Privacy Policy

(May 2018)

This Privacy Policy (“Policy”) informs you about the personal data we collect when you use our services offered on our website http://www.neffos.com/ (“Website”).

Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.

1. Controller

TP-Link Corporation Limited (“TP-Link”, “we”, “our”) is controller in accordance with the General Data Protection Regulation (GDPR) as well as further applicable data protection laws.

2. Processing of Personal Data / Purpose of Processing

2.1 When Visiting our Website

The provider of the Website automatically collects and stores information that your browser automatically transmits to us in "server log files". These are:

- Browser type and browser version

 - Operating system used

- Referrer URL

- Host name of the accessing computer

- Time of the server request

- IP address

These data will not be combined with data from other sources.

The basis for data processing is Art. 6 (1) (f) DSGVO which allows the processing of data on prevailing legitimate interest of the controller. Our legitimate interest is to ensure unimpeded and trouble-free access to our Website.

For further information on the processing by cookies and tools of third party providers see Sections 3 ff. below.

The hosting of the Website and our services offered is carried out by an external service provider on our behalf. Your data will be stored on protected servers outside the EU (i.e. in the USA). Access is only possible to a few specially authorised persons who are involved with the technical, commercial or editorial support of the servers. The transfer outside the EU is safeguarded by appropriate measures in accordance with the GDPR.

2.2 When Subscribing to Our Newsletter/Information E-Mails

If you have given your consent, we will send you a newsletter/information at irregular intervals to inform you about news on our products and services as well as on the products and services of our affiliated companies.

For this we need your e-mail address. You can unsubscribe from the newsletter at any time by clicking on the corresponding link at the end of the e-mail. You can also revoke this consent at any time with effect for the future by e-mail to gdpr@tp-link.com.

The legal basis for sending the newsletter is Art. 6 (1) (a) GDPR.

Legal basis for the processing of your personal data is Art. (1) (b) GDPR. The personal data is necessary for the fulfilment of the agreement between you and us.

3. Cookies

3.1 General

We use cookies with our services. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you use our services. Cookies do no damage to your end device and do not contain viruses, Trojans or other malware.

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

The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our Website. These will be deleted automatically after leaving our site.

In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our Website and to evaluate it for you for the purpose of optimising our offer (see Section 3.2). These cookies enable us to automatically recognize when you return to our site that you have already been with us. These cookies are automatically deleted after a defined period of time.

The data processed by cookies is required for the above purposes in order to protect our legitimate interests and those of third parties (Art. 6 (1) (f) GDPR).

Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that you cannot use all functions of our Website.

3.2 Google Analytics

For the purpose of demand-oriented design and continuous optimization of our Website, we use Google Analytics, a web analysis service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google"). In this context, pseudonymized user profiles are created and cookies (see above) are used. The information generated by the cookie about your use of this Website such as

- browser type/version,

- operating system used,

- referrer URL (the previously visited page),

- host name of the accessing computer (IP address),

- time of the server request,

are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the Website, to compile reports on the Website activities and to provide further services associated with the use of the Website and the Internet for the purposes of market research and demand-oriented design of these Internet pages. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of the company. Under no circumstances will your IP address be merged with other data from Google. The IP addresses are anonymized so that an assignment is not possible.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website.

You can also prevent the collection of data generated by the cookie and related to your use of the Website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on this link. An opt-out cookie is set to prevent future collection of your data when you visit this Website. The opt-out cookie is only valid in this browser and only for our Website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

Further information on data protection in connection with Google Analytics can be found in the Google Analytics Help (https://support.google.com/analytics/answer/6004245?hl=en).

4. Google Tag Manager

This website uses Google Tag Manager. Google Tag Manager is a solution operated by Google that allows marketed website tags to be managed using an interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, this setting will remain in place for all tracking tags implemented with Google Tag Manager.

5. YouTube

On our Website you can watch videos that are integrated via plugin from YouTube (a Google company). As soon as you visit a web page of our offer, on which such a YouTube plugin is merged, a connection to the servers of YouTube is established. Data transmitted to YouTube include your IP address or which page of our online offer you are currently visiting.

If you are logged in to YouTube at the same time as your YouTube account when you visit one of our Website, YouTube may associate your surfing behaviour with your YouTube user profile. You can prevent such data processing by logging out of your YouTube account before visiting our Website.

On our web pages, the "privacy enhanced mode" for YouTube videos is activated. Only when you play the videos, the above described connection to the servers of the provider is established.

As this is the service of a third party, we have no influence on the processing of such data by YouTube. The purpose and scope of data collection and the further processing and use of the data by YouTube or Google as well as your rights and setting options for the protection of your privacy can be found in the relevant information on data protection at https://www.google.de/intl/de/policies/privacy/.

6. Border Data Transfers

Your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards than your country of residence. Please note, that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to keep up an adequate level of data protection also when sharing your personal data with such countries.

7. Security

We have implemented measures, including SSL or TLS encryption, designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

8. No requirement to provide personal data

The provision of your personal data will generally be voluntarily and there is no statutory nor contractual obligation to provide your personal data. We generally do not contractually require provision of your personal data; but note that in any event non-provision of personal data might exclude you from using some of our services or parts thereof.

9. Data Retention

We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this Policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements. In case we maintain a user account, your data will be stored for the duration such account remains active. In case of consent, your personal data will be at the latest deleted without undue delay after withdrawal of such consent.

10. Your Rights

You have the right, at any time

- without giving reasons according to Art. 15 GDPR to request information about your data stored with us. With the exception of any connection fees charged by your provider, you will not incur any costs as a result of the enquiry;

- to have the data corrected in accordance with Art. 16 GDPR;

- to have the data deleted in accordance with Art. 17 GDPR;

- to have the data blocked in accordance with Art. 18 GDPR;

- to object to the processing for sending the newsletter according to Art. 21 (2) GDPR;

- to object to other forms of processing of your personal data in accordance with Art. 21 (1) GDPR;

- to revoke any consent to the collection and use of data given to us in accordance with Art. 7 (3) GDPR;

- to receive your personal data in a machine-readable format and to transmit them to another person responsible in accordance with Art. 20 GDPR;

- lodge an appeal with a supervisory authority in accordance with Art. 77 GDPR, without prejudice to any other administrative or judicial remedy.

11. Contact

If you have any questions that this policy could not answer, or if you require further information on a particular point, please do not hesitate to contact us at any time. You can reach us as follows under the above address or by writing an e-mail to our Data Protection Officer (gdpr@tp-link.com).