Privacy Notice

Name and address of the data controller

The data controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:

PalNet GmbH Air Cargo Products

Klaus Demtröder

Vulkanstrasse 10

D-54578 Wiesbaum

Tel.: +49-6593-980 930

E-Mail: demtroeder@palnet-acp.com

General provisions on data processing

Scope of processing of personal data

In general, we process personal data of our users only where it is necessary to provide a proper functioning website as well as our contents and services. The processing of personal data of our users takes place normally only after the consent of the user. An exception applies in those cases where prior consent cannot be obtained for factual reasons and where the processing of the data is permitted by law.

Legal basis relating to the processing of personal data

Insofar as we obtain the consent of the person concerned (‘data subject’) for the processing of his or her personal data, Art. 6 para. 1 lit. a of the EU General Data Protection Regulation (GDPR) serves as the legal basis. In the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures. If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

Data erasure and storage time

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the data controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion of a contract, performance of a contract or for security reasons.

Changes and updates to this privacy notice

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as these changes require your cooperation (e.g. your consent) or other individual notification.

Security measures

The security measures include in particular the encrypted transmission of data between your browser and our server.

Cooperation with processors and third parties

If we disclose data to other persons and companies (processors or third parties) within the scope of our processing, transmit data to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 lit. b GDPR for contract fulfilment is necessary), if you have consented to it, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or let the data process in a third country only if the special requirements of Art. 44 ff. GDPR apply. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU standards (e.g. for the USA by the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "Standard Contractual Clauses").

Provision of the website and creation of log files

Description and scope of data processing

Each time our website is called up, our system automatically collects data and information from the computer system of the calling computer. The following data is collected:

• Information about the browser type and version used
• The user's operating system
• The user's Internet service provider
• The IP address of the user
• Date and time of access
• Websites from which the user's system reaches our website
• Websites accessed by the user's system through our website

The data is also stored in the log files of our system. There is no storage of this data together with other personal data of the user.

Legal basis and purpose of data processing

The legal basis for the temporary storage of the data in the log files is Art. 6 para. 1 lit. f GDPR. The temporary storage of the IP address by the system is necessary to enable delivery of our website to the user's computer. For this the IP address of the user must remain stored for the duration of the session. The data is stored in log files to ensure the functionality of our website. In addition, the data serves us to optimise our website, to ensure the security of our information technology systems and for the purpose of tracking suspected illegal use of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. These purposes also represent our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f DSGVO.

Duration of storage and possibility of objection and elimination

The data will be deleted as soon as storage is no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of our website, this is the case at the end of the respective session. If the data is stored in log files, anonymisation takes place immediately and deletion takes place after 190 days at the latest. Further storage is possible in case of suspicion of illegal use of our information technology systems for security reasons. The collection of data for the provision of our website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

Use of technically necessary cookies

Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. If a user visits a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic character string that enables a unique identification of the browser when the website is called up again. We use cookies to make our website more user-friendly.

Legal basis and purpose of data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR. The purpose of using technically necessary cookies is to simplify the use of websites for users. The user data collected by technically necessary cookies are not used to create user profiles. These purposes also represent our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f DSGVO.

Duration of storage, possibility of objection and elimination

Cookies are stored on the user's computer and transmitted to our website. Therefore, as a user you also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically.

Contact form and e-mail contact

Description and scope of data processing

There is a contact form on our website which can be used for electronic contact. If a user takes advantage of this possibility, the data entered in the input mask will be transmitted to us and stored. At the time the message is sent, the following data is also stored:

• IP address of the user

Date and time of registration.

Your consent is obtained for the processing of the data within the scope of the sending process and reference is made to this data protection declaration. Alternatively, you can contact us via the e-mail address provided. In this case, the user's personal data transmitted by e-mail will be stored. In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation.

Legal basis for data processing

The legal basis for the processing of data is Art. 6 para. 1 lit. a GDPR if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, then the additional legal basis for the processing is Art. 6 exp. 1 lit. b GDPR.

Purpose of data processing

The processing of the personal data from the input mask serves us only for the processing of the contact. In the event of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

Duration of storage

The data will be deleted as soon as storage is no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those that were sent by e-mail, this is the case when the respective conversation with the user is finished. The conversation is terminated when it can be inferred from the circumstances that the facts in question have been finally clarified. The same applies to the additional personal data collected during the sending process.

Possibility of objection and elimination

The user has the possibility to revoke his consent to the processing of his or her personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. Please send us an informal e-mail with your objection/removal request. All personal data stored in the course of contacting us will be deleted in this case.

Web analysis by Google Analytics

Description and scope of data collection

We use Google Analytics, a web analysis service of Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transferred to a Google server in the USA and stored there. Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Google will use the collected information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services connected with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by the user's browser is not merged with other Google data.

Legal basis and purpose of data processing

The legal basis for the analysis of personal data of users is Art. 6 para. 1 lit. f GDPR. We use Google Analytics to display the ads placed by Google and its partners within advertising services only to users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are determined by the websites visited) that we transmit to Google (so-called "remarketing" or "Google Analytics Audiences"). With the help of remarketing audiences we would also like to ensure that our ads correspond to the potential interest of the users and are not annoying. Our interest in the analysis, optimisation and economic operation of our online offer represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

Possibility of objection and elimination

You may refuse the use of cookies by selecting the appropriate settings on your browser. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en. Further information on data use by Google, possible settings and objections can be found on Google's websites: https://www.google.com/intl/de/policies/privacy/partners ("Data use by Google when using our partners' websites or apps"), https://policies.google.com/technologies/ads ("Data use for advertising purposes"), https://adssettings.google.com/authenticated ("Manage information that Google uses to show you advertisements").

In addition, you will find a link at the end of this privacy policy to deactivate tracking on mobile devices.

Web analysis through Google Conversion Tracking

Description and scope of data collection

We also use Google Conversion Tracking. Google Adwords sets a cookie on your computer if you have accessed our website via a Google ad. These cookies expire after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer's website and the cookie has not yet expired, Google and the customer can recognize that the user has clicked on the ad and has been redirected to this page. Each Adwords customer receives a different cookie. Cookies cannot therefore be traced through the websites of Adwords customers. The information collected using the conversion cookie is used to generate conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, you will not receive any information that personally identifies users.

Legal basis and purpose Data collection

The legal basis for the analysis of personal data of users is Art. 6 para. 1 lit. f GDPR. We use Google Conversion Tracking to statistically record and optimize the use of our website. Our interest in the analysis, optimisation and economic operation of our online offer represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

Possibility of objection and elimination

You may refuse the use of cookies by selecting the appropriate settings on your browser. You can also deactivate cookies for conversion tracking by setting your browser to block cookies from the "www.googleadservices.com" domain. Google's privacy policy for conversion tracking can be found here (https://services.google.com/sitestats/de.html).

Google-Marketing-Services (Google AdWords und Google AdSense)

Description and scope of data collection

We use Google's marketing and remarketing services ("Google Marketing Services" for short). Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). The Google marketing services allow us to target ads for and on our site in order to present users only with ads that potentially match their interests. For example, if a user sees ads for products he has been interested in on other websites, this is referred to as "remarketing". For these purposes, when our and other websites on which Google marketing services are active are accessed, Google directly executes a code from Google and (re)marketing tags (invisible graphics or code, also known as "web beacons") are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file contains information about which websites the user visits, what content he is interested in and what offers he has clicked on, technical information about the browser and operating system, referring websites, visiting time and other information about the use of the online offer.

The IP address of the users is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other signatory states of the European Economic Area Agreement and only in exceptional cases completely transmitted to a Google server in the USA and shortened there. The IP address is not combined with the user's data within other Google offers. The above information may also be linked by Google to such information from other sources. If the user then visits other websites, the ads tailored to his or her interests can be displayed.

Users' data is processed pseudonymously within the framework of Google marketing services. This means that Google does not store and process, for example, the names or e-mail addresses of users, but processes the relevant data cookie-related within pseudonymous user profiles. This means from Google's point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google's servers in the USA.

One of the Google marketing services we use is the online advertising program "Google AdWords". Google AdWords is an Internet advertising service that allows advertisers to place ads in both Google's search engine results and the Google Advertising Network. Google AdWords allows an advertiser to pre-define certain keywords to display an ad in Google's search engine results only when the user uses the search engine to retrieve a keyword-relevant search result. On the Google Network, ads are distributed to thematically relevant websites using an automatic algorithm and using the previously defined keywords. In the case of Google AdWords, each AdWords customer receives a different "conversion cookie". Cookies cannot therefore be traced through the websites of AdWords customers. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not obtain any information that personally identifies users.

We may include third-party advertisements based on the Google marketing service "AdSense". AdSense uses cookies to enable Google and its partner sites to serve ads based on users' visits to this site or other sites on the Internet.

Further information on Google's use of data for marketing purposes can be found on the overview page: https://policies.google.com/technologies/ads, Google's data protection declaration can be accessed at https://policies.google.com/privacy

Legal basis and purpose of data processing

The legal basis for the analysis of personal data of users for marketing purposes is Art. 6 para. 1 lit. f GDPR. The purpose of Google marketing services is to display interest-relevant and user-friendly advertising that does not cause a nuisance. The use of Google marketing services serves our interest in the analysis, optimization and economic operation of our online offer. These purposes constitute a legitimate interest within the meaning of Art. 6 para. 1 lit. f. GDPR.

Possibility of objection and elimination

You can prevent the setting of cookies at any time by means of an appropriate setting of your Internet browser and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a cookie on the information technology system of the person concerned. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

You may also object to interest-based advertising by Google marketing services by using the setting and opt-out options provided by Google: https://adssettings.google.com/authenticated. Further information and Google's current privacy policy can be found at https://policies.google.com/privacy

Rights of the data subject

If personal data related to you are processed, you are affected within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

Right to information

You may require confirmation from the controller of whether personal data related to you is processed by us. If such processing has taken place, you may request the following information from the controller:

• the purposes for which the personal data are processed;
• the categories of personal data processed;
• the recipients or categories of recipients to whom the personal data related to you have been or are still being disclosed;
• the planned duration of the storage of the personal data related to you or, if specific information on this is not possible, criteria for determining the storage period;
• the existence of a right to rectification or deletion of personal data related to you, a right to limitation of processing by the controller or a right to object to such processing;
• the existence of a right of appeal to a supervisory authority;
• any available information on the origin of the data if the personal data are not collected from the data subject;
• the existence of automated decision-making, including profiling in accordance with Article 22(1) and (4) GDPR and - at least in these cases - meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.

You are entitled to request information as to whether the personal data related to you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission of data.

Right of rectification

You have a right of rectification and/or completion vis-à-vis the data controller if the processed personal data related to you are incorrect or incomplete. The controller shall make the correction without delay.

Right to limitation of processing

Under the following conditions, you may request that the processing of personal data related to you be restricted:

• if you dispute the accuracy of the personal data related to you for a period of time that enables the controller to verify the accuracy of the personal data;
• if the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data is restricted;
• if the controller no longer needs the personal data for the purposes of the processing, but you do need them to assert, exercise or defend legal claims, or
• if you have filed an objection to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.

If the processing of personal data related to you has been restricted, such data may only be processed - apart from being stored - with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest of the European Union or a Member State. If the processing restriction has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.

Right to cancellation

You can demand from the controller to delete the personal data related to you immediately. The controller is obliged to delete this data immediately if one of the following reasons applies:

• The personal data related to you are no longer necessary for the purposes for which they were collected or otherwise processed.
• You revoke your consent, on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.
• You file an objection against the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Art. 21 para. 2 GDPR.
• The personal data related to you have been processed unlawfully.
• The deletion of personal data related to you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject.
• The personal data related to you have been collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.

If the data controller has made the personal data related to you public and is obliged to delete it pursuant to Art. 17 para. 1 GDPR, he shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform data processors who process the personal data that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of these personal data.

The right to cancellation does not exist insofar as the processing is necessary to exercise 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 the controller is subject or for the performance of a task in the public interest or in the exercise of official authority conferred on the controller; for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the aforementioned law is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or to assert, exercise or defend legal claims.

Right to information

If you have exercised your right to have the data controller correct, delete or limit the processing, he/she is obliged to inform all recipients to whom the personal data related to you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.

You shall have the right vis-à-vis the person responsible to be informed of such recipients.

Right to data transferability

You have the right to receive the personal data related to you that you have provided to the person responsible in a structured, common and machine-readable format. In addition, you have the right to pass this data on to another data controller without obstruction by the controller to whom the personal data was provided, if

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

In exercising this right, you also have the right to request that the personal data related to you be transferred directly from one data controller to another data controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

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

Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data related to you under Article 6(1)(e) or (f) of the DGPR; this also applies to profiling based on these provisions. The data controller no longer processes the personal data related to you, unless he can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. If the personal data related to you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data related to you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing. If you object to the processing for direct marketing purposes, the personal data related to you will no longer be processed for these purposes. You have the possibility to exercise your right of objection in connection with the use of Information Society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.

Right to revoke the data protection declaration of consent

You have the right to revoke your data protection declaration of consent at any time. The revocation of consent shall not affect the legality of the processing carried out on the basis of the consent until revocation.

Automated decision in individual cases including profiling

You have the right not to be subject to a decision based exclusively on automated processing - including profiling - that has legal effect against you or significantly impairs you in a similar manner. This does not apply if the decision is necessary for the conclusion or performance of a contract between you and the data controller,

is admissible by law of the Union or of the Member States to which the controller is subject and that law contains appropriate measures to safeguard your rights, freedoms and legitimate interests, or  with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

Right of appeal to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the Member State where you reside, work or of the place of suspected infringement, if you believe that the processing of personal data related to you is contrary to the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.