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Privacy Agreement

Data Protection Declaration Pursuant to GDPR

I. Name and Address of the Party Responsible

The party responsible within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other provisions of data protection law is:

Sugatsune Europe GmbH
Heerdter Lohweg 87-89
D-40549 Düsseldorf
Tel.: +49 (0) 211-53812-900
E-Mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
Website: www.sugatsune.eu

II. Name and Address of the Data Protection Officer

The data protection officer of the responsible party is:

Sugatsune Europe GmbH
Heerdter Lohweg 87-89
D-40549 Düsseldorf
Tel.: +49 (0) 211-53812-900
E-Mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
Website: www.sugatsune.eu

III. General Information on Data Processing

1. Scope of Personal Data Processing

We only process the personal data of our users if this is necessary in order to provide a functional website as well as our contents and services. As a rule processing of the personal data of our users takes place only after consent has been given by the user. An exception applies in those cases in which prior consent cannot be obtained for practical reasons and the processing of data is permitted by statutory provisions.

2. Legal Basis for the Processing of Personal Data

Article 6 Paragraph 1 lit. a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis insofar as we obtain the consent of the data subject for the processing of personal data.

In the processing of personal data required for the performance of a contract to which the data subject is a party, the legal basis is provided by Article 6 Paragraph 1 lit. b) GDPR. This also applies to processing operations required in order to carry out pre-contractual measures.

Article 6 Paragraph 1 lit. c) of the EU General Data Protection Regulation (GDPR) provides the legal basis insofar as the processing of personal data is required to comply with a legal obligation to which our company is subject.

In the event that the vital interests of the data subject or another natural person require the processing of personal data, then Article 6 Paragraph 1 lit. d) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

If processing is necessary to safeguard a legitimate interest on the part of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh this interest, then Article 6 Paragraph 1 lit. f) of the EU General Data Protection Regulation (GDPR) shall provide the legal basis for such processing.

3. Data Deletion and Storage Period

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. However, data may continue to be stored if this has been provided for by European or national legislators in EU regulations, laws or other provisions to which the responsible party is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for conclusion or fulfilment of a contract.

IV. Provision of the Website and Creation of Log Files

1. Description and Scope of Data Processing

Each time you visit our website our system automatically collects data and information from the computer system of the invoking computer.

The following data is collected:

  • Information about the browser type and version used
  • The user‘s operating system
  • The IP address of the user
  • Date and time of access
  • Websites accessed by the user’s system via our website

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Legal Basis for Data Processing

The legal basis for the temporary storage of data and log files is Article 6 Paragraph 1 lit. f) of the EU General Data Protection Regulation (GDPR).

3. Purpose of Data Processing

Temporary storage of the IP address by the system is required in order to enable the website to be delivered to the user’s computer. For this purpose the user’s IP address must remain stored for the duration of the session.

The data is stored in log files to ensure the functionality of the website. In addition, the data serves us in order to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also constitute our legitimate interest in data processing in accordance with Article 6 Paragraph 1 lit. f) of the EU General Data Protection Regulation (GDPR).

4. Duration of Storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session is terminated.

If the data is stored in log files, then this is the case after seven days at the latest. Further storage is possible. In this case the IP addresses of the users are deleted or anonymised so that assignment of the invoking client is no longer possible.

5. Possibility of Objection and Removal

The collection of data for provision of the website and the storage of data in log files is absolutely necessary for operation of the website. Consequently, there is no possibility of objection on the part of the user.

V. Use of Cookies

a) Description and Scope of Data Processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. If a user visits a website, then a cookie may be stored on the user’s operating system. This cookie contains a characteristic string that uniquely identifies the browser when the website is reloaded.

We use cookies to make our website more user-friendly. Some elements of our website require that the invoking browser can also be identified after a page change.

The following data is stored and transmitted in the cookies:

  • Session number

b) Legal Basis for Data Processing

The legal basis for the processing of personal data using cookies is Article 6 Paragraph 1 lit. f) of the EU General Data Protection Regulation (GDPR).

c) Purpose of Data Processing

The purpose of using technically required cookies is to simplify the use of websites for users. Some of the functions of our website cannot be offered without using cookies. For these it is necessary that the browser is also recognised after a page change.

We require cookies for the following applications:

  • Session number

The user data collected by technically required cookies are not used to create user profiles.

These purposes also constitute our legitimate interest in data processing in accordance with Article 6 Paragraph 1 lit. f) of the EU General Data Protection Regulation (GDPR).

d) Duration of Storage, Possibility of Objection and Removal

Cookies are stored on the user’s computer and transmitted to our site. Therefore, you as a user also have complete control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, then it may no longer be possible to use all of the functions of the website in full.

VI. Newsletter

1. Description and Scope of Data Processing

You can subscribe to a free newsletter on our website. When registering for the newsletter, the data from the input mask are transmitted to us.

The following data may be collected:

  • E-mail address
  • Language selection (optional)
  • Name (optional)
  • First name (optional)
  • Company (optional)

In addition, the following data is collected during registration:

(1) IP address of the invoking computer

(2) Date and time of registration

Within the scope of the registration process your consent is obtained for processing of the data and reference is made to this data protection declaration.

No data is passed on to third parties in connection with data processing for the dispatch of newsletters. The data will only be used for sending the newsletter.

2. Legal Basis for Data Processing

The legal basis for the processing of data after registration for the newsletter by the user and given the user’s consent is Article 6 Paragraph 1 lit. a) of the EU General Data Protection Regulation (GDPR).

3. Purpose of Data Processing

Collection of the user’s e-mail address serves to send the newsletter.

The collection of other personal data within the scope of the registration process serves to prevent misuse of the services or the e-mail address used.

4. Duration of Storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The user’s e-mail address will therefore be stored for as long as the subscription to the newsletter is active.

Other personal data collected within the scope of the registration process will generally be deleted after a period of seven days.

5. Possibility of Objection and Removal

The subscription to the newsletter can be cancelled by the user concerned at any time. For this purpose there is a corresponding link in every newsletter.

This also makes it possible to revoke consent to the storage of personal data collected during the registration process.

VII. Contact Form and E-mail Contact

1. Description and Scope of Data Processing

There is a contact form on our website that can be used for electronic contact. If a user takes advantage of this possibility, then the data entered in the input mask will be transmitted to us and stored. This data includes:

The following data may be collected:

  • E-mail address
  • Name (optional)
  • First name (optional)
  • Company (optional)

In addition, the following data is collected during registration:

(1) IP address of the invoking computer

(2) Date and time of registration

Your consent is obtained for the processing of the data within the scope of the sending process and reference is made to this data protection declaration.

Alternatively, you can contact us via the e-mail address provided. In this case the user’s personal data transmitted via e-mail will be stored.

In this context the data will not be passed on to third parties. The data is used exclusively for processing the conversation.

2. Legal Basis for Data Processing

The legal basis for the processing of data if the user has given consent is Article 6 Paragraph 1 lit. a) of the EU General Data Protection Regulation (GDPR).

The legal basis for the processing of data transmitted in the course of sending an e-mail is Article 6 Paragraph 1 lit. f) of the EU General Data Protection Regulation (GDPR). If the e-mail contact is aimed at conclusion of a contract, then the additional legal basis for the processing is Article 6 Paragraph 1 lit. b) of the EU General Data Protection Regulation (GDPR).

3. Purpose of Data Processing

We process personal data from the input mask only in order to establish contact. In the event of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the respective data.

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of Storage

The data will be deleted as soon as they are no longer required in order to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and data sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be inferred from the respective circumstances that the matter in question has finally been settled.

The additional personal data collected during the sending process will be deleted at the latest after a period of seven days.

5. Possibility of Objection and Removal

The user has the possibility to revoke consent to the processing of personal data at any time. If the user contacts us by e-mail, then the user may object to the storage of his or her personal data at any time. In this case the conversation cannot be continued.

A description follows on how revocation of consent and objection to storage is made possible.

In this case any personal data stored in the course of contacting us will be deleted.

VIII. Rights of the Data Subject

The following list includes all of the rights of the data subjects in accordance with GDPR. Rights which are not relevant for the company’s own website need not be specified. In this respect, the list can be shortened.

If your personal data are processed, then you are the data subject within the meaning of GDPR and you have the following rights vis-à-vis the party responsible:

1. Right to Access

You can request that the responsible party confirms whether or not personal data related to you will be processed by us.

If such processing has taken place, then you may request the following information from the party responsible:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data being processed;

(3) the recipients or categories of recipients to whom the personal data related to you have been or are still being disclosed;

(4) the planned duration of storage of the personal data related to you or, if specific information is not possible in this regard, criteria for determining the storage period;

(5) the existence of a right to rectification or deletion of personal data related to you, a right to restriction of processing by the controller or a right to object to such processing;

(6) the existence of a right to lodge a complaint with a supervisory authority;

(7) any available information on the origin of the data if the personal data are not collected from the data subject;

(8) the existence of automated decision-making, including profiling in accordance with Article 22 Paragraphs 1 and 4 of the EU General Data Protection Regulation (GDPR) and – at least in these cases – sound information on the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data related to you is transferred to a third country or to an international organisation. In this context you may request that you be informed of the appropriate safeguards in accordance with Article 46 of the EU General Data Protection Regulation (GDPR) in connection with such transfer.

2. Right to Rectification

You have a right to rectification and/or completion vis-à-vis the data controller if the processed personal data related to you are inaccurate or incomplete. The controller shall make the correction without delay.

3. Right to Restriction of Processing

You can request restriction of the processing of personal data related to you under the following conditions:

(1) if you dispute the accuracy of the personal data related to you for a period enabling the controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you oppose erasure of the personal data and instead request that use of the personal data be restricted;

(3) the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, or

(4) if you have objected to processing pursuant to Article 21 Paragraph 1 GDPR pending verification whether the legitimate grounds of the controller override your own.

If the processing of personal data related to you has been restricted, then such data may only be processed – apart from being stored – with your consent or for the purpose of establishment, exercise or defence 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 of a Member State.

If the processing restriction has been constrained in accordance with the above prerequisites, then you will be informed by the controller before the restriction is lifted.

4. Right to Erasure

a) Erasure Obligation

You may request that the controller immediately erases the personal data related to you and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(1) The personal data related to you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You revoke your consent on which the processing is based in accordance with Article 6 Paragraph 1 lit. a) or Article 9 Paragraph 2 lit. a) of the EU General Data Protection Regulation (GDPR), and where there is no other legal ground for the processing.

(3) You object to the processing pursuant to Article 21 Paragraph 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 Paragraph 2 GDPR.

(4) The personal data related to you have been unlawfully processed.

(5) The deletion of personal data related to you have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

(6) The personal data related to you have been collected in relation to the offer of information society services referred to in accordance with Article 8 Paragraph 1 of the EU General Data Protection Regulation (GDPR).

b) Information to third parties

If the data controller has made the personal data related to you public and is obliged to delete such in accordance with Article 17 Paragraph 1 of the EU General Data Protection Regulation (GDPR), then the controller, taking into account the available technology and the cost of implementation, shall take reasonable steps, including technical measures to inform data processors who process the personal data, that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.

c) Exceptions

The right to erasure shall not apply insofar as processing is necessary

(1) for exercising the freedom of expression and information;

(2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(3) for reasons of public interest in the area of public health in accordance with Article 9 Paragraph 2 lit. h) and i) as well as Article 9 Paragraph 3 of the EU General Data Protection Regulation (GDPR);

(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 Paragraph 1 GDPR in so far as the right referred to in Section a is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(5) for the establishment, exercise or defence of legal claims.

5. Right to be Informed

If you have exercised your right to have the processing corrected, deleted or restricted, then the controller is obliged to inform all recipients to whom the personal data related to you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves disproportionate effort.

You have the right vis-à-vis the party responsible to be informed of these recipients.

6. Right to Data Portability

You have the right to receive the personal data related to you that you have provided to the party responsible in a structured, commonly used and machine-readable format. In addition, you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where

(1) the processing is based on consent in accordance with Article 6 Paragraph 1 lit. a) of the EU General Data Protection Regulation (GDPR) or Article 9 Paragraph 2 lit. a) GDPR or on a contract pursuant to Article 6 Paragraph 1 lit. b) and

(2) the processing is carried out by automated means.

In exercising this right, you also have the right to request that the personal data related to you be transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons may not be affected by this.

The right to portability shall 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.

7. Right to Object

You have the right to object at any time, for reasons arising out of your particular situation, to the processing of personal data related to you under Article 6 Paragraph 1 lit. e) or f) of the EU General Data Protection Regulation (GDPR); this also applies to profiling based on these provisions.

The data controller shall no longer processes the personal data related to you, unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves to establish, exercise or defend legal claims.

If the personal data related to you are processed for direct marketing purposes, then you have the right to object at any time to the processing of the personal data related to you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing.

If you object to the processing for direct marketing purposes, then the personal data related to you will no longer be processed for these purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you have the possibility to exercise your right to object by automated means using technical specifications.

8. Right to Revoke the Data Protection Declaration of Consent

You have the right to revoke your data protection declaration of consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until revocation.

9. Automated Individual Decision-making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or significantly affects you in a similar manner. This does not apply if the decision

(1) is necessary for entering into or performance of a contract between you and the party responsible,

(2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or

(3) is based on your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Article 9 Paragraph 1 of the EU General Data Protection Regulation (GDPR), unless Article 9 Paragraph 2 lit. a) or g) GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

In the cases referred to in (1) and (3) the controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, which include at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

10. Right to Lodge a Complaint with a Supervisory Authority

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 habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relate to you violates the EU General Data Protection Regulation (GDPR).

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 of the EU General Data Protection Regulation (GDPR).


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