Data Privacy Statement
This data privacy statement explains our processing of your personal data in connection with your use of our website and your related rights.
1. Entity responsible for data processing
(referred to in the following as ‘(data) controller’ or ‘we’)
Kikkoman Trading Europe GmbH
Managing Directors: Taku Otsuka, Masahiro Kobayashi
Theodorstraße 180
40472 Düsseldorf
Germany
Phone +49 (0) 211 / 5 37 59 40
Fax +49 (0) 211 / 5 37 95 55
E-Mail info@kikkoman.eu
2. Data protection officer
We have designated a data protection officer that you may contact with questions and enquiries about your personal data at any time via the following contact details:
Enobyte GmbH
Augustenstraße 49
80333 Munich
Germany
E-Mail: dpo@enobyte.com
Web: https://enobyte.com/en/contact
3. Personal data, purpose of processing and legal basis
We process personal data (“Data”) on our website to operate a website with information about our services and about us.
Generally, personal data is processed on our website if necessary
- to enable you to access and use the website (legal basis: Article 6 (1) f) GDPR);
- to maintain website security (legal basis: Article 6 (1) f) GDPR);
- where you have given your consent, to analyse your use of our website, improve the user experience on our website and/or advertise our services (legal basis: Article 6 (1) a GDPR)
- to use the features offered on the website, e.g. the contact form, recipe bookmarking (legal basis: Article 6 (1) f) GDPR), recipe subscription (legal basis: Article 6 (1) a) GDPR)
- to enter into or perform a contract (legal basis: Article 6 (1) b) GDPR) and/or
- to comply with a legal obligation (such as fiscal law requirements; legal basis: Article 6 (1) c) GDPR in conjunction with the relevant legal requirement).
You can find more detailed information about data processing under each of the following headers.
a. Access data / Server log files
When you visit our website, the servers automatically save server log file information sent by your browser. This information includes:
- Name of the website being accessed
- File name
- Date and time of access
- Transmitted data volume
- Successful access message
- Browser type and version
- User’s operating system
- Referrer URL (URL of the previously visited website)
- IP address of the computer accessing the website and provider
Our website is hosted by Hetzner Online GmbH, Industriestraße 25, 91710 Gunzenhausen, Germany, with whom we have concluded a data processing agreement.
Temporary storage of the IP address by the system is necessary to display website content on your device. The information is used exclusively to maintain the technical operation of the servers and the network and ensure its security. We store server log files for 7 days. The legal basis is our legitimate interest to provide the website in a secure manner, Article 6 (1) f) GDPR).
b. Cookies
Our website uses cookies. Cookies are small text files which are placed on your terminal and stored in your browser.
Cookies that are required to provide the website and the use of such features as you have requested in a secure manner (necessary cookies) are stored and the relevant personal data is processed based on Article 6 (1) f) of the GDPR, unless another legal basis is specified. We have a legitimate interest in the use and storage of necessary cookies for the technically error-free provision of our services.
Cookies are also used to document your consent to the use of cookies and to provide the services listed under the following letters. You can find a full overview of the cookies that we use and further information about third party providers, duration of use, consent and opt-out possibilities here or by clicking on the small symbol of a shield in the bottom left corner of our website.
For example, when you bookmark a recipe on our website, a cookie is used to store the information about the recipes you have bookmarked. In these processes, therefore, information is stored in cookies to allow us to provide our website functions that you have requested to use. The legal basis for the associated processing of personal data is Article 6 (1) f) GDPR. We have a legitimate interest in providing you with these features if you request their use.
Cookies are also used to analyse your use of our website, show relevant advertisements to users, to optimise campaign performance reports and to prevent users from seeing the same advertisements more than once. The legal basis for this is your consent (Article 6 (1) a) GDPR).
Consent can be withdrawn at any time with future effect via our cookie banner. You can also change your browser settings so that it blocks certain sites’ cookies, or blocks all cookies, or deletes cookies when the browser is closed. Some website functions, such as recipe bookmarking, may become unavailable if you block all cookies.
c. Contact
When you send us an e-mail enquiry or a message via the contact form, the information contained in the message and your contact details (especially your name, your e-mail address, the subject line, and date of your message) are processed by us to deal with the enquiry and any follow-up correspondence.
We delete contact data in general after we have answered your request, though we might have a legal obligation to archive data relating to certain transactions for at least six years (section 257 of the German Commercial Code, HGB) or ten years (section 147 of the German Fiscal Code, AO). This can also apply to the content of contact enquiries and e-mails.
d. Newsletter, recipe subscription
If you subscribe to our recipe service by entering your e-mail address, we will send you weekly recipe ideas with our products. You can find examples of the recipes here: https://www.kikkoman.eu/recipes
If you subscribe to our newsletter, we will send you information about the Kikkoman brand and new products and promotions.
When you provide us your e-mail address to subscribe to the service, we send a message to the e-mail address you provided requesting you to confirm your subscription by clicking on a link ("double opt-in"). This is necessary to prevent an unauthorised person from subscribing to the service with your e-mail address. The double opt-in process is logged as proof of subscription for 3 years. We store the time of subscription, the time of confirmation and your IP address. Afterwards we will use your e-mail address to send you the recipes. The e-mails are sent via inxmail, a service offered by Inxmail GmbH, Wentzinger Str. 17, 79106 Freiburg, Germany. We have concluded a data processing agreement witht the provider.
To measure the effectiveness of our newsletter and recipe subscription service, we analyse the open-rate and click-rate of our subscribers. Every newsletter contains a small file that alerts our servers if you have viewed the newsletter. All links contained within the newsletter are also customized. Each link is unique so that if you click it, we are alerted that one new subscriber has opened one of our links. We only receive aggregated reports of this activitiy and cannot connect your use of the newsletter back to you. We also analyse the e-mail clients used, in order to better optimize our newsletters for these.
The legal basis for the processing of your personal data to send you the newsletter and to analyse the use of the newsletter is your consent (Article 6 (1) a) GDPR).
You can also revoke your consent with future effect at any time by unsubscribing from the recipe service or the newsletter by clicking on the link that is included in every e-mail we send you, or by contacting us with the details above. Finally, we offer a web-form where you can unsubscribe. When you unsubscribe, we will delete your data without undue delay.
e. Google Tag Manager
Google Tag Manager is a service provided by Google Ireland Ltd., which allows us to manage website tools via a single interface.
Google Tag Manager itself does not process personal data; however, it is used to load further tools and contents (e.g., Google Ads Enhanced Conversions) which may process personal data, such as hashed email addresses, provided that the user has given their explicit consent.
f. Google Ads
We use the Google Ads network provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Ads allows us to advertise our products and campaigns to internet users. If you click any such advertisement, Google will place cookies in your browser to store your interest and to measure the click and conversion rate. Google will store your IP address, information about your browser and language settings, the date and time of your click, which advert you have clicked on and which website you are referred to.
We receive statistics on the conversion rate from Google. We have concluded a data processing agreement with Google for this processing of your personal data.
We do not use personalised advertisements, and do not provide your personal data to Google for advertisement purposes. Google Ads determines which users will see our advertisements.
For further information on Google Ads and on how Google processes your data, please refer to this policy: https://policies.google.com/technologies/ads
Google pledges to anonymise your personal data after 18 months.
For onwards transfers from Google to Google Inc. in the USA, Google Inc. has self-certified under the E.U.-U.S. Data Privacy Framework.
g. Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) to analyse the use of the website and optimise its design. We have concluded a data processing agreement with Google. In this contract, Google undertakes to protect our users’ data, to process it in compliance with data protection laws on our behalf and not to pass it on to third parties unless on our instructions. Google partly transmits information to Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. For this transfer, Google has concluded standard contractual clauses (SCC) as approved by the EU Commission.
Google Analytics uses cookies which are saved on your computer so that your use of the website can be analysed and linked back by Google Analytics to you and to our website. (Please refer to section b. above). Information about your use of this website is transferred to a Google server in the USA and stored there. The IP address sent by your browser as part of Google Analytics is not combined with other Google data.
We have set a cookie expiry time and data deletion time of 14 months.
IP anonymization is activated on our website. Your IP address is truncated by Google within the Member States of the European Union and in other states that are parties to the Agreement on the European Economic Area. The full IP address will only be transmitted to a Google server in the USA and truncated there in specific, exceptional cases. We have instructed Google to use this information to evaluate your use of the website, to compile reports about website activities and to provide other services relating to website and Internet usage. The legal basis for this is your consent (Article 6 (1) a) GDPR).
You can also download and install the browser add-on available at the following link (http://tools.google.com/dlpage/gaoptout?hl=en) to prevent data from being collected and transmitted to Google and prevent Google from processing this data.
You can find further information about the terms and conditions of use and the Google privacy policy at www.google.com/analytics/terms/gb.html and policies.google.com.
h. Meta Pixel / Facebook Pixel
This website uses Facebook Pixel to analyse your use of our website. The service is provided by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland (‘Facebook’).
Facebook Pixel uses your device settings, IP address, and a Unique Identifier stored in a cookie (“_fbp”) to analyse which websites you visit to discern your interests.
This data is shared with Facebook, which uses this data to create profiles of website audiences that might be interested in our products. This allows us to retarget advertisements, better tailor advertisements to new audiences and understand the use of our website of users across devices.
Our legal basis for setting the cookie and the connected data processing is your consent (Article 6 (1) a) GDPR).
Meta Ireland transfers data to Meta Platforms, Inc., in 1 Meta Way Menlo Park, CA, 94025-1444, USA. This transfer is based on Standard Contractual Clauses or on other transfer instruments. More details on the data transfers can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum/update
i. Integration of third-party services and content
(Google Maps, RSS feeds, graphics from other websites, YouTube videos etc.)
Third party content may be published on this website, such as YouTube videos, Google Maps, RSS feeds or graphics from other websites. In these cases, the third-party providers of the contant may become aware of your IP address and the website you visited. Third party providers can store the IP address, e.g. for statistical purposes. You can prevent any data from being transmitted by deactivating JavaScript in your browser or with one of the following opt-out options. In that case no third-party content or services will be displayed to you.
The following third-party services and content may be integrated in our websites:
- Google Maps from third party provider Google
- Data privacy statement: policies.google.com/privacy and www.google.com/intl/en_en/help/terms_maps.html
- Opt-out to analysis for advertisement purposes: www.google.com/settings/ads/
- YouTube videos from third party provider Google (embedded without cookies)
- Data privacy statement: policies.google.com/privacy and support.google.com/youtube/answer/7671399
- Opt-out to analysis for advertisement purposes: www.google.com/settings/ads/
- Vimeo videos from third party provider Vimeo.com, Inc., 330 West 34 Street, New York 10001, USA
- Data privacy statement: https://vimeo.com/privacy
- We have concluded SCC with Vimeo, which you can see here: https://www.vimeo.axdraft.com/
The legal basis for the processing of your personal data in connection with this embedded content is Article 6 (1) f) GDPR. We have a legitimate interest in embedding this content in our website to improve the user experience.
j. Entering into raffles
From time to time, we might conduct raffles or sweepstakes via various channels. If you decide to enter, we may ask you to provide certain personal data, as laid out in the respective terms and conditions. We will use this data to draw or select a winner, and send you the price. We conduct these raffles or sweepstakes as a promotion of our company and products and our processing of your personal data, should you enter one of these, is based on Article 6 (1) f) GDPR, our legitimate interest to host promotional activities.
k. Our social media profiles on Facebook and Instagram
We do not use any social media plugins on www.kikkoman.eu. We only use hyperlinks to our social media pages. Therefore, when you visit our website, no personal data is forwarded to the social media platforms.
However, if you visit the social media platforms or our profiles on those platforms, the following applies.
The website with URL www.facebook.com is operated by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland (‘Facebook’). When you visit our profile on this platform, we may process certain personal data about you when you contact us directly. The legal basis for this data processing is Art. 6 (1) f) GDPR. We have a legitimate interest in communicating with you via this platform.
Moreover, Facebook may process personal data about you. Facebook is itself responsible for such data processing. To learn more about the purpose and extent of data collection, processing and the use of this data by Facebook, as well as your rights and the settings available for the protection of your privacy, please read Facebook's privacy policy at www.facebook.com/about/privacy/
To delineate our respective responsibilities, we have concluded a contract on data processing with Facebook which you can find here: https://www.facebook.com/legal/terms/page_controller_addendum
If you are a Facebook member and do not want Facebook to collect data about you via our website, or to link this with your data stored on Facebook, you need to log off from Facebook before going to our site on Facebook and delete the Facebook cookies. Further settings and opt-outs to the use of data for promotional purposes exist on Facebook: www.facebook.com/settings. Or you can visit the US website www.aboutads.info/choices/ or the EU website www.youronlinechoices.com
The website with URL www.instagram.com is operated by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland (‘Instagram’). When you visit our profile on this platform, we may process certain personal data about you when you contact us directly. The legal basis for this data processing is Art. 6 (1) f) GDPR. We have a legitimate interest in communicating with you via this platform.
Moreover, Instagram may process personal data about you. Instagram is itself responsible for such data processing. To learn more about the purpose and extent of data collection, processing and the use of this data by Instagram as well as all your relevant rights and the settings available for the protection of your privacy, please see Instagram’s privacy policy at: help.instagram.com/155833707900388
To delineate our respective responsibilities, we have concluded a contract on data processing with Instagram which you can find here: https://www.facebook.com/legal/terms/page_controller_addendum
If you are an Instagram member and do not want Instagram to collect data about you via our website, or to link this with your data stored on Instagram, you need to log off from Instagram before going to our website and delete the Instagram cookies. Further settings and opt-outs to the use of data for promotional purposes exist in the Instagram profile settings: help.instagram.com/284802804971822
4. Recipients of personal data
Personal data is transmitted to the following categories of recipients: processors, i.e. certain technical service providers whom we grant access to personal data in order to make use of their services and on whom we impose contractual obligations to process such personal data only according to our instructions, software developers, server hosters, newsletter services, customer support and web analysis service providers. Please refer to the specific sections above and/or reach out to us if you require more specific information.
We may also share your data, where necessary, with specialized advisors or public entities if this necessary to avail ourselves of their services or specific public functions, for example lawyers, auditors, accountants, or courts, public agencies, and law enforcement.
5. Duration of storage
We delete personal data immediately after the purpose for which it was stored has been served.
We also implement annual reviews to ascertain whether data can be deleted. Data is deleted when the purpose and legal basis for processing no longer applies, and we are not under any legal obligation to archive it.
6. Provision of personal data and rights of data subjects
You are not legally required to provide your personal data to us. However, it may be necessary to conclude a contract with us or use our website functions. If you decide not to provide your personal data, it may not be possible to offer a contract or function on the website.
There is no automated decision making or profiling on the website.
At any time, you have the right to request
- access to,
- rectification (including supplementation) of or
- erasure of your personal data, and to
- impose restrictions on data processing and to data portability.
You also have the right to object to the processing of your data where it is based on our legitimate interest, Article 6 (1) f) GDPR.
If you have granted your consent to the processing of personal data, you have the right to withdraw your consent at any time with future effect.
If you believe that processing your personal data contravenes data protection laws, you have the right to lodge a complaint with a competent supervisory authority.
