Data Protection Declaration

Welcome to the Cargobull Parts & Services GmbH website. Data protection has a particularly high priority for our company and our entire group of companies. This data protection declaration gives you an overview of how we process your personal data when you visit our website. We inform you about what data we collect from you and how we use it. We also inform you about your rights under applicable data protection law and tell you who you can contact if you have any questions.


1. Person responsible and data protection officer
Cargobull Parts & Services GmbH
Siemensstrasse 49
48341 Altenberge
E-Mail: info@cargobull.com

You can reach our data protection officer at:

Schmitz Cargobull AG
Data Protection Officer
Bahnhofstraße 22
48612 Horstmar
E-mail: dataprotection@cargobull.com


2. Subject of data protection
The subject of data protection involves safeguarding personal data. This is all information relating to an identified or identifiable natural person (the so-called data subject). This includes details such as name, postal address, e-mail address or telephone number, and any other information that arises in the context of the application process, such as information about your qualifications, training or professional stations.


3. Legal basis of our data processing
Personal data can be processed from several legal bases.. If we need your data for the performance of a contract with you, or to respond to inquiries from you regarding a contract, the legal basis for this data processing is Art. 6 para. 1 p. 1 lit. b DSGVO. If we obtain your consent for certain data processing, the legal basis is Art. 6 para. 1. p. 1 lit. a DSGVO. We carry out some data processing on the basis of our legitimate interest, always weighing your interests worthy of protection against our legitimate interests. The legal basis here is Art. 6 para. 1 p. 1 lit. f DSGVO. Insofar as the processing is necessary for the fulfilment of a legal obligation to which we are subject, the legal basis is Art. 6 para. 1 p. 1 lit. c DSGVO. In the following, we explain how we process personal data via our website.


4. Collection of personal data when calling up the website
During informational use of the website, i.e., if you do not register or otherwise transmit information to us (e.g., via a contact form), we collect the following technical information (log file data): - IP address of the calling computer - Operating system, language and version of the calling end device - Browser version of the calling computer - Language of the browser used - Time zone difference to Greenwich Mean Time (GMT) - Name of the retrieved file - Date and time of the retrieval - Amount of data transferred - Referring URL ("Referrer") The collection of this data is technically necessary to display our website to you, and to ensure stability and security. We regularly do not know who is behind an IP address. We do not combine the data listed above with other data. The legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO. Since the collection of data for the provision of the website and the storage in log files are absolutely necessary for the operation of the website and to protect against misuse, our legitimate interest in data processing prevails at this point.


5. Cookies
5.1 General
Our website uses cookies. Cookies are files that are placed on your computer by a website you visit and allow your browser to be reassigned. Cookies transmit information to the entity that sets the cookie. Cookies can store various information, such as your language setting, the duration of your visit to our website or the entries you have made there. This avoids, for example, that you have to re-enter required form data each time you use the site. The information stored in cookies can also be used to recognize preferences and to tailor content according to areas of interest.
There are different types of cookies:
- Session cookies are sets of data that are only temporarily held in memory and deleted when you close your browser.
- Permanent or persistent cookies are automatically deleted after a specified duration, which may differ depending on the cookie. The information can also be stored in text files on your computer with this type of cookie. However, you can also delete these cookies at any time via your browser settings.
- First-party cookies are set by the website you are currently visiting. Only that website is allowed to read information from these cookies.
- Third-party cookies are set by organizations that are not operators of the website you are visiting. For example, these cookies are used by marketing companies.
- In addition, we use HTML5 storage objects that are placed on your terminal device. In addition, we use HTML5 storage objects that are placed on your terminal device. These objects store the required data regardless of the browser you are using and have no automatic expiration date. If you do not want Flash cookies to be processed, you must install an appropriate add-on, e.g. "Better Privacy" for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash Killer cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. We also recommend that you manually delete your cookies and browser history on a regular basis.
The legal basis for possible processing of personal data by means of cookies and their storage period may vary. Insofar as you have given us your consent, the legal basis is Art.6 para. 1 p. 1 lit. a DSGVO, § 25 para. 1 p. 1 TDDDG. Insofar as the data processing is based on our overriding legitimate interests, the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO. The stated purpose then corresponds to our legitimate interest.
We use cookies to ensure the proper operation of the website, to provide basic functionalities, for range measurement and to tailor our services to preferred areas of interest.
You can delete cookies already stored on your terminal device at any time. If you wish to prevent cookies from being stored, you can do so via the settings in your internet browser. You can find instructions on how to do this on the websites of the most popular browser providers (Internet Explorer, Firefox, Google Chrome, Google Chrome mobile, Microsoft Edge, Safari). Alternatively, you can also install so-called ad blockers. Please note that individual functions of our website may not work if you have disabled the use of cookies.
When you access our website, you will also be informed by an info banner of our consent management platform Usercentrics about our use of cookies and referred to this privacy policy. As a user, you will also be asked for your consent to the use of certain cookies, in particular for the personalization of services and for marketing measures. Once you have given your consent, you can revoke it at any time with effect for the future by calling up the tracking settings via the icon displayed at the bottom left (fingerprint) and removing the check mark behind the processing to which you had consented."


5.2 Technically necessary cookies
We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

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The technically necessary cookies are mandatory to display the website and/or serve your re-authentication in the system. Consequently, there is no possibility to object, a deactivation of these cookies can be made by setting the respective browser.


5.3 Google Tag Manager
For reasons of transparency, we point out that we use the Google Tag Manager. The Google Tag Manager itself does not collect any personal data. The Tag Manager makes it easier for us to integrate and manage our tags. Tags are small code elements that are used, among other things, to measure traffic and visitor behaviour, to record the impact of online advertising and social channels, to set up remarketing and targeting, and to test and optimise websites. We use Tag Manager for all digital services listed in this Privacy Policy. If you have opted out, Google Tag Manager will honour that opt-out. For more information about Google Tag Manager, see: https://www.google.com/intl/de/tagmanager/use-policy.html.


6. Website analysis and marketing services
For the purpose of analysing and optimising our website and for marketing purposes, we use various services, which are described below. We use these services to analyse how many users visit our website, which information is most in demand or how users find the offer. We also collect data on which website you came to our website from (so-called referrer), which sub-pages of the website were accessed or how often and for how long a sub-page was viewed. This helps us to design our offers in a user-friendly way, to find errors and to improve our offers.


6.1 Google Analytics
Google Analytics 4
With your consent, we use Google Analytics 4, the web analytics service of Google LLC, on our website. The responsible entity for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").

Google Analytics 4 uses cookies that enable an analysis of your use of our website. The information collected by means of the cookies about your use of this website is generally transferred to a Google server in the USA and stored there. In Google Analytics 4, the anonymization of IP addresses is activated by default. Due to IP anonymization, your IP address will be shortened by Google within member states of the EU or EEA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics is not merged with other data from Google.
During your website visit, your user behaviour is recorded in the form of "events". Events can be:

- Page views
- First visit to the website
- Start of session
- Your "click path", interaction with the website
- Scrolls (whenever a user scrolls to the bottom of the page (90%)
- clicks on external links
- internal search queries
- interaction with videos
- seen / clicked ads
So recorded:
- Your approximate location (region)
- your IP address (in shortened form)
- technical information about your browser and the end devices you use (e.g., language setting, screen resolution)
- Your Internet service provider
- the referrer URL (via which website/advertising medium you came to this website)

On our behalf, Google will use this information to evaluate your pseudonymous use of the website and to compile reports on website activity. The reports provided by Google Analytics are used to analyse the performance of our website and the success of our marketing campaigns.
Recipients of the data are/may be:

- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor according to Art. 28 DSGVO)
- Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
- Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
It cannot be ruled out that US authorities will access the data stored by Google.

Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against access by authorities.

The legal basis for the described data processing is your consent, Art. 6 para. 1 p. 1 lit. a DSGVO, § 25 para. 1 p. 1 TDDDG, which we request from you when you call up the website and which you must give before using Google Analytics. The data processing described will not be carried out without your corresponding consent. Once you have given your consent, you can revoke it at any time with future effect by changing your selection in the cookie settings of our consent management platform (see above, 5.1. Cookies). Alternatively, you can delete your cookies (all or only from this website).
Even if you have initially consented to all cookies and services on our website, you can independently prevent the processing of data collected by cookies by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
For more information on Google Analytics terms of use and Googles privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/de/ and https://policies.google.com/?hl=de.


7. Other services
7.1 Font Awesome
We use Font Awesome from the US company Fonticons (307 S. Main St., Suite 202, Bentonville, AR 72712, USA) on our website. When you visit our website, icons from Font Awesome are loaded via the Font Awesome Content Delivery Network (CDN) for an appealing display. Font Awesome allows us to better present content on our website for you, the user.
For this purpose, your browser establishes a connection to the servers of the company Fonticons Inc (USA). Your IP address is transmitted in the process. Font Awesome also collects data about which icon files are downloaded and when. Font Awesome also collects data about which icon files are downloaded and when. In addition, technical data such as your browser version, screen resolution or the time of the page accessed is transmitted. To the best of our current knowledge, no cookies are set. If your browser does not allow web fonts, a standard font of your PC is automatically used.

Font Awesome stores your data in the United States of America. Font Awesome stores data about your use of the CDN on servers also located in the United States of America. The CDN servers are located around the world and store user data wherever you are. We have concluded the EU standard data protection clauses adopted by the EU Commission in accordance with Art. 46 DSGVO with the service provider Fonticons in order to establish a secure level of data protection.

The legal basis for the described data processing is your consent, Art. 6 para. 1 p. 1 lit. a DSGVO, which we request from you when you access the website. The data processing described will not be carried out without your corresponding consent. Once you have given your consent, you can revoke it at any time with future effect by changing your selection in the tracking settings (see above, under 5.1. Cookies).

For more information on data processing by Forticons, please see the privacy policy at https://fontawesome.com/privacy and the help page at https://fontawesome.com/help.


8. Contact
When you contact us by e-mail, telephone or via our contact forms, the data you provide (your e-mail address, your name if applicable, your telephone number and the information you have provided) will be stored by us in order to answer your questions and process your requests. The legal basis in this respect is Art. 6 para. 1 p. 1 lit. f DSGVO, our legitimate interest in processing your request. Insofar as we request information via our contact forms that is not required for contacting you, we have always marked this as optional. This information is used to specify your request and to improve the processing of your request. Any communication of this information is expressly on a voluntary basis and with your consent, Art. 6 para. 1 p. 1 lit. a DSGVO. Insofar as this involves information on communication channels (e.g. e-mail address, telephone number), you also consent to us contacting you via this communication channel, if necessary, in order to respond to your request. Of course, you can revoke this consent at any time for the future.

Your data, which we have received in the course of contacting you, will be deleted as soon as it is no longer required to achieve the purpose for which it was collected, your request has been fully processed and no further communication with you is necessary or desired by you.


9. Telephone contact for support requests
If you contact us by telephone with support questions, the following personal data will generally be collected and processed from you: First name and surname, company, customer number and order number and contact details as well as other information about your enquiry that you provide to us.

We process this data for the purpose of processing your enquiry. If you contact us in connection with the initiation or implementation of a contractual relationship that you have entered into with us, the legal basis for the data processing is Art. 6 para. 1 sentence 1 lit. b. DSGVO. The legal basis for processing in the context of our complaint management is Art. 6 para. 1 p. 1 lit. f DSGVO, our legitimate interest in establishing customer satisfaction with our offers through dialogue with our customers. We store your personal data as long as it is necessary for the fulfilment of our legal and contractual obligations.

For training purposes and to improve the quality of service, we may occasionally record conversations. You will be informed about the possibility of such a call recording at the beginning of your contact and before the start of a possible recording. The recording is made exclusively on the basis of your express and previously given consent in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO. You can revoke this consent at any time, even in the course of the further conversation, vis-à-vis your conversation partner. The recorded conversation will be deleted after evaluation, but at the latest after 365 days.


10. Newsletter
You can register on our website for our newsletter, which we use to inform you about our company´s activities, current information about our services, current and special offers, promotions, events, and competitions. This may also include offers from other companies in the Schmitz Cargobull Group. Promotional information will only be sent to your e-mail address as part of our newsletter if you have consented to the use of your e-mail address. The legal basis is therefore your consent in accordance with Art. 6 Para. 1 Sentence 1 lit. a DSGVO in conjunction with. § 7 para. 2 no. 3 UWG.

We use the so-called double opt-in procedure to register for our newsletter. This means that after your registration, we will send you an email to the email address you provided in which we ask you to confirm that you wish to receive the newsletter.
The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary: this data is used to be able to address you personally. After your confirmation, we store your e-mail address for the purpose of sending the newsletter and until revoked. We also store your current IP address at the time of registration, and the times of registration and confirmation. The purpose of this procedure is to be able to prove your registration in case of doubt and to clarify any misuse of your personal data.
You can, of course, revoke your consent to receive newsletters at any time by clicking on the unsubscribe link in the newsletter or by informing us of your wish to unsubscribe via info@cargobull.com.

Newsletter tracking

In order to better understand how our newsletter is used, we evaluate your user behaviour when sending the newsletter. For this evaluation, the e-mails sent contain so-called web beacons, also known as tracking pixels. These are one-pixel image files that link to our website and thus enable us to evaluate your user behaviour. This is done through the use of web beacons, which are assigned to your email address and linked to a unique ID. Links received in the newsletter also contain these. With the data obtained in this way, we create a user profile, in order to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click on in them and deduce your personal interests from this. We link this data to actions you have taken on our website. The legal basis for this data processing is your consent, Art. 6 para. 1 p. 1 lit. a DSGVO, § 25 para. 1 TDDDG.

You can revoke your consent at any time with effect for the future by clicking on the separate link provided in each email. In this case, the revocation includes the entire newsletter, as a separate revocation of the tracking is unfortunately not technically possible. Tracking the opening of the newsletter is also not possible if you have deactivated the display of images by default in your e-mail programme. In this case, the newsletter will not be displayed in full, and you may not be able to use all the functions. If you display the images manually, the above-mentioned tracking will take place. The data you provide us with for the purpose of receiving the newsletter will be stored by us for as long as you are subscribed to the newsletter. After unsubscribing, we store the data purely statistically and anonymously.


11. Direct advertising without prior registration
If we have received your email address or postal address in connection with the sale of a product or service, we may use this data to inform you about our own similar product and service offers by email and post from time to time.
The legal basis for this data processing is § 7 para. 3 UWG, Art. 6 para. 1 lit. f DSGVO.

If you do not wish to receive any further advertising information by e-mail or post, you can object to the use of your contact data for advertising purposes at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates. You can send your objection to the following contact addresses. Schmitz Cargobull AG, Bahnhofstraße 22, 48612 Horstmar, e-mail: info@cargobull.com


12. Applications /Career portal
You can apply to one of our companies in the Schmitz Cargobull Group electronically, in particular by e-mail or via the careers portal. In order to process your application, we will process the personal data you have provided us with, which is usually your applicant master data (first name, surname, address, job position), qualification data (cover letter, CV, previous activities, professional experience, etc.), and your personal data.
qualifications), references and certificates (performance data, assessment data, etc.) and, if applicable, special information that is required due to the position to be filled (e.g. police clearance certificate, Schufa information). Your details will only be used to process your application. Please note that unencrypted e-mails will not be protected against unauthorised access.
The data processing is based on Art. 6 para. 1 lit. b., Art. 88 DSGVO in conjunction with § 26 para. 1 p. 1 BDSG. In this respect, we process those personal data that are necessary for the implementation of the application procedure. If we obtain your consent for certain data processing, the legal basis is Art. 6 para. 1 lit. a DSGVO, Section 26 para. 2 BDSG.
Your personal data will be deleted after a maximum of 6 months following completion of the application process unless you have expressly given us your consent to store your data for a longer period.


13. Will my data be transferred to third parties?
As a matter of principle, your personal data will not be transferred to third parties unless we are legally obliged to do so, or the transfer of data is necessary for the performance of the contractual relationship, or you have previously expressly consented to the transfer of your data.
In order for us to process your data in accordance with the purposes described above, it may be necessary for other recipients to be able to view and process your data.

13.1 Recipients within the Schmitz Cargobull Group
In special cases, it may be necessary for us to process your data across the group. However, data processing within the Schmitz Cargobull Group will only take place if we have legal permission to do so. This is the case, for example, if other companies in the Schmitz Cargobull Group act on our behalf as part of commissioned processing or if there is a legitimate interest in accordance with Art. 6 Para. 1 f DSGVO.

13.2 Other service providers, partners and third parties
We work with selected external service providers and partner companies to fulfil our contractual and legal obligations.
These external service providers and partner companies only receive your data insofar as this is necessary to fulfil our service offers or if we are legally obliged to release data. In these cases, however, the scope of the transmitted data is limited to the necessary minimum. Please also note the data protection information of the respective providers. The respective service provider is responsible for the content of third-party services, whereby we check the services for compliance with legal requirements within the scope of reasonableness.
Insofar as our service providers process your personal data on our behalf, we ensure within the framework of commissioned processing pursuant to Art. 28 DSGVO that they comply with the provisions of the data protection laws in the same manner.

14. Data transfer to third countries
We make a point of processing your data within the EU/EEA. However, it may happen that we use service providers who process data for us outside the EU/EEA. In the case of such a data transfer, the high European level of data protection does not apply. In the case of a transfer, it may be that there is currently no adequacy decision by the EU Commission within the meaning of Article 45 (1), (3) of the GDPR. This means that the EU Commission has not yet positively determined that the country-specific level of data protection corresponds to the level of data protection in the EU based on the GDPR, which is why we have created the aforementioned appropriate guarantees. In these cases, by agreeing on EU standard contractual clauses of the EU Commission in accordance with Art. 46 (2) lit. c DSGVO and possibly agreeing on further necessary measures with our contractual partners, we ensure that an adequate level of data protection is established at the recipient`s end prior to the transfer of your personal data.
If you have any questions about such data protection contracts based on the EU standard contractual clauses or would like more information about further security mechanisms and security measures for data transfer to third countries, please feel free to contact us by email at Dataprotection@Cargobull.com.


15. Storage period
We store your personal data as long as it is necessary for the fulfilment of our legal and contractual obligations. Should storage of the data no longer be necessary for the fulfilment of contractual or legal obligations, your data will be deleted unless its further processing is necessary for the following purposes:
- Fulfilment of retention obligations under commercial and tax law. These include retention periods from the German Commercial Code (HGB) or the German Fiscal Code (AO).
- Preservation of evidence within the framework of the statutory limitation provisions. According to the statutes of limitation of the German Civil Code (BGB), these limitation periods can be up to 30 years in some cases; the regular limitation period is three years.


16. Data security
We use encryption to transfer your personal data securely. This applies to all form processes (including registration, login, ordering). Schmitz Cargobull uses the SSL/TLS (Secure Socket Layer/Transport Layer Security) coding system for this. Although no one can guarantee absolute protection, Schmitz Cargobull secures its website and other systems against loss, destruction, access, modification or distribution of your data by unauthorised persons using technical and organisational measures. Our security procedures are regularly reviewed and adapted to technological progress.


17. Your rights
You have the following rights in relation to personal data relating to you:

17.1 General rights
You have the right to information, correction, deletion, restriction of processing, objection to processing and data portability. If processing is based on your consent, you have the right to revoke this consent with effect for the future.

To exercise your rights, please contact us by e-mail at Dataprotection@Cargobull.com or by post at Schmitz Cargobull AG, Bahnhofstraße 22, DE-48612 Horstmar.
The exercise of your rights described under this point is free of charge for you.

17.2 Rights in data processing according to legitimate interest
Pursuant to Art. 21 (1) DSGVO, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) e DSGVO (data processing in the public interest) or on the basis of Art. 6 (1) f DSGVO (data processing for the protection of a legitimate interest); this also applies to profiling based on this provision. In the event of your objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

17.3 Direct marketing rights
If we process your personal data for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing in accordance with Art. 21 (2) of the German Data Protection Act (DSGVO); this also applies to profiling insofar as it is associated with such direct marketing.

In the event of your objection to processing for the purposes of direct marketing, we will no longer process your personal data for these purposes.

17.4 Right to complain to a supervisory authority
Without prejudice to these rights and the possibility of seeking any other administrative or judicial remedy, you may at any time exercise your right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes data protection rules (Article 77 of the GDPR).

The supervisory authority responsible for us is:

State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia
Kavalleriestr. 2-4
40213 Düsseldorf
Phone: 0211/38424-0
Fax: 0211/38424-999
E-mail: poststelle@ldi.nrw.de


18. Links to other websites
Our website may contain links to websites of other providers. We would like to point out that this information on data protection applies exclusively to the website www.cargobull.com/de. We have no influence on and do not control that other providers comply with the applicable data protection regulations.


19. Changes to the privacy policy
We reserve the right to change or adapt this information on data protection at any time in compliance with the applicable data protection regulations.

Status: 12 October 2023