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Privacy Policy

 

Data Protection Information Art 13, 14 GDPR WEBSITE

In our data privacy statement, we provide you with information about the processing of your personal data within the scope of our website.

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We at Surplus Ink consider it a matter of course to handle your personal data responsibly whenever you use our webpages and communicate with us by electronic means. We take all the required measures to protect the personal data provided by you and to comply with applicable national and European data protection regulations at all times. The collection, processing and use of the data by Surplus Ink is exclusively based on applicable legal provisions, in particular in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC – GDPR), the Data Privacy Act 2018 (DSG 2018), the Privacy and Electronic Communications Directive (Directive 2002/58/EC of the European Parliament and of the Council dated July 12, 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector – ePrivacy Directive) and the Telecommunications Act (TKG 2003), as well as any other applicable regulations under Union law.

 

1. Controller within the meaning of Art4(7)GDPR

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surplusink.com is a website that is operated by
 

Impro Group Sàrl

19 rue De-Candolle

1205 Genève

Switzerland
CHE.261.776.214

who is the controller within the meaning of Art 4 (7) GDPR.

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Should you have any questions regarding the protection and safety of your data, or if you want to assert your data privacy-related rights and claims, please call, or send an e-mail to the above-stated contact.

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During access to or use of surplusink.com, data will be collected and used that are personal and/or may influence your privacy – as described in greater detail below. You will not be able to use the services offered unless you provide your data.

 

2. Processing of personal data, purposes of data processing and legal basis

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2.1. Visit to the website​

Each access to the surplusink.com website is logged by Impro Corp.

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Personal data

In the process, the following data will be recorded about you:

- IP address

- date and time of your visit

- duration of the visit

- pages called up

- continent

- country

- region

- ZIP code

- city/town

- language

- longitude and latitude

- type and version of browser

- operating system

- referrer URL (the page from which you were linked through to our website)

- Internet Service Provider

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Purpose of data processing

This data will be statistically analysed in order to modify our website according to the users’ needs, to optimise the user friendliness of our website, to improve the services offered on the website, to identify any errors more quickly, and consequently optimise the website, as well as to control server capacities. Your IP address (internet identifier of your computer, consisting of numbers) will not be analysed by us.

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Accordingly, the usage data will not deliberately be linked up with personal data at any time.

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Legal basis

The legal basis for the processing of access data according to Art 6 (1) (f) GDPR is the legitimate interest (online service offer and data security) of the Controller.

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2.2. Data processing / commercial distribution list

On surplusink.com you can consent to being sent current news from our press release distribution list.

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Personal data

If you register for our commercial distribution list, you can enter and notify Impro Corp of the following of your personal data:

- full company info (mandatory)

- first name and surname

- e-mail address (mandatory)

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Purpose of data processing

The data will be used to send you current commercial offers and company information by e-mail.

To avoid any abuse of email addresses, subscribers must confirm the registration for our newsletter in the course of an automated process by email (double opt-in)

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Legal basis

The legal basis of data processing for the purpose of sending you current commercial distributions is your consent (acc. to Art 6 (1) (a) GDPR). By sending the form (click on the “Send” button), you consent to the data entered by you being processed for the specified purposes.

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Unsubscribe option

Unsubscribing from the press release distribution list is effected through the “Unsubscribe Link” that is shown in each of our commercial distributions. You may also declare your revocation by contacting us at surplusink.com. By revoking the consent, the lawfulness of the consent-based data processing effected until the revocation shall not be affected. If you revoke your consent, you will not receive any further commercial distributions after your notification has been processed.

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Data recipients

For the purpose of dispatching the commercial distributions, your data will be handled by ourselves or our marketing service provider, who is responsible for handling the commercial distributions for us.

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Storage period

The data processed for the above-stated purposes will basically be stored until revocation of your consent to being sent commercial distributions. Moreover, only the data absolutely required will be stored based on applicable legal provisions or retention obligations for the purpose of providing evidence of your consent and/or revocation.

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2.3.Data processing/contact inquiry

The contact form available on our homepage surplusink.com serves to establish contact and/or to submit your remarks.

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Personal data

You need to enter some data to establish contact.

Specifically, also personal data will be processed and stored in the process, namely

- salutation

- name (mandatory)

- company information (mandatory if applicable)

- e-mail (mandatory)

- telephone

- city (town)/country

- subject (mandatory)

- message (mandatory)

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Purpose of data processing

The data will be used to process your inquiry and to get into contact with you in this respect.

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Legal basis

The legal basis for data processing to handle your inquiry is the legitimate interest (adequate relationship with contact person) of Controller acc. to Art 6 (1) (f) GDPR. Potentially, the inquiry may also be considered as a pre-contractual measure or be associated with a contract (Art 6 (1) (b) GDPR).

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Data recipients

For the above mentioned reasons your data may be sent also to the respective subsidiary of Impro Corp.

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Storage period

The data processed for the above-stated purposes will basically be stored until your inquiry has been processed. Moreover, only the data absolutely required will be stored based on applicable legal provisions or retention obligations. Should your inquiry relate to the performance of our contract, the data shall be stored for a maximum of seven years .

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2.9.Licensed photos/use of images

Individual photos on the website originate from our own creations.

We dispose of the relevant rights of use.

 

3. Webtracking

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3.1.Google Analytics and Google Remarketing

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Purpose of data processing:

This website uses Google Analytics and Google Remarketing, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

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Google Analytics uses so-called cookies, or text files that are stored on your computer enabling an analysis of your use of the website. As a rule, the information generated by cookies regarding your use of the website is transferred to and stored on a server in the USA that is operated by Google.

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Third-party providers, including Google, use the cookies to place ads on the basis of previous visits by a user to that website. In this way (if applicable), Google provides a service associated with the use of the website and with Internet use in general and transmits cookie information to third parties, provided it is required under the law or to the extent that this data is processed by third parties on behalf of Google.

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We have activated IP-anonymization on this website. Thereby, your IP address will first be truncated by Google within the member states of the European Union or in other signatories of the treaty on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA to be truncated there. Google will use this information on behalf of the operator of this website in order to evaluate your use of the website, compile reports regarding website activities and provide further services for the website operator relating to website and Internet usage.

The IP address sent by your browser when using Google Analytics is not combined with any other Google data. You can prevent the storage of cookies through a corresponding setting in your browser software; please note, however, that in this case you may not be able to use all functions of this website to their full extent. You can also prevent Google from collecting and processing data relating to your use of the website (incl. your IP address) that is generated by the cookie by downloading and installing the available browser plug-in https://tools.google.com/dlpage/gaoptout?hl=en.

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We will carry out anonymized click tracking for statistical purposes. But this does not allow to retrace individual recipients. The tracking of personal responses enables us to optimise the content of our newsletter and to adjust the same to the changing habits and technical requirements of our users. The data collected will be analysed in anonymized form; accordingly no personal data will be analysed.

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You can prevent the data use of Google Analytics if you click on the following link. An opt-out cookie will be set which prevents the collection of your data in future visits on our website: deactivate Google Analytics

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This website uses the Remarketing function of Google Inc. (“Google”). This function serves to present interest-based publicity ads to website visitors within the scope of the Google advertising network. The browser of the website visitor stores so-called cookies, or text files that are saved on your computer, allowing for the recognition of the visitor when he or she calls up any websites belonging to the advertising network of Google. Publicity ads can then be presented to the visitor on those pages that relate to content which the visitor has previously called up on websites using the Remarketing function of Google. Google claims not to collect any personal data during that process. Should you not agree to Google’s Remarketing function nevertheless, you can deactivate the same in general by making the corresponding settings at www.google.com/settings/ads.

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3.2.Google AdWords and Google Conversion-Tracking

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Purpose of data processing:

This website uses Google AdWords. AdWords is an online ad program of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 994043, United States ("Google").

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In the course of Google AdWords we use so-called conversion tracking. If you click on an ad placed by Google a cookie for conversion tracking is placed. Cookies are small text files that are stored on the computer of the user by the internet browser. Thee cookie expires after 30 days and does not serve for an personal identification purpose of the user. If the user visits certain pages of the website and the cookie is not expired yet,Google and Impro Corp can identify that the user has clicked on an add to get to this page.

Every Google AdWords customer gets a different cookie. The cookies can not be tracked through the websites. The collected information with the help of conversion cookies serve to prepare statistics of AdWords customers who decided for conversion tracking. Customers get to know the total number of users who have clicked on the ad and who have been redirected to a page which includes a conversion tracking tag. No information will be provided where the user can be identified by person. If you do not want to participate in the tracking, you can easily contradict if you deactivate the cookie of Google conversion tracking in the internet browser in your user settings. You will then not be recorded in the statistics.

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The storage of "Conversion cookies" is based on Art 6 Abs 1 lit. f. GDPR. The website operator has a legitimate interest on the analysis of user behavior to optimise the web offer as well as ads.

More information on Google AdWords and Google conversion tracking can be found in the data policy of Google: https://www.google.de/policies/privacy /

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You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, the acceptance of cookies for certain cases or generally exclude and enable the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.

 

4. Cookies

On this page, you will find information about the handling of cookies and personal data (tracking technology).

 

4.1.Technical cookies

Purpose of the use of cookies

Cookies are text files that are stored on your computer, primarily enabling an analysis of your use of surplusink.com. Impro Corpuses or places cookies in accordance with the law of the European Union ePrivacy Directive.

Impro Corpuses information passed on through cookies, such as the browser types used, the operating system, as well as activities such as duration of the visit, number of pages visited or the time of your visit. The usage data will be statistically analysed only internally in order to adjust our website to the needs of the users. Your IP address (Internet identifier of your computer, consisting of numbers) will not be analysed by us. Accordingly, the usage data will not be linked up with personal data at any time. After termination of your visit to our website, the data contained in the cookies are no longer available to us. Make sure that your computer settings reflect whether you want to accept cookies. You may choose your browser settings such that an alert will appear on the display prior to saving a cookie or that the placing of cookies is not possible. But please be aware that in that case you renounce the benefits of personal cookies and that certain applications may not be available in full.

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Legal basis (technical cookies)

The legal basis for the placing of cookies is the legitimate interest of the Controller (Art 6 (1) (f) GDPR), which consists in maintaining the website functions as well as the technically flawless provision of the services of the Controller

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4.2.Other cookies

Legal basis (other cookies)

When using or placing cookies that include personal data or affect privacy, Impro Corp will previously ask for your consent (Art 6 (1) (a)), in fact by your active behavior when you read and accept the cookie information after being informed about the purposes of the cookies used through our cookie banners on surplusink.com, thus agreeing to the cookies, by clicking on “accept”. By not accepting the consent, the lawfulness of the consent-based data processing effected until revocation shall not be affected.

You have the option to receive further information about the individual cookies via a link in the cookie banner, and you can block the placing of individual or all cookies through your browser settings.

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The following cookies will be placed:

4.3.Cookies of third parties

If you visit a page on surplusink.com, that contains embedded content (e.g. YouTube), cookies may be stored by these websites as well. The cookie settings of third parties will not be checked by us. Accordingly, we recommend to obtain information for the use of cookies on the respective website.

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4.4. Further information on cookies

Further general information on cookies and their management is available at www.aboutcookies.org. Please remember that we are not responsible for the content of external websites.

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4.5.Social plug-ins & tools

Social plug-ins (“Plug-ins”) & tools might have been integrated on the website.

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The relevant social networks & tools are the following:

Facebook, operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland,

Comp. Reg. no. 462932 / Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025

Twitter, operated by Twitter International Company, 1 Cumberland Place, Fenian Street, Dublin 2

D02 AX07, Ireland, Comp. Reg. no. 503351 / Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA

Instagram, operated by Instagram LLC, 1601 Willow Rd, Menlo Park, CA 94025, USA

LinkedIn, operated by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland, Comp. Reg. no. 477441

YouTube operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA

Google Plus, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Google WebFonts, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Google Plus, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Google reCAPTCHA, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

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The plug-ins are marked with a logo or the designation of the operator. If you call up our website, which contains any of those plug-ins, your browser will establish a direct connection to the operators’ servers. The content of the plug-in is transmitted by the operator directly to your browser and embedded in the website by the same. By embedding the plug-ins, the operator receives the information that you have called up the relevant website. If you have logged in at the operator, the latter can match the visit with your user account. If you interact with the plug-ins, e.g. by activating a plug-in button, your browser will send the corresponding information directly to the operator, and the information will be stored there. By logging out from your user account, you can prevent the operator from matching the stored information with your user account.

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The purpose and extent of data collection and the further processing as well as the use of the data by the operator including your associated rights and optional settings to protect your privacy are contained in the respective notes on data protection:

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Facebook: https://www.facebook.com/privacy/explanation

Twitter: https://twitter.com/en/privacy

Instagram: https://help.instagram.com/155833707900388

LinkedIn: https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy

Xing: https://www.xing.com/en/privacy

YouTube: https://policies.google.com/privacy?hl=en

Google Plus: https://policies.google.com/privacy?hl=en

Google WebFonts: https://policies.google.com/privacy?hl=en

Google Maps: https://policies.google.com/privacy?hl=en

Google reCAPTCHA: https://policies.google.com/privacy?hl=en

 

5. Storage period

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At Controller, your personal data will be stored for varying periods – depending on the necessity and the purpose – (see the information above)

Deletion of the data shall be effected as described above, unless any legal retention obligations (under business and/or tax law) exist.

Based on applicable legal provisions (§ 212 UGB, § 132 BAO etc) we are obliged, among others, to store certain personal data for a minimum period of seven years. This concerns the following data:

- first name

- surname

- ZIP code

- city/town

- country

- invoice and delivery address

- means of payment

- client number

- order number

- name of company and UID number, if applicable

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Based on applicable legal provisions under the European ePrivacy Directive, we are obliged, among others, to store certain personal data for a minimum period of 3 years. This concerns the following data:

- salutation

- title

- date of birth

- telephone number

- user name

- e-mail address:

- password

 

6. Data security

6.1. Security measures implemented

Controller takes measures to ensure an appropriate level of protection with respect to data processing security acc. to Art 25 and Art 32 GDPR.

We have taken comprehensive security measures to protect your data against unauthorized third-party access. In doing so, we use a data protection management system.

Please note, however, that it is equally important to protect your computer against unauthorized access, for instance by only allowing trustworthy third parties to use the same and by always using up- to-date firewall and antivirus software, and by checking your e-mails for authenticity and reliability (phishing mails).

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6.2.Exclusion of liability

No liability shall be assumed for any loss caused due to the fact that you fail to adequately protect your computer against third-party access.

 

7. Rights of data subjects (Art 12–22 GDPR)

As a user of our website, you are entitled to the following rights:

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7.1.Right of access (Art 15 GDPR)

You are entitled to demand information as to whether any personal data is processed that relates to you. Moreover, you are entitled to request further information about the specific purposes of data processing, the categories of personal data, the recipients or categories of recipients of personal data, the storage period, the existence of any right to erasure or rectification of your personal data, the existence of any right to lodge a complaint, as well as with respect to all available information about the source of your data.

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7.2.Right to rectification (Art 16 GDPR)

You have the right to demand immediate rectification of your personal data.

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7.3.Right to erasure (Art 17 GDPR)

You have the right to demand immediate erasure of your personal data.

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7.4.Right to restriction of processing (Art 18 GDPR)

In the instances listed in Art 18 GDPR (for instance, the accuracy of the personal data is contested by you or the processing is unlawful), you are entitled to demand restriction of data processing.

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7.5. Right to data portability (Art 20 GDPR)

You are entitled to receive the personal data about you, which you have provided to us, in a commonly used structured format and to demand that we transmit said data to another controller.

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7.6.Right to object (Art 21 GDPR)

You have the right to object to the processing of your personal data, which is processed within the scope of our website.

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7.7.Revocation of declarations of consent (Art 7 GDPR)

You have the right to revoke, at any time, any consent you have given to us.

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7.8.Measures in connection with automated decisions in individual instances, including profiling (Art 22 GDPR)

In instances of automated decision-making, including profiling, you are entitled – provided that the relevant measure has any legal effect on you or considerably affects you in any similar way – to make any other person intervene on the part of the controller, to explain your point of view and to challenge the decision.

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7.9.Right to lodge a complaint

You may assert your rights as a data subject and file a complaint vis-à-vis Controller at the following address:

surplusink.com

Impro Group Sàrl

19 rue De-Candolle

1205 Genève

Switzerland

CHE.261.776.214

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