Privacy Policy
General information
WILKA
GmbH attaches great importance to the protection of your personal data. We
would therefore like to inform you about the personal data that we collect
during your visit to our websites (www.WILKA.de) and when you use our products
(easySmart Property Management Tool and easySmart App), how this data is used
and what configuration options are available to you. In addition, we would like to
inform you about the cookies we use, the rights to which you are entitled as a
data subject and the technical and organisational protective measures we have
taken regarding the processing of your data.
We
only process your personal data if you have given us your consent to do so or
if we are permitted to do so by law.
Our
Privacy Policy is intended to provide you with answers to the most important
questions.
1. What data is collected and
how is it used?
1.1 Websites (www.WILKA.de)
With regard to the collection and processing
of your data, the scope and type differs, depending on whether you only visit
our website to retrieve information or whether you use offers or services on
our website that require you to provide further data about yourself (for
example, when placing an order or using our contact form).
1.1.1 Personal data
You
may voluntarily provide us with your personal data for the purposes of
registration, contact enquiry (by e-mail or via a contact form), quotation
request or similar. Personal data are all information with which you can be
personally identified. This includes your name, e-mail address or telephone
number. We generally use your personal data to answer your enquiry, process
your order or provide you with access to special information or offers.
1.1.2 Non-personal data When you access our websites,
information is automatically collected in a log file that is not assigned to a
specific person; this includes
• abbreviated IP of the user’s
• date and time of access
• URL accessed
• the status of the delivery
• the size of the delivery
• the user agent used by the user
•
Your browser type, its version and the language of the browser software
• Websites that are accessed via our
site
We
use this non-personal data to determine the attractiveness of our websites and
to improve their content. We store IP addresses for a
1.2 Webshop
WILKA
or its service providers data will collect, process and use the data you enter
when ordering in the webshop for registration in the webshop and its use, as
well as for processing your orders in accordance with the provisions of the EU
General Data Protection Regulation (in particular Article 6(1)(b) of the GDPR).
WILKA and its authorised service providers are entitled to contact you for
these purposes (according to your contact details: this can be done by post,
e-mail or telephone).
Registration
and usage here means the collection, processing and use of the data you enter
for the creation and provision of your webshop user account by WILKA.
Ordering
of products and services here means the collection, processing and use of the
data you enter to process the order. This includes the use and forwarding of
data to contracted service providers, e.g. for the purpose of invoicing and
sending the goods.
Your data will also be transmitted to a credit agency, companies who will
process your chosen payment method and, if necessary, a debt collection agency,
if the transmission is necessary and WILKA is authorised to do so in accordance
with the statutory provisions.
The
service providers mentioned in this Privacy Policy (logistics companies,
service providers for on-site installation, service providers for the purposes
of billing and payment activities, telephone customer support and for the
operation of IT, sales partners, etc.) have been commissioned by WILKA in
accordance with the provisions of data protection law and are obliged to comply
with WILKA's level of data protection and data security.
As
part of this obligation, it was stipulated, among other things, that the
service providers only receive data that is required for the fulfilment of the
respective order. You can rest assured that WILKA and the service providers
commissioned in each case will collect, process and use your personal data in
strict confidence and will not pass it on to unauthorised third parties.
If
payment is made via PayPal, the data of your already existing PayPal account or
one that you create will be collected directly by PayPal. In this case, WILKA
only transmits the data required for the payment to PayPal.
WILKA
reserves the right to transfer your data to a debt collection agency if
invoices for properly rendered services and/or delivered products are not paid
even after reminders have been sent.
1.3 WILKA easySmart portal
and app (www.WILKA.de)
These
are protected applications that are only available to you after prior
registration in the portal. To enable use of the personalised and secure area,
we require various data from you during registration, which are collected and
stored and which are necessary for the use of WILKA products. (The legal basis
is Article 6(1)(b) of the GDPR). This customer data includes all information
required to identify the respective customer account, regardless of the
respective usage behaviour.
Your
customer data includes your e-mail address, your password, your surname and
first name including title, your gender, a postal address, the MAC address of
your EasySmart Hub and your usernames. Providing further data is not mandatory,
but doing so makes it easier for us to verify and identify you, for example if
you have questions and would like to use our customer service.
This
data is a prerequisite for using WILKA easySmart. We need the username and your
MAC address to be able to clearly identify you as a user. At the same time, it
is necessary to enter your valid e-mail address in the event of a password
reset.
If
you delete the user account you have created, your personal data will be
deleted accordingly. If WILKA is obliged to retain your personal data in
accordance with commercial retention periods or other overriding legal
provisions, your data will be blocked rather than deleted. To delete your user
account, please send an e-mail with the keyword "Delete user account"
stating your username, surname and first name to support@wilka.de. It is important that you
enter the data as you entered it when you registered with us.
To
use WILKA EasySmart, all data required for the smooth operation of your system
is collected.
These
include, among others:
• user agent/Bluetooth address and communication key of the door units
• IP address
• authentication information
• the assignment of the Bluetooth address of the door units to the customer
• the various software licences, activation codes and their duration
• access data for the EasySmart account
• date of account creation
• mobile phone numbers and e-mail addresses for the purpose of voluntarily set
up notifications via e-mail and push notification
• devices and device configurations used
• user-defined rules
settings
If
you make use of the customer support service, we will create tickets with your
customer data and your request in order to make your request traceable for you
and other customer support employees. If it is necessary or helpful for a more
efficient response to your enquiry, the employee will be given access to
device-specific data about your EasySmart system, such as the installed
programs, firmware, MAC address and connected devices and their firmware. In
addition, and only with your prior consent, technical customer support staff
may be granted access to the stored information (rules, usage profiles and log
files) if previous analyses and troubleshooting have been unsuccessful.
This includes:
• Access to error messages and warnings that occur
• Access to information on the connection to the WILKA easySmart platform
• Access to information on changes to device statuses (e.g. change from
"switched on" to "switched off" status for a sensor)
• Access to log data of the applications
• Access to information on time-controlled processes (e.g. time of activation
of a sensor)
At no time does an employee have access to your personal passwords
1.4 Use of cookies
To
improve your user experience, we use cookies. Cookies are small text files that
are stored locally in the cache of the website visitor's Internet browser.
Among other things, cookies make it possible to recognise the Internet browser.
The use of cookies increases the user-friendliness and security of this
website. Cookies allow us, for example, to customise a website to your
interests or to save your username so that you do not have to re-enter it each
time.
Before
you access our website for the first time and before cookies are set or read,
we provide information about the details of the cookies in the form of a cookie
banner, i.e. a display of information about the cookies used.
We
may use strictly necessary cookies without your consent after informing you of
this. The use of all other cookies, on the other hand, requires your consent to
the use of cookies, which you can also give in the cookie banner or revoke at
any time.
Below
we describe the cookies that we set or read ourselves and those that are set
and/or read by any third-party providers:
(a)
Cookies
from us that are absolutely necessary for the provision of a service you have
expressly requested:
|
|
Explanation |
Storage period |
Legal basis |
|
[PHPSESSID] |
Function: Identification of your session
on the server. It contains an alphanumeric character string. This is a first-party cookie, i.e. a
cookie that is set and read from our website. |
This cookie is stored until the end of
each session, i.e. for as long as you visit our website in your browser or
for 24 hours, depending on which event occurs first |
Section 25(2)(2) of the German
Telecommunications-Telemedia Data Protection Act (TTDSG) If a link is made with your data: Art. 6(1)(1)(f) GDPR (balancing of
interests: our interest is to be able to recognise your computer even after
switching pages within our website). |
|
[cookie_consent] |
Function: Saves your answer to the
question of whether you agree to the use of cookies on this website. It
contains the digits 0 or 1 (No or Yes). This is a first-party cookie, i.e. a
cookie that is set and read from our website. |
The cookie is stored for one year. At the
end of the year, we will ask you for your consent to this cookie again. |
Section 25(2)(2) of the German
Telecommunications-Telemedia Data Protection Act (TTDSG) If a link is made with your data: Art. 6(1)(1)(f) GDPR (balancing of
interests: our interest is to remember your decision, especially the
rejection of a cookie; this can only be done on your computer in the form of
this cookie, as we do not store any information about you that enables us to
recognise you). |
|
is set when the user selects "stay
logged in" |
Seven days |
Customer's consent |
|
|
language |
Saves the selected or system language of
the user |
One year |
Customer's consent |
(b)
(c)
|
Cookie name |
Explanation |
Storage period |
Legal basis |
|
[_ga] |
Function: This cookie is part of Google
Analytics (see below) and is used to identify a user. It contains a sequence
of digits. The cookie is a first-party cookie, i.e.
a cookie that is controlled by our website. |
The cookie is stored for two years. |
Section 25(1) TTDSG (your consent to the
cookie) If a link is made with your data: Art. 6(1)(1)(a) GDPR in conjunction with
your consent, if you have given it for the use of Google Analytics. |
|
[_gat] |
Function: This cookie is part of Google
Analytics (see below) and is used to control the website usage query rate. It
typically contains a number. The cookie is a first-party cookie, i.e.
a cookie that is controlled by our website. |
The cookie is stored for 10 minutes. |
Section 25(1) TTDSG (your consent to the
cookie) If a link is made with your data: Art. 6(1)(1)(a) GDPR in conjunction with
your consent, if you have given it for the use of Google Analytics. |
You
can determine yourself whether cookies can be set and retrieved by changing the
settings in your browser. For example, you can completely deactivate the
storage of cookies in your browser, restrict this to certain websites or
configure your browser so that it automatically notifies you as soon as a
cookie is about to be set and asks you to respond. By doing so, you can block
or delete individual cookies. This applies to both strictly necessary cookies
and all other cookies.
For
technical reasons, however, deactivating all cookies, especially the absolutely
necessary cookies, may result in some of our website’s functions being impaired
and no longer being fully displayed or available.
2. Where will my data be
processed?
Your
data will be processed in Germany. To the extent permitted by law, data
processing also takes place in other European and non-European countries.
3. How secure is my data?
To
protect your data from unauthorised access and misuse, we have taken extensive
technical and operational security precautions in accordance with German and
European law.
Your
personal data is also encrypted using
4. Will my data be passed on
to third parties?
In
principle, it is possible to use our websites without entering personal data.
For the use of certain functions and services, however, it may be necessary to
pass on the data to third parties.
Under certain circumstances, your data will only be passed on to the following
third parties in accordance with data protection regulations:
Service
provider: We engage service providers to perform certain activities on our
behalf, such as processing purchases, hosting and securing our applications,
shipping products, processing credit card payments, sending emails, sending
text messages, managing support requests, providing advertising, analysing the
use of our websites and apps, tracking the effectiveness of our marketing
campaigns and enabling users to connect with their social networks. We may
share information with these service providers about you, to the extent
required for the sole purpose of performing these services on our behalf and as
permitted by law.
Our
carefully selected service providers are commissioned within the context of
In
certain cases, we are legally obliged to transmit data to a government agency
which requests this. Beyond this, we do not pass on any data to third parties
unless you have expressly given consent.
5. Is my usage behaviour
evaluated, e.g. to improve WILKA's products?
It
is important to us to optimise the design of our website to make it as
attractive as possible for our visitors. To do this, we need to know what
content is of interest to our visitors.
To
this end, we create pseudonymised user profiles within the scope of the legal
regulations. We may analyse this data for advertising and market research
purposes, in particular to improve our products. It is not possible to draw any
direct conclusions about you personally. The profile data is not linked to any
other personal information about you.
We
use tracking technology if we have your consent to do so. This website uses
Google Analytics, Google Ads, Matomo and FullStory. The legal basis for the use of these
tracking tools is your consent (Art. 6(1)(1)(a), Art. 7 GDPR).
Below
we inform you of the procedures used on our websites and as to how you can
withdraw your consent:
5.1 Google Analytics This website uses Google
Analytics, a web analytics service provided by Google Inc, (1600 Amphitheatre
Parkway Mountain View, CA 94043, USA; "Google"). The use includes the
"Universal Analytics" operating mode. This makes it possible to
assign data, sessions and interactions across multiple devices to a
pseudonymous user ID and thereby analyse a user's activities across devices.
Google Analytics uses "cookies", which are text files placed on your
computer, to help the website analyse how users use the site (see also section
1.4).
The
information generated by the cookie about your use of this website is usually
transferred to a Google server in the USA and stored there. However, if IP
anonymisation is activated on this website, your IP address will first be
truncated by Google within member states of the European Union or in other
signatory states to the Agreement on the European Economic Area. Only in
exceptional cases will the full IP address be transferred to a Google server in
the USA and truncated there.
The
IP address transmitted by your browser as part of Google Analytics will not be
merged with other Google data.
As
part of the data processing agreement that we as the website operator have
concluded with Google Inc., Google Inc. uses the information collected to
analyse website usage in order to compile reports on website activity and to
provide the website operator with other services relating to website and
Internet usage. The data collected by Google on our behalf is used to analyse
the use of our online offering by individual users to improve our online
offering. The data we send and that is linked to cookies, user identifiers
(e.g. user ID) or advertising IDs is automatically deleted after
You
can refuse the use of cookies by selecting the appropriate settings on your
browser, however please note that if you do this you may not be able to use the
full functionality of this website. You can also prevent the collection of data
generated by the cookie and related to your use of the website, (including your
IP address) as well as the the processing of this data by Google, by
downloading and installing this browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de). Opt-out cookies prevent
collection of your data when you visit this website in the future. To prevent
Universal Analytics from collecting data across different devices, you must opt
out on all systems used. If you click here, the opt-out cookie will be set:
Google
Analytics activated
5.2 Google Ads
The
following Google Ads functions are used on this website:
•
Remarketing
• Interest categories
• Similar target groups
• Other types of interest-based advertising
We
use these Google Ads features on third party websites to retarget visitors to
this website or internet users with specific interest profiles based on their
internet usage. We do not collect any personal information with our cookies,
remarketing lists or other anonymous IDs.
5.3 Matomo
In
some of our products, data is collected and stored using the web analysis
service software Matomo (www.matomo.org), a service of the provider InnoCraft
Ltd, 150 Willis St, 6011 Wellington, New Zealand, ("Matomo") on the
basis of our legitimate interest in the statistical analysis of user behaviour
for optimisation and marketing purposes in accordance with Art. 6(1)(f) GDPR.
Pseudonymised user profiles can be created and evaluated from this data for the
same purpose.
Cookies
can be used for this purpose. The data collected using Matomo technology
(including your pseudonymised IP address) is processed on our servers.
The
information generated by the cookie in the pseudonymised user profile is not
used to personally identify the visitor to this website and is not merged with
personal data about the bearer of the pseudonym.
If
you do not consent to the storage and analysis of this data from your visit,
you can object to the storage and use of this data at any time by clicking
below. In this case, an opt-out cookie is stored in your browser, which means
that Matomo does not collect any session data. Please note that completely
deleting your cookies means that the opt-out cookie will also be deleted and
may have to be reactivated by you.
Matomo
tracking activated
5.4 FullStory
FullStory
records user behaviour in our online shop. The recording of visitor sessions
enables us to analyse them and subsequently improve the website experience for
visitors. Fullstory stores and collects data in anonymised form using cookies.
Tracking (i.e. the collection of data generated by the cookie and related to
the use of the website) can be deactivated at any time. Please follow the
instructions at https://www.fullstory.com/optout.
If
you have not given or revoked your consent for Google Analytics, Google Ads,
Matomo and FullStory, no further processing of your tracking data will take
place. However, the withdrawal of consent shall not affect the lawfulness of
processing based on consent before its withdrawal.
6. How long will my data be
stored?
We will only store your personal data for the period necessary to fulfil the purposes set out in this Privacy Notice for which the personal data was collected, unless longer storage is required or permitted by law.
Data storage
is necessary, among other things, for the performance and execution of the
contract, including the defence and enforcement of civil law claims. In
individual cases, such claims may only become time-barred after 30 years.
Retention obligations and the resulting retention periods also exist because of
tax law, money laundering law, commercial law, tax law and other statutory
provisions. The retention/documentation periods specified there are six to ten
years. To avoid violating legal regulations or losing the possibility of
enforcing a claim or defending ourselves against such a claim, we reserve the
right to delete the data only after the expiry of the last period in which data
storage is legitimate. All technical access data is stored until you delete the
cookies in your browser.
7. What rights do I have with
regard to the handling of my data?
As a
user, you have the following rights:
●
free
information about which personal data has been stored about you (Art. 15 GDPR);
●
deletion
of your personal data (Art. 17 GDPR);
●
correction
of incorrect data (Art. 16 GDPR);
●
objection
to the processing of your personal data
(Art. 21 GDPR);
●
right
to withdraw consent given for data processing (Art. 7 (3) GDPR);
●
restriction
of processing (Art. 18 GDPR);
●
right
to lodge a complaint with the competent supervisory authority (Art. 77 GDPR).
Please
note the following when deleting data: The right to deletion of data only
exists insofar as this does not conflict with a legal obligation to retain
data. The data we store will be deleted as soon as it is no longer required for
its intended purpose and any statutory retention periods have expired. If
deletion cannot be carried out because the data is required for authorised
legal purposes, data processing will be restricted. In this case, the data will
be blocked and not processed for other purposes.
You have at
any time the right to object, on grounds relating to your particular situation,
to processing of your personal data that is based on Article 6(1)(f) GDPR (data
processing based on a legitimate interest). If you object, we will no longer
process your personal data unless we can demonstrate compelling legitimate
grounds for the processing that override your interests, rights and freedoms,
or the processing serves the establishment, exercise or defence of legal
claims.
8. Who can I contact if I
have questions about data protection at WILKA?
If you have any questions, comments or wish to assert your aforementioned
rights, please contact us by e-mail at datenschutz@wilka.de.
9. Data controller
The controller for
the data processing of your personal data within the meaning of Art. 4(7) GDPR
and at the same time provider of telemedia within the meaning of the
Telecommunications-Telemedia Data Protection Act (TTDSG):
WILKA
Schließtechnik GmbH
Represented by the
Managing Director: Robert Schlieper
Mettmannerstr.58-
64
42551 Velbert,
Germany
Germany
Tel.: 02051/20810
Fax: 02051/2081151
E-mail:
info(at)wilka.de
Website: https://www.wilka.de