Thank you for visiting our website and showing interest in our company. Management at Rhoco ES Ltd is deeply committed to data protection. You can generally visit and use our website with-out providing any personal data. However, we may need to process personal data if you wish to make use of certain services offered by our company via our website. If we need to process personal data and there is no legal basis for such processing, we always ask for your consent as the data subject.
As the controller, we at Rhoco ES Ltd have taken and implemented numerous technical and organisational measures (TOMs) to ensure end-to-end protection of any personal data processed via our website. However, we also wish to point out that security gaps may arise during online data transfer. Unfortunately, we cannot guarantee complete protection in this respect. However, you are welcome to use conventional means, such as the phone or postal service, to provide us with any personal data required.
a) personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject” below). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) data subject
A data subject is any identified or identifiable natural person whose personal data are processed by the controller.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation,structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by trans- mission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of per- sonal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, pro- vided that such additional information is kept separately and is subject to technical and organisa- tional measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or pro- cessor, are authorised to process personal data.
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, sig- nifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller
The controller in the meaning of the General Data Protection Regulation, other data protection laws applicable in European Union member states and other provisions of a data protection nature is:
Rhoco ES Ltd
Tel: 01684 211888
3. Name and address of the data protection officer
The Controller’s Group Data Protection Officer is:
Rhoco ES Ltd
Any data subject with queries or suggestions regarding data protection may contact our data
protection officer directly at any time.
This allows visited websites and servers to distinguish the data subject’s individual browser from other browsers containing different cookies. A specific web browser may be recognised and identified using the unique cookie ID. By using cookies, we can provide users of this website with more user-friendly services than would be possible without cookies. Cookies enable us to optimise the information and services on our website for the benefit of users. As stated above, they allow us to remember visitors to our website. The purpose of this is to make it easier for users to use our website.
5. Collection of general data and information
Our website collects a range of general data and information each time it is accessed by you as a data subject or an automated system. This general data and information is stored in server log files. The data and information collected may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which the accessing system accessed our website (“referrer”), (4) the sub-pages which an accessing system visits on our website, (5) the date and time the website was accessed, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system and (8) other similar data and information used to protect against risks in the case of attacks on our information technology systems.
We do not draw any conclusions about the identity of the data subject when using these general data and information. Rather, this information is required to (1) correctly deliver our website content, (2) optimise our website content and promotion thereof, (3) ensure permanent functionality of our information technology systems and our website’s technology and (4) provide law enforcement agencies with the information needed for criminal prosecution in the event of a cyber-attack. Therefore, we analyse these anonymously collected data and information for statistical purposes and also with the goal of improving our company’s data protection and data security, which ultimately ensures the best level of protection for the personal data pro-cessed by us. The anonymous data contained in the server log files are stored separately from all personal data provided by data subjects.
6. Subscription to our newsletter
You have the option of subscribing to our company’s newsletter on our website. The personal data needed to order this newsletter are taken from the input screen used for this. We use a newsletter to provide our customers and business partners with regular updates on the company’s offerings. Data subjects can only receive our company’s newsletter if they (1) have a valid email address and (2) subscribe to receive the newsletter.
For legal reasons, a confirmation email is sent to the email ad-dress entered by the data subject for newsletter shipping as part of a double opt-in process. This confirmation email is used to verify whether the owner of the email address has authorised receipt of the newsletter as the data subject. We also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of subscription to the newsletter as well as the date and time of subscription. We need to collect these data in order to trace any (possible) misuse of the email address of a data subject at a later point in time and therefore for the controller’s legal protection.
The personal data collected as part of subscription to the newsletter are solely used to send out our news-letter. In addition, subscribers to our newsletter may receive information via email if this is necessary to run the newsletter service or a related subscription, as may be the case if changes are made to the newsletter service or if technical parameters change. Personal data collected in relation to the newsletter service are not shared with third parties.
The data subject may unsubscribe from our newsletter at any time. The consent to the storage of personal data given by the data subject to us for us to send them the newsletter may be withdrawn at any time. There is a corresponding link in each newsletter for the withdrawal of consent. The data subject can also unsubscribe from the newsletter at any time directly on the controller’s website or in-form the controller of this in some other way.
7. Contact option via the website
Our website is required by law to provide information on how our company can be contacted rapidly by electronic means and also communicated with directly. This includes a general address for electronic mail (email address). If a data subject makes contact with us via email or contact form, the personal data provided by the data subject are automatically stored. Such personal data provided voluntarily by a data subject to the controller are stored for the purpose of processing or contacting the data subject. These personal data are not shared with third parties.
8. Routine erasure and blocking of personal data
We only process and store personal data of data subjects for the period needed to achieve the purpose for which they were stored or where this has been provided for by the European legislator or other legislators in laws or regulations to which the controller is subject. If the storage purpose no longer applies or a retention period prescribed by the European legislator or other competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
9. Rights of the data subject
a) Right of confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether personal data concerning them are being processed. Any data subject wishing to avail themselves of this right of confirmation may contact us regarding this at any time.
b) Right of access
Every data subject has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data concerning them that is stored and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
- the purposes of the processing the categories of personal data concerned
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- the existence of the right to obtain from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
- the right to lodge a complaint with a supervisory authority
- where the personal data are not collected from the data subject: any available information as to their source
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and
- (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
Furthermore, the data subject has the right to be informed as to whether personal data are transferred to a third country or to an international organisation. Where that is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.
If you wish to make use of this right to rectification, please contact us at any time.
c) Right to rectification
Every data subject has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning them. Furthermore, taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If you wish to make use of this right to rectification, please contact us at any time.
d) Right to erasure (right to be forgotten)
Every data subject has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies and to the extent that processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no over- riding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
- The personal data have been unlawfully processed.
- The personal data have to be erased for compliance with a legal obligation in Union law or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.
If any of the aforementioned grounds apply and a data subject would like the erasure of personal data we have stored, they may contact us regarding this at any time. We will then comply with this request for erasure without undue delay.
If we have made the personal data public and our company is obliged as the controller pursuant to Art. 17(1) GDPR to erase the personal data, taking account of available technology and the cost of implementation, we shall take reasonable steps, including technical measures, to inform other con- trollers which are processing the disclosed personal data that the data subject has requested the erasure by these other controllers of any links to, or copy or replication of, those personal data to the extent that processing is not necessary or legally protected.
e) Right to restriction of processing
Every data subject has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If any of the aforementioned grounds apply and a data subject would like to obtain the restriction of personal data we have stored, they may contact us regarding this at any time. We will move to re- strict processing without undue delay.
h) Automated individual decision-making, including profiling
Every data subject has the right granted by the European legislator to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them provided it (1) is not necessary for entering into, or per- formance of, a contract between the data subject and us, or (2) is not authorised by Union or Mem- ber State law to which we are subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or performance of, a contract between the data subject and us or (2) is based on the data subject’s explicit consent, we shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express their point of view and to contest the deci-sion. Any data subject wishing to enforce rights in relation to automated decision-making may contact us regarding this at any time.
12. Privacy statement regarding the application and use of Google Analytics (with anonymization function) We have integrated the Google Analytics component (with anonymization function) into this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites.
A web analytics service collects various data, including data about the website from which a data subject has come to a website (“referrer”), which sub-pages of the website were visited, and how often and for what duration a sub-page was viewed. Web analytics are mainly used to optimise websites and carry out cost-benefit analysis of online advertising. The Google Analytics component is provided by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. The controller uses the “_gat._anonymize” extension for the web analytics via Google Analytics.
By means of this extension, the IP address of the Internet connection of the data subject is truncated and anonymised by Google if our website is accessed from a European Union member state or another country which is a contracting party to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyse traffic on our website. Google uses the data and information thus collected in a number of ways, including to analyse usage of our website, to compile reports on the activities on our website for us and to render further services connected with the usage of our website.
Google Analytics places a cookie on the data subject’s information technology system. We have already explained above what cookies are. When the cookie is placed, Google can analyse usage of our website. Each time individual pages of this website operated by the controller and into which a Google Analytics component has been integrated are accessed, the browser on the data subject’s information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis.
During this technical process, Google gains knowledge of personal data, such as the data subject’s IP address, which Google uses for a number of things, including to determine the origin of visitors and clicks and subsequently create commission settlements. The cookie is used to store personal information, such as the time of access, the location from which the access was made and the frequency of visits to our website by the data subject. Every time our website is visited, these personal data, including the IP address of the Internet connection used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America.
Google may share these personal data collected via this technical process with third parties. Data subjects may prevent cookies being placed by our website, as already described above, at any time by changing their browser settings accordingly so that all cookies are permanently rejected. Configuring the browser used in this way would also prevent Google placing a cookie on the data subject’s information technology system. A cookie already set by Google Analytics may also be deleted at any time via the browser or other software programs. Furthermore, the data subject may object to the data regarding the usage of this website generated by Google Analytics being collected and processed by Google and may prevent such.
If the data subject’s information technology system is subsequently erased, formatted or reinstalled, the data subject must reinstall the browser add-on to disable Google Analytics. If the browser add-on is uninstalled or disabled by the data subject or anybody else within their sphere of influence, the browser add-on can be reinstalled or reactivated.
For more information and the applicable Google privacy provisions, please refer to
Google Analytics is further explained at this link https://www.google.com/intl/de_de/analytics/.
13. Privacy statement regarding the application and use of Google AdWords
We have integrated Google AdWords into this website. Google AdWords is an online advertising service which enables advertisers to place ads in Google search engine results and the Google advertising network. Google AdWords allows advertisers to pre-define specific keywords. An ad is only then displayed in Google search results if the user uses the search engine to perform a search that contains the relevant key-word(s).
In the Google advertising network, ads are allocated to thematically relevant websites using an au-tomatic algorithm, taking into account the previously defined keywords. Google AdWords services are provided by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. The purpose of Google AdWords is to promote our website by showing interest-based advertising on third-party websites and in the search results of the Google search engine and display third-party advertising on our website.
The conversion cookie, if not yet expired, is used to trace whether particular sub-pages, such as the shopping cart of an online shop system, have been visited on our website. Through the conversion cookie, both we and Google can tell whether a data subject who reached our website via an AdWords ad generated a sale, i.e. completed or abandoned a purchase. The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website.
We then use these visit statistics to determine the total number of users that reached us via AdWords ads and thereby determine the success or failure of each AdWords ad and optimise our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that can be used to identify data subjects. The conversion cookie stores personal information, such as the websites visited by the data subject.
Every time our website is visited, personal data, including the IP address of the Internet connection used by the data subject, are therefore transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may share these personal data collected via this technical process with third parties. Data subjects may prevent cookies being placed by our website, as already described above, at any time by changing their browser settings accordingly so that all cookies are permanently rejected.
Configuring the browser used in this way would also prevent Google placing a conversion cookie on the data subject’s in-formation technology system. A cookie already set by Google AdWords may also be deleted at any time via the browser or other software programs. Furthermore, the data subject may object to personalised advertising by Google. For this, the data subject must go to the link www.google.de/settings/ads from every browser they use and change the settings there accordingly. For more information and the applicable Google privacy provisions, please refer to https://www.google.de/intl/de/policies/privacy/.
14. Privacy statement regarding the application and use of LinkedIn
We have integrated components of the LinkedIn Corporation into this website. LinkedIn is an online social network that connects users with existing business contacts and enables them to make new business contacts. LinkedIn has over 400 million registered users in more than 200 countries. This makes LinkedIn the largest professional network at the moment and one of the most visited websites in the world.
If the data subject is logged into LinkedIn at the same time, LinkedIn recognises every time the data subject visits our website and, for the entire duration of their stay on our website, which specific sub-page of our website was visited by the data subject. This information is collected through the LinkedIn component and associated by LinkedIn with the LinkedIn account of the respective data subject.
If the data subject clicks a LinkedIn button integrated into our website, LinkedIn assigns this information to the personal LinkedIn ac-count of the data subject and stores these personal data. LinkedIn is therefore always informed via the LinkedIn component that the data subject has visited our web-site if the data subject is logged into LinkedIn at the same time they visit our website; this occurs regardless of whether or not the data subject clicks on the LinkedIn component. If the data subject does not wish such information to be transmitted to LinkedIn, they can prevent this by logging out of their LinkedIn account before they visit our website.
14. Privacy statement regarding the application and use of YouTube
We have integrated components of YouTube into this website. YouTube is an online video portal that ena-bles video publishers to upload video clips, free of charge, and other users to view, rate and comment on these, also free of charge. YouTube permits the publication of all kinds of videos, which is why entire mov-ies and TV programmes as well as music videos, trailers and user home videos can be accessed via the web portal. YouTube is provided by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Each time individual pages of this website operated by us and into which a YouTube component (YouTube video) has been integrated are accessed, the browser on the data subject’s information technology system is automatically prompted by the respective YouTube component to download a corresponding version of the YouTube component from YouTube.
Further information on YouTube is available at www.youtube.com/yt/about/de/. During this technical process, YouTube and Google gain knowledge of which specific sub-page of our website was visited by the data subject. If the data subject is logged into YouTube at the same time, YouTube recognises which specific sub- page of our website was visited by the data subject when a sub-page containing a YouTube video is visited.
21. Legal basis for the processing
Art. 6(1)(a) GDPR serves as our company’s legal basis for processing operations for which we obtain con-sent for a specific processing purpose. If personal data must be processed to perform a contract to which the data subject is party, as is the case, for example, when processing is necessary for the supply of goods or to provide any other service, including a service in return, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations needed in order to take steps prior to entering into a contract, such as in the case of queries regarding our products or services. If our company is subject to a legal obligation which necessitates the processing of personal data, such as for the fulfilment of our tax obligations, the processing is based on Art.
6(1)(c) GDPR. In rare cases, the processing of personal data may be required in order to protect the vital interests of the data subject or another natural person. This would be the case if, for example, a visitor to our company were injured and his name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6(1)(d) GDPR. Finally, processing operations may be based on Art. 6(1)(f) GDPR.
This is the legal basis for processing operations which are not covered by any of the aforemen-tioned legal grounds if processing is necessary for the purposes of a legitimate interest pursued by our company or a third party and these are not overridden by the interests or fundamental rights and freedoms of the data subject. In particular, we are permitted to perform such processing operations because they have been specifically mentioned by the European legislator. It considers that a legitimate interest can be assumed if the data subject is a client of the controller (Recital 47, Clause 2 GDPR).
15. Legitimate interests in the processing pursued by the controller or a third party
If the processing of personal data is based on Art. 6(1)(f) GDPR, our legitimate interest is to carry out our business activities to the benefit of our employees and shareholders.
16. Duration for which personal data are stored
Personal data are stored in accordance with the relevant statutory retention periods. Once the statutory retention period expires, the corresponding data are routinely erased unless they are still needed to perform or initiate a contract.
We also offer to store your data with your explicit consent beyond the statutory retention period so that we can make placing orders easier in the future or comply with your requests for information.
17. Statutory or contractual requirements regarding the provision of personal data; necessity for contract conclusion; obligation of the data subject to provide the personal data; possible consequences of failure to provide these
Please note that some personal data must be provided by law (e.g. tax regulations) or due to contractual regulations (e.g. details of the contracting party). It can sometimes be necessary for a data subject to pro-vide us with personal data which we then have to process in order to conclude a contract. For example, data subjects are obliged to provide us with personal data when our company concludes a contract with them. If the personal data are not provided, it is not possible to conclude the contract with the data subject. Before the data subject provides personal data, the data subject must contact one of our employees. Our employ-ee makes it clear to the data subject in each instance whether the personal data must be provided for legal or contractual reasons or is necessary for contract conclusion, whether there is an obligation to provide the personal data and what the consequences of not providing the personal data would be.
18. Existence of automated decision-making
As a responsible company, we do not carry out any automated decision-making or profiling activities.