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RENZ privacy policy


Introduction


Welcome to the RENZ privacy policy.


This privacy policy will inform you about what happens to your personal data when you use the RENZ parcel box system (referred to as “the System” in this privacy policy) and tell you about your privacy rights and how the law protects you.


This privacy policy covers the specific areas set out below.


  1. Important information and who we are

  2. The data we collect about you

  3. How is your personal data collected?

  4. How we use your personal data

  5. Disclosure of your personal data

  6. International transfers

  7. Data security

  8. Data retention

  9. Your legal rights

  10. Glossary

Please use the Glossary in section 10 to understand the meaning of some of the terms used in this privacy policy.


Important information and who we are


Purpose of this privacy policy


This privacy policy aims to give you information on how your personal data is collected and processed through your use of the System.


The System is not intended for children and data relating to children is not knowingly collected.


Controller


The person who makes the System available to you and who operates the System (for example, your landlord, your property manager, your employer) is the controller and responsible for your personal data (referred to as “Controller” in this privacy policy). RENZ is not the controller.


Who is RENZ?


RENZ is made up of different legal entities, details of which can be found here: https://safetyletterbox.com/about/  (referred to as “the RENZ Group” in this privacy policy). This privacy policy is issued on behalf of the RENZ Group so when we mention "RENZ", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the RENZ Group responsible for processing your data. RENZ manufactures the System and gives the Controller the right to use the software installed in the System to operate, administer and control the System. RENZ processes personal data on behalf of the Controller for the purposes described in this privacy policy.


Your right to complain


The Controller is responsible for overseeing questions in relation to this privacy policy. If you have any questions about the use of your personal data, including any requests to exercise your legal rights, you should contact the data protection officer or data privacy manager of the Controller in the first instance.  The contact details of the data protection officer or data privacy manager of the Controller will be made available to you by the Controller.    


You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).


No liability


RENZ is not responsible for any failure by the Controller to comply with any applicable data protection and privacy laws in force from time to time in the UK.


Changes to the privacypolicy


We keep our privacy policy under regular review. From time to time, we may develop or make changes to the System. If those developments result in any material change to the way your personal data is collected or processed we may change the terms of this policy. You will be informed of any changes.  Unless stated otherwise when we introduce developments or changes to the System, they will be subject to this privacy policy


You should inform the Controller if your personal data changes during your use of the System.


The data collected about you


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


In order to operate the System the Controller may collect, use, store and transfer different kinds of personal data about you as follows:


  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title and gender.

  • Contact Data includes address, email address and telephone numbers.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the System.

  • Profile Data includes your username and password. 

  • Usage Data
    includes information about how you use the System.

The Controller may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, your Usage Data may be aggregated to calculate the percentage of users accessing a specific feature of the System. However, if Aggregated Data is combined or connected with your personal data so that it can directly or indirectly identify you, the combined data is treated as personal data which will be used in accordance with this privacy policy.


It is not necessary for the Controller to collect any Special Categories of Personal Data about you to operate the System (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Neither is it necessary for the Controller to collect any information about criminal convictions and offences.


If you fail to provide personal data


Where your personal data is required by law, or under the terms of a contract between you and us or between you and the Controller, and you fail to provide that data when requested, you may not be able to use the System.


How is your personal data collected?


The System uses different methods to collect data from and about you including through:


  • Direct interactions. You may give the Controller your identity and contact data by corresponding with the Controller by post, phone, email or otherwise. This includes personal data you provide to the Controller when you:


    • create an account on www.myrenz.com


    • register to use the System.


  • Automated technologies or interactions. As you interact with the website www.myrenz.com, the System will automatically collect Technical Data about your equipment, browsing actions and patterns. This personal data is collected by using cookies and other similar technologies. Please see our cookie policy at section 4 for further details.


How your personal data is used


our personal data should only be used when the law allows it to be used. Most commonly, your personal data is used in the following circumstances:


  • to perform a contract  about to be entered into or which has been entered into with you.


  • Where it is necessary for our legitimate interests (or those of a third party, for example the Controller) and your interests and fundamental rights do not override those interests.


  • to comply with a legal obligation.


Go to the Glossary at section 10 to find out more about the types of lawful basis that we will rely on to process your personal data.


Generally, we do not rely on consent as a legal basis for processing your personal data.


Purposes for which the Controller will use your personal data for the operation of the System


The table below sets out all the ways the Controller will use your personal data in order to operate the System and the legal basis for doing so.


Your personal data may be processed for more than one lawful ground depending on the specific purpose for which it is being used.























Purpose/Activity


Type of data


Lawful basis for processing including basis of legitimate interest



To register you as a user of the System



(a) Identity


(b) Contact


(c) Profile



(a) Performance of a contract with you


(b) Necessary for its legitimate interests (to allow you to use the System it has made available to you)


 



To operate, administer and control  the System including:


(a) allocation of access authorisation


(b) allocation of letter and parcel boxes


(c) issue of digital name tags and digital bells


(d) service messages


(e) to activate and deactivate parcel and courier services



(a) Identity


(b) Contact


(c) Profile



(a) Performance of a contract with you


(b) Necessary for its legitimate interests (to allow you to use the System is has made available to you)



To manage its relationship with you which will include:


(a) Notifying you about changes to  the System


 



(a) Identity


(b) Contact


 (c) Profile



(a) Performance of a contract with you


(b) Necessary to comply with a legal obligation


 



Purposes for which we will use your personal data


The table below sets out the ways we, RENZ, will use your personal data and the legal basis for doing so.


Your personal data may be processed for more than one lawful ground depending on the specific purpose for which it is being used.


 



















Purpose/Activity



Type of data



Lawful basis for processing including basis of legitimate interest



To administer and protect the System (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 



(a) Identity


(b) Contact


(c) Technical


(d) Usage


(e) Profile



(a) Performance of our contract with the Controller


(b)Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)


(b) Necessary to comply with a legal obligation



To integrate or interface the System with Controller management systems



(a)
Identity


(b)
Contact


(c)
Technical


(e)
Usage


(e) 
Profile



(a)
Performance of our contract with the Controller


(b)Necessary
for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)


 




Please note that your personal data may be processed without your knowledge or consent where this is required or permitted by law.


Marketing


Your data will not be processed for marketing purposes.  You will not receive marketing communications as a result of using the System.


Cookies


The System uses cookies to distinguish you from other users of the use the System. lang=EN-US This helps us to provide you with a good experience when you use the System and allows us to improve the System.


A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your
computer's hard drive.


There are a few different categories of cookies, including:


  • Session Cookies.These are cookies which expire once you close your web browser; and


  • Persistent Cookies These are cookies which stay on your device for a set period of time or until you delete them.


We use the following cookies:


  • Strictly necessary cookies. These are cookies that are required for the operation of the System. They include, for example, cookies that enable you to log into secure areas of the System. These cookies are Session Cookies.





We do not share the information collected by the cookies with any third parties.


We will not use any other cookies without your consent.


You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies
(including essential cookies) you may not be able to access all or parts of the System .


Disclosures of your personal data


Your personal data may be shared with the parties set out below for the purposes set out in the tables above.


  • Internal Third Parties as set out in the Glossary.


  • External Third Parties as set out in the Glossary.


  • Other persons authorised by the Controller to use the System (for example your neighbours or your co-workers).


  • Third parties to whom we or the Controller may choose to sell, transfer or merge parts of our respective business or assets. Alternatively, we or the Controller may seek to acquire other businesses or merge with them. If such a change happens, then the new owners may use your personal data in the same way as set out in this privacy policy.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


International transfers


Your personal data is not transferred outside the European Economic Area (EEA).


Data security


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


The Controller is required by law to put in place appropriate security measures of the type referred to above.  You should contact the data protection officer or data privacy manager of the Controller if you need details about its security measures.


Data retention


How long will your personal data be used for?


Your personal data will be retained only for as long as reasonably necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Your personal data may be retained for a longer period in the event of a complaint or if there is a reasonable prospect of litigation in respect to our relationship with you or your relationship with the Controller.


To determine the appropriate retention period for personal data, the following are considered: the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which your personal data is processed and whether those purposes cab be achieved through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


Details of retention periods for different aspects of your personal data can be obtained by contacting the data protection officer or data privacy manager of the Controller.


In some circumstances you can ask for your data to be deleted: see Your Legal Rights in the Glossary in section 10 below for further information. Any such request should be made to
the Controller.


Your legal rights


Undercertain circumstances, you have rights under data protection laws in relation to your personal data. Please see Your Legal Rights in the Glossary in section 10 to find out more about these rights. 


If you wish to exercise any of the rights set out above, please contact the data protection officer or data privacy manager of the Controller.





No fee usually required


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, a  reasonable fee may be charged if your request is clearly unfounded,
repetitive or excessive. Alternatively, your request may be refused in these circumstances.


What may be required from you


Specific information from you to help the Controller confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.


Time limit to respond


Legitimate requests are normally responded to within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, you will be notified and kept updated.


Glossary


LAWFUL BASIS


Legitimate Interest
means the interest of our/the Controller’s business in conducting and managing our/the Controller’s business to enable you to have the best service/product and the best and most secure experience. Any potential impact on you (both positive and negative) and your rights will be considered before your personal data is processed for our/the Controller’s legitimate interests. Your personal data will not be used for activities where our/the Controller’s interests are overridden by the impact on you (unless you have consented or the processing is otherwise permitted to by law).


Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or we are a party or to take steps before entering into such a contract.


Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation.


THIRD PARTIES


Internal Third Parties


Other companies in the RENZ Group acting as joint processors and who are based in the United Kingdom and Germany and provide IT and system administration services and undertake leadership reporting.


External Third Parties


  • Service providers based in the United Kingdom and Germany who provide IT and system administration services.


  • Parcel and courier service providers (for example DHL, UPS).


  • Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom and Germany who provide consultancy, banking, legal, insurance and accounting services.


  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and Germany circumstances.



YOUR LEGAL RIGHTS


You have the right to:


Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data held about you and to check that your personal data is being processed lawfully.


Request correction of the personal data that is held about you. This enables you to have any incomplete or inaccurate data held about you corrected, though you may need to verify the accuracy of the new data you provide.


Request erasure of your personal data. This enables you to ask for your personal data to be deleted or removed where there is no good reason to continue to process it. You also have the right to ask for your personal data to be deleted or removed where you have successfully exercised your right to object to processing (see below), where your information has been processed unlawfully or where the controller or processor is required to erase your personal data to comply with local law. Note, however, that it may not always be possible to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


Object to processing of your personal data on the grounds of a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, it may be demonstrated that there are compelling legitimate grounds to process your information which override your rights and freedoms.


Request restriction of processing of your personal data. This enables you to ask for the suspension of the processing of your personal data in the following scenarios:


  • If you want us to establish the data's accuracy.


  • Where the use of the data is unlawful but you do not want it to be erased.


  • Where you need the data to be retained even if it is no longer required by the controller or processor as you need it to establish, exercise or defend legal claims.


  • You have objected to the use of your data but the controller or processor needs to verify whether they have overriding legitimate grounds to use it.



Request the transfer of your personal data to you or to a third party. Note that this right only applies to automated information which you initially provided consent for it to be used or where the information has been used to perform a contract with you.


Withdraw consent at any time where consent is relied on to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, it may not be possible to provide certain services to you. You will be advised if this is the case at the time you withdraw your consent.


If you wish to exercise your legal rights, you should contact the data protection officer or data privacy manager of the Controller in the first instance.





As of: June 2020




Impressum




Erwin Renz Metallwarenfabrik GmbH & Co KG
Boschstraße 3
71737 Kirchberg/Murr
Deutschland
Tel. +49 (0) 71 44 / 301 - 0
Fax +49 (0) 71 44 / 301 - 185
E-Mail info(at)renzgroup.de
www.briefkasten.de


Sitz der Gesellschaft:
Kirchberg/Murr


Registergericht:
Stuttgart, HRA 270640


Pers. haftender Gesellschafter:
Renz GmbH, Kirchberg/Murr, HRB 270664


Geschäftsführer:
Armin Renz


Umsatzsteuer-Identifikationsnummer:
DE144740068


Wir nehmen nicht an einem Streitbeilegungsverfahren vor einer Verbraucherschlichtungsstelle teil.


Hinweis


Änderungen, die dem technischen Fortschritt dienen, behalten wir uns vor. Für Abbildungsfehler kann keine Haftung übernommen werden. Alle Abbildungen sind nicht farbverbindlich.

2020.02.240