Version dated 22 June 2020
This Privacy Statement describes the collection and further processing of personal data by companies of the V ZUG Group and its affiliates (collectively V-ZUG) as far as they are not covered by other data protection policies or are evident from the circumstances or are provided for by applicable law. The term “personal data” shall include all information relating to an identified or identifiable person.
This Privacy Statement describes in Section I the processing of personal data by V-ZUG in general. Section II contains specific provisions for individual applications (e.g. customer service, newsletter, etc.); Section II para. 5 and para. 6 also contain specific provisions regarding data processing in the GuidedCooking app and the V-ZUG Home app, respectively.
- Controller, data protection officer
- Processing of personal data
- Purpose of the processing and legal basis
- Disclosure of data and transfer of data abroad
- Store of data
- Cookies, google analytics and social plug-ins
- Rights of the business partners, visitors and partners
- Changes to the data protection policy
II. Specific Provisions
I. GENERAL PROVISIONS
1. CONTROLLER, DATA PROTECTION OFFICER
The respective subsidiary or affiliate is the controller in case V-ZUG communicates through other means of communication (e-mail, letter, telephone, in person, etc.) and the communication does not fall within an activity for which V-ZUG has appointed a specific controller within this Privacy Statement or otherwise.
Should a V-ZUG company or affiliate disclose personal data to another V-ZUG company or affiliate for certain purposes of the receiving company or affiliate, such company or affiliate is the controller according to article 4 (7) GDPR. A comprehensive list of companies and affiliates of V-ZUG can be found here.
V-ZUG has not appointed a data protection officer according to article 37 GDPR. Any enquiry, claim or concern regarding data protection at V-ZUG can be addressed to the following contact person: cHJpdmFjeUB2enVnLmNvbQo=.
In cases where a V-ZUG company that is processing personal data is not located in the EU or the EEA and the data is being processed in conjunction with an offer of goods or services to data subjects in the EU or the EEA, the following representative within the Union has been designated in writing in accordance with Art. 27 GDPR: V-ZUG Europe BVBA, Evolis 102, 8530 Harelbeke-Kortrijk, Belgium. This also applies in cases where the behaviour of data subjects in the EU or the EEA is being observed.
2. PROCESSING OF PERSONAL DATA
V-ZUG collects and processes personal data of
- visitors of its websites registered or not registered with V-ZUG;
- contact persons and employees of service providers, suppliers, retailers, vendors and providers of V-ZUG products and parts of products;
- customers, buyers, recipients and beneficiaries or prospective customers of products and services (including warranty, repair and maintenance services) of V-ZUG or its contact persons and employees;
- contact persons and employees of business partners and associated companies, personnel providers and employment agencies (as well as brokered employees/workers) and further commercial and economic partners;
- shareholders and beneficiaries of other rights to shares of V-ZUG Holding AG as well as respective interested parties;
- recipients of ad hoc-information of V-ZUG Holding AG and newsletters of V-ZUG;
- participants in market research campaigns and opinion surveys conducted by V-ZUG;
- participants in courses, seminars and other training organized by V-ZUG;
- users of Wi-Fi provided at V-ZUG stores, showrooms, business premises and other locations;
- individuals ordering or using V-ZUG customer loyalty programmes; and
- registered participants of V-ZUG customer loyalty programmes (business partner programme)
(collectively “business partners”).
The personal data of business partners is generally collected directly during the course of using the website, upon demand for or use of products or services, upon submission of reviews or reports, participation in market research or other surveys, in stores, sales offices or at events of V-ZUG or V-ZUG approved retailers or during direct communication with V-ZUG via e-mail, telephone or in any other way.
However, personal data can also be collected indirectly, namely when the business partner engages in a commercial activity which does not correspond with the person benefiting from the commercial activity or if a purchase is shipped to a different person, based on the recommendation of a third party (e.g. recommendation by friends and acquaintances of the business partner) or through further obtaining or acquisition of supplementary information from third party data sources (e.g. social media, address brokers, providers of commercial information, etc.).
In particular, the following categories of personal data are processed by V-ZUG:
- Personal data and contact information including but not limited to first and last name, address, residence, telephone number, e-mail address, age, date of birth, gender, marital status, relatives, contact in case of emergency, photos, information about function within the company, information about business relationships with this data subject, information about commercial transactions, enquiries, offers, quotes, stipulations and contracts, statements about work or other interests of the data subject, etc.;
- Data pertaining to deliveries and sales as well as orders and purchases including but not limited to payment information, credit card details and other payment details, billing and shipping address, products and services delivered and sold as well as ordered and purchased, information connected to queries, complaints and disagreements relating to products and services or respective contracts entered into such as warranty claims, rescissions and disputes, information regarding business partners blacklisted by V-ZUG, etc.;
- Data in connection with the marketing of products and services including but not limited to information about marketing activities such as the receipt of newsletters, newsletter opt-ins and opt-outs, documents received, invitations to and participations at events and special activities (as far as they are not part of a customer loyalty programme), personal preferences and interests, etc.;
- Data concerning the use of the website including but not limited to the IP address and other identification (e.g. social media username, MAC address of smartphones or computers, cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies) or other technologies, with which personal data is collected), date and time of website visits, visited sites and contents, referring websites, etc.;
- Data of shareholders and beneficiaries of shares and related communication including but not limited to number of shares, share transfers, entitlement, security deposit account, bank account for dividends, preferred means of communication, correspondence, correspondence language and communication with V-ZUG (including records of the communication), etc.;
- Data which was collected in connection with a customer programme such as membership number, access codes (including passwords), preferred language, gift certificate number, date and duration of the membership, payment information of the customer or a potential third party, information concerning the recipient of a gift, number of visits of the website, purchase history, products acquired, etc. (besides traditional customer loyalty programmes, all website accounts, activities and events for which a business partner must register with his personal data and thus enter into a contract with V-ZUG shall be deemed a customer programme for the purposes of this policy);
(collectively “business partner data”).
3. PURPOSE OF THE PROCESSING AND LEGAL BASIS
In accordance with applicable law, V-ZUG may process business partner data namely for, but not limited to, the following purposes:
- In connection with products and services offered, conclusions of contracts (namely purchases and sales of products and services), executions of contracts (namely purchase and supply agreements and contracts regarding participation in customer programmes and events), maintenance and development of relations with business partners and shareholders or other beneficiaries or prospective shareholders of V-ZUG Holding Ltd, communication, customer service and support (namely orders and enquiries), marketing, promotion and advertising activities (including newsletters and mailing of promotional materials);
- • Management of the users and visitors of the website and other activities in which business partners participate; operation and enhancement of the website (including the provision of functions which require identifiers or other personal data) and further IT systems, identity verifications;
- Quality control, market research, improvement of products and services, creation of statistics, budgets, records and management information as well as further reports on business partners, transactions and activities, offers and other commercial aspects of V-ZUG for the purposes of company management and development of the company, its range of products and services, its activities and project management;
- protection of business partners, employees and other individuals and protection of data, secrets and assets of and entrusted to V-ZUG, safety of systems and premises of V-ZUG;
- compliance with legal and regulatory requirements (in particular company law and stock exchange law and rules, ad hoc information etc.) and internal rules of V-ZUG, enforcement and exploitation of various rights, defence against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to enquiries from public authorities;
- sale or acquisition of business divisions, companies or parts of companies and other corporate transactions and the transfer of business partner data associated therewith;
- for other purposes as far as a legal obligation requires processing and such processing was evident from the circumstances or indicated at the time of the collection;
(collectively the “purpose of business partner data processing”).
V-ZUG uses the business partner data for the purpose of business partner data processing based on the following legal grounds:
- performance of contracts;
- compliance with legal obligations of V-ZUG;
- consent of the business partner (only insofar as the processing is based on a specific query and can be withdrawn at any time, namely the receipt of newsletters for which the client has registered);
- legitimate interests of V-ZUG, including but not limited to
- purchase and shipment of products and services, also in connection with individuals who are not direct contractual partners (e.g. individuals receiving a gift);
- carrying out advertisement and marketing activities;
- efficient and effective customer support, maintenance of contacts and other communication with business partners outside of the processing of contracts;
- understanding customer behaviour, activities and needs, market research;
- efficient and effective improvement of existing products and services and development of new products and services;
- efficient and effective protection of business partners, employees and other individuals as well as protection of data, secrets and assets of or entrusted to V-ZUG, safety of systems and premises of V-ZUG;
- maintenance and secure, efficient and effective organization of business operations including a secure, efficient and effective operation and successful further development of the website and other IT systems;
- reasonable corporate governance and development;
- successful sale and acquisition of business units, companies or parts of companies and other corporate transactions;
- compliance with legal and regulatory requirements and internal rules of V-ZUG;
- concerns regarding the prevention of fraud, offences and crimes as well as investigation in connection with such offences and other improper conduct, handling of legal claims and actions against V-ZUG, cooperation in legal proceedings and with public authorities as well as the prosecution, exercise of and defence against legal actions.
In accordance with applicable data protection laws, V-ZUG may process the data of registered and non-registered website visitors for the purposes of maintaining and developing the website (including the provision of functions which require identifiers or other personal data), for statistical analysis regarding the use of the website as well as for combating abusive conduct, for purposes of legal investigations or proceedings and for the response to enquiries from public authorities. The visitor data shall be processed in accordance with the principles set out for business partner data above.
In accordance with applicable data protection laws, V-ZUG may process business partner data for the purposes of entering into and performance of contracts and other business relationships with partners, advertisement and marketing, sales measures, communication, invitation to events and participation in promotions for partners, organization of joint activities, compliance with legal and regulatory requirements and internal rules of V-ZUG, enforcement of legal rights, defence against legal claims, litigation, complaints, combating fraud and abusive conduct, engaging in legal investigations and proceedings and responding to enquiries from public authorities, for the sale or acquisition of business units, companies or parts of companies and other corporate transaction and related transfers of partner data.
All the purposes of processing shall be applicable for the whole of the V-ZUG Group, i.e. not only for the company which initially collected the personal data. Personal data of business partners is collected for the purpose of all V-ZUG companies.
4. DISCLOSURE OF DATA AND TRANSFER OF DATA ABROAD
In accordance with applicable data protection laws, V-ZUG may disclose business partner data to the following categories of third parties who process business partner data in accordance with the purpose of data processing on behalf of V-ZUG or for their own purposes:
- Service providers (within V-ZUG as well as external, namely for share register, support and services), including processors;
- Distributors, suppliers and other business partners;
- V-ZUG customers and buyers;
- Local, national and foreign authorities as well as the stock exchange and related supervisory and enforcement bodies (including SIX Exchange Regulation AG, the Swiss Financial Market Supervisory Authority FINMA, law enforcement authorities and courts);
- Media and private reporters and journalists;
- The general public, including visitors of websites and social media of V-ZUG;
- Industry organizations, associations, organizations and other committees;
- Acquirers or parties interested in acquiring business units, companies or other parts of V-ZUG;
- Other parties in potential or actual legal proceedings;
- Other companies of V-ZUG
(collectively “third parties”).
V-ZUG may disclose business partner data within the V-ZUG Group as well as to third parties and in every country worldwide, including all countries in which V-ZUG is represented by companies, affiliates or other offices and representatives as well as to countries in which service providers of V-ZUG process their data. If data is disclosed to countries that do not guarantee adequate protection, V-ZUG will ensure adequate protection of data by way of putting adequate contractual guarantees in place, namely on the basis of EU standard clauses or binding corporate rules, or it bases the transfer on the exceptions of consent, performance of contract, the determination, exercise or enforcement of legal claims, overriding public interests or it discloses the data in order to protect the integrity of these individuals. The business partner can obtain a copy of the contractual guarantees from or will be advised where to obtain such copies by the contact person named in Section I, para. 1. V-ZUG reserves the right to redact such copies for reasons of data protection or secrecy reasons.
5. STORE OF DATA
As a rule, V-ZUG retains contract-related business partner data as long as the contractual relation is ongoing and for ten years after the termination of the contractual relationship unless a longer statutory store obligation is applicable on a case-by-case basis, this is required for reasons of proof or another valid reason for an exception is pertinent based on applicable law, or the deleting of the data is required earlier (namely because the data is no longer required or V-ZUG is obligated to delete the respective data).
As a rule, shorter retention periods are applicable for operational data containing business partner data (e.g. protocols, logs).
Business records, including communications, will be retained as long as V-ZUG has an interest in them (namely an interest in reasons of proof in case of claims, documentation of compliance with certain legal or other requirements, an interest in non-personalized analysis) or is obligated to do so (by way of contract, law or other provisions). Deviating legal obligations are reserved namely with respect to anonymization or pseudonymization.
6. COOKIES, GOOGLE ANALYTICS AND SOCIAL PLUG-INS
In accordance with applicable law, V-ZUG may install coding in newsletters and other marketing e-mails which allow it to determine if the recipient has opened an e-mail or downloaded pictures contained in the e-mail. However, the recipient may block this application in his/her e-mail application. In any case he consents to the application of this technology by subscribing to newsletters or other marketing-related e-mails.
Should V-ZUG place a third-party advertisement on the website (e.g. banners) or intend to place its own advertisement on the website of a third party, cookies from companies specializing in the use of such advertisements may be used. V-ZUG will not disclose personal data to such companies, i.e. they shall only place a permanent cookie with users of the website in order to recognize users and do so in the sole interest of V-ZUG. This allows V-ZUG to place targeted advertisements for these individuals on external websites. V-ZUG will not disclose personal data to the operators of external websites.
V-ZUG may use PIWIK (https://piwik.org), Google Analytics or similar services on its website. These applications are third-party services which allow V-ZUG to measure and analyse the use of its website. The provider of these services may be located in any country worldwide (in the case of Google Analytics which is operated by Google Inc. it is the USA, www.google.com). The service provider uses permanent cookies for these applications. V ZUG will not disclose any personal data to the service provider (who will also not save any IP addresses). The service provider may, however, monitor the use of the website by the user and combine this data with data from other websites monitored by the same service provider which the user has visited, and use these findings for its own benefits (e.g. control of advertisement). If the user who has registered with the service provider himself, the service provider is able to determine their identity. In this case, the processing of personal data will be the service provider's responsibility and data shall be processed according to the data protection policies of the service provider. The service provider will provide data on the use of the website to V-ZUG.
V-ZUG may integrate and use the Google Remarketing function on its websites to advertise V-ZUG products and services. This function is used to present interest-based ads from V-ZUG to visitors to the website as part of the Google advertising network. For this purpose, cookies are used, which are set by the service provider. All data is collected anonymously so that no conclusions can be drawn about specific persons. In default settings of the V-ZUG websites remarketing tags are deactivated. If a visitor to the V-ZUG websites is redirected to Google, Google's data protection regulations apply. You can make changes to the settings of Google's remarketing feature at https://www.google.com/settings/ads.
In addition, V-ZUG may use plug-ins (also add-ons) from social media networks such as Facebook, Twitter, Whatsapp, LinkedIn, YouTube, Google+, Google Maps, Pinterest, Instagram or from business partners on its websites or integrate RSS feeds or graphics from other websites. In the default settings of the website, plug-ins and other embedded third-party technologies are deactivated; the user can thus choose when to activate them. Should the user do so, the social media and other third party service providers are able to establish a direct connection to the user during his visit to the website, which allows the provider to be aware of the user's visit and may analyse the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the provider and according to his data protection policies. The provider of the respective social media offering will not disclose any information to V-ZUG.
7. RIGHTS OF THE BUSINESS PARTNERS, VISITORS AND PARTNERS
Any affected individual may request information from V ZUG as to whether data concerning them is being processed. In addition, they have the right to request the correction, destruction or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on consent, the affected individual may withdraw consent at any time. In countries of the EU and EEA the affected individual may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer. Request in this respect shall be submitted to the data protection officer or contact person (see Section I, para. 1 supra). V-ZUG reserves the right to restrict the rights of the affected individual in accordance with applicable law and, for instance, not to disclose comprehensive information or delete data.
Should V-ZUG make an automated decision with respect to a certain individual which may have a legal effect for the affected individual or seriously affect them in a similar way, the affected individual shall have, in accordance with applicable law, the right to communicate with a responsible person of V-ZUG and to request a reconsideration of the decision or to request the prior evaluation by the responsible person. In this case, the affected individual might no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance.
Any affected individual may also file a complaint with the competent data protection authority.
8. CHANGES TO THE DATA PROTECTION POLICY
V-ZUG is entitled to amend this Privacy Statement at any time and without prior notice or announcement. The latest version according to the website shall be applicable.
Should the Privacy Statement form part of an agreement with business partners, V-ZUG may inform them of an update by e-mail or in another appropriate manner. The new Privacy Statement shall be deemed to have been accepted unless an objection is raised within 30 days of notification. In case of objection, V-ZUG shall be free to terminate the agreement exceptionally and with immediate effect.
II. SPECIFIC PROVISIONS
The following provisions shall supplement the provisions of the general part for certain activities of V-ZUG. In the event of any inconsistency, the following provisions shall prevail over the provisions of the general part.
In V-ZUG online shops, the creditworthiness of a customer is evaluated automatically in order to offer the purchase on account based on this decision as far as this payment option shall be offered at all. In this case the credit rating is evaluated on the basis of information from an external credit rating agency, which will provide V ZUG with a credit score of the respective individual. The agency will calculate the score using a secret formula based on data on the payment history of the individual, their debt and insolvency history and possible limitations of its legal capacity. Should the score be below a certain threshold, no payment by invoice will be offered. In this event, the customer may contact the following contact person if they dispute the decision: cHJpdmFjeUB2enVnLmNvbQo=.
V-ZUG online shops may automatically decide whether to enter into purchase agreements. However, V-ZUG does not deem this an automated individual decision according to article 22 GDPR. In the event that the customer does not wish for a contract to be concluded automatically, they have the option of purchasing V-ZUG products and services at physical stores operated by V-ZUG and its retailers.
Any requests, claims and information regarding data protection may be addressed to the following contact person: cHJpdmFjeUB2enVnLmNvbQo=.
2. PHYSICAL STORES
The term physical store shall include but not be limited to exhibition stands, physical shops, sales points, outlets, shopping centres, permanent establishments, production plants, where goods and services of V-ZUG are displayed, exhibited, presented, marketed, sold or where there is information, advice and guidance on such goods and services. Stores and salespoints of business partners (including distributors) shall also be deemed to be physical stores. Within the scope of visits to such physical stores V-ZUG can collect personal data directly or indirectly via its business partners. Personal data include, but are not limited to name, address, phone number, e-mail address, etc. Personal data will only be processed to the extent necessary or reasonable, provided the data subject has consented or the processing is otherwise lawfully and only if necessary or reasonable. The transfer of personal data to third parties may be required, but only if necessary or reasonable to render the desired services. The term “third parties” includes, but is not limited to, administrative and technical personnel of a distributor or another business partner of V-ZUG. The use or processing of personal data for purposes other than those for which the personal data were collected is only performed in compliance with the applicable mandatory provisions or with consent of the data subject.
3. CUSTOMER SERVICE
V-ZUG processes personal data in order to fulfil obligations arising out of or in connection with orders, deliveries, installations, fittings, calibration, acceptance (FAT/SAT), warranty claims, service and support, care and maintenance, further enquiries or transfer of information material (newsletters, product information, events, etc.). Personal data include, but are not limited to, name, address, phone number, e-mail address, etc. Personal data will only be processed to the extent necessary or reasonable. Personal data will be stored within the internal customer relationship management system and serves the purposes of product, customer and quality control. The transfer of personal data to third parties may be required, but only if necessary or reasonable to render the desired services. The term “third parties” includes, but is not limited to, administrative and technical personnel of a distributor or a business or service partner of V-ZUG. The use or processing of personal data for purposes other than those for which the personal data were collected is only performed in compliance with the applicable mandatory provisions or with consent of the data subject.
4. NEWSLETTER AND BANNER ADVERTISEMENT
V-ZUG may send newsletters or other commercial communications in connection with its products and services to business partners. In accordance with applicable law V-ZUG reserves the right to do so without prior consent of existing customers and business partners. In other cases, V-ZUG will send such communications only upon previous request of the business partner (e.g. newsletter opt-in via a website-account). However, the respective customers and business partners may object to a further mailing of newsletters or other commercial communications at any time through their account on the respective website or through the link indicated in every mailing. However, the termination of one newsletter does not necessarily entail the termination of other newsletters.
It is possible that personalized advertisements are placed during the visit to the website. Every banner advertisement displayed to the business partner contains products offered on the website which have previously been viewed by the business partner. The advertisement is generated by V-ZUG by the means of cookies (see Section I para. 6 supra)
5. GUIDEDCOOKING APP
When first selecting the GuidedCooking app (the “application”), each user has the option of receiving a matching HOTPAN® Comfort 2 Litre with Bluetooth from Kuhn Rikon as a gift from V-ZUG; this option is available only once per serial number or hob, and the action is time-limited. A form must be completed for this purpose to obtain a voucher code that can then be used in the Kuhn Rikon web shop. By completing the form and then confirming the details in the e-mail link sent (double opt-in), the following personal data will be processed if the corresponding field has been filled in: title, first and last name, address and e-mail address (mandatory field).
At the same time users will have the option, by placing a cross in the appropriate box, of notifying V-ZUG whether they agree to their data being collected for marketing purposes (in particular the sending of newsletters: see above Section II para. 4). V-ZUG will process such data solely on the legal basis of user consent; users may withdraw their consent at any time (see above Section II para. 4). Existing data processing operations will not be affected by such withdrawal.
Users of the application may send voluntary feedback to V-ZUG. When sending feedback, users may also voluntarily submit their name and e-mail address (optional fields). If these optional input fields are not completed it will not be possible to make any inference regarding the user’s person or behaviour. The serial number of the hob will not be sent. The same procedure will apply if the application crashes: in this case V-ZUG will receive a crash report but will not be able to make any inference regarding the relevant person or their behaviour.
V-ZUG collects anonymous usage data on the application by means of Google Firebase, a product of Google Inc., USA. Google Firebase uses tracking technologies that permit the use of the application by users to be analysed, e.g. for performance monitoring, error logs or to analyse user behaviour. The purpose of Google Firebase is to enable the use of the application to be analysed, regularly improved and thus made more economical to operate. The statistics collected will allow V-ZUG to improve its offering and make it more attractive to users. The anonymised data will be transmitted to a Google server in Ireland or the USA. Google complies with the privacy provisions of the “Swiss-USA Privacy Shield” Agreement and thus possesses an adequate level of data protection. Further information about Google Firebase can be found at https://firebase.google.com/ and https://policies.google.com/privacy?hl=de.
6. V-ZUG APP
In conjunction with the use of the V-ZUG Home app (the "Application"), V-ZUG stores the following personal data once the user registration process has been completed (double opt-in): title, first name and surname, e-mail address and password. When a new V-ZUG household appliance is connected to the Application, location data is processed. However, this processing only takes place during activation and only within the scope of and for the purposes of authenticating the User. The appliance connection is confirmed by e-mail. Every time the Application is accessed, relevant information is recorded in a log file. This involves processing the following personal data: IP address of the requesting mobile device, serial number of the V-ZUG appliance, UID of the smartphone or tablet when using push notifications. This data is processed in order to facilitate use of the Application in its current version, to guarantee system security and stability and – in aggregated and anonymized form – for statistical and analytical purposes. Data may also be passed on to third parties – exclusively in anonymized form – for these purposes. IP addresses will only be evaluated in the event of attacks on the network infrastructure of the V-ZUG website. Log data will be automatically and irretrievably deleted after 3 months. The legal basis on which V-ZUG processes this data is that of fulfilment of a contract or the protection of legitimate interests.
In conjunction with the use of the V-ZUG Home app, users of a particular connected V-ZUG appliance are visible to other users of the same V-ZUG appliance via the V-ZUG Home app, and potentially also the appliance itself. This visibility is restricted to first and last name as well as the appliance usage data that can be retrieved from the V-ZUG Home app (e.g. whether the appliance is currently in operation). Moreover, each user has the option of removing the connection of all other users to the same V-ZUG appliance.
The User of the Application has the option of consenting to the transfer of usage and diagnostic data to V-ZUG in order to improve products and services. If the User consents to the transfer of usage and diagnostic data, technical data (e.g. temperature, selected programme and duration) will be transferred along with the serial number of the appliance when the appliance is used via the Application. Consent can be provided separately for each appliance connected to the Application and can be revoked at any time.
Users of the Application can provide V-ZUG with voluntary feedback. When sending feedback, the User can supply their title, first name, surname and e-mail address on a voluntary basis along with their message. If this information is not provided, it will not be possible to identify the person involved or to draw any conclusions about the behaviour of the User.
Any additional data relating to business partners (e.g. postal address, telephone number, date of birth, etc.) is provided on a voluntary basis. The same conditions apply to processing of such data.