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Privacy Policy

Data protection information of Otto (GmbH & Co KG) / OTTO Retail Media, as of: March 2021

With about 55 employees and headquartered in Hamburg, OTTO Retail Media is part of OTTO (GmbH & Co KG).

The following information on data protection informs you about the processing of personal data by OTTO (GmbH & Co. KG), OTTO Retail Media Division in accordance with the GDPR and the German Federal Data Protection Act (Bundesdatenschutzgesetz (BDSG 2018).

Please read our data protection information carefully. Should you have any questions or comments concerning our data protection information, please feel free to contact us at datenschutzbeauftragter@ottogroup.com.

Content

    1. Name and contact information of the controller for processing
    2. Contact data of the data protection officer
    3. Purposes of data processing, legal bases and legitimate interests pursued by the controller or a third party as well as recipient categories
      3.1 Accessing our websites/log files
      3.2 Newsletter
      3.3 Processor
      3.4 Contact
    4. Online presence and website optimization (by using cookies) including consents
      4.1 Cookies – general information and consent requirement
      4.2 Intervention option / browser settings
      4.3 Consents to the use of individual online services / the collection of tracking data
      4.3.1 Consent to processing by HubSpot
    5. Recipients outside the EU
    6. Period of data storage
    7. Your rights
      7.1 General information
      7.2 Your rights in detail
    8. Right to object

1. Name and contact information of the controller for processing

This data protection information applies to data processing by

Otto (GmbH & Co KG)
OTTO Retail Media
Werner-Otto-Straße 1-7
22179 Hamburg
Germany

Represented by: Alexander Birken (Chairman), Dr. Marcus Ackermann, Sergio Bucher, Sebastian Klauke, Petra Scharner-Wolff, Kay Schiebur

Phone: 040 – 3603 3603

E-Mail

for the website  www.ottoretail.media and all sub-domains

2. Contact data of the data protection officer

You can reach the controller’s company data protection officer(s) under

Otto (GmbH & Co KG)
– Datenschutzbeauftragte/r –
Werner-Otto-Straße 1-7
22179 Germany

E-mail: datenschutzbeauftragter@ottogroup.com

3. Purposes of data processing, legal bases and legitimate interests pursued by the controller or a third party as well as recipient categories

3.1. Accessing our websites/log files

Every time websites/applications are accessed, information is sent to the server of our website/application by the internet browser of your end device and stored temporarily in so-called log files. The data sets stored in this way contain the following data which will be stored until they are erased automatically: date and time of access, name of accessed site, IP address of the requesting device, referrer URL (origin URL from which you accessed our website), the data volume transmitted, loading time as well as product and version information of the browser used and the name of your access provider.

The legal basis for processing the IP address is Article 6(1)(f) GDPR. Our legitimate interest results from

  • ensuring a trouble-free establishment of a connection,
  • ensuring convenient use of our website/application,
  • analyzing system security and stability.

No immediate inference as to your identity is possible from the information, nor do we draw any such inference.

The data is stored and automatically erased when the aforementioned purposes have been achieved. The standard periods for erasure are determined by the criterion of necessity.

3.2 Newsletter

Via our websites/ applications, we offer you the opportunity to sign up for our newsletter. To make sure that no error occurred when the e-mail address was entered, we use the so-called double opt-in method (DOI method): After you entered your e-mail address in the registration field, we will send you a confirmation link to the address you entered.

Your e-mail address will not be included in our distribution list for sending our newsletter until you clicked on this confirmation link. The legal basis for this data processing is Article 6(1)(a) GDPR.

Notice of right of withdrawal

You may withdraw your consent at any time with future effect by sending a message to  this e-mail adress or using the cancellation option at the end of each newsletter.

3.3 Processor

This website deploys processors in the course of processing your data. A processor is a natural or legal person, agency, public authority, or any other body that processes personal data on behalf of the controller for data processing. Processors do not use the data for their own purposes, but process the data exclusively for the controller.

3.4 Contact

You may contact us in several ways: via e-mail, by phone, or by mail. When you contact us, we will use the personal data which you make available to us voluntarily within this context exclusively for the purpose of getting in touch with you and being able to process your request. Article 6(1)(a), Article 6(1)(b), Article 6(1)(c), and Article 6(1)(f) GDPR are the legal basis for this data processing.

4. Online presence and website optimization (by using cookies) including consents

Brief summary

OTTO Retail Media collects data about the behavior of users on its website. This also includes, among others, the accessing of individual sub-pages. For this purpose, OTTO Retail Media may, among others, set cookies in the browser used by the respective user. The collection of tracking data is only permitted with your prior consent. You may give such consent by clicking the “Accept” button on the “cookie banner” displayed on ottoretail.media. However, no consent is required for the processing of such tracking data which is necessary for operating the ottoretail.media website. If you want to erase individual cookies set in your browser or find out which service providers / vendors have set cookies in your browser, you can do so or find it out via a “Preference Manager”. You can access one, for instance, under www.youronlinechoices.com. In addition, you have the option of setting up your browser in such a way that it prevents the setting of cookies or only allows certain types of cookies to be set. For details about the option to change the settings in common browser types (including Google Chrome, Firefox), please go to Section 4.2 of this data protection notice.

4.1 Cookies – general information and consent requirement

In accordance with legal requirements, the storing of information on end devices (desktops, smartphones, tablets and the like) – for instance, by setting cookies – and retrieving information from end devices (tracking) is only permitted with your prior consent. However, such consent is not required if such storage /retrieval is necessary for operating the website. These necessities refer to ensuring the functionalities and guaranteeing system security.

You have no right to object with regard to data processing which is necessary for operating the website.

You can use the ottoretail.media website without data from your end device being retrieved from or stored on your end device for such purposes which are not required for operating the ottoretail.media website. For this reason, only “basic tracking” is activated when the ottoretail.media website is used – insofar as no further consent is given on your part.

4.2 Intervention options / browser settings

You can of course set up your browser so that it does not store certain cookies on your end device. The Help function in the menu bar of most web browsers explains how you prevent your browser from accepting new cookies, how you set your browser to notify you when you receive a new cookie and also how you can erase all cookies already received and block any additional ones.

 

To do so, please take the following steps:

In Internet Explorer:

  1. In the “Tools” menu, select “Options”.
  2. Click the “Privacy” tab.
  3. Now you can select the security settings for the internet zone. Here you can see whether and what cookies should be accepted or blocked.
  4. Confirm your selection by clicking “OK”.

In Firefox:

  1. Click the Menu button and select “Options”.
  2. Click “Privacy”.
  3. From the drop-down menu, click the “Create according to user-defined settings”.

In Google Chrome:

  1. Click the Chrome menu button in the top right corner of the browser.
  2. Select “Settings”.
  3. Click “Show Advanced Settings”. [Click “Privacy and security”].
  4. Under “Privacy”, click “Content settings”. [Click “Cookies and other site data”].
  5. Under “Cookies”, you can select the following settings for cookies: [Here you can select the following settings for cookies:]:
  • clear Cookies
  • Block cookies by default [“Block all cookies (not recommended)”]
  • Clear cookies and website data by default on exiting the browser [Clear cookies and site data when you quit Chrome]
  • Allow exceptions for cookies from certain websites or domains

If you want to erase individual cookies set in your browser or find out which service providers / vendors have set cookies in your browser, you can do this or find it out via a “Preference Manager”. You can access one, for instance, under www.youronlinechoices.com

4.3 Consents to the use of individual online services / the collection of tracking data

As explained already in Section 4 of this data protection notice, OTTO Retail Media collects and processes tracking data, partly on the basis of consent. You give this consent by clicking the “Accept” button that is reproduced on the ottoretail.media website in a banner which is linked to these consent texts. By clicking the “Accept” button, you give your consent for OTTO Retail Media to store data on your end device (e.g. by setting cookies) or to retrieve data from your end device. By clicking the “Accept” button, you further give your consent to the use of certain advertising functionalities of third-party providers the use of which is in itself subject to consent.

All data processing which is covered by the consent you gave by clicking the “Accept” button has the same purpose, namely that of “advertising”.

Withdrawal of all consents
By clicking here, you can withdraw any consent you have given us when you clicked on the “Accept” button reproduced in the banner.

4.3.1 Consent to processing by HubSpot

A pixel of HubSpot, Inc. is embedded in this website. This pixel is used to collect information about the use of this website by Otto (GmbH & Co KG) as controller. The following data is collected:

  • Time of visit
  • Number of sessions
  • Domain
  • User token
  • ID
  • Page views.

The purpose of data processing is to analyze the visit to our website and – if you subscribed to our newsletter – to link your visit to our website to your data. HubSpot processes the data exclusively as a processor and therefore does not use it for its own purposes. The legal basis for the data processing described above is Article 6(1)(a) GDPR (consent).

5. Recipients outside the EU

With the exception of the processing in regard to which we inform of the possibility of transferring data to recipients based outside the EU in this data protection notice, we do not share your data with any recipients based outside the European Union or the European Economic Area. The data is transferred based on so-called standard contractual clauses of the EU commission.

6. Period of data storage

How long the data collected about you will be stored depends on the purpose for which we process the data. Storage will continue as long as it is necessary for achieving the intended purpose. Insofar as we have to store certain data categories for a specific period of time due to legal obligations (e.g. obligations under tax law), storage of the data after their storage is no longer necessary for achieving the respective purpose will continue exclusively for the purpose of meeting the legal obligation. In these cases, access to this data is blocked.

Examples of storage periods

  • Data in the customer account: indefinite storage of master data in case of customer activity. The customer account will be erased after 3 years of inactivity.
  • Data in the Group’s internal information system: generally 3 years. Information about outstanding demands for payment will be deleted when these have been met. Insofar as they have not been met, continuation of storage will be reviewed after 4 years.
  • Use of data for marketing purposes (without tracking): 3 years.
  • Consents: permanent storage as long as the consents are used continuously (e.g. permanent sending of e-mail newsletters).
  • Information about the use of data for third-party promotional purposes for the purpose of providing information: 2 years.
  • Tracking data: 2 years.
  • Data for the purpose of implementing (advertising) objections: indefinite storage.

7. Your rights

7.1 General information

In connection with the processing of personal data by us, you are entitled to rights of the data subject. You have, for instance, the right to assert access to information regarding your data stored by us. You may also withdraw consents you gave us and object to individual instances of data processing. You also have the right to rectification of incorrect data and may demand that we transfer certain data to you in a common electronic format. Furthermore, you have the right to erasure of your data stored with us. In this regard, please note that, for legal reasons, we may be obligated to continue storing the data despite assertion of your right to erasure of the data. Furthermore, we may, in individual constellations, have an interest in continuing storage of your data that outweighs your interest in their erasure (e.g. if we still have outstanding receivables against you).

7.2 Your rights in detail

Besides the right to withdraw the consents you have given us, you are entitled to the following additional rights provided that the respective legal prerequisites have been met:

  • the right of access to your personal data stored with us (Article 15 GDPR), in particular, you can obtain access to information on the purposes of the processing, the category of the personal data concerned, the categories of recipients to whom your data were or are being disclosed, the envisaged period of storage, and the source of your data, insofar as these were not collected directly from you,
  • the right to rectification of incorrect data or completion of correct data (Article 16 GDPR),
  • the right to erasure of your data stored with us (Article 17 GDPR), unless we have to comply with statutory or contractual retention periods or other legal duties or rights concerning further storage,
  • the right to restriction of processing of your data (Article 18 GDPR), to the extent that the accuracy of the data is contested by you, that the processing is unlawful, but you oppose its erasure; the controller no longer needs the data, but you require the data for the establishment, exercise, or defense of legal claims, or have objected to the processing pursuant to Article 21 GDPR,
  • the right to data portability pursuant to Article 20 GDPR, i.e. the right to receive selected data stored with us about you transmitted in a commonly used, machine-readable format, or to request transmission to another controller,
  • the right to lodge a complaint with a supervisory authority. For this purpose, you may usually turn to the supervisory authority at your habitual residence or place of work, or where our company seat is located.

You may assert the aforementioned rights to which you are entitled against us under datenschutzauskunft@otto.de. You may assert your right to data portability under datenschutzauskunft@otto.de.

8. Right to object

Under the conditions of Article 21(1) GDPR, it is possible to object to the data processing on grounds relating to the data subject’s particular situation.

The above general right to object applies to all processing purposes described in this data protection information which are processed based on Article 6(1)(f) GDPR.

Unlike the special right to object directed at data processing for promotional purposes, we are obligated under the GDPR to implement such a general right to object only if you give us reasons of overriding importance (e.g. a possible danger to life or health).