PRIVACY POLICY
STAEDTLER-Mars Limited (referred to as STAEDTLER “we,” “us,” or “our”) is a European manufacturer and supplier of writing, painting, drawing, and creative products based in Germany.
We’ve drafted this Privacy Policy to inform you on how we handle the Personal Information of our visitors (“you
”) to our website located at www.staedtler.ca/en/ (the “
Site”). This Privacy Policy outlines the legal basis on which we process your Personal Information. Please contact our Data Protection Officer if you have any privacy questions.Please read through this Privacy Policy carefully so that you may decide to consent, refuse to consent, or later withdraw your consent to the collection and use of your Personal Information.
This Privacy Policy is effective: April 1, 2022
1. Your Consent
(a) Providing Consent
(b) Refusing Consent
(c) Withdrawing Consent
2. What is Personal Information?
3. How and Why We Collect Personal Information?
(a) Marketing Communications
(b) Contests
(c) Storage of Access Data
(d) Cookies
(a) Facebook Visitor Action Pixels
(b) Site Usage Information
(c) Third Party Collection of your Personal Information
4. How we share your Personal Information
5. Anonymized Data
6. How We Protect Your Information
7. Your Privacy Rights on this Site
8. Data Retention and Your Rights to Access and Correction
9. We May Change this Privacy Policy
10. Data Privacy Contact
1. Your Consent
(a) Providing Consent
By using our Site, you agree to the collection and use of Personal Information in accordance with this Privacy Policy.
(b) Refusing Consent
In the event you refuse to the collection and use of Personal Information in accordance with this Privacy Policy, please leave our Site immediately.
(c) Withdrawing Consent
Except as required or permitted by applicable data protection laws, we will not use or disclose your Personal Information for any purpose for which you refuse us consent or later withdraw your consent. You may at any time withdraw your consent with future effect and without affecting the lawfulness of the processing of your Personal Information based on your previous consent.
If you withdraw consent, you agree that despite this withdrawal we may continue to use the Personal Information previously provided to us (i) to the extent that we are contractually obligated to do so, (ii) to the extent necessary to enforce any contractual obligations you may have with us, and (iii) for any other legitimate purpose (including fraud prevention) permitted by applicable data protection laws.
If you withdraw your consent to use and disclose this information, we may no longer be able to respond to you when you contact us. For example, if you contact us regarding our product’s warranty and you withdraw your consent, then we will not be able to assist you.
2. What is Personal Information?
“Personal Information” is broadly defined to include all information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. Personal Information could be as simple and direct as your name, but it could also be less explicit like how a certain individual interacted with a website or an advertisement. Personal Information includes “Personal Information” as defined in PIPEDA.
3. How and Why We Collect Personal Information
The Personal Information that we collect varies depending on the nature of and reason for your interaction with us. We collect Personal Information:
- when you communicate with us by our Site’s contact form, email, or by phone for inquiries.
- when you participate in our contests—please see our Contests section below for more information;
- when you engage with our online communities or advertising, including when you click on advertisements or interact with our social media pages;
- when you access and use our Site, we store data about your access in a protocol file on the server of our Site provider. Please see our Storage of Access Data section below for more information; and,
- when we leverage our Site’s cookies and tracking pixels in order to better learn how visitors including you use our Site in order to improve it. Please see our Cookie section below for more information.
(a) Marketing Communications
Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information (referred to as “Commercial Electronic Messages, or “CEM”s). You may withdraw your consent to the receipt of CEMs at any time. This will not affect the processing of your Personal Information in relation to our communications.
In addition, if you open the marketing communication or click a link in it, this interaction will be logged by our server (date, time, email address). This data serves statistical purposes and will not be combined into personal usage profiles.
(b) Contests
When you sign up for our contests, we will use your Personal Information to only process and perform the contests. If you do not explicitly consent for any further use, your Personal Information will be deleted after the lottery has been processed. For more information, see the respective participation conditions for our contests.
(c) Storage of Access Data
Every time you access our Site, you consent to data about your access being stored on a protocol file on the server of our Site.
This data consists of your IP address, date and time of the query, name of the file your computer requested from our server, file name from which the file was requested, the transferred data volume and access status, a description of your web browser and operating system, and the name of your internet service provider.
This data is collected for technical reasons to (i) ensure a stable connection between our server and your computer, (ii) ensure you can use the website comfortably, and (iii) evaluate our system’s safety and stability. We evaluate this data only for statistical purposes.
(d) Cookies
A cookie is a small text file that is stored on your computer to help us make your visit to our Site more “user-friendly.” Cookies provide us with information about your use of the Site that can help us improve the Site and your experience with it.
Our Site uses “cookies” for statistics and marketing purposes. Our Site also uses Google Services. You may use our website without using cookies as well, but there may be restrictions on what you can and can’t do.
- Statistics cookies record information anonymously. This information helps us to understand how our visitors use our website. We use Google Analytics cookies, to which we explain in our Google Analytics section below.
- Marketing cookies are for advertising purposes where a third-party provider collects information about your use of our website and aggregates it into a user profile (association with interests or other characteristics based on statistical research). This user profile is assigned to an interest group to which advertising is then played out across websites in a target-group-oriented manner. For further information, please refer to our Google Remarketing and Facebook Visitor Action Pixels sections.
If you wish to disable the use of cookies, you may turn off the cookie function on your browser. In addition, you may also delete all cookies currently on your computer. Instructions can be found at https://www.aboutcookies.org/. However, this will impact all websites.
(i) Google Analytics
We use the Google Analytics tracking tool from Google on our website. The Analytics tool uses cookies and JavaScript functions to record, store, and evaluate your interactions with our website. The following data is collected from you: anonymized IP address, Google ID, the Site requested from your computer, parts of the Site previously requested, time spent on the Site, and frequency of requests to the Site.
Furthermore, this website uses Google Analytics reports to measure performance based on demographic characteristics (e.g., age and gender) and interests. The data on demographic characteristics and interests are determined via the third-party cookie of Google’s subsidiary DoubleClick. We evaluate demographic characteristics anonymously and do not combine them with personal data.
Your data is transmitted to Google and processed there for Google’s own purposes. If you have an account with Google, Google may also merge our account data with data obtained from Google Analytics tracking.
We retain Google Analytics data for 2 years.
(i) Google Remarketing
Our websites use Google remarketing, a web display service of Google, which permits placement of interest-related advertisements by making it possible to contact users who visited or used websites and offers with matching advertising offers on pages of the Google partner network. Google uses marketing cookies for this service in order to recognize your browser when you visit any other websites and in order to target you with interest-related advertisements.
Please note that Google Remarketing is a service of an independent third party (Google), and we are unable to influence Google’s data processing practices. Please see Google’s privacy policy: https://policies.google.com/privacy?gl=ca
(a) Facebook Visitor Action Pixels
The Visitor Action Pixel is a Facebook service and permits the tracking of the behaviour of users after they click a Facebook advertisement, which is called a “conversion.” Upon conversion, the Visitor Action pixel transmits the user’s IP address to Facebook, which is then saved and processed by Facebook for the purpose of conversion measurement. Facebook then sends STAEDTLER reports on conversion measurement in an anonymized format from Facebook.
Please note that Facebook may link the transmitted data to other Personal Information it may have about the user and may use the information for its own further purposes. We cannot influence the Facebook’s data processing practices. For more information, please see Facebook’s privacy policy www.facebook.com/about/privacy/.
(b) Site Usage Information
This Site gathers traffic patterns, usage information, and other aggregated data in order to evaluate our visitors’ preferences and the effectiveness of our Site. This aggregate usage data does not identify you individually. We may share anonymous, aggregated statistics about visitors to our Site with others outside our company, or we may allow third parties to collect aggregate data through our Site.
(c) Third Party Collection of your Personal Information
Our Site may integrate content from third party providers (“Providers”). For example, consider Google Maps, RSS feeds, or graphics from other websites. Note well that when this happens, the Providers use your IP address to ensure they are sending such content (i.e., data) to the proper browser. Think of your IP address as a mailing address to which a provider can mail you data. We strive to only use Providers that use your IP address for the strict purpose of sending you that data. We try to avoid Providers that also store your IP address for other purposes. However, we cannot guarantee that the Providers will not store and use your IP address for other purposes. Please consult the relevant Provider’s Privacy policy.
(i) Social Media Plugins
Our website uses the social media plugins (“Plugins”) of the following social networks: Facebook, Google+, Pinterest, and Twitter. These services are offered by the companies Facebook Inc., Google Inc., Pinterest, Inc., and Twitter Inc.
Facebook is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). For an overview of the plugins of Facebook and their appearance, see https://developers.facebook.com/docs/plugins
Google+ is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). For an overview of the plugins of Google and their appearance, see developers.google.com/+/web/
Pinterest is operated by Pinterest, Inc., 651 Brannan Street, San Francisco, CA 94103, USA (“Pinterest”). For an overview of the plugins of Pinterest and their appearance, see: https://developers.pinterest.com/docs/getting-started/introduction/?
Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103 (“Twitter”). For an overview of the Twitter buttons and their appearance, see: https://twitter.com/about/resources/buttons
In order to increase the protection of your data when you visit our website, the Plugins are integrated into the page with a “2-click solution.” This integration ensures that you have no contact with the servers of Facebook, Google, Pinterest, and Twitter if you merely request our website. However, once you click on a Plugin’s button, you activate the Plugin and consent to the transmission of your data to the servers of Google, Facebook, Pinterest, or Twitter. The content of the respective Plugin will then be directly transmitted to your browser by the associated social media provider and integrated into the website. Integration of the Plugins gives the Providers the information that your browser has called up the corresponding site of our internet offer, even if you do not have any profile with the corresponding provider or are not currently logged in. This information (including your Internet Protocol address) will be submitted directly to a server of the respective provider and stored there.
If you are logged into a social network, the providers may assign your visit of our website directly to your profile on Facebook, Google+, Pinterest, or Twitter. If you interact with the Plugins, e.g. by pushing the “Like” or “+1,” ”Twitter,” or the “Pin it” button, the corresponding information will also be directly transmitted to a server of the provider and stored there. The information will also be published in the social network or on your Twitter account and indicated in your contact details there.
Please see the privacy policies of the respective social media providers:
- Facebook: https://www.facebook.com/about/privacy;
- Google: https://policies.google.com/privacy?gl=ca;
- Pinterest https://about.pinterest.com/en/privacy-policy; and,
- Twitter: https://twitter.com/privacy.
If you do not want Google, Facebook, Twitter, or Pinterest to directly connect the data collected via our website to your profile in the respective service, you need to log out of the respective service before you activate the Plugins.
(ii) Google reCAPTCHA
Parts of this website, especially our contact form, use Google’s reCAPTCHA function, which is used to distinguish whether a particular electronic input is made by a natural person or by a machine and automated processing. For this purpose, a JavaScript code is used to analyze your interaction with the website in the background (such as by looking at your mouse movements, operating system, web browser used, IP address browser settings, etc.). On the basis of this analysis, the reCAPTCHA service will identify you as a human user or prevent abusive automated execution. The function includes the transmission of your IP address and possibly other data to Google.
Importantly, we do not store any of your data as part of the reCAPTCHA service. Please refer to Google’s privacy policy: https://policies.google.com/privacy?gl=ca
4. How we share your Personal Information
We do not sell Personal Information, and we will not share your Personal Information, except:
(a) to third parties performing clearly defined subprocessing functions on behalf of us (such as analyzing data, providing marketing assistance, providing search results and links, or verifying data provided by you);
(b) where we are required by law to disclose Personal Information; in connection with any legal proceedings or prospective legal proceedings;
(c) in order to establish, exercise, or defend our legal rights;
(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling. We will require any person or entity to whom we provide your Personal Information to agree to comply with our then current Privacy Policy. We will take reasonable commercial efforts to ensure that they comply with our Privacy Policy; and,
(e) in the event of a transfer of ownership or assets, or a bankruptcy, of STAEDTLER or any of its affiliates.
We may also share your Personal Information with one or more of our respective subsidiary and parent companies and other affiliated legal entities and businesses who are under common corporate control. However, all of the parent, subsidiary, and affiliated legal entities and businesses of STAEDTLER that receive your Personal Information will comply with the terms of this Privacy Policy and all applicable data protection laws with respect to their use and disclosure of such Personal Information.
5. Anonymized Data
We may create de-identified or anonymized data from Personal Information that you provide to us by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you. Anonymized data is no longer considered Personal Information and is not subject to this Privacy Policy.
6. How We Protect Your Information
To protect your Personal Information against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we and our sub-processors use appropriate physical, technical, and organizational security measures.
However, please note that when data is communicated over open networks, such as the internet, protection of the transmitted data cannot be comprehensively ensured and seamlessly protected against third-party access. Therefore, do not send us any confidential data through the internet (e.g., by email) without sufficient protection. All forms on our website in which personal data are recorded are encrypted according to the current safety protocol, which is currently TSL 1.2 .
7. Your Privacy Rights on this Site
You have the following rights with respect to the Personal Information that we collect, use, or share:
Right to be Informed | The right to be informed about the collection and use of your Personal Information. |
Right to Access | The right to be provided with a copy of your Personal Information held by us. |
Right to Rectification | The right to require us to correct your Personal Information if it’s inaccurate or incomplete. |
Right to Restriction of Processing | The right to require us to stop processing your Personal Information but still allow us to hold onto it. |
Right to Object | The right to object to our continued processing of your Personal Information. |
Right to File a Complaintwith the Privacy Commissioner of Canada | The right to complain about the breach of your rights. |
To exercise your rights or to determine what rights you may have, you may reach out to us by email at dataprotection@staedtler.com.
If you’re not satisfied with our response, you may complain to Privacy Commissioner of Canada. If you’re unsure of how to contact the Privacy Commissioner, let us know, and we’ll endeavor to help you.
8. Data Retention and Your Rights to Access and Correction
(a) Your Right to Access
The disclosure of information will be provided at a minimal or no cost to you. The cost will be directly proportional to how large your request is. We reserve the right to decline your request where the information requested:
- would disclose Personal Information of another individual or of a deceased individual;
- is subject to legal privilege;
- is personal health information that was not provided to us directly by the individual requesting access;
- is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
- does not exist, is not held, or cannot be found by us, could reasonably result in serious emotional harm to the individual or another individual, or serious bodily harm to another individual; or,
- may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions.
We also will not disclose the Personal Information where a law of your country, state, province, or other subnational entity would bar such disclosure.
(b) Your Right to Update or Correct Your Information
You may in most cases correct or update your Personal Information by instructing us to do so on your behalf.
(c) Data Retention
We do not hold onto your data for forever. Instead, our default is to retain your Personal Information until it is no longer necessary for the purposes for which it was collected or otherwise processed, or to comply with legal obligations.
9. We May Change this Privacy Policy
In order to maintain or enhance our Services it might be necessary to change this Privacy Policy from time to time. We reserve the right to modify this Privacy Policy at any time, subject to applicable data protection laws. Please visit the Site from time to time for information on updates to this Privacy Policy.
10. Data Privacy Contact
If you have any questions regarding this Privacy Policy or the privacy practices of STAEDTLER or its sub-processors, or if you require assistance to withdraw your consent to our processing of your Personal Information or wish to access or correct your Personal Information, please contact us by sending an email to:
dataprotection@staedtler.com
calling us at 49 (0) 911 93650
or in writing to STAEDTLER Mars GmbH & Co. KG, Moosaeckerstrasse 3, D-90427 Nuremberg, Germany. Attention: Data Protection Officer.