Privacy Policy

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Stravex Transport- und Handelsgesellschaft mbH. The use of the Internet pages of the Stravex Transport- und Handelsgesellschaft mbH is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Stravex Transport- und Handels- gesellschaft mbH. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, the Stravex Transport- und Handelsgesellschaft mbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of the Stravex Transport- und Handelsgesellschaft mbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union, and other provisions related to data protection is:

Stravex Transport- und Handelsgesellschaft mbH
Finkenwerder Weg 6
21129 Hamburg
Germany

Phone: +49 40 334870300
Email: office@stravex.com
Website: www.stravex.com

Data Protection Contact Person:
Evgeniy Yanov

3. Cookies

The websites of Stravex Transport- und Handelsgesellschaft mbH use cookies. Cookies are text files that are stored on a user's computer system via an internet browser.

a) General Functionality

Cookies serve to technically enable the use of our website and to make it more user-friendly. Some cookies, for example, allow the browser to be recognized when the website is visited again.

b) Consent Requirement for Non-Essential Cookies

We distinguish between essential cookies (technically necessary) and non-essential cookies (e.g., for analytics or marketing purposes).

Essential cookies are required for the operation of the website. They enable basic website functions and are stored without your consent on the basis of our legitimate interest pursuant to Section 25 (2) TDDDG and Article 6 (1) (f) GDPR.

Non-essential cookies are only stored with your explicit consent pursuant to Section 25 (1) TDDDG and Article 6 (1) (a) GDPR. These include, in particular, cookies used for analytics or marketing purposes.

c) Cookie Banner and Your Choices

When you first visit our website, you will be presented with a cookie banner offering the following options:

Accept – You consent to the use of all non-essential cookies.

Reject – You reject the use of all non-essential cookies.

Settings – You can individually select which categories of cookies you wish to allow.

You may change your cookie preferences at any time via the cookie settings on our website.

d) Withdrawal of Consent

You may withdraw your consent at any time with effect for the future. To do so, click the Cookie Settings link in the footer of our website. You may also delete cookies that have already been stored via your browser settings.

e) Browser Settings

You can restrict or prevent the storage of cookies through your browser settings. Cookies that have already been stored can be deleted at any time. If you completely disable cookies, some functions of our website may no longer be available.

4. Collection of general data and information

Each time our website is accessed, our system automatically collects general data and information, which are stored in the server log files. The following data may be collected:

Browser types and versions used
The operating system used by the accessing system
The website from which an accessing system reaches our website (referrer)
The sub-pages accessed on our website
Date and time of access
Internet Protocol address (IP address)
Internet service provider of the accessing system
Other similar data and information used for security purposes in the event of attacks on our information technology systems

a) Purpose of Processing

This data is required to:

Deliver the content of our website correctly
Ensure the long-term functionality of our information technology systems and website technology
Provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack

b) Legal Basis

The processing of server log files is based on Article 6 (1) (f) GDPR (legitimate interest). Our legitimate interest lies in ensuring the functionality, stability, and security of our website.

c) Storage Period

Server log files are stored for 7 days and then automatically deleted. Longer storage will only take place if necessary for the investigation of criminal offences or misuse. In such cases, the data will be stored until the respective incident has been fully clarified and then deleted.

d) IP Address

The IP address is considered personal data. We use it exclusively for the security purposes described above. It is not combined with other data sources and is not used for profiling, location tracking, or any other purposes.

5. Contact Possibility via the Website

The website of Stravex Transport- und Handelsgesellschaft mbH contains information that enables a quick electronic contact with our company as well as direct communication with us, including a general electronic mail (email) address.

If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject will be processed for the purpose of handling the request.

The legal basis for processing this data is Article 6 (1) (b) GDPR where the request relates to contractual or pre-contractual matters. For general inquiries that are not related to a contract, the processing is based on our legitimate interest in responding to inquiries pursuant to Article 6 (1) (f) GDPR.

The personal data transmitted by you will be stored only for as long as necessary to process your request. The data will be deleted once the request has been fully resolved, provided that no statutory retention obligations apply.

The provision of personal data is voluntary. However, without providing the necessary contact details, we may not be able to process your request.

Personal data transmitted in this context will not be disclosed to third parties.

6. Routine Erasure and Restriction of Personal Data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or as provided for by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely restricted or erased in accordance with the applicable legal requirements.

7. Rights of the data subject

a) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may contact us at any time.

b) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may contact us at any time.

c) Right to erasure (Right to be forgotten)

Each data subject has the right to request the immediate erasure of personal data concerning him or her where one of the statutory grounds applies, in particular if:

the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
the data subject withdraws consent on which the processing is based and there is no other legal basis for the processing;
the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
the personal data have been unlawfully processed; or
the erasure of the personal data is required to comply with a legal obligation.

To exercise this right, a data subject may contact us at any time.

d) Right of restriction of processing

Each data subject has the right to obtain restriction of processing of personal data where one of the following conditions applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
the controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise, or defence of legal claims; or
the data subject has objected to processing pursuant to Article 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.

To exercise this right, a data subject may contact us at any time.

e) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may contact us at any time.

f) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Stravex Transport- und Handelsgesellschaft mbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If the Stravex Transport- und Handelsgesellschaft mbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Stravex Transport- und Handelsgesellschaft mbH to the processing for direct marketing purposes, the Stravex Transport- und Handels Gesellschaft mbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Stravex Transport- und Handelsgesellschaft mbH for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact us at any time. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

g) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Stravex Transport- und Handelsgesellschaft mbH shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may contact us at any time.

h) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may contact us at any time.

i) Right to Lodge a Complaint with a Supervisory Authority

Each data subject has the right to lodge a complaint with a supervisory authority if he or she believes that the processing of personal data relating to him or her infringes the General Data Protection Regulation (GDPR).

In particular, data subjects may contact the supervisory authority responsible for our company:

Hamburg Commissioner for Data Protection and Freedom of Information

Ludwig-Erhard-Str. 22
20459 Hamburg
Germany

8. Data protection for applications and the application procedures

Stravex Transport- und Handelsgesellschaft mbH collects and processes applicants' personal data for the purpose of carrying out the application procedure.

The processing may also be carried out electronically, particularly where application documents are submitted by email or via a web form.

a) Legal Basis

The processing is based on Article 6 (1) (b) GDPR (pre-contractual measures) in conjunction with Section 26 of the German Federal Data Protection Act (BDSG).

Where applicants provide consent, for example for inclusion in an applicant pool, processing is based on Article 6 (1) (a) GDPR.

b) Recipients of the Data

Within our company, only those persons involved in the application process have access to the applicant's data.

Personal data will not be disclosed to third parties unless this is required by law or the applicant has expressly consented to such disclosure.

Technical service providers, such as hosting or email service providers, may process applicant data on our behalf within the framework of data processing agreements pursuant to Article 28 GDPR.

c) Storage Period

If an employment contract is concluded, the data submitted by the applicant will be stored for the purpose of carrying out the employment relationship in accordance with applicable legal requirements and will become part of the personnel records.

If no employment contract is concluded, the application documents will generally be deleted six months after notification of the rejection decision, unless longer storage is required for the establishment, exercise, or defence of legal claims, particularly under the German General Equal Treatment Act (AGG).

In such cases, the processing of the data will be restricted and the data will be deleted after the respective procedure has been completed.

9. Legal Basis for the Processing

Article 6 (1) (a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract, the processing is based on Article 6 (1) (b) GDPR. This applies, for example, to inquiries concerning our services or the performance of contractual obligations.

Where processing is necessary for compliance with a legal obligation to which our company is subject, such as tax or commercial law obligations, the processing is based on Article 6 (1) (c) GDPR.

Finally, processing operations may be based on Article 6 (1) (f) GDPR where processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, provided that such interests are not overridden by the interests, fundamental rights, and freedoms of the data subject.

Such processing operations are permissible in particular where the European legislator has expressly recognized the existence of a legitimate interest, for example where the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

10. Legitimate Interests Pursued by the Controller or by a Third Party

Where personal data is processed on the basis of Article 6 (1) (f) GDPR, we pursue the following legitimate interests:

Ensuring the operation, functionality, stability, and security of our website, including the processing of server log files;
Protecting our information technology systems against cyber threats and unauthorized access;
Responding to general inquiries where no contractual or pre-contractual relationship exists;
Establishing, exercising, or defending legal claims.

When relying on legitimate interests as a legal basis for processing, we carefully balance our interests against the rights and freedoms of the data subjects and implement appropriate safeguards, including data minimization, limited retention periods, and, where feasible, pseudonymization or anonymization.

11. Right to Object

You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data where such processing is based on Article 6 (1) (f) GDPR.

12. Period for Which Personal Data Will Be Stored

The criterion used to determine the storage period of personal data is the applicable statutory retention period.

After the expiration of the respective retention period, the corresponding data will be routinely deleted, provided that it is no longer required for the performance of a contract, the initiation of a contract, or other legitimate purposes permitted by law.

13. Statutory or Contractual Requirements to Provide Personal Data; Necessity for Entering into a Contract; Consequences of Failure to Provide Personal Data

The provision of personal data may be required by law (for example, under tax or commercial regulations) or may result from contractual provisions (for example, information relating to a contractual partner, delivery address, or payment details).

In order to conclude a contract with our company, it is generally necessary for you to provide certain personal data. The specific data required in each case will be indicated in the relevant forms or communicated during the contract initiation process.

Without the provision of such data, it may not be possible to conclude or perform the contract, as we may be unable to provide our contractual services (for example, delivery of goods or invoicing).

Consequences of Failure to Provide Data:

If you do not provide the personal data required for the conclusion of a contract, the contract may not be concluded or performed as intended.
Where certain data is required by law, failure to provide such data may result in our inability to enter into or continue the contractual relationship.

The provision of any additional personal data beyond those requirements is voluntary.

14. Automated Decision-Making

Automated decision-making or profiling within the meaning of Article 22 GDPR does not take place.

15. SSL/TLS Encryption

For security reasons and to protect the transmission of confidential content, such as inquiries that you send to us as the website operator, this website uses SSL or TLS encryption.

You can recognize an encrypted connection by the fact that the browser address line changes from "http://" to "https://" and by the lock symbol in your browser address bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

16. Hosting

Our website is hosted by STRATO AG:

STRATO AG
Otto-Ostrowski-Straße 7
10249 Berlin
Germany

When visiting our website, personal data may be processed on STRATO's servers. This may include IP addresses, metadata and communication data, and data relating to website access.

The processing is carried out on the basis of Article 6 (1) (f) GDPR. Our legitimate interest lies in the secure, stable, and efficient provision of our website.

A Data Processing Agreement pursuant to Article 28 GDPR has been concluded with STRATO AG.

17. Google Analytics

Provided that you have given your consent, we use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses cookies that enable an analysis of your use of our website. The information generated by these cookies about your use of this website is generally transmitted to and stored on Google servers.

We use Google Analytics exclusively on the basis of your consent pursuant to Article 6 (1) (a) GDPR and Section 25 (1) TDDDG. You may withdraw your consent at any time with effect for the future via the cookie settings on our website.

Google Analytics helps us evaluate the use of our website and improve our online services. The following information may be processed, among others:

Pages visited;
Time spent on the website;
Referrer information (origin of visitors);
Device and browser information;
Approximate geographic location;
IP address in shortened or anonymized form.

We have activated IP anonymization. As a result, your IP address is shortened by Google within the European Union or the European Economic Area before being transmitted.

A transfer of personal data to the United States cannot be ruled out. Google is certified under the EU-U.S. Data Privacy Framework.

Further information about Google's privacy practices can be found at:

https://policies.google.com/privacy

The retention period of the data is determined by the retention settings configured in Google Analytics.

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STRAVEX TRANSPORT- UND
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