Anrui Lighting GmbH is committed to a policy of protecting the rights and privacy of individuals, in accordance with the General Data Protection Regulation (GDPR).
GDPR contains provisions that the organisation will need to be aware of as data controllers, including provisions intended to enhance the protection of personal data.
GDPR requires that:
Anrui Lighting GmbH needs to process certain information about its staff, customer, suppliers, and other individuals with whom it has a relationship for various purposes such as, but not limited to:
- The recruitment and payment of staff.
- The day to day purchasing and sales of goods.
- The making or receiving of payments as part of day to day trading.
- To contact you about a submission or request for information you have made.
- In relation to any correspondence we receive from you or any comment or complaint you make about our products or services.
- Complying with legal obligations and government including local government.
To comply with various legal obligations, including the obligations imposed on it by GDPR, Anrui Lighting GmbH must ensure that all these information about individuals is collected and used fairly, stored safely and securely, and not disclosed to any third party unlawfully.
Compliance
All members of staff are responsible for ensuring that any personal information which they hold is kept securely and not disclosed to any unauthorised third parties. Anrui Lighting GmbH will ensure that all personal information is accessible only to those who have a valid reason for using it. Anrui Lighting GmbH will have in place appropriate security measures to protect information physically and electronically.
As a matter of best practice, other agencies and individuals working with Anrui Lighting GmbH and who have access to personal information, will be expected to read and comply with this policy. It is expected that departments who are responsible for dealing with external bodies will take the responsibility for ensuring that such bodies sign a contract, which among other things will include an agreement to abide by this policy.
Consent as a basis for processing information although not always necessary is the best way to ensure that information is collected and processed in an open and transparent manner. Consent is especially important when Anrui Lighting GmbH is processing any sensitive information, as defined by the legislation. Anrui Lighting GmbH understands consent to mean that the individual has been fully informed of the intended processing and has signified their agreement.
Anrui Lighting GmbH also confirms consent cannot be inferred from the non-response to communication.
This policy will be updated as necessary to reflect best practice in information management, security, and control and to ensure compliance with any changes or amendments to the GDPR and other relevant legislation.
This policy applies to all staff of Anrui Lighting GmbH. Any breach of this policy or of the Regulation itself will be considered an offence and the Company’s disciplinary procedures may be invoked.
Responsibility
Responsibilities under GDPR
Anrui Lighting GmbH will be the ‘data controller’ under the terms of the legislation. This means it is ultimately responsible for controlling the use and processing of personal data. The company appoints a Data Protection Officer (DPO) for each site who is available to address any concerns regarding the data held by the Company and how it is processed, held, and used.
The Senior Management Team is responsible for all day-to-day data protection matters and will be responsible for ensuring that all members of staff and relevant individuals abide by this policy, and for developing and encouraging good information handling within the company.
The Senior Management Team is also responsible for ensuring that the Company policy is kept up to date. Details of the Anrui Lighting GmbH policy can also be found on their website. Compliance with the legislation is the personal responsibility of all staff at Anrui Lighting GmbH who process personal information.
Individuals who provide personal data to Anrui Lighting GmbH are responsible for ensuring that the information is accurate and up-to-date.
Data Protection Principles
To comply with its obligations, Anrui Lighting GmbH undertakes to adhere to the eight principles:
1) Process personal data fairly and lawfully (the right to be informed). Anrui Lighting GmbH will make all reasonable efforts to ensure that individuals who are the focus of personal Identifying information (PII) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant.
The Company will ensure that the data is adequate, relevant and not excessive in relation to the purpose for which it is processed. Anrui Lighting GmbH will not seek to collect any personal data, which is not strictly necessary for the purpose for which it obtained
The Company will process the data for the specific and lawful purpose for which it was collected and not further process the data in a manner incompatible with this purpose. The Company will ensure that the reason for which it collected the data originally is the only reason for which it processes that data, unless the individual consents to any additional processing before it takes place.
Anrui Lighting GmbH undertakes not to disclose personal data to unauthorised third parties. Legitimate disclosures may occur in the following instances:
- Where the individual has given their consent to the disclosure.
- The disclosure is required for the performance of a contract.
There are other instances when the legislation permits disclosure without the consent of the individual
CCTV. There are some CCTV systems operating within Anrui Lighting GmbH for the purpose of protecting staff and property. Anrui Lighting GmbH will only process personal data obtained by the CCTV system in a manner, which ensures compliance with the legislation.
2) Subject Access Rights (SARs – the right of access) Individuals have a right to access any personal data relating to them, which is held by Anrui Lighting GmbH. We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information about you on our files.
Any individual wishing to exercise this right should apply in writing to the Data Protection Officer.
Any member of staff receiving a SAR should forward this to the Data Protection Officer.
To ensure security we require you to prove your identity with 2 pieces of approved identification before any SARs request can be released.
3) Keep personal data accurate (the right to rectification). It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify the Company if a change in circumstances mean that the data needs to be updated. It is the responsibility of the Company to ensure that any notification regarding the change is noted and acted on.
4) Only keep personal data for as long as is necessary (the right to erasure). Anrui Lighting GmbH undertakes not to retain personal data for longer than is necessary to ensure compliance with GDPR legislation, and other statutory requirements.
This means Anrui Lighting GmbH will undertake a periodic review of the information held and implement a purge process as required. Anrui Lighting GmbH will dispose of any personal data in a way that protects the rights and privacy of the individual concerned.
5) Restrict the process of personal information. Individuals have the right to prevent processing of information while that information is subject to corrective action. At any time a person can request to know what information is stored and request action to rectify, block, erase or destroy inaccurate information while that process is underway.
6) Ensure that no personal data is transferred to a country or a territory outside the European Economic Area (EEA) unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. Anrui Lighting GmbH will not transfer data to such territories without the explicit consent of the individual. This also applies to publishing information on the Internet – because transfer of data can include placing data on a website that can be accessed from outside the EEA – so Anrui Lighting GmbH will always seek the consent of individuals before placing any personal data (including photographs) on its website. If Anrui Lighting GmbH collects personal data in any form via its website, it will provide a clear and detailed privacy statement prominently on the website, and wherever else personal data is collected.
7) The right to object allows an individual to prevent processing for purposes of:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).
- direct marketing (including profiling).
- processing for purposes of scientific/historical research and statistics.
8) Rights in relation to automated decision making and profiling.
- automated individual decision-making (making a decision solely by automated means without any human involvement)
- profiling (automated processing of personal data to evaluate certain things about an individual).
Incident Response
GDPR introduces a duty to report certain types of personal data breach to the relevant supervisory authority. Where feasible Anrui Lighting GmbH will do this within 72 hours of becoming aware of the breach.
If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, Anrui Lighting GmbH will also inform those individuals without undue delay.
This policy has been updated to reflect the General Data Protection Regulation (GDPR) 25th May 2018.
Please view the European Union’s website (https://europa.eu/youreurope/business/dealing-with-customers/data-protection/data-protection-gdpr/) which provides further details and guidance.
For help or advice on any data protection or freedom of information issues, please do not hesitate to contact info@anrui-lighting.com.
Plug-ins and Tools
YouTube with expanded data protection integration
Our website uses plug-ins of the YouTube platform, which is being operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.
As soon as you start to play a YouTube video on our website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.
Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device. With the assistance of these cookies, YouTube will be able to obtain information about our website visitor. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud. These cookies will stay on your device until you delete them.
Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.
The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest.
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.
Google Maps
Via an API, this website uses the mapping service Google Maps. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer.
We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6 Sect. 1 lit. f GDPR.
For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.
Our social media appearances
Data processing through social networks
We maintain publicly available profiles in social networks. The individual social networks we use can be found below.
Social networks such as Facebook, Google+ etc. can generally analyse your user behaviour comprehensively if you visit their website or a website with integrated social media content (e.g. like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered. In detail:
If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.
Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to.
Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.
Legal basis
Our social media appearances should ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6 (1) lit. f GDPR. The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6 (1) (a) GDPR).
Responsibility and assertion of rights
If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g. Facebook).
Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.
Storage time
The data collected directly from us via the social media presence will be deleted from our systems as soon as the purpose for their storage lapses, you ask us to delete it, you revoke your consent to the storage or the purpose for the data storage lapses. Stored cookies remain on your device until you delete them. Mandatory statutory provisions – in particular, retention periods – remain unaffected.
We have no control over the storage duration of your data that are stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g. in their privacy policy, see below).
Individual social networks
We have a profile on Facebook. The provider is Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. Facebook is certified under the EU-US Privacy Shield.
You can customise your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads.
Details can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/.
We use the short message service Twitter. The provider is Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States. Twitter is certified under the EU-US Privacy Shield.
You can customise your Twitter privacy settings in your user account. Click on the following link and log in: https://twitter.com/personalization. For details, see the Twitter Privacy Policy: https://twitter.com/privacy.
We have a profile on Instagram. The provider is Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. For details on how they handle your personal information, see the Instagram Privacy Policy: https://help.instagram.com/519522125107875.
We have a profile on XING. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Details on their handling of your personal data can be found in the XING Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
We have a LinkedIn profile. The provider is the LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn is certified under the EU-US Privacy Shield. LinkedIn uses advertising cookies.
If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
For details on how they handle your personal information, please refer to LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.