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Privacy Policy
Privacy Policy
Abal Security Group Ltd Privacy Policy
Abal Security Group Ltd believe that Data Protection is of the utmost
importance and it is possible to use our website freely without any
indication of personal data: however, if a data subject (person) wishes
to request a call-back, a quote or specific information via our website
then processing of personal data can become necessary. If the processing
of personal data is necessary and there is no statutory basis for such
processing, we generally obtain consent from the data subject (person).
The processing of personal data, such as the name, address, e-mail
address, or telephone number of a data subject shall always be in line
with the General Data Protection Regulation (GDPR), and in accordance
with the country-specific data protection regulations applicable to Abal
Security Group Ltd. By means of this data protection declaration, our
enterprise would like to inform the general public of the nature, scope,
and purpose of the personal data we collect, use and process.
Furthermore, data subjects are informed, by means of this data
protection declaration, of the rights to which they are entitled.
Abal Security Group Ltd is the Data Controller and as such we have
implemented a number of technical and organizational measures to ensure
the most complete protection of all personal data processed through our
website and CRM (Customer Relationship Management) systems.
However, in some occasions internet-based data transmissions may in
principle have security gaps, so absolute protection may not be
guaranteed. For this reason, every data subject is free to transfer
personal data to us via alternative means such as telephone if they
wish.
1. Definitions
The data protection declaration of Abal Security Group Ltd is based on
the terms used by the European legislator for the adoption of the
General Data Protection Regulation (GDPR). Our data protection
declaration should be legible and understandable in plain English for
the general public, as well as our customers and business partners. To
ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use amongst others, the following terms:
• a) Personal data
Personal data means any information relating to an identified or
identifiable natural person (“data subject”). 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
Data subject is any identified or identifiable natural person, whose
personal data is processed by the controller responsible for the
processing.
• c) Processing
Processing is 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 transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure or destruction.
• d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
• e) Profiling
Profiling means any form of automated processing of personal data
consisting of the use of personal 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.
• f) Pseudonymisation
Pseudonymisation is 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, provided that such
additional information is kept separately and is subject to technical
and organisational measures to ensure that the personal data is not
attributed to an identified or identifiable natural person.
• g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is 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.
• h) Processor
Processor is a natural or legal person, public authority, agency or
other body which processes personal data on behalf of the controller.
• i) Recipient
Recipient is 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; the processing
of those data by those public authorities shall be in compliance with
the applicable data protection rules according to the purposes of the
processing.
• j) Third party
Third party is 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 processor, are
authorised to process personal data.
• k) Consent
Consent of the data subect is 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, signifies agreement to
the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation
(GDPR), other data protection laws applicable in Member states of the
European Union and other provisions related to data protection is:
Abal Security Group Ltd
162 Dock Street,
Fleetwood, FY7 6JB
United Kingdom
Phone: 07845 416 722
Email: info@abalsecuritygroup.co.uk
Website: www.abalsecuritygroup.co.uk
3. Name and Address of the Data Protection Officer
The Data Protection Officer of the controller is:
Head of Compliance - Ian McNamara
Abal Security Group Ltd
162 Dock Street,
Fleetwood, FY7 6JB
United Kingdom
Phone: 07845 416 722
Website: www.abalsecuritygroup.co.uk
Any data subject may, at any time, can contact our Data Protection
Officer directly with all questions and suggestions concerning data
protection.
4. Collection of general data and information
The website of Abal Security Group Ltd collects a series of general data
and information when a data subject or automated system calls up the
website. This general data and information are stored in the server log
files. Collected may be (1) the browser types and versions used, (2) the
operating system used by the accessing system, (3) the website from
which an accessing system reaches our website (so-called referrers), (4)
the sub-websites, (5) the date and time of access to the Internet site,
(6) an Internet protocol address (IP address), (7) the Internet service
provider of the accessing system, and (8) any other similar data and
information that may be used in the event of attacks on our information
technology systems.
When using these general data and information, Abal Security Group Ltd
does not draw any conclusions about the data subject. Rather, this
information is needed to (1) deliver the content of our website
correctly, (2) optimize the content of our website as well as its
advertisement, (3) ensure the long-term viability of our information
technology systems and website technology, and (4) provide law
enforcement authorities with the information necessary for criminal
prosecution in case of a cyber-attack. Therefore, Abal Security Group
Ltd analyses anonymously collected data and information statistically,
with the aim of increasing the data protection and data security of our
enterprise, and to ensure an optimal level of protection for the
personal data we process. The anonymous data of the server log files are
stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to register on the website of the
controller with the indication of personal data. Which personal data is
transmitted to the controller is determined by the respective input mask
used for the registration. The personal data entered by the data
subject are collected and stored exclusively for internal use by the
controller, and for his own purposes. The controller may request
transfer to one or more processors (e.g. a parcel service) that also
uses personal data for an internal purpose which is attributable to the
controller.
By registering on the website of the controller, the IP address—assigned
by the Internet service provider (ISP) and used by the data
subject—date, and time of the registration are also stored. The storage
of this data takes place against the background that this is the only
way to prevent the misuse of our services, and, if necessary, to make it
possible to investigate committed offenses. In so far, the storage of
this data is necessary to secure the controller. This data is not passed
on to third parties unless there is a statutory obligation to pass on
the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of
personal data, is intended to enable the controller to offer the data
subject contents or services that may only be offered to registered
users due to the nature of the matter in question. Registered persons
are free to change the personal data specified during the registration
at any time, or to have them completely deleted from the data stock of
the controller.
The data controller shall, at any time, provide information upon request
to each data subject as to what personal data is stored about the data
subject. In addition, the data controller shall correct or erase
personal data at the request or indication of the data subject, in so
far as there are no statutory storage obligations. A Data Protection
Officer is particularly designated in this data protection declaration,
as well as the entirety of the controller’s employees are available to
the data subject in this respect as contact persons.
6. Submission of an enquiry form or an order form
The website of Abal Security Group Ltd contains information that enables
an enquiry on a vehicle to be submitted to ourselves, as well as direct
communication with us, which also includes a general address of the
so-called electronic mail (email address). If a data subject contacts
the controller by email or via an enquiry form, the personal data
transmitted by the data subject is automatically stored. Such personal
data transmitted on a voluntary basis by a data subject to the data
controller is stored for the purpose of processing or contacting the
data subject. There is no transfer of this personal data to third
parties.
As above - If you submit an order form, the personal data transmitted by
the data subject is automatically stored. Such personal data
transmitted on a voluntary basis by a data subject to the data
controller is stored for the purpose of processing or contacting the
data subject. As part of the process to order a vehicle we are required
to request personal data for the purpose of a credit proposal.
As we are a broker and not a lender we will ask for your express consent
to submit your data to a third party being the lender. The lender will
be one of our partner funders (the finance company who you will enter
into agreement with should you proceed with an order). Further
information regarding this process and our funders can be requested
directly from the Data Protection Officer. Vehicles are ordered through
one of the UK Automotive dealer networks. Therefore, to progress with
the order of a vehicle we must share relevant information with a dealer.
Personal information shared with a dealer will include sensitive data
such as your address and contact details to progress the order.
7. Subscription to our newsletters
On the website of Abal Security Group Ltd, users are given the
opportunity to subscribe to our newsletter. The input mask used for this
purpose determines what personal data are transmitted, as well as when
the newsletter is ordered from the controller.
Abal Security Group Ltd informs its customers and business partners
regularly by means of a newsletter about offers. The newsletter may only
be received by the data subject if (1) the data subject has a valid
email address and (2) the data subject registers for the newsletter
shipping. A confirmation email will be sent to the email address
registered by a data subject for the first time for newsletter shipping,
for legal reasons, in the double opt-in procedure. This confirmation
email is used to prove whether the owner of the e-mail address as the
data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address
of the computer system assigned by the Internet service provider (ISP)
and used by the data subject at the time of the registration, as well as
the date and time of the registration. The collection of this data is
necessary in order to understand the (possible) misuse of the email
address of a data subject at a later date, and it therefore serves the
aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter
will only be used to send our newsletter. In addition, subscribers to
the newsletter may be informed by email, as long as this is necessary
for the operation of the newsletter service or a registration in
question, as this could be the case in the event of modifications to the
newsletter offer, or in the event of a change in technical
circumstances. There will be no transfer of personal data collected by
the newsletter service to third parties. The subscription to our
newsletter may be terminated by the data subject at any time. The
consent to the storage of personal data, which the data subject has
given for shipping the newsletter, may be revoked at any time. For the
purpose of revocation of consent, a corresponding link is found in each
newsletter. It is also possible to unsubscribe from the newsletter at
any time directly on the website of the controller, or to communicate
this to the controller in a different way.
If you have any questions regarding opting- in/out to our newsletter, please email: info@abalsecuritygroup.co.uk
8. Newsletter tracking
The newsletter of Abal Security Group Ltd contains so-called tracking
pixels. A tracking pixel is a miniature graphic embedded in such emails,
which are sent in HTML format to enable log file recording and
analysis. This allows a statistical analysis of the success or failure
of online marketing campaigns. Based on the embedded tracking pixel,
Abal Security Group Ltd may see if and when an email was opened by a
data subject, and which links in the email were called up by data
subjects.
Such personal data collected in the tracking pixels contained in the
newsletters are stored and analysed by the controller to optimize the
shipping of the newsletter, as well as to adapt the content of future
newsletters even better to the interests of the data subject. These
personal data will not be passed on to third parties. Data subjects are
at any time entitled to revoke the respective separate declaration of
consent issued by means of the double-opt-in procedure. After a
revocation, these personal data will be deleted by the controller. Abal
Security Group Ltd automatically regards a withdrawal from the receipt
of the newsletter as a revocation.
9. Contact possibility via the website
The website of Abal Security Group Ltd contains information that enables
a quick electronic contact to our company, as well as direct
communication with us, which also includes a general address of the
so-called electronic mail (e-mail address). If a data subject contacts
the controller by e-mail or via a contact form, the personal data
transmitted by the data subject are automatically stored. Such personal
data transmitted on a voluntary basis by a data subject to the data
controller are stored for the purpose of processing or contacting the
data subject. There is no transfer of this personal data to third
parties.
10. Cookies
The Internet pages and website of Abal Security Group Ltd use cookies.
Cookies are text files that are stored in a computer system via an
Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a
so-called cookie ID. A cookie ID is a unique identifier of the cookie.
It consists of a character string through which Internet pages and
servers can be assigned to the specific Internet browser in which the
cookie was stored. This allows visited Internet sites and servers to
differentiate the individual browser of the data subject from other
Internet browsers that contain other cookies. A specific Internet
browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, Abal Security Group Ltd can provide the
users of this website with more user-friendly services that would not be
possible without the cookie setting.
By means of a cookie, the information and offers on our website can be
optimized with the user in mind. Cookies allow us, as previously
mentioned, to recognize our website users. The purpose of this
recognition is to make it easier for users to utilize our website. The
website user that uses cookies, does not have to enter access data each
time the website is accessed, because this is taken over by the website,
and the cookie is thus stored on the user's computer system. Another
example is the cookie of a shopping cart in an online shop. The online
store remembers the articles that a customer has placed in the virtual
shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies
through our website by means of a corresponding setting of the Internet
browser used, and may thus permanently deny the setting of cookies.
Furthermore, already set cookies may be deleted at any time via an
Internet browser or other software programs. This is possible in all
popular Internet browsers. If the data subject deactivates the setting
of cookies in the Internet browser used, not all functions of our
website may be entirely usable.
You can find more information about cookies at
http://www.allaboutcookies.org and http://www.youronlinechoices.eu. For a
video about cookies visit
http://www.google.com/intl/en-GB/policies/technologies/cookies/.
How to manage cookies?
You can enable or disable cookies by changing your website browser
settings to accept or reject cookies as required. You can also delete
any existing cookies from your browser settings.
Cookies we use:
a. Cookies from Google Analytics:
We use Google Analytics log cookies (such as _utma, _utmv, _utmc, _utmz,
and _utmb) to identify user’s activities such as which pages are being
visited and how long. This helps us analyse data about webpage traffic
and user’s behaviours to improve our website in order to tailor it to
customer needs. We only use this information for statistical analysis
purposes and then the data is removed from the system. You can find more
details about Google analytics cookies here.
Overall, cookies help provide you with a better website, by enabling us
to monitor which pages you find useful and which you do not. A cookie in
no way gives us access to your computer or any information about you,
other than the data you choose to share with us.
11. Social Media Use, including but not limited to, Facebook, Twitter, Instagram, Linked In.
Abal Security Group Ltd uses social media for the purposes of promoting
and communicating about the company; This includes, but is not limited
to Facebook, Twitter, Instagram and Linked In. By signing up to, liking,
following or using any of Abal Security Group Ltd social media pages,
the user is subject to the data and privacy policies of these
organisations, not Abal Security Group Ltd. For more information please
visit the respective Social Media Company’s website and privacy policy
pages. Some examples are highlighted below:
• https://www.facebook.com/full_data_use_policy
• https://www.facebook.com/legal/FB_Work_Privacy
• https://twitter.com/en/privacy
• https://help.instagram.com/155833707900388
• https://www.linkedin.com/legal/privacy-policy
12. Links to Other Websites and Enterprises
Our enterprise links to other third parties, including but not limited
to entities such as finance companies, UK dealerships, etc. As noted in
point 7, Submission of an enquiry form or an order form, once you order
a car then we are obliged to share your personal information with them
in order to progress the order. You are then subject to their privacy
policies. Our website contains links from and to other websites. Please
note Abal Security Group Ltd has no control over other websites and
cannot be responsible for the protection and privacy of any information
which you provide whilst visiting these sites prior to or after visiting
the Abal Security Group Ltd website. These sites are not within the
sphere of control of this privacy statement and since we do not control
those websites, you are responsible for reviewing and abiding by the
privacy policies of these third-party sites to ensure they comply with
the applicable data protection regulations.
13. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the
data subject only for the period necessary to achieve the purpose of
storage, or as far as this is granted by the European legislator or
other legislators in laws or regulations to which the controller is
subject to.
If the storage purpose is not applicable, or if a storage period
prescribed by the European legislator or another competent legislator
expires, the personal data are routinely blocked or erased in accordance
with legal requirements.
14. Complaining
When we receive a complaint, we record all the information you have
given to us. We use that information to resolve your complaint. If your
complaint reasonably requires us to contact some other person, we may
decide to give to that other person some of the information contained in
your complaint. We do this as infrequently as possible, but it is a
matter for our sole discretion as to whether we do give information, and
if we do, what that information is.
We may also compile statistics showing information obtained from this
source to assess the level of service we provide, but not in a way that
could identify you or any other person.
To register a complaint with Abal Security Group Ltd can be done in
several ways, in person, over the telephone or via email with the
relevant addresses and details being listed above.
15. Rights of the data subject
• a) Right of confirmation
Each data subject shall have the right granted by the European
legislator to obtain from the controller the confirmation as to whether
or not personal data concerning him or her are being processed. If a
data subject wishes to avail himself of this right of confirmation, he
or she may, at any time, contact our Data Protection Officer or another
employee of the controller.
• b) Right of access
Each data subject shall have the right granted by the European
legislator to obtain from the controller free information about his or
her personal data stored at any time and a copy of this information.
Furthermore, the European directives and regulations grant 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
has 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 request 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 existence of the right to lodge a complaint with a supervisory authority
• Where the personal data is 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) of the GDPR and, at least in those
cases, meaningful information about the logic involved, as well as the
significance and envisaged consequences of such processing for the data
subject.
Furthermore, the data subject shall have a right to obtain information
as to whether personal data are transferred to a third country or to an
international organisation. Where this is the case, the data subject
shall have the right to be informed of the appropriate safeguards
relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or
she may at any time contact our Data Protection Officer or another
employee of the controller.
• c) Right to rectification
Each data subject shall have the right granted by the European
legislator to obtain from the controller without undue delay the
rectification of inaccurate personal data concerning him or her. Taking
into account the purposes of the processing, the data subject shall have
the right to have incomplete personal data completed, including by
means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or
she may, at any time, contact our Data Protection Officer or another
employee of the controller.
• d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European
legislator to obtain from the controller the erasure of personal data
concerning him or her without undue delay, and the controller shall have
the obligation to erase personal data without undue delay where one of
the following grounds applies, as long as the processing is not
necessary:
• The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed
• The data subject withdraws consent to which the processing is based to
according to point (a) of Article 6(1) of the GDPR, or point (a) of
Article 9(2) of the GDPR, and where there is no other legal ground for
the processing.
• The data subject objects to the processing pursuant to Article 21(1)
of the GDPR and there are no overriding legitimate grounds for the
processing, or the data subject objects to the processing pursuant to
Article 21(2) of the GDPR
• The personal data has been unlawfully processed
• The personal data must be erased for compliance with a legal
obligation in Union or Member State law to which the controller is
subject.
• The personal data has been collected in relation to the offer of
information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes
to request the erasure of personal data stored by Abal Security Group
Ltd, he or she may at any time contact our Data Protection Officer or
another employee of the controller. The Data Protection Officer of Abal
Security Group Ltd or another employee shall promptly ensure that the
erasure request is complied with immediately.
Where the controller has made personal data public and is obliged
pursuant to Article 17(1) to erase the personal data, the controller,
taking account of available technology and the cost of implementation,
shall take reasonable steps, including technical measures, to inform
other controllers processing the personal data that the data subject has
requested erasure by such controllers of any links to, or copy or
replication of, those personal data, as far as processing is not
required. The Data Protection Officer of Abal Security Group Ltd or
another employee will arrange the necessary measures in individual
cases.
• e) Right of restriction of processing
Each data subject shall have 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 instead 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 of defence of legal claims.
• The data subject has objected to processing pursuant to Article 21(1)
of the GDPR, pending he verification whether the legitimate grounds of
the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject
wishes to request the restriction of the processing of personal data
stored by the Abal Security Group Ltd, he or she may at any time contact
our Data Protection Officer or another employee of the controller. The
Data Protection Officer of the Abal Security Group Ltd or another
employee will arrange the restriction of the processing.
• f) Right to data portability
Each data subject shall have the right granted by the European
legislator, to receive the personal data concerning him or her, which
was provided to a controller, in a structured, commonly used and
machine-readable format. He or she shall have the right to transmit
those data to another controller without hindrance from the controller
to which the personal data have been provided, as long as the processing
is based on consent pursuant to point (a) of Article 6(1) of the GDPR
or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to
point (b) of Article 6(1) of the GDPR, and the processing is carried out
by automated means, as long as the processing is not necessary for the
performance of a task carried out in the public interest or in the
exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant
to Article 20(1) of the GDPR, the data subject shall have the right to
have personal data transmitted directly from one controller to another,
where technically feasible and when doing so does not adversely affect
the rights and freedoms of others.
In order to assert the right to data portability, the data subject may
at any time contact the Data Protection Officer designated by Abal
Security Group Ltd or another employee.
• g) Right to object
Each data subject shall have the right granted by the European
legislator to object, on grounds relating to his or her particular
situation, at any time, to processing of personal data concerning him or
her, which is based on point (e) or (f) of Article 6(1) of the GDPR.
This also applies to profiling based on these provisions.
Abal Security Group Ltd shall no longer process the personal data in the
event of the objection, unless we can demonstrate compelling legitimate
grounds for the processing which override the interests, rights and
freedoms of the data subject, or for the establishment, exercise or
defence of legal claims.
If Abal Security Group Ltd processes personal data for direct marketing
purposes, the data subject shall have the right to object at any time to
processing of personal data concerning him or her for such marketing.
This applies to profiling to the extent that it is related to such
direct marketing. If the data subject objects to Abal Security Group Ltd
to the processing for direct marketing purposes, Abal Security Group
Ltd will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his
or her particular situation, to object to processing of personal data
concerning him or her by Abal Security Group for scientific or
historical research purposes, or for statistical purposes pursuant to
Article 89(1) of the GDPR, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly
contact the Data Protection Officer of Abal Security Group Ltd or
another employee. In addition, the data subject is free in the context
of the use of information society services, and notwithstanding
Directive 2002/58/EC, to use his or her right to object by automated
means using technical specifications.
• h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European
legislator not to be subject to a decision based solely on automated
processing, including profiling, which produces legal effects concerning
him or her, or similarly significantly affects him or her, as long as
the decision (1) is not is necessary for entering into, or the
performance of, a contract between the data subject and a data
controller, or (2) is not authorised 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 (3) is not based on the data subject's explicit
consent.
If the decision (1) is necessary for entering into, or the performance
of, a contract between the data subject and a data controller, or (2) it
is based on the data subject's explicit consent, Abal Security Group
Ltd 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 the part of the controller, to express his
or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated
individual decision-making, he or she may at any time directly contact
our Data Protection Officer of Abal Security Group Ltd or another
employee of the controller.
• i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European
legislator to withdraw his or her consent to processing of his or her
personal data at any time.
If the data subject wishes to exercise the right to withdraw the
consent, he or she may at any time directly contact our Data Protection
Officer of the Abal Security Group Ltd or another employee of the
controller.
16. Data protection for applications and the application procedures
The data controller shall collect and process the personal data of
applicants for the purpose of the processing of the application
procedure. The processing may also be carried out electronically. This
is the case, in particular, if an applicant submits corresponding
application documents by email or by means of a web form on the website
to the controller. If the data controller concludes an employment
contract with an applicant, the submitted data will be stored for the
purpose of processing the employment relationship in compliance with
legal requirements. If no employment contract is concluded with the
applicant by the controller, the application documents shall be
automatically erased two months after notification of the refusal
decision, provided that no other legitimate interests of the controller
are opposed to the erasure. Other legitimate interest in this relation
is, e.g. a burden of proof in a procedure under the General Equal
Treatment Act (AGG).
17. Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google
Analytics (with the anonymizer function). Google Analytics is a web
analytics service. Web analytics is the collection, gathering, and
analysis of data about the behaviour of visitors to websites. A web
analysis service collects, inter alia, data about the website from which
a person has come (the so-called referrer), which sub-pages were
visited, or how often and for what duration a sub-page was viewed. Web
analytics are mainly used for the optimization of a website and in order
to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600
Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the
application "_gat. _anonymizeIp". By means of this application the IP
address of the Internet connection of the data subject is abridged by
Google and anonymised when accessing our websites from a Member State of
the European Union or another Contracting State to the Agreement on the
European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic
on our website. Google uses the collected data and information, inter
alia, to evaluate the use of our website and to provide online reports,
which show the activities on our websites, and to provide other services
concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of
the data subject. The definition of cookies is explained above. With
the setting of the cookie, Google is enabled to analyze the use of our
website. With each call-up to one of the individual pages of this
Internet site, which is operated by the controller and into which a
Google Analytics component was integrated, the Internet browser on the
information technology system of the data subject will automatically
submit data through the Google Analytics component for the purpose of
online advertising and the settlement of commissions to Google. During
the course of this technical procedure, the enterprise Google gains
knowledge of personal information, such as the IP address of the data
subject, which serves Google, amongst others, to understand the origin
of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access
time, the location from which the access was made, and the frequency of
visits of our website by the data subject. With each visit to our
Internet site, such personal data, including the IP address of the
Internet access used by the data subject, will be transmitted to Google
in the United States of America. These personal data are stored by
Google in the United States of America. Google may pass these personal
data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies
through our website at any time by means of a corresponding adjustment
of the web browser used and thus permanently deny the setting of
cookies. Such an adjustment to the Internet browser used would also
prevent Google Analytics from setting a cookie on the information
technology system of the data subject. In addition, cookies already in
use by Google Analytics may be deleted at any time via a web browser or
other software programs.
In addition, the data subject has the possibility of objecting to a
collection of data that are generated by Google Analytics, which is
related to the use of this website, as well as the processing of this
data by Google and the chance to preclude any such. For this purpose,
the data subject must download a browser add-on under the link
https://tools.google.com/dlpage/gaoptout and install it. This browser
add-on tells Google Analytics through a JavaScript, that any data and
information about the visits of Internet pages may not be transmitted to
Google Analytics. The installation of the browser add-ons is considered
an objection by Google. If the information technology system of the
data subject is later deleted, formatted, or newly installed, then the
data subject must reinstall the browser add-ons to disable Google
Analytics. If the browser add-on was uninstalled by the data subject or
any other person who is attributable to their sphere of competence, or
is disabled, it is possible to execute the reinstallation or
reactivation of the browser add-ons.
Further information and the applicable data protection provisions of
Google may be retrieved under
https://www.google.com/intl/en/policies/privacy/ and under
http://www.google.com/analytics/terms/us.html. Google Analytics is
further explained under the following Link
https://www.google.com/analytics/.
18. Data protection provisions about the application and use of Google-AdWords
On this website, the controller has integrated Google AdWords. Google
AdWords is a service for Internet advertising that allows the advertiser
to place ads in Google search engine results and the Google advertising
network. Google AdWords allows an advertiser to pre-define specific
keywords with the help of which an ad on Google's search results only
then displayed, when the user utilizes the search engine to retrieve a
keyword-relevant search result. In the Google Advertising Network, the
ads are distributed on relevant web pages using an automatic algorithm,
taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
The purpose of Google AdWords is the promotion of our website by the
inclusion of relevant advertising on the websites of third parties and
in the search engine results of the search engine Google and an
insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion
cookie is filed on the information technology system of the data subject
through Google. The definition of cookies is explained above. A
conversion cookie loses its validity after 30 days and is not used to
identify the data subject. If the cookie has not expired, the conversion
cookie is used to check whether certain sub-pages, e.g, the shopping
cart from an online shop system, were called up on our website. Through
the conversion cookie, both Google and the controller can understand
whether a person who reached an AdWords ad on our website generated
sales, that is, executed or cancelled a sale of goods.
The data and information collected through the use of the conversion
cookie is used by Google to create visit statistics for our website.
These visit statistics are used in order to determine the total number
of users who have been served through AdWords ads to ascertain the
success or failure of each AdWords ad and to optimize our AdWords ads in
the future. Neither our company nor other Google AdWords advertisers
receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet
pages visited by the data subject. Each time we visit our Internet
pages, personal data, including the IP address of the Internet access
used by the data subject, is transmitted to Google in the United States
of America. These personal data are stored by Google in the United
States of America. Google may pass these personal data collected through
the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our
website, as stated above, by means of a corresponding setting of the
Internet browser used and thus permanently deny the setting of cookies.
Such a setting of the Internet browser used would also prevent Google
from placing a conversion cookie on the information technology system of
the data subject. In addition, a cookie set by Google AdWords may be
deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based
advertisement of Google. Therefore, the data subject must access from
each of the browsers in use the link www.google.de/settings/ads and set
the desired settings.
Further information and the applicable data protection provisions of
Google may be retrieved under
https://www.google.com/intl/en/policies/privacy/.
19. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing
operations for which we obtain consent for a specific processing
purpose. If the processing of personal data is necessary for the
performance of a contract to which the data subject is party, as is the
case, for example, when processing operations are necessary for the
supply of goods or to provide any other service, the processing is based
on Article 6(1) lit. b GDPR. The same applies to such processing
operations which are necessary for carrying out pre-contractual
measures, for example in the case of inquiries concerning our products
or services. Is our company subject to a legal obligation by which
processing of personal data is required, such as for the fulfilment of
tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In
rare cases, the processing of personal data may be necessary to protect
the vital interests of the data subject or of another natural person.
This would be the case, for example, if a visitor were injured in our
company and his name, age, health insurance data or other vital
information would have to be passed on to a doctor, hospital or other
third party. Then the processing would be based on Art. 6(1) lit. d
GDPR. Finally, processing operations could be based on Article 6(1) lit.
f GDPR. This legal basis is used for processing operations which are
not covered by any of the abovementioned legal grounds, if processing is
necessary for the purposes of the legitimate interests pursued by our
company or by a third party, except where such interests are overridden
by the interests or fundamental rights and freedoms of the data subject
which require protection of personal data. Such processing operations
are particularly permissible because they have been specifically
mentioned by the European legislator. He considered that a legitimate
interest could be assumed if the data subject is a client of the
controller (Recital 47 Sentence 2 GDPR).
20. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. of
GDPR our legitimate interest is to carry out our business in favour of
the well-being of all our employees and the shareholders.
21. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is
the respective statutory retention period. After expiration of that
period, the corresponding data is routinely deleted, as long as it is no
longer necessary for the fulfilment of the contract or the initiation
of a contract.
22. Provision of personal data as statutory or contractual
requirement; Requirement necessary to enter into a contract; Obligation
of the data subject to provide the personal data; possible consequences
of failure to provide such data
We clarify that the provision of personal data is partly required by law
(e.g. tax regulations) or can also result from contractual provisions
(e.g. information on the contractual partner). Sometimes it may be
necessary to conclude a contract that the data subject provides us with
personal data, which must subsequently be processed by us. The data
subject is, for example, obliged to provide us with personal data when
our company signs a contract with him or her. The non-provision of the
personal data would have the consequence that the contract with the data
subject could not be concluded. Before personal data is provided by the
data subject, the data subject must contact our Data Protection
Officer. Our Data Protection Officer clarifies to the data subject
whether the provision of the personal data is required by law or
contract or is necessary for the conclusion of the contract, whether
there is an obligation to provide the personal data and the consequences
of non-provision of the personal data.
23. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
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