Privacy Statement  (Version as of 01/15/2016)

The following Privacy Statement by Klöckner Group (hereafter also referred to as “Klöckner“, “we“, or “us“) describes the  personal data we collect about you when you use our website at www.kloeckner.co.uk (hereafter together referred to as “websites“) and how we process and use these data.

We welcome you to our website and we are pleased by your interest in our company group and our products.

I. Members of Klöckner Group in the UK

ASD Metal Services Ltd.

II. Service Provider and Data Controller

The company mentioned in the imprint is the Data Controller according to Section 1(1) of the Data Protection Act 1998, and is legally responsible for the website.

III. Personal Data

Personal data means any information relating to a living individual who can be identified from those data, or from those data and other information which is in the possession of, or is likely to come into the possession of, the Data Controller (hereafter referred to as “data“). This is information such as your first and last name, your address, your telephone number or e-mail address, for instance.

 

IV. Collection, Processing and Usage of Your Personal Data

 

1. Collection, Processing and Usage of Your Personal Data while Using Our Website

If you use our websites, even if you do not register on the websites to use specific functions and if you do not disclose information to us in another way, the following data, together referred to as “Usage Data”, will still be processed by us to enable proper usage of our websites

  • connection details of the requesting device, including the IP address
  • previous visited websites, including the last website you visited before ours
  • date and time of your visit
  • type and version of your internet browser and operating system
  • volume of transferred data

(together referred to as “usage data“)

We analyze this Usage Data by means of web tracking tools for the purposes of system security and improving our websites. More information on how to object to this tracking can be found here[update link].

For the purposes of business development, and to personalize our interactions with you, we may analyse your Usage Data jointly with: (i) data provided by the use of the services mentioned in section IV. 3 to IV. 7, (ii) data provided for contact and / or (iii) data from existing customer relationships (hereafter referred to as “Content data”),, insofar as you have given your explicit consent under section V of this privacy statement. In some cases, we will add other data to your User and Content data, such as your position in your company and your communication contact details, in order to provide you with better support.

If you are a business owner, we will add further information to your data e.g. information on the nature of your business or your industry. As far as we use service providers for these purposes, we will ensure that they contractually undertake to observe our privacy standards.

 

2. Collection, Processing and Usage of Your Personal Data while Using Our Online Shop

If you order products in our online shop at https://shop.kloeckner.co.uk as a new customer, you will need to register and create a customer account, which requires the collection and storage of data (including title, last name, given name, business email address, business telephone number, password, company name, billing address, tax number) for later purchases.

If you or the company for which you work are/is a customer of Klöckner already, a separate registration is not required, but only an activation of your webshop account. You can activate your account by inserting the customer ID assigned to you and your e-mail address directly into our webshop. After comparing the data you have inserted with the data already stored at Klöckner with regard to the company you are assigned to, you will receive a username assigned to you and a one-time password to log in to the webshop. Any data that already exists from a previous client relationships with you and the company assigned to you that are stored in other systems of Klöckner will be transferred to the webshop system. For the purpose of better usability of the data, content data will be exchanged mutually between the webshop and other existing systems in the Klöckner Group.

After logging in, you can view any already closed contracts and orders placed (including e.g. order ID, delivery address, item number, desired unit of measure and time) which are assigned to your function.

If you have registered with our web shop, or activated your account, you have consented to the collection, processing and use of the data inserted and to the processing and use of the data already stored through the existing customer relationship in the webshop – where available – as stipulated in section V.

The data you have provided is used for the purposes of processing and fulfilling your orders. For this purpose we disclose your address data to third parties (e.g. contracted shipping companies or contracted suppliers/forwarders) and if necessary your payment data to our bank. In carrying out your order, we also disclose your data to other participating Klöckner Group members as far as required for the fulfilment of the contract. Finally, we also use companies of the Klöckner-Group to provide us with support for the online shop. In this context, access to your data is also possible by other companies of the Klöckner-Group.

From time to time, we use external service providers to process your data. We have carefully selected them and have entered into written contracts with them.

If you have made an order in the webshop, we will also collect, process and use your company name and your business address to fulfill legal requirements to check against the so-called terror-lists. This is a requirement of European terrorism regulation, governing the fight against terrorism, and therefore we will comply with it. For this purpose we use a service provider who carries out the comparison for us and who is contractually bound to us, particularly in relation to data privacy.

After the full execution of the contract and after the expiry of the fiscal and commercial statutory retention periods we will delete your personal data.

3. Collection, Processing and Usage of Your Personal Data while Using Our Contract Platform

If you work for a company which is already a customer of Klöckner, and your account has been activated for the registration on the contract platform, you can access the already existing contracts you are assigned for online at https://contracts.kloeckner.co.uk. An activation is possible in various ways. If you would like to activate your account on the web pages, you can insert your assigned customer number and your e-mail address directly in the activation form on our contract platform. After comparing the data you have inserted with the data already stored at Klöckner with regard to the company you are assigned to, you will receive a username assigned to you and a one-time password to log in to the contract platform.

If you need further information about platform account activation, please contact your sales agent at Klöckner.

After activation of your account, you will receive an e-mail with your username, which is personal to you, a one-time-password for your initial login for the contract platform and an access link to the contract platform in a separate e-mail.

The first time you log in to the contract platform, you have to enter your user name and one-time password and consent to the collection, processing and usage of your personal data in line with this Privacy Statement.

If you have activated your account and / or logged in to our contract platform, you have consented to the collection, processing and use of the data inserted and to the processing and use of the data already stored through the existing customer relationship in the contract platform as stipulated in section V.

After your first log in, you will be required choose a new password, afterwards you can sign in to the contract platform with your username and password to access the information of the contracts assigned to you. You can then stay up to date with regard to the quantities available and the remaining time of the contracts, and also any expired contracts. The information already stored at Klöckner regarding existing contracts (duration, ID, order number, key contact etc.) will be exchanged for this purpose and for the purpose of better usability of the data between the contract platform and other existing systems in the Klöckner Group.

If you are authorized to start a new order on the contract platform or request a follow-up contract, you will be required to provide the necessary data, e.g. order number, order quantity, address, article number, requested quantity and date.

The data you provided will be used to process your order. Insofar as we collect, process and use your data for other purposes, this is performed solely as described in section IV.7

We will delete your personal data at your request or after completion of the contract and after the expiry of the fiscal and commercial statutory retention periods.

4. Collection, Processing and Usage of Your Personal Data while Using Our Order History Platform

If you work for a company which is already a customer of Klöckner, and your account has been activated for the registration on the order history platform, you can access your order history for your already completed orders online at https://orders.kloeckner.co.uk. An activation is possible in various ways. If you would like to activate your account on the web pages, you can insert your assigned customer number and your e-mail address directly in the activation form on our order history platform. After comparing the data you have inserted with the data already stored at Klöckner with regard to the company you are assigned to, you will receive a username assigned to you and a one-time password to log in to the order history platform.

If you need further information about platform account activation, please contact your sales agent at Klöckner.

After activation of your account, you will receive an e-mail with your username, which is associated with your person, a one-time-password for your initial login for the order history platform and an access link to the order history platform in a separate e-mail.

The first time you log in to the order history platform, you will be required to enter your user name and one-time password and consent to the collection, processing and usage of your personal data in line with this Privacy Statement.

If you have activated your account and / or logged in to our order history platform, you have consented to the collection, processing and use of the data inserted and to the processing and use of the data already stored through the existing customer relationship in the order history platform as stipulated in section V.

After your first log in you will be required to choose a new password. Afterwards you can sign in to the order history platform with your user name and password to access the information relating to your orders. The information already stored at Klöckner regarding existing orders (duration, ID, order number, key contact etc.) will be exchanged for this purpose and for the purpose of better usability of the data between the order history platform and other existing systems in the Klöckner Group.

We will delete your data at your request or after completion of the order and after the expiry of the fiscal and commercial statutory retention periods.

5. Collection, Processing and Usage of Your Personal Data while Using other Services on our Website

If you want to use other services on our website, you can also register for these or register yourself directly on the website.

In this regard, you have to provide contact details, including your name, e-mail address, the company you work for and the address as well as your telephone number at your company and the services you request.

If you or the company for which you work are/is a customer of Klöckner, you can view already existing services rendered which are assigned to you in your function. The information already stored at Klöckner regarding existing services rendered, will be exchanged for this purpose and for the purpose of better usability of the data between the service platform and other existing systems in the Klöckner Group.

If you have activated your account and / or logged in to a service platform, you have consented to the collection, processing and use of the data inserted and to the processing and use of the data already stored through the existing customer relationship in the respective service platform as stipulated in section V.

We collect, process, and use the data provided in this context to provide you with the requested services.

If we collect, process, and use your data for other purposes, this is performed solely as described in section IV.7.

6. Collection, Processing and Usage of Your Personal Data while Using Our Contact Form

We offer users the option to contact Klöckner by using contact forms, for example to ask questions about our products or to order information material. For this purpose necessary personal data, for example, last name, given name, address, telephone number, e-mail address will be collected by our website to reply to your questions. For faster and more precise handling of your requests, we use a special software application, which helps us to optimize our processes. For the purpose of technical support for the software application, the Zendesk, Inc., USA (hereinafter called “Zendesk“) will have access to the software application, so it cannot be excluded that Zendesk comes into contact with your personal data. Thus, in an individual case, it cannot be ruled out that there might be a data access from the USA. To ensure that in each case an adequate level of data protection is guaranteed by Zendesk, we legally committed Zendesk so that the access to your data are in line with European data protection standards, strictly bound by our instructions and does not take place for Zendesk’s own purposes.

7. Collection, Processing and Usage of Your Personal Data for Purpose of Advertising and Market and Opinion Research; Right to Revoke

Your customer and order data will be processed and used by companies of the Klöckner-Group not only for order processing and delivery of services, but also for the purpose of advertising and market and opinion research as long as we have received your declaration of consent in line with section V.

As part of the handling of personal data for advertising and market research purposes, we will process your personal data and other information we receive from you, in particular your given name, last name, address and e- mail address, and use it to provide you with interesting offers and to create your individual shopping experience and improve it continuously. This also means that from time-to-time we can send you product recommendations for related products by e-mail based on you previous orders. However, you will only receive other advertising via e-mail, as far as we have your separate explicit consent for that (e.g. with separate newsletter sign-up).

Besides that and insofar as we have received your express permission for this (e.g. with separate newsletter sign up when registering at the webshop), we will use your information to send you personalized offers and information, newsletters about products, services and marketing offers as well as invitations to rate our products by e-mail. In this case the text of your separate declaration of consent is as follows:

“Yes, I would like to subscribe to the free newsletter and would like to be informed about vouchers and promotions. The de-registration is possible at any time. Further information can be found in the privacy statement“.

You are entitled to revoke your consent to the use of your personal data for advertising and market research purposes and / or for the sending of advertisement via e-mail at any time for the future as described in the following section V.

V. Consent of the Collection, Processing and Usage of Your Personal Data

Provided that you have already ordered or otherwise subscribed to certain services (for example. the use of contract platform or order history platform through the Klöckner’s website), you have declared the following consent to the collection, processing and usage of your personal data:

“I have read the Klöckner’s privacy statement and hereby give my consent to the collection, processing and usage of my personal data mentioned therein“

 

With the declaration of this consent, you hereby agree that your personal data may be collected, processed and used in line with the provisions of this privacy statement, that is for the purposes contained and within the scope specified in section IV (in particular development of the internet site including web shop, conclusion, performance, termination and communication of the legal transactions as well as advertisement, market and opinion research). Within the scope specified in this privacy statement, your consent correspondingly includes the transfer, processing and usage of your personal data to and by third parties inclusive of any other companies of Klöckner Group as well as to third parties outside the EU / EEA.

 

The consent you have given us through the websites may be at any time and with future effect revoked:

–       by an informal letter to ASD Metal Services Ltd., Data Protection Officer, Valley Farm Road, Stourton, GB-Leeds LS 10 1 SD or

–       by an e-mail to Richard.marjoribanks@kloeckner.com

The execution of the right to revoke is free of charge, with exception of any possible transfer or connection charges.

Should you choose to revoke your consent only with respect to certain processing and use purposes, we would request you to make it clear by naming these respective purposes while revoking your consent (e.g. by naming thereof “revocation of consent to advertisement”, if you want to revoke your consent only with respect to processing and use of your personal data for advertisement purposes). Your personal data may then be only used in an anonymous format for marketing purposes.

Should you not determine the scope of your revocation closely enough or you expressly specify this scope extensively, we will consider your revocation to include all collection, procession und usage of personal data as set forth in this privacy statement.

We will respect your right to revoke the consent. However, please keep in mind that we must also check if any retention obligations of legal or any other nature oblige or entitle us to process and / or use, wholly or partially, your personal data, for example because we are obliged to comply with relevant tax retention obligations or because we need your personal data in order to fulfil or otherwise complete our contractual obligations or have to use your personal data in order to fulfil or otherwise complete our contractual obligations towards you.

VI. No Sale of Your Personal Data to Third Parties

The personal data you provide to us us will not be sold, let or in any other way made available to third parties, in particular we do not trade your address. Transfer of the personal data collected through our websites to countries outside the EU or the EEA in principle does not take place. In the event that such a transfer exceptionally takes place, we will adopt the necessary measures to ensure an adequate level of data protection.

VII. Cookies

“Cookies“ are small text files, which are transferred to your computer from our webserver via the internet browser and will be saved on your computer, so that the data stored in the cookies can later be retrieved. The information stored in a cookie can thereby allow the recognition of your web browser. The data stored pseudonymously in a cookie is stored separately from any other personal data stored by us and not linked to any personal information. Cookies help us to determine the frequency of use and the number of users on our website and to design our website to you as convenient and efficient as possible. Klöckner uses both session-cookies, which are immediately deleted when your browser is closed, and persistent-cookies, which remain in the cookie file of your browser for longer. The cookies on our website collect data exclusively using pseudonyms.

Regardless of the type of cookies used, you always have the choice to decide whether to accept cookies or not. You can use our website without cookies. You can set your browser to disable cookies, limit the storing to certain websites or set your browser that it notifies you whenever a cookie is set. You can delete the stored cookies at any time. This applies in particular for persistent cookies. However, please note that this may lead to technical constraints in the representation of our websites or limited user guidance.

VIII. Webtracking and Analysis-Tools

We use tracking software to determine the frequency of use and the number of users of our websites. The data collected are solely used in anonymous and aggregated form for statistical purposes and to optimize our websites.

Google Analytics

To determine the frequency of use and the number of users of our website, we also use Google Analytics. A web analytics service provided by Google, Inc. (“Google”). We use Google Analytics under the terms and conditions on which the data protection supervisory authorities have agreed with Google. Google Analytics uses “cookies”, to help the website analyze how users use the site. For more information about cookies, click here.

The information generated by the cookie about your usage of the website will be transmitted to and stored by Google on servers in the United States. However, we have implemented the extension „anonymizelp()“ (IP- anonymization), which causes that your IP address shall be reduced to the last octet by Google within the European Union or state to the agreement on the European Economic Area before a storage and transmission.

Only in exceptional cases, the full IP address is transmitted to a Google server in the US and shortened there. On our behalf, Google uses this information to evaluate your use of the website, to compile reports on website activity and to provide other website usage and internet related services to the website operator.

The IP address, which is transferred from your browser to Google Analytics will not be merged with other data from Google.

Possibility to Object

You can prevent the storage of Cookies by editing your browser preferences. More information can be found here [update link]. Alternatively, you can prevent the collection of data generated by the Cookie and related to your usage of our websites (including your IP address) and the transfer to Google as well as the processing of such data by Google by downloading and installing the browser plug-in at the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB. Please note that you will leave our websites.

Information of third-party provider:

Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms for users: http://www.google.com/analytics/terms/gb.html overview of data privacy: https://support.google.com/analytics/answer/6004245?hl=en as well as the data privacy statement: http://www.google.de/intl/en-GB/policies/privacy/Please note that you will leave our websites by clicking on a link above.

We also use Google Tag Manager to improve the integration of third-party provider tools like Google Analytics. The Google Tag Manager is a tool that allows us to integrate tags (code snippets of different providers and partners) directly to our websites. We use the tool inter alia for the integration of service providers in the fields of online marketing. The Google Tag Manager itself is a management system only that works according to Google without the creation of cookies or the collection of personal data. If a deactivation was made for domains or cookies, these settings remain for all tracking tags that are implemented at Google Tag Manager.

 

In this regard, we engage the intra-group service provider Kloecker.i GmbH based in Berlin with the data collection, processing, and usage, in particular with the analysis of the obtained tracking data.

IX. Data Security

Klöckner has implemented extensive technical and organizational security measures, such as access controls, to protect your data against unauthorized disclosure and misuse.

X. Right to Information and Other Rights of the Data Subject

You have a right to access the information which Klöckner stores about you. If you are a registered user of our online shops, you can access your data at any time at „http://www.kloeckner.co.uk” and make corrections if needed. Please address your requests relating personal data to our Data Protection Officer of Klöckner (see also “Contact”).

XI. Contact

Please address your questions relating the processing of your personal data and requests for information to the Data Protection Officer of Klöckner, who will also be able to address suggestions or concerns you may have in relation to this Privacy Statement.

ASD Metal Services Ltd., Data Protection Officer, Valley Farm Road, Stourton, GB-Leeds LS 10 1 SD

E-Mail: Richard.marjoribanks@kloeckner.com