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Data protection policy

Protection of your privacy is important to us. For this reason, please note the following information about data protection in conjunction with the use of our website www.plus-europe.com.

1. Name and contact details of the individual responsible for processing

This data protection policy applies to data processed by PLUS Europe GmbH, Werftstr. 23, 40549 Düsseldorf, Germany, legally represented by the CEO Mikiko Horioka, phone: +49 211 522857 0, fax: +49 211 522857 29, email: info@plus-corporation.com.

Our data protection officer is Klaus Weyers. You can contact him as follows: Phone +49 173 5325758, email klaus.weyers@plus-corporation.com.

2. Collection and storage of personal data and the manner and purpose of their use

Use of our website is normally possible without you having to provide personal data.

a) When visiting our website

When you access our website at www.plus-europe.com, the browser you use on your end device automatically sends information to our website server. This information is stored temporarily in what is known as a log file. The following information is collected in the process without your intervention and stored until it is automatically deleted.

- IP address of the accessing computer

- Date and time of access

- Name and URL of the retrieved file

- The website from which access is made (referrer URL)

- The browser used and if applicable your computer’s operating system as well as the name of your access provider.

We use the specific data for the following purposes.

- To ensure a smooth connection with our website

- To ensure convenient use of our website

- To evaluate system security and stability and

- For other administrative purposes

The legal basis for data processing is Art. 6 para. 1 clause 1 lit. f GDPR. Our legitimate interest is derived from the purposes of data collection listed above. In no case do we use the data collected for the purpose of establishing connections with you as an individual.

In addition, we use cookies and analysis services when you visit our website. You can find out more about these under points 4 and 5 of this data protection policy.

b) When using our contact form

If you have any questions, we offer you the option of contacting us using a form provided on our website. In this case, you need to provide a valid email address, so we know who the request has come from and can respond to it. You can submit any further information as you wish.

Data processing for the purpose of making contact with us is in accordance with Art. 6 para. 1 clause 1 lit. a GDPR based on your voluntarily submitted consent.

The personal data we collect for the use of this contact form are deleted after the request you have submitted has been dealt with.

3. Disclosure of data

No transfer of your personal data to third parties will occur for purposes other than those listed below.

We only share your personal data with third parties if

- You have given your explicit consent to do so in accordance with Art. 6 para. 1 clause 1 lit. a GDPR

- Disclosure is required in accordance with Art. 6 para. 1 clause 1 lit. f GDPR to assert, exercise or defend legal claims and there is no reason to assume that you have a predominant interest worthy of protection in not disclosing your data

- In the event that there is a statutory obligation to disclose in accordance with Art. 6 para. 1 clause 1 lit. c GDPR and

- This is legally permissible and required for the fulfillment of contractual relationships with you in accordance with Art. 6 para. 1 clause 1 lit. b GDPR.

4. Cookies

We use cookies on our website. These are small files that your browser automatically creates and are stored on your end device (laptop, tablet, smartphone, etc.), when you visit our site. Cookies do no damage to your device, they do not contain viruses, trojans or other malicious software.

Information is stored in the cookie, which is created in connection with the specific device used in each case. However, this does not mean that we become immediately aware of your identity.

Our use of cookies serves on the one hand to make your use of our services more convenient for you. This is why we use what are known as session cookies in order to recognize that you have already visited individual pages on our website. These are automatically deleted after you leave our site.

In addition, to enhance user-friendliness, we also use temporary cookies, which are stored on your device for a specified period. If you visit our site again to take advantage of our services, we automatically recognize that you have visited us previously and the inputs and settings you have made, so you do not have to enter them again.

Secondly, we use cookies to keep a statistical record of how our website is used and in order to evaluate how we optimize our services for you (see point 5). These cookies enable us to automatically recognize that you have already visited us when you visit us again. These cookies are automatically deleted after a predefined period.

The data processed by cookies are required for the purposes designated in order to safeguard our legitimate interests and those of third parties in accordance with Art. 6 para. 1 clause 1 lit. f GDPR.

Most browsers accept cookies automatically. However, you can configure your browser in such a way that no cookies are stored on your computer or a warning appears before a new cookie is created. However, complete deactivation of cookies may result in you being unable to use all the features on our website.

5. Analysis tools

The tracking measures we use listed below are deployed in accordance with Art. 6 para. 1 clause 1 lit. f GDPR. By using applicable tracking measures, we wish to ensure that the setup of our website is as required and optimized on an ongoing basis. Secondly, we use tracking measures to record statistics to evaluate the use of our website and for the purpose of optimizing our services for you. These interests should be regarded as legitimate within the meaning of the above provision.

Please refer to the appropriate tracking tools for the data processing purposes and data categories in each case.

a) Google Analytics

For the purpose of customizing and ongoing optimization of our sites, we use Google Analytics, a web analysis service of Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”). In this regard, pseudonymized usage profiles are created and cookies used (see point 4). The information produced by the cookie about your use of this website such as

• Browser type/version
• Operating system used
• Referrer URL (the previously used page)
• Hostname of the accessing computer (IP address)
• Time of server request

is transmitted to a Google server in the US and stored there. The information is used to evaluate usage of the website, to compile reports about website activities and to provide further services associated with use of the site and the Internet for the purposes of market research and the tailored design of these websites. This information may also be transmitted to third parties if this is required by law or if third parties are commissioned to process the data. Under no circumstances will your IP address be merged with other data by Google. The IP addresses are anonymized so that allocating them is not possible (IP masking).

You can prevent the installation of cookies via the appropriate setting in your browser software; however, we wish to point out that in this case not all the features of this website can be used in their entirety.

In addition, you can prevent the data generated by the cookie and related to your use of the website from being collected (including your IP address) and Google from processing the data by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent data being collected by Google Analytics by clicking on this link. This activates an opt-out cookie, which prevents your data from being collected when you visit this website in the future. The opt-out cookie applies only to this browser and only to our website and is stored on your device. If you delete the cookies in this browser, you have to activate the opt-out cookie again.

For more information about data protection in connection with Google Analytics, see the Google Analytics help page (https://support.google.com/analytics/answer/6004245?hl=de).

b) Google Adwords conversion tracking

In order to collect statistics on the use of our website and to evaluate them for the purpose of optimizing our website for you, we also use Google conversion tracking. In this case, Google Adwords places a cookie (see point 4) on your computer, if you have reached our website via a Google ad.

These cookies become invalid after 30 days and are not used for personal identification. If the user visits certain pages on an Adwords client’s website and the cookie has not yet expired, Google and the client can recognize that the user has clicked on the ad and been redirected to this page.

Every Adwords client is given a different cookie. Cookies can therefore not be tracked via the web pages of Adwords clients. The information gathered using the conversion cookie is used to generate conversion statistics for Adwords clients who have opted for conversion tracking. The Adwords clients are notified of the total number of users who have clicked on the ad and are redirected to a page equipped with a conversion tracking tag. However, they do not receive any information that allows users to be identified personally.

If you do not wish to take part in the tracking process, you can refuse to have the required cookie placed – such as via a browser setting that disables the automatic placing of cookies in general. You can also disable cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com. Google’s data privacy policy for conversion tracking can be found here (https://services.google.com/sitestats/de.html).

7. The rights of those concerned

You have the right:

- in accordance with Art. 15 GDPR to request information about your personal data we have processed. In particular, you may request information about the purposes of processing, the category of personal data, the categories of recipients of the personal data, to whom your data have been or are disclosed, the scheduled storage period, the existence of a right to rectification, deletion, restriction on processing or objection, the existence of a right to lodge a complaint, the origin of the data if we did not collect them, as well as the existence of an automated decision-making process including profiling and, where appropriate, meaningful information about their details;

- to request in accordance with Art. 16 GDPR the immediate rectification of incorrect or completion of personal data stored with us;

- to request in accordance with Art. 17 GDPR the deletion of your personal data stored with us, unless processing is required to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;

- to request in accordance with Art. 18 GDPR the restriction of processing of your personal data, if you dispute the correctness of the data, the processing is unlawful but you reject deletion thereof and we no longer require the data but you require the data to assert, exercise or defend legal claims or you have lodged an objection to processing in accordance with Art. 21 GDPR;

- to receive in accordance with Art. 20 GDPR your personal data, which you have provided to us, in a structured, standardized and machine-readable format or transfer thereof to another responsible individual;

- to revoke in accordance with Art. 7 para. 3 GDPR your consent once given to us at any time. The result of this is that we are no longer permitted to continue with the data processing based on this consent in the future and

- to complain in accordance with Art. 77 GDPR to a supervisory authority. In this case, you may normally contact the supervisory authority at your usual place of residence or workplace or our office.

7. Right of objection

If your personal data are processed based on legitimate interests in accordance with Art. 6 para. 1 clause 1 lit. f GDPR, you have the right in accordance with Art. 21 GDPR to lodge an objection to the processing of your personal data, if there are reasons for this that arise from your particular situation or the objection is to direct mail advertising. In the latter case, you have a general right of objection, which we shall implement without specifying any particular situation.

If you wish to exercise your right to revocation or objection, simply send an email to klaus.weyers@plus-corporation.com.

8. Data security

When you visit our website, we use the common SSL method (secure socket layer) in conjunction with the highest encryption level that is supported by your browser. This is normally 256-bit encryption. If your browser does not support 256-bit encryption, we resort to 128-bit v3 technology instead. Whether an individual page on our website is sent encrypted can be identified by the closed illustration of the key or lock symbol in the lower status bar of your browser.

We also make use of appropriate technical and organizational security measures in order to protect your data from random or willful manipulation, partial or total loss, destruction, or from unauthorized access by third parties. Our security measures are subject to ongoing improvement in line with technological developments.

9. Updates and changes to this data protection policy

This data protection policy is currently valid as at May 2018.

Due to the ongoing development of our website and services on it or based on modified legal or official provisions, it may be necessary to change this data protection policy. You can access and print out the current data protection policy on the website at www.plus-europe.com at any time.

If you have any further questions about dealing with personal data, you are welcome to contact our data protection officer, whose contact details appear above.

10. Use of our legal notice company details

The use of our contact details published in the context of our legal notice obligations by third parties to transmit not explicitly requested advertising and information material is hereby expressly refused. The operators of the sites reserve the right to take specific legal action in the event of any unsolicited transmission of advertising material, such as spam emails.

Status: May 2018