Privacy Policy

We welcome you to our website and thank you for your interest. The protection of your personal data is important to us. Therefore, we conduct our activities in accordance with the applicable laws on the protection of personal data and data security. In the following, we would like to inform you which data from your visit is used and for what purposes.

Data Controller for Processing in Accordance with the GDPR

The controller within the meaning of the General Data Protection Regulation and other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is:

Bitburger Braugruppe GmbH
Römermauer 3
54643 Bitburg
Telephone: +49-6561-14-0
E-mail: info@bitburger-braugruppe.de

Data Protection Officer

Sebastian Feldmann, Keyed GmbH
Siemensstrasse 12
48341 Altenberge
E-mail: datenschutz@bitburger-braugruppe.de

What Is Personal Data?

The term “personal data” is defined in the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and the European GDPR. According to this standard, this is individual information about the personal or material circumstances of an identified or identifiable natural person. This includes, for example, your real name, your address, your telephone number, or your date of birth. Find out more here about what data protection means exactly.

Scope of Anonymous Data Collection and Processing

Unless otherwise stated in the following sections, no personal data is collected, processed, or used when you use our website. However, we learn certain technical information about the use of analytics and tracking tools based on the data transmitted by your browser (e.g., browser type/version, operating system, and websites of ours you have visited, including the time spent and website visited previously). We only analyze this information for statistical purposes.

Relevant Legal Grounds for the Processing of Personal Data

a.    If we obtain the data subject’s consent to the processing of personal data, Art. 6 (1) (a) of the General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
b.    GDPR Art. 6(1)(b) serves as the legal basis for the processing of personal data necessary for the performance of a contract to which the data subject is a party. This also applies to processing that is necessary for taking steps prior to entering into a contract.
c.    Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, GDPR Art. 6(1)(c) serves as the legal basis.
d.    If the vital interests of the data subject or another natural person necessitate the processing of personal data, GDPR Art. 6(1)(d) serves as the legal basis.
e.    If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights, and freedoms of the data subject do not outweigh the former interest, GDPR Art. 6 (1)(f) serves as the legal basis for the processing.

Use of Cookies

The websites of Bitburger Braugruppe GmbH use cookies. Cookies are data that is stored by the internet browser on the user’s computer system. Cookies can be transferred to a website when it is visited, making it possible to establish who the user is. Cookies help to simplify the usage of the websites for users.

It is possible at all times to object to cookies being set by changing the corresponding settings in the internet browser. Cookies that have been set can be erased. Be aware that deactivating cookies may potentially mean that not all functions of our website can be used to their full extent. The user data collected in this manner is made pseudonymous using technical precautions. Consequently, it ceases to be possible to link the data to the visiting user. The data is not stored together with other personal data of the users. When visiting our website, an information banner informs users about cookies being used for analytical purposes and refers them to this privacy policy. It also indicates how the browser settings can be changed to stop cookies being saved. The legal basis for processing personal data with the usage of technically necessary cookies is GDPR Art. 6(1)(f). If the user has given his or her consent, the legal basis for processing personal data with the usage of cookies for analysis purposes is GDPR Art. 6(1)(a). Please see our cookie banner and our notes in this privacy policy to know if and to what extent cookies are used on our website.

Friendly Captcha

Description and purpose
This website uses the “friendly captcha” service (www.friendlycaptcha.com). This service is offered by the provider Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee, Germany. Friendly Captcha is a new type of protection solution which is data protection friendly and has a purpose of making it more difficult for automated programs and scripts (“bots”) to use this website. In this context, we have integrated a program code from Friendly Captcha into our website (e.g., for contact forms) so that the visitor’s device can create a connection with the Friendly Captcha servers and receive an arithmetic puzzle from Friendly Captcha. The relevant visitor’s device solves the arithmetic puzzle, which utilizes certain system resources, and sends the result of the calculation to our Web server. This Web server contacts the Friendly Captcha server via an interface and receives a response about whether the puzzle was correctly solved by the device. Depending on the result, we may add security rules to requests through our website and, in doing so, process them further or reject them, for example.

Friendly Captcha processes and stores the following data during the above process:

• anonymized IP address of the requesting computer
• information about the browser used and the operating system
• anonymized counter for each IP address to manage the cryptographic challenges
• website from which access was made
• widget version
• time stamp

This data is used exclusively for protection against spam and bots as described above. Friendly Captcha does not set or read any cookies on the visitor’s device. IP addresses are only stored as hashes (using one-way encryption) and do not allow us or Friendly Captcha to make inferences about an individual person.

Legal basis
The legal basis for the processing is our overriding legitimate interests in protecting our website against misuse by bots, i.e., protection against spam and attacks (e.g., mass requests), GDPR Art. 6(1)(f).

Recipient
The recipient is Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee.

Objection
You have the right under GDPR Art. 21(1) to object at any time to the processing of your personal data. If you make use of your right, processing will no longer take place for this purpose. You can find more information about this further up in our privacy policy under “Rights of Data Subjects.”

Transfer to third countries
There is no transfer of data to a third country.

Duration of data storage
If personal data is collected, it is erased after no more than 30 days.

Contractual or statutory obligation
There does not exist any contractual or statutory obligation for the provision of personal data.

Further information about data protection
Further information about data protection when Friendly Captcha is used can be found at https://friendlycaptcha.com/legal/privacy-end-users/. 

Creation of Log Files

Any time the website is viewed, Bitburger Braugruppe GmbH collects data and information through an automated system. This data and information is stored in the server’s log files. The data is also stored in our system’s log files. It is not stored together with the user’s other personal data.

The following data may be collected as part of this:
(1) Information about the user’s browser type and version used
(2) The user’s operating system
(3) The user’s internet service provider
(4) The user’s IP address
(5) The date and time of access
(6) Websites from which the user’s system accessed our website (referrers)
(7) Websites to which the user’s system navigates from our website

Duration of Storage of Personal Data

Personal data is stored for the duration of the relevant statutory retention period. Once this period has expired, the data will be routinely deleted, unless it is necessary for initiating or fulfilling a contract.

Contact Options

The websites of Bitburger Braugruppe GmbH possess a contact form which can be used for electronic contact. Alternatively, you can contact us using the email address provided. If the data subject contacts the controller through one of these channels, the personal data transmitted by the data subject is automatically stored. The data is stored solely for the purposes of processing or contacting the data subject. Data will not be disclosed to third parties. If the user has given their consent, the legal basis for processing the data is GDPR Art. 6(1)(a). The legal basis for the processing of data transmitted in the course of sending an email is GDPR Art. 6(1)(f). If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is GDPR Art. 6(1)(b). The data is erased as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input screen of the contact form and the data sent by email, this is the case when the conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

Newsletter

When our company’s newsletter is subscribed to, the data in the relevant input screen is transferred to the controller. It is also transferred to our newsletter management contractor Inxmail GmbH, Wentzingerstr. 17, 79106 Freiburg, Germany. Our newsletter sign-up uses the double opt-in method. This means you receive an e-mail after you sign up asking you to confirm that you have signed up. This confirmation is necessary so that no one can sign up using a stranger’s e-mail address. The user’s IP address and the date and time of registration are stored when signing up for the newsletter. The purpose of this is to prevent misuse of the services and of the data subject’s e-mail address. Data is not disclosed to unauthorized third parties. However, necessary data may be transferred to corresponding contractors for the purpose of sending the newsletter. There is also an exception when there is a legal obligation to disclose data. The data is used solely for sending the newsletter. The data subject can cancel the subscription to the newsletter at any time. Consent to the storage of personal data may also be withdrawn at any time. A corresponding link is provided for this purpose in each newsletter. If the user has given their consent, the legal basis for processing the data after the user signs up for the newsletter is GDPR Art. 6(1)(a). The legal basis for sending the newsletter after the sale of goods or services is German Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb, UWG) section 7(3).

Routine Erasure and Blocking of Personal Data

The controller processes and stores the personal data of the data subject only for as long as is necessary to achieve the purpose of the storage. Data may also be stored if this has been provided for by European or national legislators in EU regulations, laws, or other provisions to which the controller is subject. Personal data is routinely blocked or erased as soon as the purpose of storage ceases to apply or a storage period prescribed by the aforementioned regulations expires.

Rights of the Data Subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights to exercise against the controller:

Right of Access Pursuant to GDPR Art. 15

You may request confirmation from the controller as to whether or not personal data concerning you is being processed by us. In the event of such processing, you may request the following information from the controller:

a.    the purposes for which the personal data is being processed;
b.    the categories of personal data being processed;
c.    the recipients or categories of recipients to whom your personal data has been or will be disclosed;
d.    the planned period for which your personal data will be stored or, if it is not possible to provide specific information, the criteria for determining the period for which it will be stored;
e.    the existence of a right to rectification or erasure of your personal data, a right to restriction of processing by the controller, or a right to object to such processing;
f.    the existence of a right to lodge a complaint with a supervisory authority;
g.    all available information on the source of the data where the personal data is not collected from the data subject;
h.    the existence of automated decision-making, including profiling pursuant to GDPR Art. 22(1) and (4) and, at least in those cases, meaningful information about the logic involved and the significance and intended consequences of such processing for the data subject.

You have the right to request information as to whether your personal data is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to GDPR Art. 46 in connection with the transfer.

Right to Rectification Pursuant to GDPR Art. 16

You have the right to obtain from the controller rectification and/or completion if the processed personal data concerning you is inaccurate or incomplete. The controller must make the rectification without delay.

Right to Erasure Pursuant to GDPR Art. 17

(1) You may demand that the controller erase your personal data without undue delay, and the controller is obligated to erase such data without undue delay if one of the following reasons applies:

a.    The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
b.    You revoke your consent on which the processing was based in accordance with GDPR Art. 6(1)(a) or Art. 9(2)(a), and there is no other legal basis for the processing.
c.    You object to the processing pursuant to GDPR Art. 21(1) and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to GDPR Art. 21(2).
d.    The personal data concerning you has been unlawfully processed.
e.    The erasure of the personal data concerning you is necessary to comply with a legal obligation under Union or member state law to which the controller is subject.
f.    The personal data concerning you was collected in relation to information society services offered pursuant to GDPR Art. 8(1).

(2) If the controller has made your personal data public and is obligated to erase your personal data pursuant to GDPR Art. 17(1), the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that you, as the data subject, have requested the erasure by them of any links to, or copy or replication of, those personal data.

(3) The right to erasure does not exist insofar as processing is necessary

a.    to exercise the right to freedom of expression and information;
b.    to comply with a legal obligation requiring processing under Union or member state law to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
c.    for reasons of public interest in the area of public health pursuant to GDPR Art. 9(2)(h) and (i) and GDPR Art. 9(3);
d.    for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to GDPR Art. 89(1), insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of such processing; or
e.    to assert, exercise, or defend against legal claims.

Right to Restriction of Processing Pursuant to GDPR Art. 18

You may request the restriction of the processing of your personal data under the following conditions:

a.    if you dispute the accuracy of your personal data for a period that allows the controller to verify the accuracy of the personal data;
b.    the processing is unlawful and you object to the erasure of the personal data and instead request that the use of the personal data be restricted;
c.    the controller no longer needs the personal data for the purposes of the processing, but you need it for the establishment, exercise, or defense of legal claims; or
d.    if you have objected to processing pursuant to GDPR Art. 21(1) and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.

Where processing of your personal data has been restricted, such data may, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or a member state. If the restriction of processing has been restricted in accordance with the aforementioned conditions, you will be informed by the controller before the restriction is lifted.

Right to Information Pursuant to GDPR Art. 19

If you have asserted the right to rectification, erasure, or restriction of processing vis-à-vis the controller, the controller is obligated to inform all recipients to whom the personal data concerning you has been disclosed of such rectification or erasure of the data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right vis-à-vis the controller to be informed about these recipients.

Right to Data Portability Pursuant to GDPR Art. 20

You have the right to receive your personal data, which you have provided to the controller, in a structured, commonly used, and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data have been provided, provided that:

a.    the processing is based on consent pursuant to GDPR Art. 6(1)(a) or GDPR Art. 9(2)(a), or on a contract pursuant to GDPR Art. 6(1)(b), and
b.    Processing is carried out by automated means. In exercising this right, you also have the right to have your personal data transmitted directly from one controller to another, insofar as this is technically feasible. The freedoms and rights of others may not be affected by this. The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right to Object Pursuant to GDPR Art. 21

You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data which is based on point (e) or (f) of GDPR Art. 6(1), including profiling based on these provisions. The controller shall no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, including profiling, to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes. In connection with the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

Right to Withdraw Consent Under Data Protection Law Pursuant to GDPR Art. 7(3)

You have the right to revoke your consent to data processing at any time. The withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of the consent prior to its withdrawal.

Right to Lodge a Complaint with a Supervisory Authority Pursuant to GDPR Art. 77

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your residence, place of work or place of the alleged infringement, if you believe that the processing of your personal data infringes the GDPR. The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to GDPR Art. 77.

Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, that has legal consequences for you or significantly affects you in a similar manner. This does not apply if the decision:

a.    is necessary for entering into, or performance of, a contract between you and the controller;
b.    is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
c.    is based on your explicit consent.

However, these decisions must not be based on special categories of personal data referred to in GDPR Art. 9(1), unless point (a) or (g) of Art. 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

In the cases referred to in points (a) and (c), the data controller implements suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view, and to contest the decision.

Integration of Other Services and Third-Party Content

Description and purpose
It may transpire that this online offering integrates content from third parties, including for example videos, fonts, or graphics from other websites. An absolute requirement for this is that the providers of this content (referred to below as “third-party providers”) obtain the user’s IP address. Without the IP address, they would not be able to send the content to the relevant user’s browser. This means that the IP address is required for the presentation of this content. We endeavor to use such content only when the relevant provider uses the IP address solely to deliver the content. However, we do not have any influence over the possibility of the third-party providers storing the IP address for purposes such as statistics. If we are aware of this, we explain this to users. In integrating such content, we seek to provide and improve our online offering.

Legal basis
The legal basis for the integration of other services and content of third parties is GDPR Art. 6(1)(f). Our overriding legitimate interest is our intention to display our online presence accordingly and to provide user-friendly and cost-effective services. Please see the providers’ data protection information for further advice.

Contractual or statutory obligation for the provision of personal data
It is not required by law or contract to provide the personal data and it is also not necessary for entering into a contract. This means that you are also not compelled to supply your personal data. However, in certain circumstances, not providing the data may mean that you cannot use this function or not use it to its full extent.

Data Transfers to Third Countries

The controller may potentially transfer personal data to a third country. Generally, the controller may apply various appropriate safeguards to ensure that an adequate level of data protection is provided for the processing. There exists the possibility of transferring data based on an adequacy decision, binding corporate rules, an approved code of conduct, standard data protection clauses, or an approved certification mechanism in accordance with GDPR Art. 46(2)(a) to (f).

If the controller transfers data to a third country on the legal ground of GDPR Art. 49(1)(a), you will be informed here about the potential risks of transferring data to a third country.

There exists a risk that the third country receiving your personal data will not offer a level of protection equivalent to the protection of personal data in the European Union. For example, this may be the case if the European Commission has not released an adequacy decision for the relevant third country or specific agreements between the European Union and the relevant third country are declared invalid. Specifically, surveillance laws in some third countries create risks in relation to the effective protection of the EU’s fundamental rights (for example the US). In such cases, it is the controller’s and recipient’s responsibility to assess if the rights of the data subject enjoy a level of protection equivalent to the European Union in the third country and if these rights can also be asserted effectively.

However, when personal data is transferred from the European Union to controllers, processors, or other recipients in third countries or to international organizations, the level of protection of natural persons ensured in the European Union by the General Data Protection Regulation should not be undermined, including in cases of onward transfers of personal data from the third country or international organization to controllers or processors in the same or another third country or to the same or another international organization.

Further Website Functions

eTracker

Description and purpose
The provider of this website uses services from etracker GmbH to analyze usage data (tracking data). Cookies are set as part of this to enable a statistical analysis of the use of this website by its users and enable the display of usage-related content or advertisements. Cookies are small text files that are stored on the user’s device by his or her internet browser. etracker cookies do not contain any information that enable identification of a user.

Legal basis
The legal basis for the processing of your personal data is GDPR Art. 6(1)(a).

Recipient
The recipient of your personal data is etracker GmbH (Erste Brunnenstrasse 1, 20459 Hamburg, Germany).

Transfer to third countries
Your personal data is not transferred to a third country. However, we are conscious of our responsibility and regularly review the wider context and changes in laws. In the event that data is transferred to a third country, we will adjust this information as quickly as possible.

Duration of data storage
The data is erased as soon as it is no longer required to achieve the purpose for which it was collected. Moreover, the data is erased if you claim your right to erasure within the meaning of GDPR Art. 17(1).

Withdrawal of consent
You have the right to withdraw at any time the consent that you have given; see GDPR Art. 7(3) first sentence. This can be done informally and without giving reason, and has effect on future processing. The withdrawal of consent does not affect the lawfulness of the processing carried out prior to the withdrawal of consent. You can find more information about this further up in our privacy policy under “Rights of Data Subjects.”

Contractual or statutory obligation
There does not exist any contractual or statutory obligation for the provision of personal data.

Further information about data protection
You can find further information about the processing of your personal data here: https://www.etracker.com/en/data-privacy/

Google Fonts

Description and purpose
We use Google Fonts (Google LLC. 1600 Amphitheatre Parkway, Mountain View, CA 94043, US). These Web fonts are integrated by accessing a server when you visit our website and the IP addresses of the device’s browser are stored. 

Legal basis
The legal basis for the processing of your personal data is GDPR Art. 6(1)(a).

Recipient
The recipient of your personal data is Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043, US).

Transfer to third countries
The personal data is transferred to the United States. The transfer is subject to appropriate safeguards in accordance with GDPR Art. 46. To this end, we have agreed appropriate safeguards within the meaning of GDPR Art. 46(2) with the data importer where necessary. Furthermore, we are conscious of our responsibility and, where necessary, take further measures to protect the rights and freedoms of natural persons, ensuring the protection of personal data.

Duration of data storage 
The data is erased as soon as it is no longer required to achieve the purpose for which it was collected. Moreover, the data is erased if you claim your right to erasure within the meaning of GDPR Art. 17(1).

Withdrawal of consent
You have the right to withdraw at any time the consent that you have given; see GDPR Art. 7(3) first sentence. This can be done informally and without giving reason, and has effect on future processing. The withdrawal of consent does not affect the lawfulness of the processing carried out prior to the withdrawal of consent. You can find more information about this further up in our privacy policy under “Rights of Data Subjects.”

Contractual or statutory obligation 
There does not exist any contractual or statutory obligation for the provision of personal data.

Further information about data protection 
You can find further information about the processing of your personal data here:  https://www.google.com/policies/privacy.

Data Recipients

We also share your personal data with other recipients that perform services for us where this is legally permissible or required, or if you have given your consent. We limit the disclosure of your personal data to the degree that is necessary. Some of our service providers receive your personal data in their capacity as processors and, in this case, are strictly required to follow our instructions when handling your personal data (processing agreement under GDPR Art. 28). In some cases, the recipients act independently using the data of yours that we transfer to them. The following categories of service providers/recipients may receive your data:

• providers of e-mail marketing via the newsletters (Inxmail)
• providers of hosting services for the operation of our servers
• service providers for job application management to assist in the selection of applicants
• service providers for development work, including software programming, development, maintenance, and support
• providers of postal services
• external legal counsel
• marketing/ website agencies
• further IT service providers (e.g., systems houses)
• other services and tools

The service providers that we contract must meet strict confidentiality requirements. They only receive the level of access to your data that is necessary to complete the tasks assigned to them.

If there is a suspicion of crime, data may be disclosed to criminal prosecution authorities.

Security

We have implemented comprehensive technical and operational safeguards to protect your data from accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. Our security procedures are regularly reviewed and adapted to keep pace with technological advancements. In addition, data protection is guaranteed on an ongoing basis by means of constant auditing and optimization of the data protection organization.

End

Bitburger Braugruppe GmbH reserves all rights to make changes and updates to this privacy policy. This privacy policy has been generated by Keyed GmbH.