Privacy Policy of winkler NOW

Section 1 Information about the collection of personal data

(1) We, Christian Winkler GmbH & Co KG, Leitzstraße 47, 70469 Stuttgart (hereinafter "winkler", "we", "us", "our"), provide you with a mobile app (hereinafter "winkler NOW") in addition to our online offer. You can download this app to your mobile device (Android/iOS) or use it in the web app. This document gives you information about the collection of personal data when you use our mobile app.

(2) Personal data means all data that can be related to you personally, e.g., name, address, email addresses, user behavior.

(3) The responsible party, in accordance with Section 4 (7) of the EU General Data Protection Regulation (GDPR), is Christian Winkler GmbH & Co. KG, Leitzstraße 47, 70469 Stuttgart, Germany. For more information, please see:

(4) You can reach our data protection officer at: Email:, Postal address Erich Zimmermann c/o ZiDa-Datenschutz GmbH, Waldhofer Str. 102, 69123 Heidelberg, Germany, Phone: +49 621 3069 6731.

Section 2 Your rights

(1) Regarding your personal data, you have the following rights with us
•    Right to information,
•    Right to correction or deletion,
•    Right to restriction of handling,
•    Right to object to the handling,
•    Right to data portability.

(2) You also have the right to file a complaint with a data protection supervisory authority about how your personal data is handled in our company.

Section 3 Download of the app

When you download the mobile app, the required information is sent to the app store: in particular, the user name, email address and customer number of your account, time of download, payment information and individual device identification number. We have no influence on this data collection and are not responsible for it. We handle the data only as far as it is necessary for downloading the mobile app to your mobile device.

Section 4 Registration and login

You need to register in order to use the app. If you already have login details for our online shop, you can use them. During the registration process, you can enter login details (email address and password of your choice) and provide the information requested on the electronic registration form, such as your name and title. If you register for a company that already has access to winkler NOW or our online shop, we also collect the customer number and the postal code of the company's registered office. If you create a new account for a company, we collect its name, address, business field and phone number. We handle this data in order to implement the user contract concluded with you (legal basis Section 6 (1) p. 1 lit. b) GDPR) and, if necessary, to check the accuracy of your information (including its updates) (legal basis Section 6 (1) p. 1 lit. b) GDPR).

Section 5 Automated collection of usage data

(1) When you want to use our mobile app, we collect the following data. This data is technically required so that we can offer you the functions of our mobile app and to ensure stability and security:
•    IP address,
•    Date and time of the request,
•    Time zone difference from Greenwich Mean Time (GMT),
•    Content of the request (specific page),
•    Access status/HTTP status code,
•    Duration of the response to the request.

(2) In addition, we also record the number and type (text, image or audio) of messages sent, the use of the search function and search terms, when a customer request was resolved and when the response took a very long time. The purpose of this handling is to evaluate and improve how the app works and communicates with you. This data is pseudonymized. This data is only evaluated on the basis of assigning it to a user group (customer or employee of winkler).

(3) The legal basis for handling is according to Section 1 and Section 2 is Section 6 (1) p. 1 lit. f) GDPR. It is in our legitimate interest to offer you the features of our mobile app, ensure stability and security, and evaluate and improve how the app works and communicates with you. This requires collecting the above-mentioned data. When doing this, we respect your interests (particularly your privacy) by pseudonymizing the data, especially in the case of Section 2, storing the data only for the time span required by Section 8 and limiting the collection to necessary categories of data. You have the right to object to this handling. For more information on objections, please see Section 7 (3).

Section 6 Tracking

To improve winkler NOW, we also use the Google Analytics for Firebase service provided by Google, which is a web analytics service provided by Google LLC, 1600 Amphitheater Parkway, Mountainview, California 94043, USA ("Google"). Google collects and stores user data on our behalf (e.g., which equipment and which operating system you use, the average session duration, country, gender, confirmation of the shopping cart, product search, calling up training courses, number of barcode scans started, number of barcode scans performed) and give us the ability to evaluate these. The information about your use of winkler NOW is sent with a shortened IP address to Google, USA, and stored there. For more information on how the IP address is shortened by Google, please see: For cases in which personal data is transferred to the USA, Google has agreed to adhere to the EU-US Privacy Shield, The legal basis for data handling is our legitimate interest (Section 6 (1) lit. f) GDPR). It is in our legitimate interest to evaluate and improve the stability and usage of our app. The collected information enables us to analyze and solve problems with the app. This requires collecting the above-mentioned data. In doing this, we respect your interests (particularly your privacy) by limiting the collection of data to what is necessary for the stated purposes.

You have the right to object to the handling of your data. You can send this objection to For more information on objections, please see Section 7 (3). For more information about Google Analytics for Firebase, please contact: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 686 5660. User terms:, Privacy policy:

Section 7 Legal basis

(1) We handle your personal data if this is required in order to offer you the full range of functions of winkler NOW (e.g., answering your inquiries) or to fulfill other services based on the user contract signed with us. The legal basis for handling data in this respect is Section 6 (1) lit. b) GDPR.

(2) If you have given your consent to the handling of personal data for certain purposes, the legitimacy of this handling is given on the basis of your consent (Section 6 (1) lit a) GDPR). A given consent can be revoked at any time. You can send your revocation to  Handling that took place before the revocation is not affected by this.

(3) In addition, to the extent that data handling is required for the protection of our legitimate interests or the legitimate interests of third parties, we collect and process your personal data in order to protect these legitimate interests. The legal basis for data handling in this respect is Section 6 (1) lit. f) GDPR. In such cases, you have the right to object to the handling of your data. You can send this objection to If you file an objection, we will no longer handle the personal data unless there are compelling legitimate grounds for handling it that override your interests, rights and freedoms or unless handling it serves to assert, exercise or defend legal claims.

Section 8 Duration of storage

(1) We will only store your data for as long as the specific purpose of the storage requires, unless you have given us your consent or we have a legitimate interest in continuing to handle the data. In such cases, we will handle your data until you revoke your consent or until you object to our legitimate interests.

(2) In cases where data handling is required in order to execute and process a contract, including the defense against and enforcement of civil law claims within the relevant limitation periods, data shall be stored on the basis of the relevant limitation periods. Due to Sections 195 ff. German Civil Code (Bürgerliches Gesetzbuch) the limitation periods can be up to thirty years; the regular limitation period is three years.

(3) Notwithstanding the above, supervisory, commercial and tax law requirements require us to store your address, payment and order data for a duration of five to ten years. In order to avoid violating legal regulations or losing the possibility of enforcing or defending ourselves against a claim, we reserve the right to delete the data only after expiration of the last period that legitimizes the data storage.

Section 9 Transfer to third parties

(1) If you have shared personal data with us, this data will never be passed on to third parties. Data will only be passed on
•    within the scope of your consent,
•    within the scope of processing your inquiries, your orders and the use of our services to commissioned subcontractors, who will only receive the necessary data in order to execute this order and use it for the intended purpose,
•    within the scope of order handling according to the statutory provisions to service providers bound by instructions,
•    within the scope of fulfilling legal obligations to bodies entitled to receive information.

(2) Data will only be sent to third countries (countries outside the European Economic Area – EEA) if this is required in order to fulfill your orders, if it is mandatory by law or if you have given us your consent.

Section 10 No automated decision making

As a rule, in accordance with Article 22 GDPR, we do not use fully automated decision-making when establishing and implementing our business relationship with you. If we do use these procedures in individual cases, we will inform you about this separately if this is required by law.

Section 11 Obligation to consent or to provide data

In conjunction with using winkler NOW, you only have to provide the personal data that is required in order to establish, implement and terminate the relationship of use or that we are legally required to collect. As a rule, without this data, we will either have to refuse to establish a user relationship or we will no longer be able to maintain an existing relationship of use and may have to terminate it.

Section 12 Adjusting the privacy policy

This Privacy Policy may require updating from time to time, for example, when new technologies are introduced or new features are implemented. We reserve the right to change or amend this Privacy Policy at any time. We will inform you about any corresponding changes.

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