PRIVACY POLICY
Responsible:
Inh. Kristin Heil
Gramm Tourpacking
Josef-Orlopp-Str. 56
10365 Berlin, Germany
+49 (0) 30-57794973
post@gramm-tourpacking.com

GENERAL INFORMATION ON DATA PROCESSING
Gramm Tourpacking generally only process data of users if this is necessary for the provision and functional website, our content and service. Gramm Tourpacking is committed to protecting the privacy of its customers and maintaining your trust and confidence is one of Gramm Tourpacking’s highest priorities. Gramm Tourpacking is committed to collect and process Personal Data only in accordance with its rights and responsibilities under the applicable laws and regulations, including the European Union’s General Data Protection Regulation (“GDPR”).

The basic principles under GDPR are that Personal Data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals
- processed only for specified, explicit and legitimate purposes and not processed in a manner that is incompatible with those purposes
- processed only in a way that adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that Personal Data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
- processed for no longer than is necessary for the purposes for which the Personal Data are processed; and
- processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
This Privacy Policy explains Gramm Tourpacking's Personal Data collection and processing practices.
Please read this Privacy Policy before using the site or submitting any Personal Data.

The Website contains links to third party sites or functionalities, which are not subject to this Privacy Policy.
Gramm Tourpacking does not endorse and is not responsible for the privacy practices or the content on such third party sites or functionalities.

COLLECTION AND PROCESSING OF PERSONAL DATA
Please note that you need to provide Gramm Tourpacking with certain Personal Data if you would like to purchase products directly from www.gramm-tourpacking.com and in some cases when you contact the support or customer service.
If you choose to withhold any Personal Data requested by Gramm Tourpacking for such purposes, it might not be possible for Gramm Tourpacking to accept your purchase of products or solve the matter that you would like to have solved by the support or customer service. Gramm Tourpacking collects and processes Personal Data in accordance with this Privacy Policy.

UPON PURCHASE OF PRODUCTS
The types of Personal Data that Gramm Tourpacking collects and processes upon purchase of products consists of the following for the following purpose and time periods:
Personal Data type Legal Ground and Purpose Personal Data Retention Period
-Operating system of the user
-Internet service provider of the user
-IP-Address of the user
-Date and time of access
This data is stored in the log files of the system of our hosting provider. This data is not stored together with other personal data of the user.

PURPOSE OF DATA PROCESSING
The necessary purpose of fulfilling Gramm Tourpacking obligations related to the purchase, such as processing orders, perform delivery of the products, provide product warranty, resolving disputes, collecting payments, handling claims, withdrawals and repayment, and for compliance with legal obligations (such as book keeping). For the time needed to fulfill Gramm Tourpackings' obligations, including facilitating warranty obligations.
IP-address For the necessary purpose of fulfilling Gramm Tourpacking obligations related to security and fraud prevention. For the time needed to fulfill Gramm Tourpackings’ obligations towards law enforcement authorities and banks.

UPON CONTACT WITH SUPPORT OR CUSTOMER SERVICE
The types of Personal Data that Gramm Tourpacking collects upon your contacts with support or customer service:

Personal Data type Legal Ground and Purpose Personal Data Retention Period
Your e-mail address and other information you voluntarily provide upon contacts with support or customer service. For the necessary purpose of fulfilling Gramm Tourpackings’ obligations related to the contact, such as handling claims, withdrawals and repayment. For the time needed to fulfill Gramm Tourpackings’ obligations.

UNSOLICITED PERSONAL DATA
Any Personal Data related to you that you voluntarily choose to provide in any open areas of the Website, such as forums, commentary sections etc. are deemed to be given under the consent that Gramm Tourpacking has the right to process such Personal Data until further notice from you and you are informed that such Personal Data may be available to any other visitor of the Website and that Gramm Tourpacking may have difficulties, or even not being able, to keep track of such Personal Data.
If you therefore would like Gramm Tourpacking to take action in accordance with what is set out in Section 3 below, Gramm Tourpacking may request you to provide information about where such Personal Data is located to take appropriate actions.

THIRD PARTIES AND PERSONAL DATA TRANSFER
Except as provided in this Privacy Policy, Gramm Tourpacking will not intentionally disclose your Personal Data to third parties without your consent. Gramm Tourpacking may however disclose information to third parties, for them to process the same, in the circumstances set out below.

SERVICE PROVIDERS
Gramm Tourpacking works with third party service providers who provide (i) Website and application development, hosting, maintenance, e-mail servers, and other related services, (ii) order fulfillment, payment fulfillment, product shipment, after sales services, support services and other related services, (iii) services related to the sending of E-mails, Newsletters, providing Marketing and other related services, and (iv) financial services, bookkeeping services and audits and other related services.
Such third parties may receive access to your Personal Data in order for them to provide the intended services for Gramm Tourpacking. Gramm Tourpacking will however limit the Personal Data provided to such third parties to what is reasonably necessary for such third parties to perform their obligation in relation to Gramm Tourpacking, and always subject to obligations of confidentiality.

LAW ENFORCEMENT AND LEGAL PROCESSES
Gramm Tourpacking may disclose Personal Data if required to do so by applicable laws, court orders, judicial and government subpoenas or warrants, or otherwise to cooperate with law enforcement or other governmental agencies.
Furthermore, Gramm Tourpacking reserves the right to disclose Personal Data that Gramm Tourpacking believe is appropriate or necessary to take actions to protect Gramm Tourpacking and others from fraudulent, abusive or unlawful use or activity, to investigate and defend Gramm Tourpacking from third party claims or allegations and to protect Gramm Tourpacking s business and legal rights, enforce contracts or protect the rights, property or safety of others.

CHANGE OF OWNERSHIP
Personal Data may be transferred to an acquirer or assignee as part of a sale of the business of AGramm Tourpacking , either in whole or in part, for the sole purpose of continuing the business subject to such sale and only of the recipient of such of the Personal Data commits to a Privacy Policy with terms materially consistent with this Privacy Policy.

PERSONAL DATA TRANSFER
Gramm Tourpacking may transfer Personal Data to service providers, as stated in Section 2.1 above, located outside of the EU reasonably necessary for such service providers to perform their obligation in relation to Gramm Tourpacking. Gramm Tourpacking will however at all times comply with GDPR requirements providing adequate protection for the transfer of such Personal Data to such third countries and will try to minimize such transfer.

INFORMATION ABOUT YOUR RIGHTS IN RELATION TO Gramm Tourpackings’ PROCESSING OF YOUR PERSONAL DATA
As concerns your Personal Data and Gramm Tourpackings’ processing of the same, you have the following rights:
Right to access: You have the right to receive information if Gramm Tourpacking is processing any of your Personal Data, and if so, what kind of Personal Data, for what purpose and for what time period, etc.;
Right of rectification: You are entitled to require Gramm Tourpacking to correct any errors in or update your Personal Data;
Right to be forgotten: You are entitled to require Gramm Tourpacking to delete all Personal Data, or parts thereof, that is being processed by Gramm Tourpacking in certain circumstances;
Right to restrict processing: You have the right to require that Gramm Tourpacking restricts or suppresses the Personal Data that Gramm Tourpacking processes or Gramm Tourpackings’ use of the same in certain circumstances; and
Right of data portability: You have the right to export your Personal Data provided by you to Gramm Tourpacking.

In order to allow you to enforce your rights set out above Gramm Tourpacking provides you access to a personal account where your Personal Data can be managed, reviewed, corrected, updated and exported. If you haven’t created a login to your personal account you can create such login by using the same e-mail address as used during purchase.
You may also contact Gramm Tourpacking with regards to your rights via the contact information provided in section 10 below.
Upon contact with customer service for this purpose you may need access to the same e-mail address as used during purchase or registration with Gramm Tourpacking in order for Gramm Tourpacking to have the possibility of verifying your identity and right to access your Personal Data.
Please note that while changes or updates will be reflected within Gramm Tourpacking systems immediately or within a reasonable period of time, Gramm Tourpacking reserves the right to retain all your Personal Data for backups, prevention of fraud or abuse, satisfaction of legal obligations, or where Gramm Tourpacking otherwise believes that Gramm Tourpacking has the legitimate or mandatory reason to do so.
Gramm Tourpacking will not be able to correct or update any Personal Data in relation to orders for products being processed or being shipped to you.

YOUR RIGHT TO LODGE A COMPLAINT
At any time you may contact Gramm Tourpacking to object to the processing of your Personal Data where processing is justified based on Gramm Tourpackings’ legitimate interests or where you believe that your rights to privacy under applicable data protection laws has been infringed upon. For such contacts please use the contact information provided in Section 10 below.
You also have a right to lodge a complaint with the relevant data protection supervisory authority.

SECURITY POLICY
Gramm Tourpacking is committed to keeping your Personal Data secure against unauthorized access or use, alteration, unlawful or accidental destruction and accidental loss by using for example accepted industry standards, modern software that is kept-up-to-date and appropriate administrative, technical and physical safeguards. This includes for example firewalls, password protection, and authentication controls. Only authorized employees, agents and service providers (who have agreed to keep information secure and confidential) have access to your Personal Data. However, you should be aware that there is always some risk involved in transmitting information over the internet.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Data, Gramm Tourpacking will promptly assess the risk such event has on your rights and freedoms and if appropriate inform you and the relevant data protection supervisory authority of such event.
If you believe that your Personal Data has been compromised, please contact Gramm Tourpacking via the contact information provided in Section 10 below as soon as possible.

COOKIES AND ANALYTICS INFORMATION
Gramm Tourpacking uses automatically collected information – however not any Personal Data – through cookies and other technologies to personalize your experience of the Website, to provide customized advertisement, information and content, and to monitor and analyze your use of the Website. Please see Gramm Tourpacking Cookie Policy [LINK] to obtain more information about the cookies and other technologies used.
Furthermore, Gramm Tourpacking uses analytics technologies (Google Analytics) to measure and evaluate the access to and traffic on the Website, and to generate navigation reports. Such technology is not collecting any Personal Data.

CHANGES AND UPDATES
Gramm Tourpacking may update this Privacy Policy from time to time. Upon such updates Gramm Tourpacking will make the new Privacy Policy available on the Website and indicate the date of the latest revisions made.
You are encouraged to revisit this Privacy Policy periodically to keep yourself informed about any changes to this Privacy Policy. Your continued use of the Website, your personal account, contacts with the support or customer service or purchase of products after the revised Privacy Policy has become effective will indicate that you have read, understood and accepted the then current version of the Privacy Policy.

PERSONAL DATA CONTROLLER CONTACT INFORMATION
You may contact Gramm Tourpacking at any time:
- to request access your Personal Data that Gramm Tourpacking is processing,
- to correct such Personal Data,
- to request that Gramm Tourpacking either restricts it use of your Personal Data or deletes such Personal Data, or
- if you do not understand any of the foregoing terms and conditions or if you have any questions, concerns or comments about Gramm Tourpackings’ Privacy Policy.

Contact information:
By Email: post@gramm-tourpacking.com
Gramm Tourpacking
Kristin Heil
Josef-Orlopp-Str. 56
10365 Berlin, Germany
This Privacy Policy was last updated: Jan. 2023