Data Protection Website

Data protection on the AZ Direct GmbH website

We, AZ Direct GmbH, welcome your visit to our website and your interest in our company and the range of services that we offer. Data protection is a top priority and a matter of course at AZ Direct GmbH. As an employer and as a service provider, we strictly follow the latest regulations.
We stand for safety and transparency – day in, day out, in everything we do. In addition, with Data Secure[hoch]TTP[/hoch] we have developed a patented, unique process that makes data processing even safer.
As a member of the Deutsches Dialogmarketing Verband e.V. (DDV - German Dialogue Marketing Association), we guarantee compliance with data security standards and the highest standard of professionalism and quality.
The data protection notice meets the information obligations pursuant to the requirements of Art. 12 et seq. of the EU General Data Protection Regulation (hereinafter “GDPR”) and gives you an overview of how your personal data (hereinafter “data”) is processed on this website.

1. Who is responsible for processing my data?

AZ Direct GmbH
Carl-Bertelsmann-Str. 161 S
33311 Gütersloh
Phone: +49 5241 80-70800
Telefax: +49 5241 80-9317
E-mail: az(at)bertelsmann.de

is responsible for processing your data on this website (hereinafter “AZ Direct”). AZ Direct processes personal data in accordance with the provisions of the GDPR and the Federal Data Protection Act (hereinafter “BDSG” [Bundesdatenschutzgesetz]).

You can contact the AZ Direct data protection officers at:

AZ Direct GmbH
Data protection officer
Carl-Bertelsmann-Str. 161 S
33311 Gütersloh
Phone: +49 5241 80-75039
Telefax: +49 5241 80-66909
E-mail: az.datenschutz@bertelsmann.de

2. What data is collected?

Information is automatically recorded from the requesting computer (hereinafter “access data”) when you visit the website. The access data includes server log files which generally consist of information on your browser type and version, your operating system, your internet service provider, the date and time you used the website, the websites you previously visited and the newly visited websites and the IP address of the computer. With the exception of your IP address, server log files are not personal. An IP address is personal if it is permanently assigned when using the internet connection and the Internet provider can assign it to a person.

3. Do you use cookies?

We use cookies on this website. Cookies are small text files that are stored on your computer when you visit a website. The stored cookies are assigned by the browser that you used. If the same website is visited again, the web browser returns the content of the cookies, thereby allowing the user to be recognized again. Certain cookies are deleted if you log out or end the browser session (“transient cookies”). Other cookies are stored for a prescribed time or permanently (“temporary cookies” or “persistent cookies”). These cookies are deleted automatically after the defined time has expired. You may also delete cookies at any time in your browser’s security settings and configure the use of cookies as you so wish. However, AZ Direct would like to point out that you may not be able to use all the functions of the website.

Generally speaking, cookies are merely an impersonal form of online identification. Cookies are only personal when additional data is added to the information generated by the cookies. In doing so, a distinction has been made between cookies that are necessary to provide the website and cookies that are necessary for additional purposes such as analyzing user behavior or advertising. We use analysis and tracking cookies on the website (see points 4.5 and 4.6).

4. What data is recorded and for what purpose?

The purposes of data processing can be based on technical, contractual or legal requirements and may also result from consent being granted to do so, where relevant.

We use the data mentioned in point 2 for the following purposes:

• to provide the website and ensure technical security, in particular troubleshooting, and to ensure that unauthorized parties cannot access the website’s systems;
• for communication purposes, initiating an agreement, and customer care;
• to send newsletters and/or program communication by email;
• for reach measurement and web analysis to design the website for you in a more efficient and interesting way, and to conduct market research;

Further information about these purposes for processing data is available in the following sections of this data protection notice.

4.1 Technical provision of the website

4.1.1 Description and scope of data processing

In order for the website to function, to conduct security analyses and to defend the website from attacks, server log files are automatically recorded and temporarily stored as a component of the access data pursuant to point 2 of the computer system of the requesting computer upon access when using the website. Server log files are not stored together with other data. AZ Direct uses the server log files for statistical assessments to analyze disruptions and troubleshoot, defend against attacks and attempted fraud, and to optimize the functionality of the website.

4.1.2 Purposes and legal basis for data processing

The legal basis for recording server log files is Art. 6 Para. 1 (f) GDPR. AZ Direct’s legitimate interests lie in the website’s ability to function, conducting security analyses and defending it against risks.

4.1.3 Storage period and criteria for determining this period

After visiting the websites, server log files are stored on the web sever and the IP address that they include shall be deleted after seven days at the latest. An assessment shall only be made during this storage duration in the event of an attack.

4.1.4 Opportunity to object and request removal

You shall have the right to object to your data being processed as server log files provided there are reasons for doing so arising from your particular situation. If you would like to assert your right to object, please contact the data protection officer at the address specified under point 1.

4.2 Contact form, email and phone contact

4.2.1 Description and scope of data processing

You can contact AZ Direct via the contact form, email address, or telephone number that is available on the website. Whichever option you select, the data entered in the contact form, your email address and/or your telephone number and your concerns shall be sent directly to AZ Direct. Depending on the concern (e.g. questions about AZ Direct’s products and services, asserting your individual rights as data subject, such as the right to information), your contact data shall continue to be processed (through service providers). Your contact data may be forwarded to third parties (e.g. partner companies) if this is required to process your concern.

4.2.2 Purposes and legal basis for data processing

The legal basis for processing your contact information is Art. 6 Para. 1 (f) GDPR. Our legitimate interests lie in processing your concern and further communication. If you have initiated contact to conclude an agreement with AZ Direct, the legal basis for processing your contact information is Art. 6 Para. 1 (f) GDPR. The legality of processing the personal data sent to us in order to be recorded on our advertisement block list is based on Article 6 Para. 1 (a) and (f) GDPR.

4.2.3 Storage period and criteria for determining this period

Your contact information will be deleted after processing your concern and having ended further communication. This shall not apply if you initiated contact to conclude an agreement with AZ Direct or if you assert your rights as data subject, such as the right to information. For this purpose, data is stored for as long as the contractual and/or statutory obligations are met and the statutory storage periods do not oppose deletion. Entries on AZ Direct’s internal advertisement block list shall be permanently stored so that the persons concerned do not receive advertisements from AZ Direct in future. The data subject may delete their entry at any time.

4.2.4 Opportunity to object and request removal

You have the right to object to your contact information being processed provided there are reasons for doing so arising from your particular situation. If you would like to avail yourself of your right to object, please contact the data protection officer at the address specified under point 1. If you raise an objection, communication cannot continue. This shall not apply if it is necessary to store your contact information to initiate an agreement, fulfill an agreement or assert your individual rights as data subject.

4.3 Newsletters

4.3.1 Description and scope of data processing

The website offers you the option of subscribing to a free newsletter. In this process, your data from the login mask is sent to AZ Direct (through service providers) and further processed for sending newsletters. Consent shall be obtained from you when logging in and you shall be directed to this data protection notice. Your data shall not be forwarded to third parties. Mandatory information to receive the newsletter is your company name, forename, surname, and email address. Processing of your login information (login IP, login date, confirmation IP, confirmation date) is also necessary to prove that you gave your consent. Other information may be given voluntarily in order to be able to address you personally.

We would like to point out that AZ Direct assesses your user behavior when sending its newsletter. The emails sent contain “web beacons” or “tracking pixels”, which are one-pixel image files that are stored on the website to assess this behavior. AZ Direct links your information and the web beacons with your email address and individual ID for these assessments. We use Adform’s retargeting technology for this purpose. This allows us to address each individual user who has already shown interest in our websites and products with targeted advertising on our partner websites. Advertising media is displayed during retargeting based on cookie-based analysis of the user’s previous behavior.

4.3.2 Purposes and legal basis for data processing

It is necessary to process your data that we receive via the login mask to advertise AZ Direct’s goods and/or services. The legal basis for processing data when signing up for the newsletter is consent pursuant to Art. 6 Para. 1 (a) GDPR in combination with Section 7 Para. 2 (3) of the Law against unfair competition (Gesetz gegen den unlauteren Wettbewerb - hereinafter “UWG”). The legal basis for processing your data after purchasing the company’s goods and/or services is Art. 6 Para. 1 (f) GDPR in combination with Section 7 Para. 3 UWG. The justified interests of AZ Direct lie in advertising to existing customers.

4.3.3 Storage period and criteria for determining this period

Data is stored for as long as you are subscribed to the newsletter. Data is only stored after newsletter inactivity to prove that AZ Direct obtained your consent for the newsletter, i.e. that AZ Direct acted in compliance with data protection laws. The same shall apply if you revoke your consent.

Tracking cookies are temporary cookies that lose their validity after 60 days.

4.3.4 Opportunity to object and request removal

You may revoke your consent to receive the newsletter at any time by confirming the unsubscribe link in a AZ Direct newsletter, communicating your revocation to AZ Direct at az.datenschutz(at)bertelsmann.de with the subject “Newsletter revocation” or through the other contact methods listed under point 1.

You can object to this tracking at any time by clicking on the separate link included in each email or by informing AZ Direct through a different means of contact.

4.4 Google Tag Manager

This website uses Google Tag Manager for the purpose of functionality. This service is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google Inc.). By using Google Tag Manager, web-tracking services (see point 4.5) can be incorporated into this website and other services managed by using “tags” (placeholders for a website code). Only Google Tag Manager implements these tags. No cookies are used and no personal data is specifically recorded by Google Tag Manager. Google Tag Manager only produces other tags that in turn record data, where appropriate. However, Google Tag Manager does not access this data.

4.5 Web tracking

Services are included on the website that optimize user-friendliness and enable the website’s reach to be measured. In doing so, your access data (see point 2) is recorded and user behavior assessed using analysis cookies (see point 3). Personal identification is generally not required for web tracking. This means that the stored IP addresses are either not used or only used in an abbreviated form and a pseudonymous user profile is created when recording your access data. Therefore, they are not combined with other data and you may revoke this at any time. Personal user profiles are only created in exceptional cases and provided you have given your consent.

Web-tracking services are generally provided by service providers that process that data only according to the instructions of the controller (person responsible for the data) and not for their own purposes as processors. This is ensured based on agreements on order processing. If service providers process your data outside of the European Union or European Economic Area (hereinafter “EU” and “EEA”), a third-country transfer takes place. This is permitted if the service provider has consented to AZ Direct creating guarantees for a level of data protection appropriate for the European standard or if the EU Commission has classified the third-party country in question as a safe third-country. The third-country transfer of each service is identified below.

The web-tracking service of the website is described in more detail below.

4.5.1 Google Analytics

The website uses Google Analytics. The provider of Google Analytics is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. A pseudonymous user profile is created by Google Analytics to optimize the user-friendliness of the website. Pseudonymity is ensured as a result of your IP address being abbreviated before your data is sent to Google, meaning that no conclusions may be drawn about your person. The pseudonymous user profile is assessed after transfer to optimize user-friendliness. It is not combined with other data from Google. AZ Direct ensures that Google only processes data according to its instructions by means of an agreement on order processing.

A third-country transfer takes place by using Google Analytics (see point 4.5). 

More information on data processing at Google Analytics is available in Google’s Privacy Policy.

4.5.2 Purposes and legal basis for data processing:

The legal basis for recording and assessing pseudonymous user profiles is Art. 6 Para. 1 (f) GDPR and Section 15 Para. 3 of the Telemedia Act (Telemediengesetz - TMG). AZ Direct’s legitimate interests lie in optimizing the website’s user-friendliness and measuring its reach. If personal user profiles are recorded and assessed, the legal basis for this shall be your consent pursuant to Art. 6 Para. 1 (a) GDPR.

4.5.3 Storage period and criteria for determining this period:

Data that is recorded and assessed when using web-tracking services is generally stored until you object to its use. If data is processed based on your consent, your data shall be stored until you revoke your consent.

4.5.4 Opportunity to object and request removal:

You can prevent the use of cookies by simply selecting the appropriate settings in your browser.

You may object to Google Analytics collecting and using your IP address at any time with effect for the future. You may also install a plug-in offered by Google for this purpose. You can find the plug-in as well as more information on Google’s website here.

Further information on how Google uses data for advertising purposes, settings and options for raising objections is available on Google’s websites:(“Google’s use of data when you use our partners’ websites or apps“), (“Using data for advertising purposes“), (“Managing the information that Google uses to display advertisements to you“) and (“Determine which advertisements Google shows you“).

4.6 Online advertising

Services that are used for online advertising are included on the website. In doing so, your access data (see point 2) is recorded and user behavior assessed using advertising cookies or the advertising cookies of third parties (see point 3) where both the company’s own advertisements and third-party advertisements are shown. Personal identification is, generally speaking, not required for online advertising. This means that the stored IP addresses are either not used or only used in an abbreviated form, and a pseudonymous user profile is created when recording your access data. Therefore, they are not combined with other data and you may revoke this at any time. Personal user profiles are only created in exceptional cases and provided you have given your consent.

Online advertising can be managed locally or by multiple providers. If online advertising is managed by multiple providers, advertising networks appear as an intermediary between the advertiser and advertising medium. In doing so, the advertising networks record user profiles and deduce their interests in order to display individual advertising the next time that the user visits the website. Depending on the activity of each advertising network, they, as service providers, act according to instructions and AZ Direct concludes a processing agreement with them.

4.6.1 Adform A/S

This website uses cookies provided by Adform A/S, a company that offers us digital advertising services. By using cookies, Adform can recognize your computer when you visit our website and when you visit certain other websites.  Based on cookies, Adform can collect information about your device and search behavior, including:

(i) your IP address – this is anonymized before further use so that no-one can directly identify you;

(ii) the cookie ID, a random string of characters that is stored on your device;

(iii) information about your operating system and other technical information (screen resolution, language settings, country settings, device ID, device type and the type of browser you use to visit a website); and

(iv) the date, time and location of your visit to the website, the domain you visit and the URLs you previously entered.

The information collected during this process do not allow us or Adform to discover your name, contact information or other personal identification information.

4.6.2 Purposes and legal basis for data processing:

These cookies and the data collected from them are used to create advertisements that are more relevant to you. They include the following functions: Preventing the same advertisement from being repeatedly displayed, measuring and reporting the efficacy of advertisements, determining prices and bid decisions for certain elements of advertising options, selecting advertisements and content based on your interests and ensuring the integrity and security of the services that Adform offers its customers, including analysis as to whether a visit to a website originates from a robot or software program.

The purposes of this data processing are advertising, reach measurement and designing the website according to our needs. The legal basis for data processing is Art. 6 Para. 1 (f) GDPR.

4.6.3 Storage period and criteria for determining this period:

The data is automatically deleted 60 days after the last interaction. Adform does not store any cookie-based information for longer than 13 months.

4.6.4 Opportunity to object and request removal:

Further information about the use of cookies and Adform’s data protection principles is available here. You may turn off Adform cookies at any time here or by deactivating Adform cookies via your browser settings.

4.7 Analysis by wiredminds

Our website uses a counting pixel technology provided by wiredminds GmbH (www.wiredminds.de) to analyze visitor behavior. If necessary, data is collected, processed and stored, from which user profiles are created under a pseudonym. Wherever possible and reasonable, these usage profiles are completely anonymized. Cookies can be used for this purpose. Cookies are small text files that are stored in the visitor's Internet browser and serve to recognize the Internet browser. The collected data, which may also contain personal data, will be transmitted to wiredminds or collected directly by wiredminds. wiredminds may use information that is left by visiting the websites to create anonymized usage profiles. The data obtained without explicit consent of the affected person will not be used to personally identify the visitor of this website and will not be merged with personal data of the bearer of the pseudonym. Whenever IP addresses are recorded, their immediate anonymization takes place by deleting the last number block.

Exclude from tracking.

5. Who receives my data?

At AZ Direct, departments requiring your data to fulfill the purposes shown under point 4 shall have access to your data. Service providers employed by AZ Direct may also have access to your data (“processors”, e.g. computer centers, sending newsletters, customer service, and debtor management). Complying with instructions, data security and confidential handling of your data is ensured by these service providers by means of processing agreements.
Data is forwarded to other recipients such as advertising partners, social media service providers or credit institutions (“third parties”) if legal provisions so require or if you have given your consent.
Further information on forwarding data to third parties is listed in the individual purposes under point 4.

6. Is my data processed outside of the EU or EEA (third-country transfer)?

If the service providers and/or third parties named under point 5 process your data for the purposes under point 4 outside of the EU or EEA, this can lead to your data being sent to a country in which a level of data protection adequate for the EU or EEA cannot be guaranteed. However, such a level of data protection can be ensured by means of a suitable guarantee. Standard contractual clauses provided by the EU Commission are considered to be a suitable guarantee. You may request a copy of these guarantees from the contacts mentioned under point 1. As an exception, guarantees may be waived if you consent to this or if the third-country transfer is necessary to fulfill your agreement with AZ Direct. The EU Commission has also recognized certain third-countries as safe third-countries, so AZ Direct may also waive suitable guarantees in these locations.

The following service providers process your data outside of the EU or EEA:

• A third-country transfer takes place by using Google Analytics (see point 4.4).

7. What data protection rights do I have?

You shall have the right to information about the personal data that we have stored about you at any time. If your data is incorrect or no longer up-to-date, you shall have the right to demand its correction. Moreover, you have the right to demand the erasure or processing limitation of your data pursuant to Art. 17 or 18 GDPR. You shall also be entitled to request that the data provided to you is issued in a common and machine-readable format (right to data portability).
If you have given your consent to the processing of personal data for certain purposes, you may revoke said consent at any time with effect for the future. The revocation must be sent to AZ Direct to the contact address mentioned in point 1. You may also revoke consent that you granted to the website using the contact information mentioned in point 1.

Pursuant to Art. 21 GDPR, you shall have the right to submit an objection to your data being processed - which takes place on the legal basis of Art. 6 Para. 1 (f) GDPR - at any time for the reasons arising from your particular situation. You shall also have the right to submit an objection at any time to your data being processed for the purposes of direct advertising. The same shall apply for the automated process when using individual cookies if they are not required as mandatory to provide the website.

Furthermore, you shall have the option to contact the data protection authorities and submit complaints. The authority responsible for AZ Direct is

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
(State Officer for Data Protection and Information Freedom in North Rhine-Westphalia)
Kavalleriestr. 2-4
40213 Duesseldorf
Telephone: 0211/38424-0
Fax: 0211/38424-10
E-mail: poststelle(at)ldi.nrw.de

You may also contact the competent data protection authorities for your place of residence.

8. To what extent do you use automated processes to make decisions?

We do not use any fully-automated decision-making processes for the purposes named under point 4.

9. Do you profile?

We do not profile for the purposes named under point 4.

10. Conclusion/version information

As part of continuing to develop our website and implementing new technologies, and in order to improve our service for you, amendments to this data protection notice may be necessary. We therefore advise that you read through this Privacy Policy again from time to time. The latest version of the Privacy Policy is available here:

Last updated: May 2018