PRIVACY POLICY

LEDVANCE's Commitment to Data Privacy Protection


Protecting the security and privacy of your personal data is important to LEDVANCE; therefore, we conduct our business in compliance with applicable laws on data protection. This privacy policy (“Policy”) outlined below will give you the information necessary to help you understand what data LEDVANCE collects when you visit our website www.myledvance.com, how LEDVANCE uses that data and with whom we share it.

Controller

The controller according to Art. 4(7) GDPR is
LEDVANCE GmbH,
Parkring 29-33,
85748 Garching, Germany.
Phone: +49 89 780673-100
Email: contact@ledvance.com

Hereinafter referred to as “LEDVANCE”, “we”, “our”, “us”.
 

Data Protection Officer

The controller’s data protection officer is as follows:

Mr. Matthias Lindner
bDSB LEDVANCE
c/o intersoft consulting services AG
Beim Strohhause 17
20097 Hamburg
Germany
Phone: +49 40 790235 – 0
Fax: +49 40 790235 – 170
E-Mail: privacy@ledvance.com
 

Collection and Processing of Personal Data

We obtain personal data when you visit the website, which include:

  • - Visiting our website

When visiting our website, we collect and store the anonymized IP address (ie removed by last three digits) assigned to your computer in order to provide you with the contents of our website requested by you (e.g. texts, images and product information). The legal basis is Art. 6(1)(b) GDPR (contractual obligation) for registered visitors and Art. 6(1)(f) GDPR (legitimate interest) for any other visitor. We furthermore collect that information for the detection and defense of misuse which is justified by our legitimate interest according Art. 6(1)(f) GDPR and is being conducted in order to ensure the proper functioning of our website. Furthermore, we collect and process information about the browser type you use as well as date and time of access and use of our website based on Art. 6(1)(f) GDPR, in order to optimize our website and our services which also is our legitimate interest in the meaning of Art. 6(1)(f) GDPR. This information is stored in log files and is not linked to personal data gathered elsewhere on the website. To the extent our processing of your personal data is based on our legitimate interest, and if you need any further information on the balancing test according to Art. 6(1)(f) GDPR, please contact us at the contact details mentioned in this Policy.

- Registration
When you use our services, registration may be required. Personal data you are providing to us within the scope of the registration process will be processed by us for verification purposes on the legal basis of Art. 6(1)(b) GDPR. Insofar you are contractually obligated to provide us with your personal data since we otherwise won’t be able to provide you with our respective services. The following data will be processed:
E-Mail address
First name
Last name
Title
Country
Language
Employer’s name
Employer’s branch

- Contact form
On our website you will have the possibility to use our contact form to send us enquiries. You will thereby be requested to provide us with personal data of yours that will be stored and processed by us in order to process your enquiry on the legal basis of Art. 6(1)(b) GDPR. Insofar you are contractually obligated to provide us with your personal data since we otherwise won’t be able to properly process your enquiry. The following data will be processed:
- Employer’s street and house number
- Employer’s ZIP code
- Employer’s City
- Employer’s region
- Employer’s full name
- Employer’s VAT
- LEDVANCE customer number
- Your position at your employer
- Employer’s homepage
- Email
- Your comments
- attachments

- Newsletter and marketing communications
On our website you will also have the possibility to sign up for newsletters or other marketing communications via email. We will ask you for your prior consent before contacting you accordingly. Processing of your personal data is based on the legal basis of Art. 6(1)(a) GDPR. You may revoke your consent at any time with future effect, e.g. via following the respective instructions for opting out in each email communication or by withdrawing your consent directly in the respective section after having logged in our B2B portal. This will not affect the processing of your personal data being undertaken until the revocation. You are legally not obligated to provide us with the relevant information for the abovementioned purpose. Without that information, however, we will not be able to send you relevant newsletter and marketing communications.
 

Third party access to your personal data

We will share personal data only in accordance with applicable law. We will not sell or otherwise share your personal data with third parties for their own marketing purposes without your consent. The transfer of your personal data to third parties without your prior consent only takes place under the following circumstances:

We will share your personal data with service providers that we use to provide the product services. The respective service provider will use the data only for providing the services and in accordance with contractual agreements regarding the confidentiality and purpose limitation of the data processed. Regardless of where these service providers or other third parties are located; we require that they also comply with the GDPR and the applicable data protection laws.

We use the following categories of service providers or other third parties:

Social media
- Provider of embedded applications or services

The transfer of data to our service providers or the third parties mentioned above is based on the legal basis of Art. 6(1)(f) GDPR and our legitimate interest in the economic and technical advantages associated with the use of specialized service providers. If you need any further information on the balancing test according to Art. 6(1)(f) GDPR, please contact us at the contact details mentioned in this Policy.

Your personal data will be transferred to law enforcement authorities as well as to injured third parties if this is necessary to evaluate an illegal use of our services or for legal prosecution. This only happens, however, if there are specific indications of illegal or abusive behavior. A transfer of your personal data to third parties can also take place if this serves the enforcement of terms of use or other agreements. We are also legally obligated to provide information to certain public bodies upon request. Those are criminal prosecution authorities, authorities that prosecute administrative offences subject to a fine and the tax authorities.

The transfer of your personal data is based on Art. 6(1)(c) GDPR to comply with legal obligations to which we are subject and our legitimate interest in combating abuse, prosecution of criminal and administrative offences and the safeguarding, assertion and enforcement of claims under the legal basis of Art. 6(1)(f) GDPR. If you need any further information on the balancing test according to Art. 6(1)(f) GDPR, please contact us at the contact details mentioned in this Policy.
 

Use of Google Tag Manager

1. Scope of processing of personal data
This website uses the Google Tag Manager of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") to collect information about user behavior and manage tags.
 
2. How the tagging works
To utilize the Google Tag Manager, we use so-called "server-side tagging". With the assistance of a tag, your IP-address is being collected and sent to our own server with hosting location within the EU , where the Google Tag Manager is implemented and receives the IP-address. Here, still on our own server, the IP-address is anonymized and only then sent to further services connected to the Tag Manager. This means that we only process your personal data on our own server and a connection to Google servers is technically excluded.
 
3. Purpose of data processing
The purpose of the processing lies in the collected and clear administration as well as an efficient integration of the services of third parties through tags. Tags are small code elements on an online presence that are used, among other things, to measure visitor numbers and behavior, capture the impact of online advertising and social channels, use remarketing and targeting, and test and optimize online presences. When a user visits the online presence, the current tag configuration is sent to the user's browser. It contains statements about which tags are to be triggered.
 
4. Legal basis for the processing of personal data
The legal basis for the processing of personal data is Art. 6 (1) (1) (f) GDPR. The website operator has a legitimate interest in a technically error-free provision of the website and therefore a clear administration as well as an efficient integration of the services of third parties through tags.
 
5. Duration of storage
The data collected in the context of the use of the Google Tag Manager will be retained for 14 days and then deleted. [IM1]  Beyond the aforementioned storage period, the data is only used for analysis purposes in aggregated and anonymized form, i.e. without the possibility of identifying individuals.
 
6. Additional measures
We have concluded a so-called data processing agreement with Google for our use of Google Analytics 4, by which Google is obliged to protect the data of our website users and not to pass it on to third parties.
 
To ensure a higher level of data protection, we have agreed standard data protection clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavor to obtain additional regulations and commitments from the recipient in the USA.
 
7. Objection and removal
The collection of data for the provision of the website as well as the storage is essential for the operation of the website. Therefore, the user may not object to the aforementioned processes.

 

Use of Google Analytics 4

1. Scope of processing of personal data
This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which can be utilized to analyze the use of websites.

2. How the tracking works
In order to utilize Google Analytics 4, we use so-called "server-side tracking". If you give your consent in accordance with Art. 6 (1) lit. a GDPR via the cookie banner, we will assign you a unique tracking ID. We store this ID together with other data transmitted to us when you visit the website on one of our own servers with hosting location within the EU. The following data is hereby transmitted:
·       IP address
·       referrer ID
·       timestamps
·       browser type
·       user agent
·       if applicable, mobile identifiers such as IDFA, UDID, Android ID or Google Advertising ID, Windows Advertising ID or other Windows IDs, IMEI or IMSI, MSISDN.
In order to ensure that Google Analytics does not receive any personal data, the tracking ID we create is detached from any personal as well as device data listed above so that the ID is an anonymized record. Once this has been ensured, we will solely transmit your anonymized ID to Google Analytics 4. This may also result in the transmission of this information to the servers of the company Google LLC, which is based in the USA, and further processing of the information there.
Google Analytics 4 also enables the creation of statistics with statements about age, gender and interests of website users on the basis of an evaluation of interest-based advertising and with the involvement of third-party information via a special function, the so-called "demographic characteristics". This makes it possible to determine and distinguish between groups of website users for the purpose of targeted marketing measures. However, data collected via the "demographic characteristics" cannot be assigned to a specific person and thus not to you personally. This data collected via the "demographic characteristics" function is retained for 2 months and then deleted.
As an extension of Google Analytics 4, the "UserIDs" function is also used for this website. By assigning individual UserIDs, we can have Google create cross-device reports (so-called "cross-device tracking"). This means that your usage behavior can also be analyzed across devices if you have given your corresponding consent to the use of Google Analytics 4 in accordance with Art. 6 (1) lit. a GDPR, if you have set up a personal account by registering on this website and are logged into your personal account on different end devices with your relevant login data. The data collected in this way shows, among other things, which end device was used to click on an ad for the first time and which end device was used for conversion.

3. Purpose of data processing

The purpose of the processing is the evaluation of the use of the website, the compilation of reports (reports) on website activities or usage behavior and to provide us with further services related to website and internet usage.

4. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (a) GDPR.

5. Duration of storage
The data collected in the context of the use of Google Analytics 4 will be retained for 14 months and then deleted.  Beyond the aforementioned storage period, the data is only used for analysis purposes in aggregated and anonymized form, i.e. without the possibility of identifying individuals.
 
6. Additional measures
We have concluded a so-called data processing agreement with Google for our use of Google Analytics 4, by which Google is obliged to protect the data of our website users and not to pass it on to third parties.
To ensure a higher level of data protection, we have agreed standard data protection clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavor to obtain additional regulations and commitments from the recipient in the USA.

7. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
 

Use of analytics data for aggregated evaluations and customer insights

In order to get the best insights from tools used on this website, we transfer data that is collected through various tools into our customer resource management (CRM) system and to our specific service providers, with whom we can aggregate data from analytics and tracking services. These providers act as our data processors and we have concluded data processing agreements accordingly.
 
In our CRM system, we process information gathered from our analytics and tracking tools about your website behavior (e.g. when you visited, from which location you visited or how many times you visited our website). Depending on the permissions you gave us through the cookie banner for the usage of specific analytics and tracking tools, the according analytics and tracking data will be combined with data from the CRM system.
 
Analytics data from our website as well as data from our CRM system will be used in aggregated form, meaning that any personal reference will have been removed. We analyze the aggregated data insights to improve our marketing strategy and tailor our services to our clientele.


Cookies

Please visit our cookie policy page for more information on the use of cookies:
www.ledvance.com/cookie-policy

 

Data Retention

We delete or anonymize your personal data as soon as it is no longer required for the purposes we have collected your personal data as outlined in this Policy, unless further processing or storage of your personal data is necessary in order to comply with a respective legal obligation. If you need further information on our data retention and deletion periods, please contact us at the contact details mentioned in this Policy.
 

Additional use of personal data

Should your personal data be processed for other purposes than those outlined in this Policy or other purposes than the ones your personal data has been originally collected for, we will provide you with information on that other purpose and any other relevant information as referred to in this Policy.
 

Information about your rights

You have the following rights:
Right of access (Art. 15 GDPR): You have the right to request confirmation as to whether or not your personal data is being processed, and, where that is the case, to request access to the personal data and information such as the purposes of the processing or the categories of personal data concerned.

Right to rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate personal data.

Right to erasure (Art. 17 GDPR): You have the right to request erasure of personal data without undue delay under certain circumstances, e.g. if your personal data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which processing is based according to Art. 6(1)(a) GDPR and where there is no other legal ground for processing.

Right to restriction of processing (Art. 18 GDPR): You have the right to request us to restrict the processing of your personal data under certain circumstances, e.g. if you think that the personal data we process about you is incorrect or unlawful.

Right to object (Art. 21 GDPR): You have the right to object to the processing of your personal data under certain circumstances, in particular if we process your personal data on the legal basis of legitimate interest (Art. 6(1)(f) GDPR) or if we use your personal data for marketing purposes.

Right to data portability (Art. 20 GDPR): Under certain circumstances, you have the right to receive your personal data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
You can assert your abovementioned rights by contacting us at the contact details mentioned in this Policy.
 

Right to lodge a complaint before the data protection authority

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your data relating to you infringes the GDPR. Please contact us at the contact details mentioned in this Policy and we will provide you with detailed information as regards the contact details of the respective supervisory authority.
 

Automated individual decision-making, including profiling

We don’t use your personal data for automated decision-making, including profiling.
 

Changes to this Policy

The products that LEDVANCE provides are always evolving and the form and nature of the products. For this reason, we reserve the right to change or add to this Policy and will post any material revisions on our website.
The new Policy will be effective upon publication
We encourage you to check back regularly to review the latest version of this Policy.
 

Contact us

If you have questions regarding this Policy or our privacy practices in general, you can contact us at any time by emailing privacy@ledvance.com or by mail at:
LEDVANCE GmbH,
Corporate Data Protection Officer
Parkring 29-33,
85748 Garching, Germany