Privacy Policy

Truma Gerätetechnik GmbH & Co. KG, Wernher-von-Braun-Straße 12, 85640 Putzbrunn

This Privacy Policy applies to the websites truma.com, truma.com/serviceblog, dealer.truma.com, oem.truma.com and go2-camping.com (“the websites”), the Truma App for iOS and Android, as operated by Truma Gerätetechnik GmbH & Co. KG (“Truma” or “we”) and the Learning Management System of the Truma Academy. This privacy policy also applies moreover to our presences on Facebook (http://www.facebook.com/truma.official) and Instagram (@truma.official).

This policy does not apply to third party websites which we use a link to refer to.

We process personal data collected whenever our websites are visited or whenever the apps are used at all times in accordance with the respectively relevant provisions of data protection laws.

This privacy policy provides you with information about when and which personal data is processed whenever you use our websites and apps and about how such data is used. It informs you moreover about which rights you have with regard to the use of your data and whom you should contact for such purposes.

1. Data processing and purposes of the processing

1.1 Personal data

Personal data is all information relating to an identified or identifiable natural person, Art. 4 (1) GDPR. This includes such information as for example your name, address, date of birth or telephone number. Data that does not allow any conclusions to be drawn in your regard is not personal data.

1.2 Data collection

We collect personal data on the website and apps only if this is either necessary for the designated purpose or for the purpose required by you or if you have provided us with such data of your own accord, e.g. in the context of making contact with us or of any online application.

1.2.1 Websites

Whenever you visit our websites the data specified below (“usage data”) is automatically collected, without your involvement, and stored up until such time as it is automatically erased. This data is neither assigned to a specific person nor does it reveal your identity.

• The IP address of the requesting terminal
• Time of access (date and time)
• The browser used and, where applicable, your terminal’s operating system
• The name and URL of the retrieved file
• The website that brought you to our website (so-called referrer site)
• Websites that your terminal views from our website.

We collect and process this usage data to facilitate the use of our websites.  The legal basis for the processing of the data is your consent pursuant to Art. 6 (1), sentence 1, lit. a) GDPR.

We use this usage data moreover to optimise our offering, to ensure the security of our systems and for statistical purposes.  In this case also, the legal basis for the processing of the data is your consent pursuant to Art. 6 (1), sentence 1, lit. a) GDPR.

We collect personal data only where it is necessary for the initiation or performance of a contractual relationship or where you provide us with this of your own accord, in particular for the purposes of establishing contact as instigated by you, in the context of an online application or registration, to request the mobile customer service or for the dispatch of the newsletter. The legal bases for this are Art. 6 (1), sentence 1, lit. a) and b) GDPR.

The use of the data is for a specific purpose.

To help operate our website, we work with Ray Sono AG, who as part of the provision of their service are able to view the personal data.

In the area of online applications, your personal data is collected and stored by our service provider perbit Software GmbH.

The appropriate agreements as provided for under data protection laws were entered into with these service providers.

1.2.2 Portal for dealers and OEM

If you wish to use our portal for dealers and OEM, you need to register for this. For this purpose, we collect the following data from you. Please note that there are mandatory fields where an entry is required to permit us to deal with your enquiry. These are marked with an asterisk. If you provide information in the other fields also, such information will be evaluated for statistical purposes and to improve our offering:

• Customer number
• Company
• Additional company (optional)
• Salutation
• First and last name
• Address
• Language
• E-mail address
• Telephone number (optional)

The data provided by you as part of the registration will be collated and checked by Salesforce.

You can find more detailed information about Salesforce further on in this privacy policy.

We collect the data for the purpose of implementing the contractual relationship, in par-ticular order processing and the delivery of goods. The legal bases for this are in this case your consent Art. 6 (1), sentence 1, lit. a) and b) GDPR.

It is not possible to provide access to this portal without the provision of this data.

Goods are delivered through an external service provider. The legal bases for the use of the data for delivering goods are Art. 6 (1), sentence 1, lit. a) and b) GDPR.

As a registered dealer or OEM, you have various different functionalities at your disposal; in particular, you can generate your own forms and amend your address details in the portal.

1.2.3 Truma Academy / Learning Management System

If you would like to use our Learning Management System (LMS) as a customer, you must first register in the dealer portal. After registration we will check your authorization for access. Once authorization has been granted, your user data is automatically transferred to our CRM system Salesforce.   

• Customer number 
• Company name 
• Salutation 
• First name and surname 
• Address details 
• Language 
• E-mail address 
• Partner type/ customer type 
• Customer type/customer group 
• User name 
• Telephone number 
• Billing and payment data 

As part of the training administration on the LMS, we also process

• Participation and booking data of the courses 
• Course progress and results

Further information on Salesforce can be found below in this privacy policy.

We collect the data exclusively for the purpose of training and course processing. The legal basis for this is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) and the mutual fulfilment of contractual obligations in accordance with Art. 6 para. 1 sentence 1 lit. b).

Without the provision of this data, it is not possible to provide access and thus participate in Truma Academy courses and training programs.

The recipients of the data are internal employees of Truma Gerätetechnik GmbH & Co. KG and the processors Salesforce and imc information multimedia communication AG used to operate the platform. We have concluded order processing contracts with both of them in accordance with Art. 28 EU GDPR.

As a responsible company, we do not use automated decision-making or profiling for this data processing.

The processing does not take place outside the European Union (EU) or the European Economic Area (EEA) and your data will not be passed on to third parties.

1.3 Apps

1.3.1 Truma App, Truma LevelControl App, Truma Cooler App

Whenever you use our apps, we collect the following usage data in pseudonymous form from the respective app:

• Mobile device data
• Mobile device ID
• Location
• App version
• Product firmware version
• Product serial number
• The app’s usage data such as selected settings, functions used, frequency and time of access, error messages
• Usage data from connected devices and products

We process such data for statistical purposes, to optimise our offering, to ensure the secu-rity of our systems and to learn about the use of products, this with a view to improving the app, the product and our offering, to optimising test cases and to assessing service cases. The legal bases for this are therefore Art. 6 (1), sentence 1, lit. a) and b) GDPR.

The apps offer you the possibility of a setup providing for the remote operation of your Truma devices via Bluetooth or, in the case of the Truma app, via SMS also. For this and in order to be able to provide you with the service, we collect and process the device data from your mobile phone and from the device to be used for such purposes. If this data is not collected, the app’s functionality and the functions offered by the app cannot be provided.

Some of the app’s functions use your current location. Your location is determined based on its connection to WLAN networks, to mobile phone masts or via GPS. The data is nec-essary for the Bluetooth function on Android devices. You will be asked shortly after the application has started up whether you wish to use these services. You may at any time disable the use by the app of your current location in your mobile device’s settings.

In the Truma Cooler app, the camera function can also be used to establish the connection with the Truma Cooler by scanning the QR code. You will be asked shortly after the appli-cation has started up whether you wish to use these services.

1.3.2 iNet X App 

1.3.2.1. Nature and purpose of the processing

The app enables you to control the devices in your vehicle via Bluetooth. For this purpose, and to permit us to provide the service, we collect and process the device data of your mobile phone and of the devices you wish to operate. If this data is not collected, the app’s functionality and the functions offered by the app cannot be provided.

We process this data in pseudonymised form for statistical purposes, to optimise our offering, to guarantee the security of the system and to improve the app, the product and our offering for the optimisation of test cases and for the assessment of servicing requirements.

When you register in the app, we record your name and your email address. If this data is not collected, the app’s functionality and the functions offered by the app cannot be provided. We process this data in order to provide our services, which you can display and manage in the app.

If you give us your consent for the “Extended Service”, we process the aforementioned data on a personalised basis. In addition to this, we collect device data from the iNet X Panel and its telemetry data.  We process this data to permit us to establish what the fault is whenever servicing is required and how this fault might arise in the context of the device’s use. This enables us to process and resolve servicing requirements more rapidly and in a more targeted manner. We are moreover able to recognise basic reproducibilities of individual problems at an earlier stage, thus permitting us to make our products more secure.

In order to use the Bluetooth function on Android devices, your location needs to be shared. Truma will however at no time use or store the location. You will be asked shortly after the application has started up whether you wish to use these services. You can at any time disable the app’s use of your current location as part of the Bluetooth function in your mobile device’s settings. The app’s functionality will however be restricted if you disable this.

1.3.2.2. Legal basis for the processing

The processing of the data entered is based on your consent to the terms of use (Art. 6 (1) lit. b GDPR). In addition to this, further personal data may be processed based on your consent (Art. 6 (1) lit. a GDPR).

1.3.2.3. Data categories

• Mobile device data
• Mobile device ID
• App version
• Firmware version of products
• Serial numbers of products
• Name and e-mail address
• Telemetry and device data for products

1.3.2.4. Recipients

• Staff of the company itself
• IT service providers used with whom a contract for commissioned processing pursuant to Art. 28 GDPR exists

1.3.2.5. Storage periods

Data are processed in this connection only for as long as we have the corresponding consent. The data are subsequently erased or anonymised, except where this is prevented by statutory records retention requirements. Should you wish to contact us in this regard, please use the contact details provided at the start of this privacy policy.

1.3.2.6. Statutory/contractual requirement

The provision of your personal data is optional and is based solely on your consent or agreement. Should you prevent access, this can lead to restricted functionality during use.

1.3.2.7. Transfer to third countries

The data are moreover processed outside the European Union (EU) or the European Economic Area (EEA). The processing is limited to hosting the platform in Microsoft Cloud Azure To guarantee the level of data protection in this third country, we have concluded standard data protection clauses and additional guarantees with Microsoft.

1.3.2.8. Withdrawal of consent

You may withdraw your consent to the storage of your personal data at any time, to take effect in the future.

You can prevent the usage data being stored by selecting the appropriate settings in your app; however, we would point out that doing so may mean you will not be able to enjoy the full functionality of the app.

1.3.2.9. Automated decision-making and profiling

The iNet X app can be used to assess the camping vehicle’s system configuration, which can then be analysed with a view to improving the product and service. For this purpose, we create a pseudonymised user profile with the aid of a randomly generated device ID. There is no automated decision-making related to the app’s users.

2. Use, Storage and Deletion of Cookies

2.1 What are cookies?

Cookies are small text files stored on your computer or mobile terminals (“the terminal” or “the terminals”) whenever you visit our websites. This enables certain information to be collected by the website owner who sets the cookie (in this case us).

In some circumstances, we use similar methods such as pixels, web beacons etc. For rea-sons of consistency, we shall refer to all these methods jointly as “cookies”.

We differentiate between four categories of cookies: (a) essential and (b) functional cookies, (c) marketing cookies and (d) analytical cookies.

Cookies may be essential to the proper functioning of our website (essential cookies).

We can moreover use cookies to provide you with more user-friendly and effective func-tionalities, which would be limited or impossible without the setting of cookies.

By setting a cookie, the information and offerings on our websites can for example for the purposes of users be optimised to their needs. As already mentioned, cookies enable us to recognise you on our website. The purpose of this recognition is to facilitate the use by you of our website (functional cookies).

A further possible area in which cookies can be used is online advertising. This can be per-sonalised to ensure that you are provided with relevant and interesting advertisements both on Truma’s websites and on third party websites. This is achieved through (targeted) marketing cookies.

Cookies can also be used to analyse website use, to determine the number of visitors and to find out how the website can be improved. We do not make any connection between the statistics on website use and other reports with individuals. These cookies are analysis cookies.

2.2 Managing and disabling cookies in your browser and on our websites

Cookies are stored on your computer. You may at any time decide whether you wish to de-lete cookies from your computer. By adjusting the settings in your browser, you yourself can determine whether the transfer of cookies from your computer to us should be disa-bled or restricted or whether in fact all cookies should be deleted. If you disable all cookies for our website, this may mean that the full functionality of the website can no longer be used.

The following list offers further information on the disabling of cookies or on the manage-ment of your cookie preferences in the browser used by you:

• Google Chrome
• Firefox
• Internet Explorer
• Safari

You also have the option of adjusting your cookie settings directly on our websites. By clicking on “cookies”, you can choose which kinds of cookies you wish to enable on our website and which you wish to disable through a so-called “opt-out”. You can change your preferences at any time. Please note: If you delete your cookies, this will also delete the opt-out cookie, which may where necessary have to be enabled once again by you. You will moreover find a list of all the cookies used by us under the heading “Cookie settings”.

2.3 Cookie Settings

The following table lists which cookies we use on our websites. Further information can be found in the sections of this privacy policy that follow.

2.4 Essential Cookies

These technologies are essential to ensure the core functionality of the website.

2.4.1 General information on Google services

We use various services from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA on our website. For the European area, the company Google Ireland Limited (“Google”) (Gordon House, Barrow Street Dublin 4, D04 E5W5, Ireland) provides all Google services.

This privacy policy contains more detailed information on the specific individual services from Google that are used on this website.

The integration of the Google services means that Google may in some circumstances col-lect and process information (including personal data). The possibility that Google may also send this information to a server in a third country cannot be excluded.

The data is moreover processed outside the European Union (EU) or the European Eco-nomic Area (EEA). To safeguard the level of data protection in this third country, we have concluded standard data protection clauses with Google (Analytics).

We have no influence over which data Google does in fact collect and process. Google does however state that, in principle, the following information (including personal data) may inter alia be processed:

• Protocol data (notably the IP address);
• Location-related information;
• Unique application numbers;
• Cookies and similar technologies.

If you are logged into your Google account, Google may add the processed information to your account, depending on your account settings, and treat this as personal data, cf. in this regard in particular.

You can prevent the direct addition of this data by logging out of your Google account or by selecting the appropriate account settings in your Google account. You can moreover prevent the installation of cookies, insofar as Google sets any such cookies, by selecting the appropriate settings in your browser; we would however point out to you that you may in this case, where applicable, not be able to use the full functionality of this website.

The purpose and scope of the data collection and the further processing and use of the data by Google as well as your rights in this regard and setting options to protect your privacy can be found in Google’s data privacy notice.

Information about Google’s privacy settings can be found here.

2.4.2 Google Maps

The websites use Google Maps to display interactive maps and to provide directions to lo-cations. Google Maps is a map service of Google Inc., 1600 Amphitheatre Parkway, Moun-tain View, California 94043, USA. For the European area, the company Google Ireland Lim-ited (Gordon House, Barrow Street Dublin 4, D04 E5W5, Ireland) provides all Google ser-vices. By using Google Maps, information about the use of this website, including your IP address and the (start) address entered as part of the route planner function, may be transmitted to Google Inc. in the USA. Whenever you visit a website on our online pres-ence that contains Google Maps, your browser establishes a direct connection with Google’s servers. The map content is transmitted by Google directly to your browser and integrated into the website by it. To the best of our knowledge, this is at least the following data:

• Date and time of the visit to the website concerned;
• Internet address or URL of the website viewed;
• IP address;
• where applicable, location data and
• the (start) address entered during route planning.

The legal basis for the processing of your personal data is your consent pursuant to Art. 6 (1), sentence 1, lit. a) GDPR on account of the transmission of the data to Google for their own purposes. We process your data until you withdraw your consent or up until such time as your personal data is no longer required for the achievement of the aforementioned purpose. This is as a rule the case once your Google Maps request has been conclusively dealt with.

We have no influence on the further processing and use of the data by Google.

If you do not wish Google to process data about you via our online presence, you can dis-able JavaScript in your browser settings. In this case, however, you cannot use the map display.

2.4.3 Google Webfonts

We integrate fonts provided by Google („Google Fonts“), for which your data is used solely for the purposes of displaying your browser’s fonts. For the European area, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, D04 E5W5, Ireland) pro-vides all Google services. This integration is based on our legitimate interests pursuant to Art. 6 (1), sentence 1, lit. f) GDPR in a technically secure, maintenance-free and efficient provision of fonts (enhanced loading time) and in their uniform presentation, and takes due account of possible restrictions on their integration under licensing laws. We should be more than happy to receive any request by you for additional information on our legiti-mate interests at privacy@truma.com.

We process your personal data according to the setting in your browser. If you have not adjusted your setting manually, we process your personal data for a maximum of one year.

The personal data that we process for such purpose, which is collected as the result of the use of this service, is as follows:

• Browser information (browser type, referrer and closed sites, files displayed on our website, operating system, date and time stamp and/or clickstream data);
• Usage data (views, clicks);
• Cookie data;
• Google account information (if you are logged in);
• CSS requests;
• IP address;
• Font file requirements;
• Usage data collected;
• Referrer URL.

2.4.4 Google Tag Manager

We use Google Tag Manager. This is a solution that allows you, as the user, to manage website tags via an interface. The tool that implements the tags is itself a cookie-free do-main and does not collect any of your personal data. The tool triggers other tags, which may under some circumstances themselves collect data. Google Tag Manager does not access this data. If this has been disabled at domain or cookie level, all tracking tags im-plemented via Google Tag Manager will be disabled.

2.5 Functional cookies

2.5.1 Vimeo

We use the provider Vimeo inter alia for the integration of videos. Vimeo is operated by Vimeo, LLC, whose headquarters are at 555 West 18th Street, New York, New York 10011.

We use plug-ins provided by Vimeo on our websites. If you view the website from our online presences that features such a plug-in – for example, our media library-, a connec-tion to the Vimeo servers is established, permitting the plug-in to be displayed. This transmits the information about which of our websites you have visited to the Vimeo serv-er. If you are at the same time logged in as a member to Vimeo, Vimeo will assign this in-formation to your personal user account. If the plug-in is used, such as e.g. clicking the start button on a video, this information is also assigned to your user account. You can prevent the assignment of this information by logging out of your Vimeo user account and deleting the corresponding cookies from Vimeo before using our website.

The data is moreover processed outside the European Union (EU) or the European Eco-nomic Area (EEA). To safeguard the level of data protection in this third country, we have concluded standard data protection clauses with Vimeo.

Further information on data processing by Vimeo and its data protection notice can be found here.

We are in connection with the offering of Vimeo videos on our website the joint data con-troller jointly responsible for collecting your data and disclosing such data through trans-mission, cf. Art. 26 GDPR. Vimeo is the sole data controller as defined by the GDPR with respect to any further processing in connection with the offering of Vimeo videos on our website. The legal basis for the use of Vimeo by the data controller is your consent pursu-ant to Art. 6 (1), sentence 1) lit. a) GDPR.

We process your personal data only if this is required in order to play the videos and do not store your views.

2.5.2 YouTube Video

We integrate videos from YouTube on our website. In this case, this is a video portal from YouTube LLC., 901 Cherry Ave., 94066 San Bruno, CA, USA, (referred to as “YouTube“).

YouTube is a subsidiary of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA.

The data is moreover processed outside the European Union (EU) or the European Eco-nomic Area (EEA). To safeguard the level of data protection in this third country, we have concluded standard data protection clauses with YouTube.

We use YouTube in combination with the “extended data protection mode” function to be able to show you videos. According to YouTube, the “extended data protection mode” function means that the data specified in more detail below will only be transmitted to the YouTube server if you actually start a video.

Unless you are currently logged in to a Google service, as soon as you start playing an in-tegrated video by clicking on it, the extended data protection mode ensures that YouTube only stores cookies on your device that do not contain any personal data. These cookies can be prevented by appropriate browser settings and extensions.

Without this “extended data protection”, a connection to the YouTube server in the USA will be established as soon as you view one of our online sites on which a YouTube video is embedded.

This connection is required in order to be able to display the respective video on our online site via your internet browser. In the course of this, YouTube will collect and process at least your IP address, the date and time as well as the online site visited by you. In addi-tion, a connection to the “DoubleClick” advertising network from Google is established.

We are in connection with the offering of YouTube videos on our websites the joint data controller jointly responsible for collecting your data and disclosing such data through transmission, cf. Art. 26 GDPR. YouTube is the sole data controller as defined by the GDPR with respect to any further processing in connection with the offering of YouTube videos on our website. The legal basis for our use of YouTube is your consent pursuant to Art. 6 (1), sentence 1) lit. a) GDPR.

If you are logged in at the same time to YouTube, YouTube will assign the connection in-formation to your YouTube account. If you wish to prevent this, you must either log out of YouTube before visiting our online presence or select the appropriate settings in your YouTube user account.

For the purpose of functionality and the analysis of usage behaviour, YouTube permanent-ly stores cookies on your terminal via your internet browser. If you do not agree to this processing, you have the option of preventing the storage of cookies through a setting in your internet browser. You can find more detailed information on this in the section “Man-aging and disabling cookies in your browser and on our websites”.

Google provides further information on the collection and use of data, as well as your rights and protection options in this regard, in the data protection notice available here.

2.6 Marketing cookies

We use these cookies so that we can show you personalised and therefore relevant advertising content.

2.6.1 Pardot

This is a marketing service. We use for such purposes the analysis tool Pardot from salesforce.com Inc., The Landmark at One Market, Suite 300, San Francisco, CA 94105, USA (“Salesforce”). To permit the evaluation, the e-mails sent contain so-called “web beacons”. These are one pixel size files which are viewed by our service provider’s server when the newsletter is opened. To permit the evaluations, the following data is collected and linked to the web beacons together with your e-mail address and an individual ID:

• Browser type
• IP address
• Operating system
• Number of sites viewed.

Admittedly, this information may for technical reasons be assigned to individual newsletter recipients. It is however neither our aim, nor that of the service provider, to monitor indi-vidual users. On the contrary, for us, the evaluations serve the purpose of identifying the reading habits of our users and tailoring our content to them, or of sending our users vary-ing content in keeping with their interests.

We process your personal data based on your consent pursuant to Art. 6 (1), sentence 1, lit. a) GDPR. We process your personal data until such time as this is no longer required for the achievement of the aforementioned purpose or you have withdrawn your consent.

The data is moreover processed outside the European Union (EU) or the European Eco-nomic Area (EEA). To safeguard the level of data protection in this third country, we have concluded standard data protection clauses with Salesforce.

We have moreover concluded a “Data Processing Agreement“ with Salesforce. This is an agreement in which Salesforce undertakes to protect our users’ data, to process this data on our behalf in accordance with its data protection provisions and, in particular, not to disclose such data to third parties.

2.6.2 Facebook Pixel

This is a tracking technology offered by Meta Platforms Inc., 1601 S California Ave, Palo Alto, Cal-ifornia 94304, USA and/or, if you are based in the EU, Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, (“Facebook“) and used by other Facebook services such as e.g. Facebook Custom Audiences. Facebook Pixel allows Facebook on the one hand to identify visitors to our online offering as a target group for particular adverts (so-called “Facebook ads”). Accordingly, we use Facebook Pixel to display Facebook ads placed by us only to Facebook users who have also shown an interest in our online offering or who dis-play certain characteristics (e.g. interests in certain topics or products, as determined by the websites visited), which we submit to Facebook (so-called “custom audiences”). We also use Facebook Pixel to ensure that our Facebook ads match the potential interest of users and do not come across as annoying. With the help of Facebook Pixel, we can moreover track the effectiveness of Facebook ads for statistical and market research purposes by see-ing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

We process your personal data based on your consent pursuant to Art. 6 (1), sentence 1, lit. a) GDPR.

Facebook Pixel is directly integrated by Facebook whenever you view our websites and can store a so-called cookie on your device. If you subsequently log in to Facebook or visit Fa-cebook while logged in, the visit to our online offering will be noted in your profile. The data collected about you is anonymous as far as we are concerned and does not therefore allow us to draw conclusions about the user’s identity. However, the data is stored and processed by Facebook, and so a connection to the respective user profile can be made and used by Facebook as well as for our own market research and advertising purposes. If we transmit data to Facebook for comparison purposes, this data is encrypted locally in the browser and only then sent to Facebook via a secure https connection. This is done solely for the purpose of comparing it with the data similarly encrypted by Facebook.

We have no influence on the extent of the data collected by Facebook through the use of this tool and on the further use of such data. Please refer to Facebook’s data protection no-tice for further information on the collection and further processing of your personal data by Facebook. This is available here.

The data is moreover processed outside the European Union (EU) or the European Eco-nomic Area (EEA). To safeguard the level of data protection in this third country, we have concluded standard data protection clauses with Facebook.

We process your personal data for up to 180 days after your last interaction (this only ap-plies to cookies that were set via this website) or up until the withdrawal of your consent.

You have the option of disabling Facebook Pixel by clicking here.

2.6.3 DoubleClick Ad

The websites also use the online marketing tool DoubleClick by Google. For the European area, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, D04 E5W5, Ireland) provides all Google services. DoubleClick is used to place ads relevant to users, to improve campaign performance reports or to prevent a user from seeing the same ads many times. Google uses a cookie ID to track which ads are placed in which browser and to prevent them from being repeatedly displayed. In addition, DoubleClick may use cookie IDs to collect so-called conversions related to ad requests. This is the case, for ex-ample, when a user sees a DoubleClick ad and later views the advertiser’s website with the same browser and buys something there.

On account of the marketing tool used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent of the data collected by Google through the use of this tool and on the further use of such data.

The DoubleClick Floodlight cookies used enable us moreover to find out whether you complete certain actions on our website after you have viewed or clicked on one of our display/video ads on Google or on any other platform via DoubleClick (conversion track-ing). DoubleClick uses this cookie to find out which content you have interacted with on our websites so they may subsequently deliver targeted advertising to you.

We process your personal data based on your consent pursuant to Art. 6 (1), sentence 1, lit. a) GDPR. We process your data until such time as this is no longer required for the achievement of the aforementioned purpose or you have withdrawn your consent to this.

You can prevent your participation in this tracking process in various ways:

• by setting your browser accordingly; in particular by suppressing third-party cookies, you will not receive any ads from third-party providers;
• by disabling cookies for conversion tracking by setting your browser in such a way that cookies are blocked by the domain “www.googleadservices.com“, this setting being deleted when you delete your cookies;
• by disabling the interest-based ads of providers that are part of the „About Ads“ self-regulation campaign via this link, this setting being deleted when you delete your cookies; or
• by permanently disabling tracking in your Firefox, Internet Explorer or Google Chrome browsers via the link. We would however point out to you that you may in this case, where applicable, not be able to use the full functionality of this offering.

You can find further information on data processing by Google in the context of the use of DoubleClick by Google here and AdSense , and on data protection at Google in general here.

2.7 Analytical cookies

These technologies enable us to analyse the use of the website with a view to measuring and improving the performance.

Google Analytics

This website uses Google Analytics, a web analysis service of Google. Google can be reached through Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses “cookies”. The information (IP address, date and time of the visit, usage data, click path, app updates, browser information, device information, Ja-vaScript support, sites visited, referrer URL, downloads, Flash version, location infor-mation, purchase activity, widget interactions) about your use of our website generated by the cookies is generally transmitted to a Google server in the USA and stored there. Where IP anonymization is activated on this website, however, Google will shorten your IP ad-dress beforehand within Member States of the European Union or in other Contracting States to 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. Google will use this information on behalf of the operator of our website to evaluate your use of the website, to compile reports on website activity and to provide other services to Truma that are related to the use of the websites and of the internet. The IP address trans-mitted by your browser in the context of Google Analytics is not merged with other Google data.

Our website uses Google Analytics with the extension “anonymizeIP” to ensure that IP ad-dresses are further processed in shortened form only, to rule out the possibility of their be-ing directly referable to an individual. Thus if the data collected about you has any refer-ence to an individual, this will be immediately excluded and the personal data will there-fore be erased at once.

The use of Google Analytics is warranted pursuant to Art. 6 (1), sentence 1, lit. a) GD PR based on your consent.

We use Google Analytics to analyse and regularly improve the usage of our website.

The data is moreover processed outside the European Union (EU) or the European Eco-nomic Area (EEA). To safeguard the level of data protection in this third country, we have concluded standard data protection clauses with Google (Analytics).

We shall process your data for as long as this is required for the purpose of the data collec-tion (in this case, production of statistics and evaluation thereof).

You can prevent the storage of cookies by selecting the appropriate settings in your brows-er software; we would however point out to you that you may in this case, where applica-ble, no longer be able to use the full functionality of this website. In addition, you can pre-vent Google from collecting the data relating to your use of the website generated by the cookie (incl. your IP address) and from processing this data by downloading and installing the browser plug-in available via the following link.

You can also stop the collection of the data by setting a so-called opt-out cookie. If you wish to prevent the future collection of your data when visiting this website, please click here.

Outbrain

This website uses conversion tracking from Outbrain (Outbrain UK Ltd, 5 New Bridge Street, London, EC4V 6JA, UK). The conversion tracking pixel is set, when a user makes contact with an ad served by Outbrain. The ads integrated by Outbrain are determined based on your previously read content. The content is technically controlled and delivered automatically by Outbrain. Outbrain pixels do not contain any information with which users can be personally identified. Personal data is not stored. The pixel uses information on the device source, browser type and your IP address, which is completely anonymised by removing the last octet, to select suitable content.

The processing of the entered data is based on the user’s consent (Art. 6 para. 1 lit. a GDPR).

Further information on Outbrain’s data protection can be found here. You can object to the tracking for the display of interest-based recommendations at any time; to do so, click on the “Refuse” (opt-out) field under Outbrain’s privacy policy, available here.

Processing outside the European Union as well as the EEA cannot be excluded.

3. Truma newsletter

3.1 Signing up for the Truma newsletter

To sign up to our newsletter, we use the so-called double-opt-in method. If you have signed up for the Truma newsletter, we use your data as specified by you during the regis-tration process for the purpose of sending you the newsletter from Truma or from a com-pany in the Truma Group. The legal basis for the processing of this data is Art. 6 (1) lit. a) GDPR. Without this data, we are unable to send you the newsletter.

Your data are not disclosed to any other third parties. The only exception to this are partner companies, who are responsible for the technical implementation of the newsletter dis-patch. In such cases, however, the extent of the data transmitted is limited to the minimum required.

3.2 Users’ consent to the collection and processing of data

If you have ordered a newsletter from us, your declaration of consent reads as follows:

“Yes, I should like to receive the newsletter by e-mail from Truma Gerätetechnik GmbH & Co. KG or from companies in the Truma Group. If I no longer wish to receive information from Truma, I can withdraw this consent at any time.”

We use your e-mail address and your name to send you the newsletter and to personalise it.

To improve our newsletter, we use the e-mail analysis service of Pardot, a service of Salesforce.com, Inc.. For such purposes, we log your individual reader preferences by ana-lysing whether an e-mail was opened and which links were clicked on. We know that the e-mail was opened if the newsletter retrieves a specially prepared graphic file from the server. You can find further information on data protection at Salesforce here.

3.3 Unsubscribing from the Truma newsletter

If you no longer wish to receive our newsletter, you can click at any time on a link entitled “unsubscribe here”, which is included in all e-mails sent by Truma. In so doing, you with-draw your consent with effect for the future, albeit that this shall not affect the lawfulness of any processing done in the past on the basis of the consent.

4. Competitions

If you participate in a competition, we collect the personal data provided by you for the purposes of conducting the competition. We pass this data on to the company in the Tru-ma Group which is organising the competition.

If you win a prize, we or the company in the Truma Group organising the competition will contact you personally to complete the arrangements in relation to the prize. In case of a Facebook competition, we publish your profile name.

Participants’ personal data is processed to permit the company in the Truma Group organ-ising the competition to conduct the same and for statistical purposes by Truma Geräte-technik GmbH & Co. KG. The stored personal data is erased once it is no longer required for the purposes of conducting the competition or if the storage of such data is and/or be-comes unlawful on other statutory grounds.

It is not possible for you to participate in a competition without your data being processed.

The legal basis for the processing of your data in this case is your consent, Art. 6 (1), sen-tence 1, lit. a) GDPR.

5. Data security

We protect your personal data against the risks associated with data processing, in particu-lar unauthorised access, use or publication. For this purpose, we implement appropriate technical and organisational measures that are guided by current state of the art. The data collected from you whenever you enter data into forms included on HTML pages is trans-mitted in encrypted form (SSL – Secure Socket Layer) from your terminal to our server.

6. Data subjects’ rights

As the data subject, you have the rights set out below.

6.1 Right of objection

You have the right to withdraw the consents given by you to the processing of your per-sonal data at any time with effect for the future. Any withdrawal shall not affect the lawful-ness of the processing done on the basis of the consent up until such withdrawal.

6.2 Right of access

You have the right pursuant to Art. 15 GDPR to request information on the personal data stored to be provided free of charge. The information may at your request also be provided electronically.

6.3 Rectification, completion, erasure and restriction [of processing] of data

You have the right to request the rectification (Art. 16 GDPR), erasure (Art. 17 GDPR) or re-striction of processing (Art. 18 GDPR) of personal data concerning you. If your data is erased or locked however, you will no longer be able to use the corresponding services. Your right to erasure may be ruled out on account of statutory records retention requirements.

6.4 Right to data portability

For data which we process by automated means and the use of which you have consented to, you have the right, subject to the necessary conditions provided for in Art. 20 GDPR, to require us to provide you with such data in a machine-readable format or to transfer the data to other controllers.

6.5 Right to object

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 Art. 6 (1), sentence 1, lit. e) or lit. f) GDPR, Art. 21 GDPR. In this case, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which over-ride your interests, rights and freedoms, or unless the processing serves the establishment, exercise or defence of legal claims.

6.6 Exercising rights

You can exercise your rights by writing an informal letter to Truma Gerätetechnik GmbH & Co. KG, Data Protection, Wernher-von-Braun-Straße 12, 85640 Putzbrunn or by sending an e-mail to privacy@truma.com.

Any complaints may be referred to a data protection supervisory authority.

The supervisory authority that has jurisdiction over us in matters coming under data pro-tection laws is Der Bayerische Landesbeauftragte für den Datenschutz [Bavarian State Data Protection Officer] (BayLfD). Their contact details can be found here.

7. Data disclosure

There is no disclosure of your data unless we are required by law (e.g. request from an in-vestigating authority) or authorised (e.g. in the context of commissioned data processing) to do so. Data is transferred to third countries only where this is expressly referred to in this privacy policy. Where data is disclosed, we implement appropriate measures to ensure that the third parties maintain a reasonable level of protection for personal data.

8. Erasure and locking of data

Your data is erased once the matter raised by you has been conclusively dealt with, if you have withdrawn your consent to the processing or if the storage of such data is and/or be-comes unlawful on other statutory grounds. Once data has been erased or locked, the cor-responding services can no longer be used. Where the data is covered by statutory records retention requirements, it will instead be locked for further use.

9. Contacting us  

9.1. Nature and purpose of the processing

The data which you enter on the contact form are stored for the purposes of communicating with you individually. This requires you to enter a valid e-mail address and your name. This allows the enquiry to be allocated and subsequently responded to. The entry of additional data is optional.

Should you moreover contact us by e-mail or by phone, we process the contact details used by you to respond to your concerns.

9.2. Legal basis for the processing

Your personal data are processed on the basis of a legitimate interest (Art. 6 (1) lit. f GDPR). Our intention in providing the contact form is to enable you to have an uncomplicated means of contacting us. The data entered are stored for the purposes of dealing with the enquiry and with any possible follow-up queries. If you contact us enquiring about a quote, the data provided are processed for the completion of precontractual steps (Art. 6 (1) lit. b GDPR).

9.3. Data categories

Address details (name, e-mail address), telephone number

9.4. Recipients

The recipients of the data include internal staff of Truma Gerätetechnik GmbH & Co. KG as well as other IT service providers with whom we have concluded a contract for commissioned processing pursuant to Art. 28 GDPR.

9.5. Storage periods

Data are erased no later than 6 months after the enquiry has been dealt with. If a contractual relationship is formed, we are subject to the statutory records retention periods as provided for in the Commercial Code, and we erase your data once these periods have expired.

9.6 Statutory/contractual requirement

The provision of your personal data is optional. However we can only deal with your enquiry if you provide us with your name, your e-mail address and the reason for the enquiry.

9.7. Transfer to third countries

The data are not processed outside the European Union (EU) or the European Economic Area (EEA).

9.8. Option of objection

You have the right to object at any time to the processing of your personal data. You may inform us at any time of your withdrawal of the option to contact you as referred to at the start of this privacy notice.

9.9. Automated decision-making and profiling

As a responsible company, we waive our right to automated decision-making or profiling with respect to this data processing.

10. Data controller

Truma Gerätetechnik GmbH & Co. KG
Data Protection
Wernher-von-Braun-Straße 12
85640 Putzbrunn
Tel. +49 (0)89 4617-0
Fax +49 (0)89 4617-2116
E-Mail: privacy@truma.com

Data protection officer:
Alexander Bugl
Bugl & Kollegen GmbH
Sedanstr. 7
93055 Regensburg
Tel. +49 (0)941 630 49 789
E-Mail: kontakt@buglundkollegen.de