Privacy policy contracting parties, customers and suppliers

I. Data controller and contact information

Fragol AG, Solinger Str. 16, 45481 Mülheim an der Ruhr, registered in the Commercial Register of the Duisburg District Court under HRB 29863 (hereinafter also referred to as “we” or “Fragol”), is responsible for the collection, processing and management of personal data processed in connection with the initiation and implementation of this contractual relationship.

If you have any questions, comments or suggestions about your rights as a data subject or about the processing of your personal data by Fragol, please feel free to contact us. You can reach our data protection officer at:

AGAD - Arbeitgeberverband Großhandel, Außenhandel, Dienstleistungen e.V. (Employers' Association of Wholesale, Foreign Trade, Services).
Dr. Nils Helmke
Waldring 43 – 47
D-44789 Bochum
Telephone: +49(0)234 28253320
E-mail: datenschutzbeauftragter (at) fragol.de

II. Purposes and legal basis of the processing

We process your data in order to decide on a possible conclusion of a contract or in order to be able to conclude, fulfil or execute a contract with you. We also process your data on the basis of our legitimate interest in entering into and maintaining business relationships as well as to fulfil our legal obligations. The legal basis for the processing of the data is therefore Art. 6 para. 1 p. 1 lit. b), lit. c), lit. f) GDPR.

III. Data categories concerned

With this privacy policy we inform our contracting parties, interested parties, customers and suppliers about the processing of your personal data which we process when you seek or conduct a business relationship with us. We only process data that is related to the initiation or execution of the contract. This may be general data about you, your company or the contact persons in your company (in particular name, address, contact data, functions, contract data, invoice address, payment information, processing data, creditworthiness data including scoring, sanctions lists, etc.) as well as, if applicable, other data that you provide to us within the scope of our contractual relationship.

We collect and update the data in the course of our business relationship from information provided by our contracting parties, the employees of our contracting parties, publicly accessible sources (e.g. commercial register) and in individual cases from credit agencies.

There is no legal or contractual obligation to provide this data. However, without this data we may not be able to conclude a contract with you or provide our contractually owed services (e.g. payment for services rendered) in full or at all.

Since we can initially only reach the directly responsible decision-makers of our contracting parties with this privacy policy, you are also obliged within the framework of our contractual relationship to pass on this privacy policy to your employees if we process their data in the course of the contractual relationship. This applies in particular to all contact persons who are to contact us or with whom we will cooperate for the successful implementation of the contractual relationship.

IV. Duration of data retention

Your personal data will only be processed for the duration of the fulfilment of the aforementioned purposes and beyond that only if and insofar as we are obliged to do so for legal reasons (for example, statutory commercial and tax retention obligations). As a rule, this applies to contractual data until the end of the calendar year three years after the end of the contractual relationship and with regard to documents subject to retention for 6 or 10 years. Afterwards, the aforementioned data will be deleted, anonymised or access to the data blocked, if this is possible on the system side.

V. Transfer of personal data

The personal data will only be transferred to the service providers who process your data for the purposes mentioned above (for example, to make or receive payments, to prepare or review invoices or to receive or provide services).

VI. No transfer of personal data to a third country

We do not intend to transfer personal data to a country outside the EU or the EEA unless this is necessary for the fulfilment of our contractual agreements or for the initiation of a contract (for example, if you have your registered office in a third country or we are to provide our services for a subsidiary in a third country).

VII. Rights of data subjects

You can exercise the following rights with regard to your personal data:

• Right of access, Art. 15 GDPR
• Right to rectification, Art. 16 GDPR
• Right to erasure, Art. 17 GDPR
• Right to restriction of processing, Art. 18 GDPR
• Right to data portability, Art. 20 GDPR
• Right to object to processing, Art. 21 GDPR

Furthermore, you can file a complaint with a competent data protection supervisory authority at any time if you believe that your data is being processed unlawfully. For Fragol, for example, this is generally the data protection supervisory authority of North Rhine-Westphalia, Germany.