Privacy Policy
Whistleblowing -
Information on data processing by ADLER Vertriebs GmbH & Co. Werbegeschenke KG
1. name and contact details of the controller and the company data protection officer
This data protection information applies to data processing by
Controller: ADLER Vertriebs GmbH & Co. Werbegeschenke KG (hereinafter also referred to as the "Company"), Altenkesseler Straße 17/B7, 66115 Saarbrücken, Germany
E-mail: kundenservice@adlerglobal.com
Telephone: +49 681 99 25 450
Fax: +49 681 99 25 250
The company data protection officer of the GmbH can be contacted at the above address, with the addition "for the attention of the data protection officer" or via datenschutz@adlerglobal.com.
2. Purpose of data processing and categories of personal data processed by us
In order to comply with legal requirements (in particular the EU Whistleblowing Directive) and to strengthen integrity and responsiveness within the company, a whistleblowing system has been set up through which whistleblowers can anonymously report grievances and misconduct within the company.
Whistleblowers can use our browser-based whistleblowing system completely anonymously, i.e. it is not mandatory to disclose your identity or provide other personal data when submitting a report. It is also not necessary to register in the whistleblowing system to submit a report. If the whistleblower submits a report regarding a specific person in your company via the whistleblower system, we record the information you provide on the facts of the case and the data of any person to whom the report relates. We only process the data that the whistleblower enters manually into our whistleblowing system or communicates via the telephone hotline. This may include, for example (non-exhaustive list), names, contact details and the employer of the whistleblower as well as other affected and/or accused persons.
If the whistleblower uses the whistleblower telephone hotline to submit the report, we hereby expressly point out that messages left on the answering machine will be saved as audio recordings. If we take the call in person, we will log the report in writing (and electronically) via the whistleblower reporting system for processing purposes.
3. lawfulness of the processing of personal data
The provision of personal data concerning you is voluntary, therefore the processing of the whistleblower's data is based on explicit consent. The legal basis for the processing of your data is then Art. 6 para. 1 sentence 1 lit. a) GDPR.
In addition, after receiving the report, we are legally obliged to check the report, which makes it necessary to process the data specified in the report (of the whistleblower and the persons affected and/or accused). The legal basis for the processing of your data is then Art. 6 para. 1 sentence 1 lit. c) GDPR.
4 Retention period of the personal data
We will retain the personal data and other information from your report until the events or grievances described have been clarified and resolved, i.e. the purpose of the data processing has ceased to apply, Art. 5 para. 1 lit. e) GDPR. In addition, statutory retention obligations may apply that oblige us to store data for a longer period (e.g. HGB, AO etc.)
5. disclosure of data to third parties
Insofar as this is necessary to determine the facts and clarify the reported grievance in the respective company, the necessary information will be forwarded to superiors or the relevant department of the company. The processing and forwarding also takes place completely anonymously and without providing personal data of the whistleblower, unless the whistleblower has expressly consented to this, Art. 6 para. 1 sentence 1 a) GDPR.
If the company concerned (internal or external) has appointed or commissioned a whistleblowing officer, they will also have access to your report. If the company has appointed a whistleblowing coordinator internally, this coordinator will only receive the information required to determine the facts and clarify the reported grievance.
If the whistleblowing report is relevant under criminal law, the information may also be forwarded to the competent authority. This forwarding also takes place while maintaining the anonymity of the whistleblower, unless you have given your express consent regarding the disclosure of your identity, Art. 6 para. 1 sentence 1 a) GDPR or we are legally obliged to disclose (legal basis) or disclosure is ordered by the authorities (legal basis).
Our whistleblower system is hosted by Vispato GmbH, Hansaallee 299, 40549 Düsseldorf at Datev eG in Nuremberg. We have therefore concluded an order processing contract with Vispato GmbH within the meaning of Art. 28 GDPR. Vispato GmbH does not have access to the data in the whistleblowing system.
6. rights of data subjects
You have the right:
- in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given to us at any time. As a result, we may no longer continue the data processing based on this consent in the future;
- to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the purposes of processing, the categories of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us.
- in accordance with Art. 16 GDPR, to demand the immediate rectification of incorrect data or the completion of your personal data stored by us
- in accordance with Art. 17 GDPR, to demand the erasure of your personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims
- in accordance with Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR
- in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request its transmission to another controller; and
- to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. The supervisory authority responsible for us is: State Commissioner for Data Protection and Freedom of Information, Fritz-Dobisch-Str. 12, 66111 Saarbrücken.
Information on data processing by ADLER Vertriebs GmbH & Co. Werbegeschenke KG
1. name and contact details of the controller and the company data protection officer
This data protection information applies to data processing by
Controller: ADLER Vertriebs GmbH & Co. Werbegeschenke KG (hereinafter also referred to as the "Company"), Altenkesseler Straße 17/B7, 66115 Saarbrücken, Germany
E-mail: kundenservice@adlerglobal.com
Telephone: +49 681 99 25 450
Fax: +49 681 99 25 250
The company data protection officer of the GmbH can be contacted at the above address, with the addition "for the attention of the data protection officer" or via datenschutz@adlerglobal.com.
2. Purpose of data processing and categories of personal data processed by us
In order to comply with legal requirements (in particular the EU Whistleblowing Directive) and to strengthen integrity and responsiveness within the company, a whistleblowing system has been set up through which whistleblowers can anonymously report grievances and misconduct within the company.
Whistleblowers can use our browser-based whistleblowing system completely anonymously, i.e. it is not mandatory to disclose your identity or provide other personal data when submitting a report. It is also not necessary to register in the whistleblowing system to submit a report. If the whistleblower submits a report regarding a specific person in your company via the whistleblower system, we record the information you provide on the facts of the case and the data of any person to whom the report relates. We only process the data that the whistleblower enters manually into our whistleblowing system or communicates via the telephone hotline. This may include, for example (non-exhaustive list), names, contact details and the employer of the whistleblower as well as other affected and/or accused persons.
If the whistleblower uses the whistleblower telephone hotline to submit the report, we hereby expressly point out that messages left on the answering machine will be saved as audio recordings. If we take the call in person, we will log the report in writing (and electronically) via the whistleblower reporting system for processing purposes.
3. lawfulness of the processing of personal data
The provision of personal data concerning you is voluntary, therefore the processing of the whistleblower's data is based on explicit consent. The legal basis for the processing of your data is then Art. 6 para. 1 sentence 1 lit. a) GDPR.
In addition, after receiving the report, we are legally obliged to check the report, which makes it necessary to process the data specified in the report (of the whistleblower and the persons affected and/or accused). The legal basis for the processing of your data is then Art. 6 para. 1 sentence 1 lit. c) GDPR.
4 Retention period of the personal data
We will retain the personal data and other information from your report until the events or grievances described have been clarified and resolved, i.e. the purpose of the data processing has ceased to apply, Art. 5 para. 1 lit. e) GDPR. In addition, statutory retention obligations may apply that oblige us to store data for a longer period (e.g. HGB, AO etc.)
5. disclosure of data to third parties
Insofar as this is necessary to determine the facts and clarify the reported grievance in the respective company, the necessary information will be forwarded to superiors or the relevant department of the company. The processing and forwarding also takes place completely anonymously and without providing personal data of the whistleblower, unless the whistleblower has expressly consented to this, Art. 6 para. 1 sentence 1 a) GDPR.
If the company concerned (internal or external) has appointed or commissioned a whistleblowing officer, they will also have access to your report. If the company has appointed a whistleblowing coordinator internally, this coordinator will only receive the information required to determine the facts and clarify the reported grievance.
If the whistleblowing report is relevant under criminal law, the information may also be forwarded to the competent authority. This forwarding also takes place while maintaining the anonymity of the whistleblower, unless you have given your express consent regarding the disclosure of your identity, Art. 6 para. 1 sentence 1 a) GDPR or we are legally obliged to disclose (legal basis) or disclosure is ordered by the authorities (legal basis).
Our whistleblower system is hosted by Vispato GmbH, Hansaallee 299, 40549 Düsseldorf at Datev eG in Nuremberg. We have therefore concluded an order processing contract with Vispato GmbH within the meaning of Art. 28 GDPR. Vispato GmbH does not have access to the data in the whistleblowing system.
6. rights of data subjects
You have the right:
- in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given to us at any time. As a result, we may no longer continue the data processing based on this consent in the future;
- to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the purposes of processing, the categories of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us.
- in accordance with Art. 16 GDPR, to demand the immediate rectification of incorrect data or the completion of your personal data stored by us
- in accordance with Art. 17 GDPR, to demand the erasure of your personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims
- in accordance with Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR
- in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request its transmission to another controller; and
- to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. The supervisory authority responsible for us is: State Commissioner for Data Protection and Freedom of Information, Fritz-Dobisch-Str. 12, 66111 Saarbrücken.