Privacy Policy

This Privacy Policy applies to the websites truma.com, truma.com/serviceblog, dealer.truma.com, oem.truma.com and go2-camping.com as well as to the Truma App for iOS and Android, as they are operated by Truma Gerätetechnik GmbH & Co. KG ("Truma“). This declaration concerning the data protection only applies to these websites and their sub-pages as well as to the apps. Thus, it does not cover websites of third parties to which Truma refers by means of links.

1. Collection and Use of Data

On our websites and apps we collect personal data only if this is required for the purpose defined by you and/or if you provide us with such data on consent. Personal data means any information relating to an identified or identifiable natural person.

1.1 Usage data

When visiting our websites we collect usage data (for example, which browser is used, access times, visited product site etc.) which we are evaluating for statistical purposes, for optimizing our offer and for guaranteeing system security.

1.2 Website

If you visit our website we will collect personal data, in particular, for the purpose of contacting you at your request, processing online applications, mobile customer service requests or sending you the Newsletter. The data will only be used for the purposes disclosed. To help operate our website, we work with Edelweiss72 GmbH, Agentur für interaktive Medien as well as with Ray Sono AG, which can both access personal data as part of their services. As part of the online application, your personal data is collected and stored by our service provider perbit Software GmbH.

1.3 Dealer and OEM Portal

If you intend to use our Dealer and OEM Portal, you have to register for this purpose. In doing so, we will collect the following data about you. Please note that there are mandatory fields which have to be completed in order to process your request. They are marked with an asterisk. If you also make entries in the other fields, then they will be used for statistical purposes and for the improvement of our offer.

• Customer number
• Name of company
• Addition to name of company (optional)
• Title
• First and last name
• Address
• Language
• E-mail address
• Phone (optional)

We collect the data for the purpose of processing orders and delivering products. Products will be delivered by an external service provider. As a registered dealer and OEM, you may also generate your own forms and, for example, change your address data in the portal.

We will use the data collected for the purpose of processing your order and delivering the products.

1.4 Truma app

If you use our app we will collect usage data of the app (for example, the device data, the firmware version, the application version of the app and the usage data of the app, such as preference settings, functions used, frequency and date of access, error reports). We will process such data for statistical purposes, to optimise our offer and to guarantee system security.

In the app you have the possibility to install a remote control for your Truma devices via Bluetooth or SMS. For this purpose, we collect and process the device data of your mobile phone as well as the device to be operated in order to be able to provide the service.

You have the option to download the instruction manual for your Truma devices by means of the app. We collect your user ID in order to assign it to the download. Additionally, you have the option to register for our newsletter using your e-mail address.

Some functions of this application use your current location. Your location is determined via the connection to WLAN networks, to mobile masts or using GPS. The data is used to offer you location-based services and not to find out your location. Shortly after you start using the application, you will be asked whether you wish to use these services during the current session. You have the option to save your decision on a permanent basis so that you do not get asked again. You can subsequently change this in your settings.

2. Use, Storage and Deletion of Cookies

Cookies are small text files which are stored on your end device. The purpose of these cookies is to control the Internet connection during your visit to our websites. We store the data collected by cookies separately from other files. We process such data exclusively for statistical purposes, for guaranteeing system security and for technical improvement. At the same time, these cookies enable us to optimize our offer in accordance with your needs. We will exclusively use session cookies. They remain on you terminal device only until you close your web browser. Thereafter, they will be deleted automatically. By changing the settings for your web browser, you may prevent the cookies from being saved on your end device.

3. Data Security

We protect your personal data against any risks connected with data processing, in particular, against unauthorised access, use or publication. For this purpose, we implement appropriate technical and organisational measures incorporating the latest technical advances. The data collected and obtained from you in a standard form on HTML-pages will be transferred in encrypted form (SSL – Secure Socket Layer) from your terminal device to our server.

4. Data Protection Rights

4.1 Right to withdraw: You are entitled to withdraw your consent given with regard to the processing of your personal data at any time with effect for the future. A withdrawal shall not affect the lawfulness of the processing of data on the basis of your consent until withdrawal of such consent.

4.2 Right of access: You are entitled to obtain information free of charge about the personal data stored. On your request, such information may also be provided by electronic means.

4.3 Rectification, erasure and restriction of data: You are entitled to request the rectification, erasure and restriction of your personal data. However, after erasure or blocking of your personal data, you can no longer use relevant services. Your right to erasure may be excluded by statutory retention requirements.

4.4 Data portability: You have the right that we provide you with data, which we are processing by automatic means and to the use of which you have given your consent, in machine-readable form or transfer such data to other controllers.

4.5 Assertion of rights: You may assert your rights by informal notification to Truma Gerätetechnik GmbH & Co. KG, Wernher-von-Braun-Strasse 12, 85640 Putzbrunn or by e-mail to info@truma.com.
If you have any complaints, you may also contact the competent data protection supervisory authority in Ansbach.

5. Disclosure of Data

Your personal data will not be disclosed unless Truma is legally obliged to such disclosure (e.g. request of an investigating authority) or authorised (e.g. within the scope of contract data processing). A transfer to third countries will only take place insofar as we expressly refer to such transfer and disclosure in this Privacy Policy. Upon disclosure and transfer of data, we will make sure that third parties comply with and observe a reasonable level of protection for personal data.

6. Erasure and Restriction of Data

Your data will be erased to the extent that the processing of your request has been terminated, you have withdrawn your consent to the processing or if the storage of your data is or becomes inadmissible for other legal reasons. Upon erasure or restriction of data, relevant services can no longer be used. If statutory retention requirements apply to your data, the data will instead be barred from any other use.

7. Tracking

7.1 Google Analytics

On the websites, data will be processed for marketing and optimisation purposes by the Google Analytics service, a web analysis service of Google Inc. ("Google").

Google Analytics uses cookies, i.e. text files which are stored on your computer and make an analysis of your use of the websites possible. The information on how you use the websites gathered by the cookies, as a rule, will be transferred to and stored on a Google server in the USA. You may prevent that by installing your browser in such a manner that no cookies are stored.

By activating IP anonymisation on the websites, your IP address will be truncated by Google beforehand within the Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be transferred to a Google server in the USA and truncated there.

We have concluded an appropriate contract concerning contract data processing with the provider. The transmission and transfer of data to the USA is in line with the required data protection level. The data protection level is safeguarded by Google's Privacy Shield Framework Licensing.
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

By order of the website operator, Google will use the processed information to evaluate the use of the website in order to compile reports concerning the website activities and to render further services associated with website use and Internet use vis-à-vis the website operator. The anonymised IP address transmitted by your browser within the scope of Google Analytics will not be merged with other Google data.

You can prevent cookies from being stored by selecting the appropriate setting in your browser software; however, we would like you to note that in this case you could be prevented from fully using all functions of this website. You can further prevent collection of the data generated by the cookies and referring to your use of the website (including your IP address) as well as the processing of such data by Google by downloading and installing the browser plugin available under the following link
http://tools.google.com/dlpage/gaoptout?hl=en

7.2 Google Tag Manager

Our website uses Google Tag Manager. Using this service, website tags can be managed via one interface. Google Tag Manager only implements tags. This means that no cookies are used and no personal data is collected. Google Tag Manager triggers other tags such as Google Analytics which, in turn, may collect data. However, Google Tag Manager does not access this data.

7.3 Pardot Services

We use Pardot Services, an analytics service provided by Salesforce.com, Inc., The Landmark @ One Market Street, San Francisco, CA 94105, USA. Pardot Services uses a “visitor cookie” to generate an identification number that is used to recognise the website visitor’s browser. The identification number is a generated numerical code that is meaningless outside Pardot Services. A “Pardot app session cookie” is also created on logging into the Pardot app. All cookies receive the generated numerical code only. In addition, we use Pardot for logins to our email service. Emails sent with the help of Pardot use tracking technologies. We use this data to find out what the recipients are interested in. To do this, Pardot registers whether our emails are opened and on which links the recipients click. We then use this information to improve the emails we send and the services we provide.

If you wish to stop Pardot tracking your information, you can do this via your browser settings or the appropriate browser extension. However, this may lead to certain restrictions to the functions and user-friendliness of our website.
 

8. Integration of YouTube and Vimeo videos

8.1 We have integrated YouTube and Vimeo videos on our website which are saved at https://www.YouTube.com and https://vimeo.com and which can be played directly from our website. These are all integrated in "extended data protection mode", i.e. so that no data about you as the user is transmitted to YouTube or Vimeo if you do not play the videos. Only if you play the videos will the data referred to in 8.2 be transmitted. We have no influence over this data transfer.

8.2 When you visit the website, YouTube and Vimeo are informed that you have called up the corresponding sub-page of our website. The following data will also be transmitted.

• 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
• Volume of data transferred in each case
• Website from which the request is received
• Browser
• Operating system and its interface
• Language and version of the browser software.

This data is transmitted regardless of whether YouTube or Vimeo provides a user account via which you are logged in or no user account exists. 
If you are logged in via Google, your data will be assigned directly to your account. If you do not wish data to be assigned to your YouTube profile, you must log out before activating the button. YouTube saves your data as a usage profile and uses it for the purposes of advertising, market research and/or the customised design of its website. This analysis is carried out (even for users who are not logged in) particularly in order to provide requirements-based advertising and inform other users of the social network about your activities on our website. You have the right to object to the creation of this user profile, whereby you must exercise this right with YouTube.

8.3 You can find further information about the purpose and scope of the data collection and the processing thereof by YouTube or Vimeo in this Privacy Policy. This Policy also provides more information about your rights and setting options for protecting your privacy: https://policies.google.com/privacy. Google also processes your personal data in the USA and complies with the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
Vimeo has the following Privacy Policy: https://vimeo.com/privacy
 

9. Integration of Google Maps

9.1 We use Google Maps on our website. This means that we can show you interactive maps directly on the website and it allows you to use the map function at your convenience.

9.2 When you visit the website, Google is informed that you have called up the corresponding sub-page of our website. The data specified under Section 8 of this Privacy Policy will also be transmitted. This is transmitted regardless of whether Google provides a user account via which you are logged in or whether no user account exists. If you are logged in via Google, your data will be assigned directly to your account. If you do not wish data to be assigned to your Google profile, you must log out before activating the button. Google saves your data as a usage profile and uses it for the purposes of advertising, market research and/or the customised design of its website. This analysis is carried out (even for users who are not logged in) particularly in order to provide requirements-based advertising and inform other users of the social network about your activities on our website. You have the right to object to the creation of this user profile, whereby you must exercise this right with Google.

9.3 You can find further information about the purpose and scope of the data collection and the processing thereof by Google Maps in the provider's privacy policies. These policies also provide more information about your rights regarding this topic and your setting options for protecting your privacy: https://policies.google.com/privacy Google also processes your personal data in the USA and complies with the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework
 

10. Use of the Facebook pixel, Facebook Custom Audience pixels and Facebook conversions

Because of our legitimate interests in the analysis, optimisation and economic operation of our website, the “Facebook pixel” by social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA or, if you are resident in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”) is used for these purposes on our website.

Facebook is certified under the Privacy Shield Agreement https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active and thus guarantees to comply with European data protection law.

The Facebook pixel allows Facebook to identify visitors to our website as a target group for particular Facebook ads. Accordingly, we use the Facebook pixel to display Facebook ads placed by us only to Facebook users who have also shown an interest in our website or who display certain characteristics (e.g., interests in certain topics or products determined by the websites visited), which we submit to Facebook ( “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads match users’ potential interests and are not annoying. The Facebook pixel additionally enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were directed to our website after clicking on a Facebook ad ( “conversion”).

The Facebook pixel is embedded by Facebook when you visit our website and can store a “cookie”, i.e. a small file, on your device. Your IP address is anonymised as soon as it is collected by the plug-in provider (Facebook). If you subsequently log in to Facebook or visit Facebook when logged in, the visit to our website will be noted in your profile. The data collected about you is anonymous to us and does not provide us with any information about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile can be made and used by Facebook as well as for our own market research and advertising purposes. We have no influence on the collected data and data processing operations, and are also unaware of the full scope of data collection, the purposes of processing and the storage periods. We are also not given any information about the deletion of the data collected by the plug-in provider.

If we transmit data to Facebook for comparison purposes, this data is encrypted locally in the browser and only then sent to Facebook via a secure https connection. This is done solely for the purpose of comparing it with the data similarly encrypted by Facebook.

You have the option of deactivating the collection of data for the purpose of personalised advertising. A cookie that permanently prevents the collection of data is then created, unless you deliberately delete this cookie in your browser or do so by using the “Delete all cookies” function. You may opt out of the collection of data again at any time. To set the cookie, please click here.

Facebook processes the data in accordance with the Facebook data usage policy. For general information about the displaying of Facebook ads, see Facebook’s data usage policy: https://www.facebook.com/policy.php. For in-depth information and details about the Facebook pixel and how it works, visit the Facebook Help section: https://www.facebook.com/business/help/651294705016616.

You may opt out of Facebook pixel data collection and the use of your information to display Facebook ads. To set what types of ads you are shown on Facebook, you can go to the relevant Facebook page and follow the instructions there about the settings for usage-based ads: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

You may also opt out of the use of cookies that measure reach and serve advertising purposes via the Network Advertising Initiative opt-out page https://optout.networkadvertising.org/ as well as via the US website https://www.aboutads.info/choices/ or the European website https://www.youronlinechoices.com/uk/your-ad-choices/.
 

11. Truma Newsletter

11.1 Registration for the Truma Newsletter

If you have signed up to the Truma Newsletter Truma shall use your data provided upon registration for the purpose of sending the newsletter from Truma or from another company in the Truma Group. Your data will not be disclosed to any third parties. Only partner companies which are responsible for the technical handling of the Newsletter dispatch will be exempted. In these cases the scope of data transmitted will be limited to the required minimum.

11.2 Consent of the user to the collection and processing of data

If you have ordered a Newsletter with Truma the wording of your declaration of consent reads as follows:

"Yes, I would like to receive the Truma Gerätetechnik GmbH & Co. KG newsletter and/or the newsletters of companies within the Truma Group by e-mail. If I do not want to receive any more information, I can simply revoke this consent at any time.“

We only use your data for the purpose of sending this newsletter."

To improve our Newsletter we are using the e-mail analysis service of Emarsys, a service of Emarsys eMarketing Systems AG. For this purpose we are recording your individual preferences as a reader by analyzing whether an e-mail had been opened and which links had been activated. An opening will be recorded by the Newsletter retrieving a specially prepared graphics file from the server. More information on the Privacy Policy of Emarsys is available at: https://www.emarsys.com/en/privacy-policy/

11.3 Cancellation of Truma newsletter

Users, who do no longer wish to be provided with our Newsletter or our advertising E-mails, click on the link "unsubscribe here" which is included in all e-mails sent by Truma.

12. Prize Competition

If you take part in a prize competition, we process the personal data provided by you for the conduct and performance of the prize competition. We will pass this data on to the company within the Truma Group that organises the competition.

In the event of a win, Truma Gerätetechnik GmbH & Co. KG or the company within the Truma Group responsible for the event will contact you personally to settle the winnings. In the case of a Facebook competition, we may publish your profile name.

The personal data of the participant will be processed by the company within the Truma Group organising the event for the conduct and performance of the competition as well as by Truma Gerätetechnik GmbH & Co. KG for statistical purposes. The personal data stored will be erased if such data is no longer required for the performance of the prize competition or if the storage of such data is or becomes inadmissible for other legal reasons.

13. Controller

Truma Gerätetechnik GmbH & Co. KG 
Wernher-von-Braun-Straße 12 
85640 Putzbrunn
Tel. +49 (0)89 4617-0 
Fax +49 (0)89 4617-2116 
E-Mail: info@truma.com

Data Protection Officer: 
Alexander Bugl
Bugl & Kollegen GmbH
Sedanstr. 7
93055 Regensburg
Tel. +49 (0)941 630 49 789
E-Mail: kontakt@buglkollegen.de