Privacy Policy

Data Protection / Privacy policy

As operators of the website at www.kumpan-electric.com (also “website”), we are responsible for the personal data of the user (“you”) of this website within the meaning of the applicable data protection law, in particular the General Data Protection Regulation (“GDPR”).

In the following we provide you clear information pursuant to our information obligation (Art. 13 ff. GDPR) about which data are processed during your visit to our website and on what legal basis this is done. You are also provided with information on how we protect your data from a technical and organisational point of view and what rights you have towards us and the competent supervisory authority.

1. Information on the Controller

Name and contact details:
e-bility GmbH
Dieselstraße 28, 53424 Remagen
Telephone: +49 (0) 2642 999 800
E-mail: info@ebility.de
Fax: +49 (0) 2642 999 80-29

2. Data protection officer

We have appointed a company data protection officer:
Philipp Tykesson
E-Mail: philipp.tykesson@ebility.de
Telephone: +49 (0) 2642 999 80 -18

3. Processing your personal data

3.1. Informational use of our website

When you access our website for a simple visit, so-called logfiles are processed by our system by being automatically collected.

The following log files are processed automatically:

  • IP address of the requesting computer
  • Type of Internet browser used
  • Language of Internet browser used
  • Version of Internet browser used
  • Operating system and its version
  • Interface of the operating system
  • Accessed pages
  • Date and time of visit
  • Time zone difference to Greenwich Mean Time (GMT)
  • Access status/http status code
  • Transferred data volume
  • Success or error of the loading process
  • Referrer

The log files contain your IP address and possibly other personal data. Therefore, an assignment to you is generally possible. However, we store your data only temporarily and in particular, not together with other personal data.

The processing of the above data is necessary for the provision of our website. We also store the data for the security of our information technology systems. These purposes also justify our legitimate interest in processing the data on the legal basis of Art. 6 (1) lit. f GDPR. The log files, which also contain your IP address, will be deleted or made anonymous immediately after they are no longer necessary to achieve the aforementioned purposes, at the latest however after three months.

4. Use of offers

4.1. Customer account/registration

You have the option to create a customer account on our website with your personal data. This is voluntary, and the data will not be passed on to third parties. If you decide to create a customer account, you must provide us with the following information:

  • E-mail address
  • Name
  • Date of birth
  • Address
  • Telephone number

All other information is voluntary. We store the following voluntary information together with your e-mail address when you make it available to us: In the dealer area you can log in with your user ID and password.

When you submit your application / registration, we store your IP address and the date and time of your registration together with the information you provide. By sending the registration you agree to the processing of your data by us.

Your data will be used for the purpose of managing your customer account and providing the associated functions, such as editing your customer details, and displaying your orders. The legal basis for the storage of your customer account data is Art. 6 (1) lit. a GDPR.

We store your data that you have made available to us as part of your voluntary registration as long as you do not delete your customer account with us. If you make changes to your details, the old data will be deleted and only the updated data will be saved. Furthermore, we only store your data in order to fulfill our contractual or legal obligations (e.g. tax obligations) (Art. 6 (1) lit.c GDPR). In this case we block your data to the extent that they are then only processed for the necessary purposes.

In addition to this data, we save the date and time of the transmission of your data, as well as your IP address. The processing of this data corresponds to our legitimate interest (Art 6 (1) lit.f GDPR), in order to guarantee the security of our systems and to counteract misuse. These additional data will be deleted as soon as they are no longer needed, at the latest when the contract with you is completed.

You can delete or change your voluntary customer account with us at any time. You will find the functions for changing your details or closing your account in your profile.

4.2 Orders

If you place an order on our website, we need the following data to fulfil the contract with you:

  • Title, first name, last name and (billing and delivery) address to send the order and the invoice
  • E-mail address to send the order confirmation and to provide you with contract documents immediately after the order.
  • Telephone number to process the payment of your order
  • Customer group (private or dealer, for price calculation)

In order to send your order to you, we pass on your address data to our shipping or logistics service provider for the purpose of delivery. The legal basis for the processing of the data is Art. 6 (1) lit. b GDPR. The data will be stored as long as it is necessary for the contract execution.

In addition, we only store your data in order to fulfill our contractual or legal obligations (e.g. tax obligations) (Art. 6 (1) lit c GDPR). In this case we will block your data to the extent that they are only processed for the necessary purposes.

In addition to this data, we store the time (date and time) of the transmission of your data. The processing of this data is in line with our legitimate interest (Art. 6 (1) lit f GDPR) in order to guarantee the security of our systems and to prevent misuse.

These additional data will be deleted as soon as they are no longer needed, at the latest when the contract with you is completed.

4.3 Payment methods

If you select a payment provider on our payment page, this provider will also receive your personal data, such as your name, address and bank account details. In addition, our house bank receives your bank details when an electronic payment is received.

Payment by direct debit/advance payment: If you pay on our website by direct debit, our house bank will receive your bank account details for payment processing.

4.4. Contact form / feedback

You can contact us electronically via our contact form, for example to give us feedback or to ask questions. If you use this option, you transmit the following data to us:

  • E-mail address (to contact you)
  • First name and last name (to address you and for purposes of misuse prevention)

In addition to the data that you voluntarily provide us with, we store the date and time of transmission of your data to us, as well as your IP address. These data are processed in accordance with our legitimate interest (Art. 6 (1) lit.f GDPR) in order to guarantee the security of our systems and to prevent misuse. These data, which we additionally collect when you contact us, are deleted as soon as they are no longer needed, at the latest when the reason for your initiation of contact with us is comprehensively clarified.

By submitting the contact form, you agree to the processing of your data by us. The legal basis for the processing of your data for the purposes of your initiated contact is Art. 6 (1) lit. a GDPR. The data will be stored until they are no longer necessary to achieve the purpose of the conversation with us and the purpose of your initiated contact has been fully clarified.

If your initiated contact aims to conclude a contract with us, the additional legal basis for processing your personal data is Art. 6 (1) lit. b GDPR. These data are stored as long as they are necessary for the execution of the contract. Furthermore, we only store your data in order to fulfill contractual or legal obligations (e.g. tax obligations) (Art. 6 (1) lit.c GDPR).

4.5. “Request a test ride” form

You can contact us electronically using our “Request a test ride” form to request a test ride of your desired model. If you use this option, you transmit the following data to us:

  • E-mail address
  • First name and last name (to address you and for purposes of misuse prevention)
  • Postal code
  • Desired model
  • Telephone number (for possible queries)

In addition to the data that you voluntarily provide us with, we store the date and time of transmission of your data to us, as well as your IP address. These data are processed in accordance with our legitimate interest (Art. 6 (1) lit.f GDPR) in order to guarantee the security of our systems and to prevent misuse. The data, which we additionally collect when you contact us, are deleted as soon as they are no longer needed, at the latest when the reason for your contact with us is comprehensively clarified.

By submitting the contact form, you agree to the processing of your data by us. The legal basis for the processing of your data for the purposes of your contact is Art. 6 (1) lit. a GDPR. The data will be stored until they are no longer necessary to achieve the purpose of the conversation with us and the purpose of your initiated contact has been fully clarified.

If your initiated contact aims to conclude a contract with us, the additional legal basis for processing your personal data is Art. 6 (1) lit. b GDPR. The data is stored for as long as necessary for the execution of the contract. Furthermore, we only store your data in order to fulfil contractual or legal obligations (e.g. tax obligations) (Art. 6 (1) lit.c GDPR).

4.6. “Sign up for updates” form

You can contact us electronically via our “Sign up for updates” form to Sign up for updates on the Kumpan 54i. If you use this option, you transmit the following data to us:

  • E-mail address
  • First name and last name (for misuse prevention purposes)

In addition to the data that you voluntarily provide us with, we store the date and time of transmission of your data to us, as well as your IP address. These data are processed in accordance with our legitimate interest (Art. 6 (1) lit.f GDPR) in order to guarantee the security of our systems and to prevent misuse. The data, which we additionally collect when you contact us, are deleted as soon as they are no longer needed, at the latest when the reason for your contact with us is comprehensively clarified.

By submitting the contact form, you agree to the processing of your data by us. The legal basis for the processing of your data for the purposes of your contact is Art. 6 (1) lit. a GDPR. The data will be stored until they are no longer necessary to achieve the purpose of the conversation with us and the purpose of your initiated contact has been fully clarified.

If your initiated contact aims to conclude a contract with us, the additional legal basis for processing your personal data is Art. 6 (1) lit. b GDPR. The data is stored for as long as necessary for the execution of the contract. Furthermore, we only store your data in order to fulfil contractual or legal obligations (e.g. tax obligations) (Art. 6 (1) lit.c GDPR).

4.7. Contact by e-mail

You have the option to contact us by e-mail. Your personal data transmitted in the e-mail will be stored by us. The data is not passed on to third parties. The data will only be processed in order to process your initiated contact. The legal basis for the processing of your personal data is Art. 6 (1) lit. f GDPR. The data will be stored until it is no longer necessary to achieve the purpose of the conversation with us and the purpose of your initiated contact has been fully clarified.

If your e-mail aims to conclude a contract with us, the additional legal basis for processing your personal data is Art. 6 (1) lit. b GDPR. The data is stored as long as it is necessary for the execution of the contract. Furthermore, we only store your data in order to fulfil contractual or legal obligations (e.g. tax obligations) (Art. 6 (1) lit.c GDPR).

In addition to the data that you voluntarily provide us with, we receive the time (date and time) of transmission of your data to us, as well as your IP address. The data is processed in accordance with our legitimate interest (Art. 6 (1) lit.f GDPR) in order to guarantee the security of our systems and to prevent misuse. The data, which we additionally collect when you contact us, is deleted as soon as it is no longer needed, at the latest when the reason for your contact with us is comprehensively clarified.

You can revoke your consent to the processing of your personal data at any time by sending an e-mail to info@ebility.de. In this case, all personal data of the conversation will be deleted, and a continuation of the conversation is not possible.

4.8. Newsletter

On our website, we provide you the option to subscribe to our newsletter free of charge. For this, we need your e-mail address in addition to your declaration of consent. By submitting the newsletter registration, you agree to the processing of your data by us.

Further information, e.g. your name, is voluntary and is used to contact you personally. The legal basis for sending the newsletter is Art. 6 (1) lit. b GDPR with regard to your e-mail address, and to further voluntarily provided data. By sending the newsletter registration you agree to the processing of your data by us.

We will only send you the newsletter once you confirm your registration by clicking on the appropriate link in a confirmation e-mail sent to you for this purpose. This is to ensure that only you yourself can subscribe to the newsletter. Your confirmation in this regard must be sent shortly after receipt of the confirmation e-mail, otherwise your newsletter subscription will be automatically deleted from our database.

Additionally, in the course of your newsletter registration we store the date and time of transmission of your data to us, as well as your IP address. These data are processed in accordance with our legitimate interest pursuant to Art. 6 (1) lit. f GDPR in order to guarantee the security of our systems and to prevent misuse.

Your data will not be passed on to third parties and will only be processed in connection with the sending of newsletters. The purpose of processing your e-mail address is to be able to send you the newsletter. Further data within the course of the registration process are used either to address you personally or to guarantee the security of our services and to prevent misuse of the e-mail address used.

Your data will only be stored for as long as it is necessary to achieve the purpose. Your e-mail address will therefore be stored for the period of your active newsletter subscription, if you have given your consent. The data that we additionally collect automatically during your registration (IP address, date and time) will be deleted at the latest when you cancel your newsletter subscription.

Cancellation option / Unsubscribe newsletter
You can unsubscribe from our newsletter at any time. You will find the link at the end of each newsletter. By doing so, you revoke your consent and object to further use of your data for the purpose of sending the newsletter.

5. Cookies

Please note the following information: You can ensure yourself that no cookies at all are stored on your computer, or that only the storage of certain cookies is permitted. You can select this in your Internet browser settings. You can also view and delete the stored cookies there.

If you block all cookies, you may not be able to use all the features of our website.

We use cookies on our website. Cookies are text files that are sent by our web server to your browser during your visit to our website and are stored on your computer for later retrieval. A cookie can therefore identify your Internet browser when you visit the website again. The types of cookies include session cookies which are deleted when you close your browser, and persistent cookies that are stored on your hard drive until their default expiration date is reached or until you actively remove them.

5.1. Own cookies

We use own cookies to ensure the functionality of our website. Some elements of our website require your Internet browser to be recognised after a page change. In the overview you can see for what purposes your data are collected and for how long they are stored: The legal basis for the processing of personal data in cookies that we set on our website to provide the functionality of our website and our offer, is Art. 6 (1) lit. f GDPR.

Possibility of objection and removal
As explained in this section, you can enable or restrict the transmission of cookies by changing the settings in your Internet browser. You can delete cookies that have already been saved by your Internet browser at any time. If cookies for our website are restricted or deactivated, it may be that not all functionalities can be used.

5.2. Third-party cookies

On our website we use cookies by so-called “third parties”. This means that when you visit our website, data is transferred from your web browser to the third party’s web server and stored there.

In the respective explanations of our third-party cookies, you will see the option of clicking an “Opt-Out” button. The “Opt-Out” works in such a way that the third-party provider stores an “Opt-Out” cookie that prevents tracking.

5.2.1. Google Analytics

Our website has implemented the analysis service Google Analytics of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (hereinafter: “Google Analytics”).

Google Analytics uses cookies that store the following information:

  • Type of Internet browser used
  • Version of the Internet browser
  • The operating system you are using
  • Referrer (previously visited website)
  • Your truncated IP address
  • Time of the server request

We use the function of Google Analytics to anonymise your IP address before saving or processing. Your IP address is usually truncated within the European Union / EEA and only then transmitted to Google servers in the USA. Your information will be processed pseudonymised and we will not combine it with other personal data of yours.

We use the data collected in this way for statistical purposes in order to optimise our website and offers. The legal basis for this is Art. 6 (1) lit. f GDPR.

Further, you can avoid collection of the data created by the cookie and referring to your use of the website (incl. Your IP address) by Google as well as the processing of these data by Google if you download and install the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de .

You can either prevent Google cookies from being saved directly in your browser settings, or you can prevent the processing of your data by clicking on the following link and causing an “opt-out”: https://developers.google.com/analytics / devguides / collection / gajs /? hl = en # disable . This will set an “opt-out cookie” which prevents the collection of your user data on this website.

You can find Google’s privacy policy at the following link: https://policies.google.com/privacy?hl=en .

5.2.2. Facebook Pixel

On our website we use the Facebook Pixel analysis tool from Facebook Inc, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbor, D2 Dublin, Ireland (“Facebook”). Facebook Custom Audiences works with a JavaScript code snippet that is executed when someone opens a page. We use it to analyze the effectiveness of our advertising. We cannot identify individual users via our Facebook Business Profile or address them specifically with advertising, but only user groups.

We use Facebook pixels in such a way that the sending of pixel actions to Facebook is interrupted until the cookie approval has been given. With Facebook pixels, we want to ensure that Facebook advertisements are displayed to those visitors to our website who meet certain characteristics (interest in certain products, gender, certain age, live in a certain city, etc.). Facebook calls the grouping of users according to certain characteristics “Custom Audiences”. Advertising on Facebook should be shown to potential interests and not to those who are unlikely to be interested in our product.

Our Custom Audience consists of the function “Custom Audience through websites”, ie the Facebook pixel matches visitors to our website with people on Facebook. The following data is sent to Facebook: context data: This includes the redirection URL, browser information and the person’s Facebook user ID (hashed).

In addition, the pixel helps to statistically track the effectiveness of advertisements, this is called “conversion” by Facebook. The Facebook pixel tells us whether people from the target group have visited our website, searched for a specific product on our website, looked at a specific product or product category, whether a purchase was initiated, whether a purchase was completed. The Facebook pixel tells us whether people have been directed to our site from a paid search engine result and whether people are interested in special offers. We can only see from the statistics that this has happened – we cannot identify individual persons.

We have noticed that our product gets much more attention when we use Facebook pixels. It is therefore in our legitimate interest to integrate Facebook pixels on our website (legal basis Art. 6 lit.f GDPR).

In your Facebook profile, you can choose whether you want to receive personalised advertising. You may object to Facebook pixel collection and use of your information for Facebook Ads (as part of a custom audience). If your browser does not accept third party cookies, the Facebook pixel will not be set.

You can set an opt-out cookie and disable Facebook pixels by clicking this link. The Facebook data policy can be found here: https://www.facebook.com/policy.php. You can find more information from Facebook Pixel here: https://www.facebook.com/business/help/651294705016616.

6. Social media

5.1. Icon links to social networks

On our website we use small icons that refer to our website on platforms of third parties (LinkedIn, Facebook, Instagram, YouTube). These are hyperlinks, so no data from you is transferred automatically, but only when you click on the icons and a new tab with the website of the third-party provider opens in your browser.

5.2. Facebook fan page

On the social media platform Facebook (Facebook Inc., Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbor, D2 Dublin, Ireland (“Facebook”)) we operate a fan page that we link on our company page via the Facebook icon. As long as you do not click on the link, Facebook will not receive any data from you. If you click on the link, for example to view our company website on Facebook or to “like” our page, Facebook receives data from you (the data Facebook receives also depends on whether you are logged in to Facebook when you click on the page or not).

While Facebook uses this data on its own responsibility to create profiles and generate so-called custom audiences, we can only see aggregated data on our company homepage, i.e. statistics that do not allow any personal reference. Linking to our social media presence on Facebook and the associated data processing corresponds to our legitimate interests. The legal basis for this is Art. 6 lit. f GDPR.

Due to the requirements of the GDPR, we have entered into an agreement with Facebook, provided by Facebook, in which the joint responsibility for our fan page is regulated. You will find this agreement in German language under the following link: https://www.facebook.com/legal/terms/page_conmtroller_addendum .

As a result, Facebook is primarily responsible for the aggregated insight data. In addition, Facebook will fulfill all obligations arising from the GDPR with regard to the processing of Insights data (including articles 12, 13 GDPR, articles 15-22 GDPR and articles 32-34 GDPR). If you send us a request regarding our Facebook fan page, we will inform Facebook about it as soon as possible. Facebook will answer the request according to our agreement.

The Facebook Data Policy is available here: https://www.facebook.com/policy.php

7. Your rights

When we process your data, you are a “data subject” within the meaning of the GDPR. You have the following rights: right to information, right to rectification, right to restriction of processing, right to erasure, right to notification and right to data portability. In addition, you have a right to objection and a right to revocation.

Below you will find details on the individual rights:

7.1. Right to information

You have the right to ask us to confirm whether your personal data are being processed.

If we process your personal data, you have the right to obtain information about the following:

  • The processing purposes
  • The categories of personal data being processed;
  • The recipients or categories of recipients to whom your personal data have been disclosed or are yet to be disclosed, in particular with regard to recipients in third countries or international organisations;
  • If possible, the planned duration for which your personal data will be stored or, if that is not possible, the criteria for determining that duration;
  • The existence of a right to rectification or erasure of the personal data concerning you or to restriction of processing by the controller or a right to object to such processing;
  • The existence of a right to lodge a complaint with a supervisory authority;
  • If the personal data were not collected directly from you, all available information about the origin of the data;
  • The existence of automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on you.

If we have transferred your data to an international organisation or to a third country, you also have the right to request information on whether suitable guarantees pursuant to Art. 46 GDPR exist in connection with the transfer.

7.2. Right to rectification

You have the right to rectify and / or complete the data that we have stored about you if these data are incorrect or incomplete. We will undertake the rectification or completion without delay.

7.3. Right to restriction of processing

Under certain conditions you have the right to request the restriction of the processing of your data by us. At least one of the following conditions must be fulfilled:

  • You deny the accuracy of the personal data for a period of time that enables us to verify the accuracy of the personal data,
  • The processing is unlawful and you reject the erasure the personal data and instead demand the restriction of the use of personal data;
  • We no longer need the personal data for the purposes of processing, but you require them to assert, exercise or defend legal claims; or
  • You have filed an objection to the processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether our legitimate reasons outweigh your interests.

7.4. Right to erasure

You have the right to demand that we erase your personal data immediately if we are obliged to do so. This is the case if one of the following conditions is fulfilled:

  • Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  • You withdraw your consent on which the processing was based in accordance with Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR and there is no other legal basis for processing.
  • You object to processing in accordance with Art. 21 (1) GDPR and there are no overriding legitimate reasons for processing, or you object to processing in accordance with Art. 21 (2) GDPR.
  • Your personal data were processed unlawfully.
  • The erasure of the personal data is necessary to fulfil a legal obligation under Union or Member State law which we are subject to.
  • Your personal data were collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

If we have made your personal data concerning you public and are obliged to erase them pursuant to the above conditions, we shall take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform data processors who process the personal data that you as the data subject have requested the erasure of all links to these personal data or of copies or replications of these personal data.

However, your right to cancellation does not exist if processing is necessary for the following reasons (exceptions):

  • To exercise the right to freedom of expression and information;
  • For the performance of a legal obligation required for processing under the law of the Union or of the Member States to which we are subject or for the performance of a task in the public interest or in the exercise of official authority conferred on us;
  • For reasons of public interest in the field of public health pursuant to Art. 9 (2) lit. h and i and Art. 9 (3) GDPR;
  • For archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the law referred to (1) is likely to render impossible or seriously impair the attainment of the objectives of such processing, or
  • To assert, exercise or defend legal claims.

7.5. Right to notification

If you have exercised your right to rectification, erasure or restriction against us, we are obliged to notify all recipients to whom we have disclosed your personal data of the rectification, erasure or restriction of the processing of your data, unless this proves impossible or involves a disproportionate effort.

7.6. Right to data portability

You have the right to receive the personal data you have provided to us in a structured, common and machine-readable format and you have the right to have this data transferred to another controller, subject to the following conditions:

  • Processing is based on consent pursuant to Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR or on a contract pursuant to Art. 6 (1) lit. b GDPR and
  • Processing is carried out using automated methods.

You have the right to have us transfer your personal data directly to another controller, insofar as this is technically feasible and does not impair the freedoms and rights of other persons.

The right to data portability shall not apply if the processing of personal data is necessary for the performance of a task in the public interest or to exercise official authority conferred on the controller.

7.7. Right to objection

You have the right to object, for reasons arising from your particular situation, at any time to processing of your personal data which is based on Art. 6 (1) lit. e or f GDPR. This also includes profiling based on those provisions.

In the event of an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is required for the establishment, exercise or defence of legal claims.

Where our company processes your personal data for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing. This also includes profiling to the extent that it is related to such direct marketing.

If you object to the processing of your personal data for direct marketing purposes, we will no longer process them for these purposes.

Further, in the context of the use of information society services, and notwithstanding RL 2002/58/EC (Privacy and Electronic Communications Directive), you have the option of exercising your right to objection by automated means using technical specifications.

7.8. Right to revocation

Pursuant to Art. 7 (3) GDPR, you have the right to revoke your consent at any time. The revocation of consent does not render the legality of the processing retroactively ineffective.

7.9. Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, without prejudice to any other administrative or judicial remedy. In particular, you may exercise your right to lodge a complaint in your Member State of residence, place of work or place of suspected infringement if you believe that the processing of your personal data is contrary to the GDPR.

An overview of the respective data protection officers of the German Federal States and their contact data is available at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

8. Information about the Kumpan Key app

Status at 31 January 2020.

The app is used via Bluetooth. This means that at no time will personal data be collected, stored or further used.

9. Up-to-dateness and amendment of this Privacy Policy

Last updated: June 2020.