personal data which is used for statistical purposes in accordance with Art. 89 (1) GDPR.

At your request your personal data will be deleted in accordance with your right to erasure and under the conditions set out above.

 

11.7 Right to withdraw consent (Art. 6 (1) a), 7 GDPR)

In the event that the processing by us is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect processing based on consent prior to its withdrawal.

11.8 Automated decision in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing - including profiling - which has a legal effect on you or similarly significantly affects you. This does not apply if the decision

- is necessary for the conclusion or performance of a contract between you and us
- is permitted by European Union or Member State law to which we are subject and this legislation contains appropriate measures to safeguard your rights and freedoms as well as your legitimate interests, or
- with your express consent.

However, these decisions must not be based on special categories of personal data in accordance with Article 9 (1) GDPR, unless Article 9 (2) a) or g) GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.

We take reasonable measures to safeguard the rights and freedoms as well as your legitimate interests, which include at least the right to trigger active intervention by a person on the side of the controller, to express your point of view and to challenge the decision.

11.9 Right to lodge a complaint with the supervisory authority (Art. 77 GDPR)

If you believe that ALPS ALPINE has breached its obligations under the General Data Protection Regulation or the applicable national data protection regulations, you have the right, in addition to national legal remedies, to lodge a complaint with a supervisory authority, in particular at your regular place of residence, at your workplace or at the location of the alleged breach. 

12. Consequences of not providing data

You are not legally obliged to provide us with your data. However, insofar as the data is necessary to provide a service, we will not be able to provide you with the corresponding service without transmission of the data.

13. Changes to this policy

We may change this policy from time to time by updating this page. You should therefore check this page occasionally to ensure that you agree with the changes. Subsequent material or substantive changes will be notified accordingly.