Welcome to www.staedtler.us/en/ (the “Site”), a website provided by STAEDTLER, Inc. (hereinafter also: “STAEDTLER,” “we” or “us”). STAEDTLER respects your privacy, and this Data Protection Statement (“Statement”) covers our handling, use and disclosure of information collected from you through the Site.
You should review this Statement carefully, and be sure you understand it, prior to using the Site or otherwise providing any information to STAEDTLER. Your use of the Site, providing any information to STAEDTLER or any other indication of your assent is deemed to be acceptance by you of this Statement. If you do not agree to this Statement, you should not use, and should immediately terminate your use of, the Site and not otherwise provide any information to STAEDTLER. For purposes of this Section, accessing the Site only to review this Statement is not deemed to be use of the Site.
In this Statement:
(b) “Collected Information” means all (i) Personal Information and (ii) Non-Personal Information received by STAEDTLER from you;
(c) “Non-Personal Information” means all information collected by STAEDTLER, whether electronically or manually, through (i) the Site, and (ii) e-mail messages and other electronic communications that you may send to us, that is not Personal Information (including, but not limited to, any Analytical Information); and
(d) “Personal Information” means all information collected by STAEDTLER, whether electronically or manually, through (i) the Site, or (ii) e-mail messages and other electronic communications that you may send to STAEDTLER, that relates to an individual and that identifies, or can be used in conjunction with other readily-accessible information to identify, such individual (including, but not limited to, name, e-mail address, physical address and phone number).
Except for any Collected Information obtained automatically through the Site as set forth in Section 5, no Collected Information is obtained from you, unless it is voluntarily provided. For example, STAEDTLER collects the full name, email address, postal address, phone number, and other identification and contact data from its customers or from consumers who sign-up to receive newsletters. There is no statutory obligation to provide any data. If you decline to provide certain data, STAEDTLER may not be able to render services, or may only be able to do so with restrictions.
Regardless of the method used to obtain Collected Information, we will only collect and retain Personal Information in a manner that is consistent with the purposes for which it is provided. However, STAEDTLER may collect and retain Personal Information for other legitimate business purposes, (including, but not limited to, marketing). You are responsible for obtaining any approvals, authorizations, consents, permissions and permits that are required in connection with your providing us with any information (including, but not limited to, any information relating to a third party).
4. Transmission of Personal Information
Any Collected Information obtained by STAEDTLER, whether or not for a specific purpose, may be transferred to third parties designated by STAEDTLER (including, but not limited to, any affiliates, distributors, sub-contractors or vendors engaged by us to perform administrative and technological functions) for any purposes for which STAEDTLER could use such Collected Information. On such occasions, STAEDTLER will require third parties to provide at least the same level of privacy protection as is required by this Statement.
STAEDTLER is controlled and operated from Mississauga, Ontario and data is stored on servers in Germany. If you choose to use the Site, provide information to us or purchase products from us, please note that we may transfer Personal Information provided by you for processing in Ontario or Germany. By providing Personal Information to us for the purpose of purchasing products or placing you or your company on our contact lists, you consent to the transfer of Personal Information to Ontario or Germany. The transfer of that Personal Information to these countries is necessary for STAEDTLER to provide services.
STAEDTLER may also at any time, in its sole discretion, transfer any Collected Information (including, but not limited to, a computer’s Internet protocol addresses), whether or not you furnished such Collected Information for a specific purpose, to (a) comply with, or as permitted by, any applicable law or lawful request of a government or public authority for purposes of satisfying, among others, national security and law enforcement requirements, (b) cooperate with law enforcement, and other third parties, in investigating a claim of fraud, illegal activity or infringement of intellectual property rights, (c) protect the rights, property or legitimate business interests of STAEDTLER, or (d) transfer such Collected Information to a third party acquiring all, or substantially all, of STAEDTLER’s assets. If Collected Information is so transferred, STAEDTLER will have no responsibility for any action of the third party to whom or which such Collected Information is transferred.
5. Analytical Information and Statistical Cookies
Every time you access the Site, access data regarding this process will be stored in a protocol file on the server of our Internet Service Provider (“ISP”). This data record comprises your IP address, date and time of the query, name of the requested file, file name from which the file was requested, the transferred data volume and access status, a description of the web browser and operating system used and the name of your ISP. We collect this data for technical reasons, including to ensure a smooth connection and comfortable use of the Site, as well as to permit evaluation of system safety and system stability.
For example, this Site utilizes statistical cookies for analytical purposes. Cookies are small text files that your browser may store on the hard drive of your computer. Cookies help you use the Site. They also help STAEDTLER understand how the Site is used and allows us to improve navigation. Cookies enable us to see if you have visited our website before or whether you are a new visitor. Google Analytics is one of the third parties used by STAEDTLER to collect Analytical Information. These third parties may combine and use data collected through your use of the Site with data they collect over time and across different websites for their own purposes. You can learn about how Google collects and processes data at https://policies.google.com/technologies/partner-sites. You can also learn about the controls Google offers to manage the collection and use of your information at https://policies.google.com/privacy. We recommend that you review these privacy policies or notices at the links provided above. Absent additional information from your ISP, these cookies do not provide Personal Information. By clicking on “Change Website Settings” you can change the functions and corresponding cookies that you wish to allow. In addition, you can set your internet browser so that storage of cookies on your hard drive is prevented or so that you will be asked every time if you agree to cookies being placed.
6. Marketing Cookies
For advertising purposes, 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 Section 7, Google Remarketing and Section 13, Consent to Conversion Measurement with the Visitor Action Pixels of Facebook.
7. Google Remarketing
8. Electronic Communications
Whether or not you have previously sent STAEDTLER an e-mail message, you consent to us sending you e-mail messages and other electronic communications (a) in connection with your use of the Site, (b) in the ordinary course of business, or (c) for any other legitimate business purpose (including, but not limited to, marketing). Any information you provide shall be saved for processing of your inquiry and to address any subsequent questions that may arise. Since STAEDTLER endeavors to send e-mail messages and other electronic communications only to individuals desiring to receive them, you can unsubscribe to such e-mail messages or other electronic communications at any time by contacting STAEDTLER as set forth in Section 18, or by following the directions contained in such e-mail messages or other electronic communications. Any request to unsubscribe to e-mail or other electronic communications will likely be effective within 48 hours after your request is received by STAEDTLER.
Unless you have provided additional consents, the Personal Information collected by us in the scope of lotteries shall only be collected, processed and used to design, perform and/or process the lottery and shall be deleted after the lottery has been processed. This Personal Information will not be passed on to any third parties. For more information, see the respective participation conditions for our lotteries.
If you sign up for our newsletter, we will use your email address to send you the newsletter. You may unsubscribe from it at any time. Your email address shall not be used in any other manner. If you open the newsletter or click a link in it, this will be logged by our web server (date, time, email address). This serves statistical purposes and will not be combined into personal usage profiles.
11. Integration of Services and Third-Party Content
In some cases, this Site integrates content from third parties, e.g. map material from Google Maps, RSS feeds or graphics from other websites. This always requires that the providers of such third-party content (“Third-Party Content”) use your IP address. Without your IP address, it would not be possible to send Third-Party Content to your browser. The IP address is therefore required to present Third-Party Content. We strive to use content from providers that only use the IP address to provide Third-Party Content. However, we cannot control whether providers store the IP address, e.g. for statistical purposes. For more information on the corresponding services and social plugins, see Section 12.
12. Social Plugins using the “2-click solution”
Our Site uses social plugins (“Plugins”) of the social networks Facebook and Pinterest as well as the microblogging service Twitter. These services are offered by the companies Facebook Inc., Twitter Inc. and Pinterest (“Providers”).
- 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.
- 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.
- 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/?
In order to increase protection of your data when you visit this Site, the Plugins are integrated into the page with the “2-click solution”. This integration ensures that no contact with the servers of Facebook and Twitter is established at the point at which you call up a page of our Site that contains such Plugins. Only if you activate the Plugins and thereby consent to data transmission will your browser contact the servers of Facebook or Twitter. The content of the respective Plugin will then be directly transmitted to your browser by the associated provider and integrated into the website. Integration of the Plugins gives the Providers the information that your browser has called up the corresponding website 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 IP address) will be submitted directly to a server of the respective provider in the USA by your browser and stored there.
If you are logged into a social network, the providers may assign your visit of this Site directly to your profile on Facebook or Pinterest. If you interact with the Plugins, e.g. by pushing the “Like” 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.
For the purpose and scope of data collection and further processing and use of the personal data by the providers as well as your rights and setting options to that extent to protect your privacy, see the data privacy notes of the providers. If you do not want Facebook, Twitter or Pinterest to directly assign the data collected via this Site to your profile in the respective service, you need to log out of the respective service before you activate the Plugins.
13. Consent to Conversion Measurement with the Visitor Action Pixels of Facebook
This Site uses the Visitor Action Pixel which is a service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA. It permits tracking of the behavior of users after they click a Facebook advertisement and are forwarded to the website of the advertising or advertised company. The conversion measurement with the Visitor Action Pixel permits measurement, evaluation and optimization of the effectiveness of Facebook advertisements for statistical purposes and purposes of market research. The data collected on the Sites of STAEDTLER by the Visitor Action Pixel do not enable STAEDTLER to draw any conclusions as to the person of the user. The collected data (e.g. the IP address of the user) is transmitted to Facebook by the Visitor Action Pixel. This data will be saved and processed by Facebook for the purpose of conversion measurement. STAEDTLER receives reports on conversion measurement in an anonymized form from Facebook. These reports do not permit any conclusions as to the user either. However, Facebook may link the transmitted data to other Personal Information of the user (e.g. user data on an existing Facebook account) or that Facebook may use the corresponding data for its own further purposes.
The Visitor Action Pixel is a service of a company that is independent of STAEDTLER. STAEDTLER cannot control Facebook’s data processing procedures in this respect. For further notes on use of the collected data by Facebook, see the corresponding notes of Facebook at www.facebook.com/about/privacy/.
Facebook and its partners permit the placement of advertisements on websites of Facebook and on Third-Party Sites. For the purpose of use of the Visitor Action Pixel and tracking of the corresponding activities, a cookie may be stored on the user’s computer for these purposes. By clicking the OK button in the corresponding banner of the website, you agree to use of the conversion measurement with the Visitor Action Pixel of Facebook. You may revoke consent to use of conversion measurement with the Visitor Action Pixel at any time. To revoke consent, use this link: www.facebook.com/ads/website_custom_audiences/.
14. Security of Collected Information
STAEDTLER will protect Collected Information from loss, misuse and unauthorized access, alteration, destruction and disclosure as required by all applicable laws, including privacy and security laws. We will, at a minimum, use commercially reasonable efforts to protect Personal Information from loss, misuse and unauthorized access, alteration, destruction and disclosure. We implement reasonable administrative, technical, organizational and physical precautions to safeguard against the loss, misuse or alteration of your Collected Information, including Personal Information.
Since no transmission of information over the Internet or electronic storage of information is completely secure, it is possible that Collected Information could be lost, misused or accessed, altered, destroyed or disclosed without authorization, even if STAEDTLER uses such reasonable efforts. Specifically, when data is transmitted on open networks, such as the internet, protection of the transmitted data according to the current state of the art cannot be comprehensively ensured and they cannot be 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 Site in which personal data is recorded are encrypted according to the current safety protocol, currently TSL 1.2 .
The Site is not intended for children under 13 years of age. However, if a parent or guardian of a child who is under 13 years of age discovers that Personal Information of such child has been submitted to STAEDTLER through the Site without the parent’s or guardian’s consent, we will use commercially reasonable efforts to remove such information from the Site and our servers at the parent’s or guardian’s request. To request the removal of such Personal Information, the parent or guardian must contact STAEDTLER as set forth in Section 18, and provide all information requested by STAEDTLER to assist it in identifying the Personal Information to be removed.
16. Applicable Law
This policy shall be governed by, and construed and interpreted in accordance with, (a) any applicable privacy law solely to the extent required by such law, and (c) in all other cases, the laws of the state of New York, without regard to its principles of conflict of laws. If there is any conflict or inconsistency between any provision of this Statement and any provision of any applicable law, the latter shall control.
Any complaint by you regarding any Collected Information, or otherwise relating to this Statement, must first be submitted to STAEDTLER as set forth in Section 18, and we must be given a reasonable opportunity of not less than 45 days to investigate and respond to your complaint. Upon the completion of STAEDTLER’s investigation and so responding, we and you must then attempt, in good faith, to promptly resolve any remaining aspects of your complaint. If any aspect of your complaint remains unresolved after an additional reasonable period of time of not less than 45 days, you may commence litigation against STAEDTLER in connection with the unresolved portion of your complaint only in a court located in Erie or Niagara Counties, New York, and having subject matter jurisdiction over your complaint. You consent to any such court’s being a proper venue for your complaint, and waive any objection thereto based on inconvenience.
18. Contact Options
If you have any questions on collection, processing or use of your personal data, and on assertion of your rights, please contact:
850 Matheson Boulevard West, Unit 4
Mississauga, ON L5V 0B4
Tel: (905) 501-9008
Fax: (905) 501-9117