Thank you for visiting our website and for your interest in our company and our products and services. The protection
of your data and therefore also your privacy is important to us. On this page we would therefore like to inform you
how we collect, use and process your data in accordance with the basic EU General Data Protection Regulation
(EU-GDPR) and inform you about your rights in this regard.
In our data protection declaration we use technical terms from the EU-GDPR, which we would like to explain to you
briefly and simply in our own words to make it easier to understand:
This is data that can be assigned to a person or that allows conclusions to be drawn about a person.
This is you and all persons whose data are processed.
Data can be processed manually by one of our employees if, for example, you contact us by telephone, but also
automatically with the help of the software used (e.g. online purchase).
Pseudonymization refers to the processing of personal data in a way that does not identify the person to whom the
data is assigned. Instead of a concrete name, the data is assigned to only one number, for example.
Consent to data processing must always be voluntary, is for the specific purpose only (e.g. newsletter registration)
and you must be well informed.
You can visit our website without providing any personal data. If personal data are required, e.g. for order
processing, when opening a customer account or when contacting us, we only collect and process this data if there is
a legal basis for this or if we ask for your consent.
Of course, we have taken numerous technical and organisational measures to protect personal data in the best
possible way. Nevertheless, data transmission over the Internet can never be guaranteed to be absolutely secure. If
you have considered this, also with regard to the IT security of your own computer, you are welcome to transmit your
data to us by alternative means (e.g. by telephone or by post). We also offer the exchange of encrypted e-mails via
For the purpose of direct marketing, we reserve the right to store your first and last name, e-mail address,
telephone number, postal address and – if we have received this additional information from you or from other public
sources within the scope of the contractual relationship – your title, academic degree and your professional,
industry or business name and, if applicable, further information and to use it for sending interesting offers and
information on our products by post, fax or e-mail or to contact you by telephone. You can object to the use of your
data for this purpose at any time by sending us a message.
2. Contact for questions concerning data protection
If you have any questions regarding data protection and the implementation of the EU-GDPR at COMINTO GmbH, please do
40211 Düsseldorf, Germany
Phone: +49 (211) 600016-87
Fax.: +49 (211) 600016-89
3. General collection of data
When you visit our website, data is generally collected which is stored in the web server’s log files. This access
data includes: Name of the website accessed, file, date and time of access, amount of data transferred, notification
of successful access, browser type and version, your operating system, referrer URL (website used to navigate to our
website), your IP address, Internet service provider and other similar information used to defend against attacks on
our IT systems.
We do not use this data to draw conclusions about the person concerned.
The data is needed to correctly deliver our websites, to optimize their content and advertising, to ensure the
function of our IT systems and to provide law enforcement authorities with the information necessary for the
investigation in the event of a cyber attack.
These anonymously collected data and information are statistically evaluated by us, but stored separately from other
personal data provided by the persons concerned and are not merged with other data sources.
With an evaluation we pursue the goal of increasing the data protection and data security in our company and thus to
be able to protect personal data in the best possible way.
4. Data transmission and encryption
In order to process your personal data and orders via our online shop, we use a secure online transmission
procedure, the so-called “Secure Socket Layer” (SSL) transmission. This proven standard procedure, recognizable by
an “https” at the beginning of the website URL, is used at least as soon as you enter personal data with us. For
secure online transmission we use a web server certificate from AlphaSSL GlobalSign. This transfer method is
supported by most browsers. All information transmitted using this method is encrypted before it is sent to us by
you. This is to prevent unauthorized persons from accessing and using your sent data.
5. Legal basis of data processing
If we obtain your consent for data processing, the processing is carried out on the basis of Article 6(1)(a) of the
EU-GDPR. Where processing is necessary for the performance of a contract, order or contract, processing shall be
carried out on the basis of Article 6(1)(b) of the EU-GDPR. This also applies to pre-contractual measures such as
the submission of offers.
If we have to observe legal obligations in the processing of personal data, the processing is carried out on the
basis of Article 6 paragraph 1 letter c of the EU-GDPR.
In cases where there is a legitimate interest on our part which outweighs the need to protect your data, the legal
basis for the collection and processing is Article 6 letter f of the EU-GDPR.
In order to make visiting our website attractive, to enable the use of certain functions and to record statistics,
we use so-called cookies on various pages. These are small text files that are stored on your device when you visit
one of our websites. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing
your browser (so-called session cookies). For example, a session cookie can be used to determine that you have
already logged in and thus have access to your licenses, for example. If a cookie contains personal data, it is used
on the basis of Article 6(1)(f) of the EU-GDPR. Some cookies remain on your terminal device and enable us or our
partner companies to recognize your browser on your next visit (persistent cookies), for example to automatically
reuse your individual settings. The storage period therefore depends on the purpose of use and is not identical for
You can set your browser in such a way that you are informed about the setting of cookies and decide individually
about their acceptance or exclude the storage of cookies for certain cases or generally. If cookies are not
accepted, the functionality of our website may be limited.
7.1 Google Tag Manager
Our websites use Google Tag Manager, a Service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043,
USA. Google Tag Manager is a solution for managing website tags. The tool Tag Manager itself (which implements the
tags) is a cookieless domain. The tool triggers other tags, which in turn may collect data. Google Tag Manager does
not access this data. Google may collect information such as how the Service is used, and how and what tags are
deployed. Google may use this data to improve, maintain, protect and develop the Service as described in their
link to get additional information about the Google Tag Manager Use Policy: https://www.google.com/analytics/tag-manager/use-policy/
7.2 Google Analytics
Our websites use Google Analytics, a web analysis service of Google Inc. “(“Google”). The application is based on
Article 6 paragraph 1 letter f of the EU-GDPR and serves the purpose of a demand-oriented structure, an overview of
the use of the website and its continuous optimisation.
Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users
use the site. The information generated by the cookie, such as
- operating system
- Browser with version number
- Referrer URL (the website you previously visited)
- Host name of your device incl. IP address
- Time of request
about your use of these websites are usually transmitted to a Google server in the USA, stored there and processed on
our behalf. However, by using Google Analytics IP anonymization on our websites, your IP address will previously be
reduced by Google within member states of the European Union or in other signatory states 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. Google will use this information on our behalf to evaluate your use of the website, to
compile reports on website activity and to provide us with other services relating to website and Internet use. The
IP address transmitted by your browser in the context of Google Analytics is not merged with other Google
you do this you may not be able to use the full functionality of this website. You can also prevent the collection
of data generated by the cookie and related to your use of the website (including your IP address) and the
processing of this data by Google by downloading and installing the browser add-on from Google, available at the
following link (https://tools.google.com/dlpage/gaoptout?hl=en).
8. Contact options on our website
In order to be able to offer you a simple contact possibility and to fulfil legal requirements in this connection,
our web page offers possibilities for a fast electronic establishment of contact. These options include e-mail
addresses for contacting us via e-mail as well as contact forms.
The personal data transmitted in each case as well as additional personal data (e.g. in the mail text) are stored
automatically. We use this data to process your request and to contact you. This personal data will only be passed
on to third parties if there is a legal basis for this or with your consent.
You have the possibility to subscribe to a newsletter about the current developments of our products. If you would
like to receive the newsletter, you only need to enter a valid e-mail address. This e-mail address will only be used
for sending the newsletter. When you register for the newsletter, we also store your IP address and the time of
registration, as we are obliged to prove your registration or that of an unauthorised third party in your name with
this information. We use the list provider MailChimp to send our newsletter. MailChimp is an offer of the Rocket
Science Group, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 (“MailChimp”).
The data stored during registration is transmitted to MailChimp and stored by MailChimp. The data entered during
registration will not be passed on to any other third parties. After registration MailChimp sends you an e-mail to
confirm your registration. Furthermore MailChimp offers different analysis possibilities about how the sent
newsletters are opened and used, e.g. to how many users an e-mail was sent, whether e-mails were rejected and
whether users have unsubscribed from the list after receiving an e-mail. However, these analyses are only
group-related and are not used by us for individual evaluation. MailChimp also uses the analysis tool Google
Analytics from Google and may include it in newsletters. Further general information on Google Analytics can also be
found on this website with our data protection information.
Further information on data protection at MailChimp can be found at: https://mailchimp.com/legal/privacy/
You can revoke your consent to the storage of the data as well as their use for sending the newsletter at any time.
The revocation can take place via a link in the newsletters themselves. Alternatively, you can also contact us by
mail, letter or telephone.
10. Passing personal data for order processing
10.1. General information
We pass on your payment data to the commissioned credit institution as part of the processing of payments.
10.2 Purchase on account
Should we make advance payments (e.g. delivery on account), we reserve the right to carry out a credit assessment on
the basis of mathematical-statistical procedures in order to protect our legitimate interests. We transfer the
personal data necessary for a credit assessment to the following service providers:
Creditreform Boniversum GmbH
Hellersberg route 11
41460 Neuss, Germany
The credit report can contain probability values (so-called score values). If score values are included in the
result of the credit report, they are based on a scientifically recognised mathematical-statistical procedure;
address data is included in the calculation of the score values, among other things. We use the result of the credit
assessment with regard to the statistical probability of non-payment for the purpose of deciding on the
establishment, execution or termination of a contractual relationship.
When paying via PayPal, credit card via PayPal, direct debit via PayPal we pass your payment data on to PayPal
(Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”). PayPal reserves
the right to carry out credit checks for the payment methods credit card via PayPal, direct debit via PayPal. PayPal
uses the result of the credit assessment in relation to the statistical probability of non-payment for the purpose
of deciding on the provision of the respective payment method. The credit report can contain probability values
(so-called score values). If score values are included in the result of the credit report, they are based on a
scientifically recognised mathematical-statistical procedure. Address data is included in the calculation of the
score values. For further information on data protection law, including the credit agencies used, please refer to
PayPal’s data protection declaration: https://www.paypal.com/en/webapps/mpp/ua/privacy-full
In order to provide you with special services (e.g. automatic pre-selection of your country-specific VAT), this
website uses software developed by MaxMind, Inc. for geolocalization. This software analyse IP addresses to
determine your approximate location. Geolocalisation is carried out exclusively on the basis of anonymised IP
addresses. An exact location determination of the website visitor is thereby excluded. Please also note MaxMind’s
12. Deletion of personal data
We process and store personal data of data subjects only until the purpose for which the data was originally
collected has been successfully achieved or the storage is provided for on the basis of German or European
directives, ordinances, regulations or laws.
After the expiry of a corresponding legal retention period or after the storage purpose has ceased to apply, your
data will be routinely blocked or deleted, provided that they are no longer required for contract fulfilment or
13. Your rights to protect and control your data
Data protection is extremely important to us and we would like to inform you here about your rights to protect your
data. You should always have control over your own data!
You can revoke your consent given to us at any time.
In accordance with Article 15 of the EU-GDPR, you may also receive information about the data we hold about you,
including any relevant information relating to such data.
Your data should of course be correct, therefore we are happy to correct any errors immediately in accordance with
Article 16 of the EU-GDPR.
You also have the right to have your data deleted in accordance with Article 17 of the EU-GDPR. Please note that
other legal or contractual retention periods or obligations may nevertheless oblige us to further store your
If you dispute the accuracy of your data and we could not agree with you on a correction, the processing of the data
should be unlawful, but a deletion should not be possible or desired, you can exercise your right to a restriction
of the processing in accordance with Article 18 EU-GDPR. This also applies if we no longer need your data, but the
data is still needed in connection with a legal claim and therefore remains, but is no longer to be used, or if you
have lodged an objection pursuant to Article 21 of the EU-GDPR or in your case there is a special situation pursuant
to para. 1.
You may also use your data transfer rights under Article 20 EU-GDPR to obtain your data in a common machine-readable
format. As software developers, we are of course familiar with many common formats and are happy to implement your
request as precisely as possible.
Of course, you also have the right to complain directly to a supervisory authority at your place of residence or at
our company headquarters in Düsseldorf. However, we would ask you to contact us first. Misunderstandings or problems
can be resolved most quickly in this way.
The general right of objection also applies to data processed by us on the basis of Article 6 paragraph 1 letter f
of the EU-GDPR. Since in these cases the interest of the processing prevails in our view, we ask you to inform us of
the reasons for your objection.
14. Online dispute resolution
The European Commission provides an online dispute resolution (OS) platform, which you can reach via the following
Do you have any questions about our data protection or our products and services? Then send us an e-mail: