This Privacy Policy applies to the websites truma.com, truma.com/serviceblog, dealernew.truma.com, oem.truma.com and go2-camping.com as well as to the Truma App for iOS and Android, as they are operated by Truma Gerätetechnik GmbH & Co. KG ("Truma"). This declaration concerning data protection only applies to these websites and their sub-pages as well as to the apps. Thus, it does not cover websites of third parties to which Truma refers by means of links.

1. Collection and Use of Data

On our websites and apps we collect personal data only if this is required for the purpose defined by you and/or if you provide us with such data on consent. Personal data means any information relating to an identified or identifiable natural person.

1.1 Usage Data

When visiting our websites we collect usage data (for example, which browser is used, access times, visited product site etc.) which we evaluate for statistical purposes, to optimize our content and guarantee system security.

1.2 Website

If you visit our website we will collect personal data, in particular, for the purpose of contacting you at your request, processing online applications, for mobile customer service requests or sending you the Newsletter. The data will only be used for the purposes disclosed. We work with Edelweiss72 GmbH, Agentur für interaktive Medien, to implement our website. Within the scope of its services the agency can have insight to personal data. For online application submissions, your personal data is collected and stored by our service provider perbit Software GmbH.

1.3 Dealer and OEM Portal

If you intend to use our Dealer and OEM Portal, you have to register for this purpose. When you do so, we will collect the following data about you. Please note that there are mandatory fields which have to be completed for processing your request. They are marked with an asterisk. If you also make entries in the other fields, then they will be used for statistical purposes and for improving our content.

• Customer number
• Name of company
• Addition to name of company (optional)
• Addressing
• First and last name
• Address
• Language
• E-mail address
• Phone (optional)

We collect the data for the purpose of processing orders and delivering products. Products will be delivered by an external service provider. As registered dealer and OEM you may generate also own forms and, for example, change your address data in the portal.

We will use the data collected for the purpose of processing your order and delivering the products.

1.4 Truma App

If you use our app we will collect usage data of the app (for example, the device data, the firmware version, the application version of the app and the usage data of the app, such as preference settings, functions used, frequency and date of access, error reports). We will process such data for statistical purposes, for optimizing our content and for guaranteeing system security.

In the app you have the ability to install a remote control function for your Truma devices via Bluetooth or SMS. For this purpose, we collect and process the device data of your mobile phone as well as the device to be operated in order to be able to provide the service.

You have the option to download the operating manual for your Truma devices using the app. In the process, we record your user ID so that we can assign it to the download. You also have the option of registering for our newsletter using your e-mail address.

Some functions of this application make use of your current location. Your location is determined by the connection to WiFi networks, mobile transmitting towers or by GPS. The data is not used in order to track you, but rather to offer your location-based services. Shortly after starting the application, you are asked whether you would like to use these services during the current session. You have the option of saving your choice permanently so that you are no longer prompted. You can change this afterward in your settings.

2. Use, Storage and Deletion of Cookies

Cookies are small text files which are stored on your terminal device. The purpose of these cookies is the control of the Internet connection during your visit of our websites. We store the data collected by cookies separately from other files. We process such data exclusively for statistical purposes, for guaranteeing system security and for technical improvement. At the same time, these cookies enable us to optimize our content to meet your needs. We will use what are known as session cookies exclusively. They remain on your terminal device only until you close your web browser. Thereafter, they will be deleted automatically. By configuring settings your web browser, you may prevent the setting of cookies on your terminal device.

3. Data Security

We protect your personal data against any risks connected with the data processing, in particular, against unauthorized access, use or publication. For this purpose we maintain appropriate technical and organizational measures incorporating the latest technical advances. The data collected and obtained from you in a standard form on HTML pages will be transferred in encrypted form (SSL – Secure Socket Layer) from your terminal device to our server.

4. Data Protection Rights

4.1 Right to withdraw: You are entitled to withdraw your consent given with regard to the processing of your personal data at any time with effect for the future. A withdrawal shall not affect the lawfulness of the processing of data on the basis of your consent until withdrawal of such consent.

4.2 Right of access: You are entitled to obtain information free of charge about the personal data stored. On your request, such information may also be provided by electronic means.

4.3 Rectification, erasure and restriction of data: You are entitled to request the rectification, erasure or restriction of your personal data. However, after erasure or blocking of your personal data you can no longer use relevant services. Your right to erasure may be excluded by statutory retention requirements.

4.4 Data portability: You have the right to have us provide you with data that we process by automatic means and to the use of which you have given your consent, in machine-readable form or transfer such data to other controllers.

4.5 Assertion of rights: You may assert your rights by informal notification to Truma Gerätetechnik GmbH & Co. KG, Wernher-von-Braun-Strasse 12, 85640 Putzbrunn or by e-mail to info@truma.com.
If you have any complaints you may also contact the competent data protection supervisory authority in Ansbach, Germany.
 

5. Disclosure of Data

Your personal data is not disclosed unless Truma is legally obliged to such disclosure (e.g. request of an investigating authority) or authorized (e.g. within the scope of contract data processing). A transfer to third countries will only take place insofar as we expressly refer to such transfer and disclosure in this Privacy Policy. Upon disclosure and transfer of data we will make sure that third parties comply and observe a reasonable level of protection for personal data.

6. Erasure and Restriction of Data

Your data will be erased to the extent that the processing of your request has been terminated, you have withdrawn your consent to the processing or if the storage of your data is or becomes inadmissible for other legal reasons. Upon erasure or restriction of data relevant services cannot be used any longer. If statutory retention requirements apply to your data, the data shall instead be barred from any other use.

7. Tracking

7.1 WiredMinds

On the websites, data will be processed for marketing and optimizing purposes by WiredMinds leadlab, a service provided by WiredMinds AG. In doing so, data will be processed on the basis of which usage profiles are prepared under a pseudonym. Where possible and reasonable, the usage profiles will be completely anonymized. For this service cookies are used. In no event will data be used for the personal identification of the visitor (if and to the extent that this is feasible at all) or in connection with data through the bearer of a pseudonym.

Consent to data processing by WiredMinds may be revoked at any time with effect for the future: Objection

 

7.2 Google Analytics

On the websites data will be processed for marketing and optimizing purposes by the service Google Analytics, a web analysis service of Google Inc. ("Google").

Google Analytics uses cookies, i.e. text files which are stored on your computer and make an analysis of your use of the websites possible. The information on how you use the websites that is gathered by the cookies, as a rule, will be transferred to and stored on a Google server in the USA. You may prevent that by configuring your browser installation in such a manner that no cookies are stored.

By activating the IP anonymization on the websites, your IP address will be abbreviated by Google, however, within the member states of the European Union or in other contracting states to the Agreement on the European Economic Area in advance. Only in exceptional cases will the complete IP address be transferred to a Google server in the USA and abbreviated there.

We have concluded an appropriate contract concerning the contracted data processing with the provider. The transmission and transfer of data to the USA is in line with the required data protection level. The data protection level is safeguarded by the Google's Privacy Shield Framework Licensing.
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

By order of the operator of the website, Google will use the processed information to evaluate the use of the website in order to compile reports concerning the website activities and to render further services associated with website use and Internet use vis-à-vis the website operator. The anonymized IP address transmitted by your browser within the scope of Google Analytics will not be merged with other Google data.

You can prevent cookies from being stored by an appropriate setting of your browser software; however, we would like you to note that in this case you could possibly be prevented from fully using all functions of this website. You can further prevent collection of the data generated by the cookies and referring to your use of the website (including your IP address) as well as the processing of such data by Google by downloading and installing the browser plugin available under the following link
http://tools.google.com/dlpage/gaoptout?hl=de

 

7.3 Google Tag Manager

Our website uses Google Tag Manager. This service makes it possible to manage website tags via an interface. Google Tag Manager only implements tags. This means that no cookies are set and no personal data is collected. Google Tag Manager may trigger other tags, such as Google Analytics, which in turn may collect data. Google Tag Manager does not have access to this data, however.

8. Integration of YouTube and Vimeo videos

8.1 We have integrated YouTube and Vimeo videos into our online services that are saved on https://www.YouTube.com and https://vimeo.com and can be played directly from our website. They are all integrated into "extended data protection mode," meaning that data about you as a user is not transmitted to YouTube or Vimeo if you do not play the videos. The information listed in Paragraph 8.2 is only transmitted once you play the videos. We have no control over this data transmission.

8.2 By visiting the website, YouTube and Vimeo are informed that you have called up the corresponding subpage of our website. In addition, the data listed below is also transmitted.

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (actual page)
• Access status/HTTP status code
• Respective transmitted data volume
• Website originating the request
• Browser
• Operating system and its interface
• Language and version of the browser software

This happens regardless of whether you are logged in to a user account provided by YouTube or Vimeo or do not have a user account. 
If you are logged in to Google, your data is assigned directly to your account. If you do not want this assignment with your YouTube profile, you have to log out before pressing the button. YouTube saves your data as a usage profile and uses it for the purposes of advertisement, market research and/or designing its website in accordance with demand. Specifically, this type of evaluation takes place (even for users who are not logged in) in order to deliver demand-based advertisement and to inform other social network users about your activities on our website. You have the right to object to the creation of a user profile. To exert this right, you must contact YouTube.

8.3 Additional information about the purpose and scope of the data collection and its processing by YouTube or Vimeo can be found in their respective data protection statements. There, you also receive other information about your rights and setting options for protecting your privacy: https://www.google.de/intl/de/policies/privacyGoogle also processes your personal data in the US and is subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework
Vimeo has the following privacy policy: https://vimeo.com/privacy

9. Incorporation of Google Maps

9.1 On our website, we use Google Maps services. This enables us to show you interactive maps right on the website and allows for convenient use of the map function.

9.2 By visiting the website, Google is informed that you have called up the corresponding subpage of our website. The data listed under § 8 of this statement is also transmitted. This happens regardless of whether you are logged in to a user account provided by Google or do not have a user account. If you are logged in to Google, your data is assigned directly to your account. If you do not want this assignment with your Google profile, you have to log out before pressing the button. Google saves your data as a usage profile and uses it for the purposes of advertisement, market research and/or designing its website in accordance with demand. Specifically, this type of evaluation takes place (even for users who are not logged in) in order to deliver demand-based advertisement and to inform other social network users about your activities on our website. You have the right to object to the creation of a user profile. To exert this right, you must contact Google.

9.3 Additional information on the purpose and scope of the data collection and its processing by Google Maps can be found in the data protection statements of the provider. There, you also receive other information about your relevant rights and setting options for protecting your privacy: http://www.google.de/intl/de/policies/privacyGoogle also processes your personal data in the US and is subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework

10. Truma Newsletter

10.1. Registration for the Truma Newsletter

If you have registered for the Truma Newsletter, Truma uses your data specified during the registration for the purpose of sending the newsletter from Truma or from another company in the Truma Group. Your data will not be disclosed to any third parties. Only partner companies who are responsible for the technical handling of the Newsletter dispatch will be exempted. In these cases the scope of data transmitted will be limited to the required minimum.

10.2 Consent of the User to the Collection and Processing of Data

If you have ordered a Newsletter from Truma the wording of your declaration of consent reads as follows:

"Yes, I would like to receive the newsletter from Truma Gerätetechnik GmbH & Co. KG or another company in the Truma Group by e-mail. If I no longer wish to receive any more information, I can revoke this permission at any time."

We only use your data for the purpose of sending this newsletter."

To improve our Newsletter we use the e-mail analysis service of Emarsys, a service of Emarsys eMarketing Systems AG. For this purpose, we record your individual preferences as a reader by analyzing whether an e-mail had been opened and which links had been activated. An opening will be recorded by the Newsletter retrieving a specially prepared graphics file from the server. More information on the Privacy Policy of Emarsys is available at: https://www.emarsys.com/en/privacy-policy/

10.3. Cancellation of Truma Newsletter

Users who do no longer wish to be provided with our Newsletter or our advertising e-mails may click on the "unsubscribe here" link which is included in all e-mails sent by Truma.

11. Prize Competition

If you take part in a prize competition, we process the personal data provided by you for the conduct and performance of the prize competition. We forward this data to the company in the Truma Group that is running the contest.

If you win, Truma Gerätetechnik GmbH & Co. KG or the company in the Truma Group running the contest will contact you personally to get your prize to you. In the case of a Facebook contest, we will publish your profile name.

This personal data from the participant is processed in order for the respective company in the Truma Group to run the contest and for statistical purposes by Truma Gerätetechnik GmbH & Co. KG. The personal data stored will be erased if such data is no longer required for the performance of the prize competition or if the storage of such data is or becomes inadmissible for other legal reasons.

12. Controller

Truma Gerätetechnik GmbH & Co. KG 
Wernher-von-Braun-Strasse 12 
85640 Putzbrunn
Phone +49 89 4617-0 
Facsimile +49 89 4617-2116 
E-mail: info@truma.com

Data Protection Officer:
Alexander Bugl
Bugl & Kollegen GmbH
Sedanstrasse 7
93055 Regensburg
Phone +49 941 630 49 789
E-mail: kontakt@buglkollegen.de