Privacy Policy

1. Data Protection at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data Collection on this Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the „Notice concerning the responsible party“ section of this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This can be, for example, data that you enter in a contact form.

Other data is collected automatically or after you have given your consent when you visit the website through our IT systems. This is primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure the error-free provision of the website. Other data can be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right to receive information free of charge at any time about the origin, recipient, and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time for this purpose and for further questions on the subject of data protection.

Analysis Tools and Third-Party Tools

When you visit this website, your surfing behavior can be statistically evaluated. This is done primarily with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

2. Hosting

We host the content of our website with the following provider:

All-Inkl

The provider is ALL-INKL.COM – Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany (hereinafter All-Inkl). For details, please see the All-Inkl privacy policy: https://all-inkl.com/datenschutzinformationen/.

The use of All-Inkl is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable presentation of our website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25 (1) TTDSG (German Telecommunications Telemedia Data Protection Act), insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g., device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

3. General Information and Mandatory Disclosures

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data are collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We would like to point out that data transmission over the Internet (e.g., when communicating by e-mail) can have security gaps. Complete protection of data from access by third parties is not possible.

Notice Concerning the Responsible Party

The responsible party for data processing on this website is:

Surply GmbH Liefergasse 5 40213 Düsseldorf, Germany

Phone: +49 211 5424 9410 Email: info@surply.de

The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, email addresses, or similar).

Storage Duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General Information on the Legal Basis for Data Processing on this Website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data according to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g., via device fingerprinting), the data processing is additionally based on Section 25 (1) TTDSG. This consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if they are required for the fulfillment of a legal obligation on the basis of Art. 6(1)(c) GDPR. The data processing can also be based on our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA ARE PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with a Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to have data which we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another responsible party, this will only be done to the extent technically feasible.

Information, Erasure, and Rectification

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient, and the purpose of the data processing and, if applicable, a right to rectification or erasure of this data. You can contact us at any time for this purpose and for further questions on the subject of personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.
If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

SSL/TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from „http://“ to „https://“, and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Data Collection on this Website

Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, if your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this was requested; the consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your inquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Inquiry by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent.

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Emailing of Offers and Information to Business Customers

a) Purpose of data processing

We use the email addresses of our existing business customers and partners to inform them about new, relevant offers of surplus food raw materials as well as important company information. This communication channel is a central part of our business relationship and serves to initiate and process commercial transactions.

b) Legal basis

The processing of email addresses for sending our offer information is based on our legitimate interest in maintaining the business relationship and in direct advertising for our products and services (Art. 6(1)(f) GDPR). Our legitimate interest is to inform our contractual partners about suitable business opportunities and thus to promote mutual business success.

If the sending takes place within the scope of a specific contract initiation or fulfillment, the legal basis is Art. 6(1)(b) GDPR.

You can object to the use of your email address for this purpose at any time.

c) Use of the shipping service provider SendGrid

For the dispatch and analysis of our emails, we use the „SendGrid“ service from the provider Twilio Inc., 101 Spear Street, Ste 500, San Francisco, CA, 94105, USA.

SendGrid is a service with which, among other things, the dispatch of emails can be organized and analyzed. The data you enter for the purpose of receiving emails (e.g., email address, name) is stored on SendGrid’s servers in the USA.

We have concluded a Data Processing Addendum (DPA) with SendGrid. This is a contract required by data protection law, which ensures that SendGrid processes the data of our customers only according to our instructions and in compliance with the GDPR.

The data transfer to the USA is based on the EU-U.S. Data Privacy Framework (DPF). Twilio Inc. (SendGrid) is certified under the DPF, which ensures an adequate level of data protection for the data transfer.

d) Performance measurement

The emails sent via SendGrid contain a so-called „web beacon“ (tracking pixel). This is a pixel-sized file that is retrieved from the server of the shipping service provider when the email is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are collected.

This information is used for the technical improvement of the services and for statistical analysis. The statistical surveys also include determining whether the emails are opened, when they are opened, and which links are clicked. This analysis of performance measurement is based on our legitimate interest (Art. 6(1)(f) GDPR) in optimizing our offer and measuring the effectiveness of our communication.

5. Plugins and Tools

Google Fonts (Local Hosting)

This site uses so-called Google Fonts, which are provided by Google, for the uniform display of fonts. The Google Fonts are installed locally. A connection to Google servers does not take place.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

6. Call Summaries

Nature and Purpose of Processing: For the efficient and high-quality documentation of business agreements, telephone calls with us are briefly processed digitally. The temporary storage of the audio file, which is a technical requirement of VoIP telephony, is used to create a transcript via a service provider (AssemblyAI) and to generate a summary of business-relevant points using AI. Immediately thereafter, the original audio file and the full transcript are permanently deleted. Only the pseudonymized summary is stored.

Legal Basis: The processing is based on our legitimate interest (Art. 6 Para. 1 lit. f GDPR) in efficient and complete documentation to ensure our service quality and to avoid business risks.

Recipients: For transcription, we use the service provider AssemblyAI as a data processor. Data processing takes place exclusively on servers within the EU. A Data Processing Agreement (DPA) in accordance with Art. 28 GDPR is in place.

Storage Duration: Audio recordings and full transcripts are only stored temporarily for the duration of the analysis process (a few minutes) and are then immediately deleted. The created summary is subject to statutory retention periods.

Right to Object: You have the right to object to this processing at any time (Art. 21 GDPR). An informal objection, e.g., by email, is sufficient. We will then immediately cease processing for your contact and place them on an internal blocklist.