How Palettenring processes personal data.

1Controller

The controller responsible for data processing is:

• Logistics Publishing Limited
• North Point Business Park
• New Mallow Road
• T23 AT2P Cork
• Ireland
• Managing Director: Olaf Oczkos
• Email: [email protected]
• Phone: +49 176 9741 9470
• Website: https://palettenring.de

Palettenring is intended exclusively for entrepreneurs, companies, merchants, and public-law entities. The processing of personal data therefore primarily concerns the contact persons of these companies acting in their professional capacity.

2Purpose of the platform

Palettenring is a B2B platform for companies from industry, trade, logistics, and the pallet sector.

The platform serves business initiation, the registration of interested parties, communication with potential members, and, at a later stage, the facilitation of direct transactions in the pallet sector, in particular EPAL Euro pallets.

As a rule, Palettenring does not become a contracting party to the transactions concluded between users; it provides the platform for contact initiation and communication.

3What data we process

Depending on how the platform is used, we may process the following categories of data in particular:

• surname, first name, and business contact details
• company, function, sector, and website
• email address and phone number
• WhatsApp phone number if users communicate with us via WhatsApp or wish to communicate via WhatsApp
• information on demand, offers, production quantities, procurement profile, or other information voluntarily submitted by users
• technical access data such as IP address, date and time of access, browser type, operating system, and pages accessed
• communication content if users send us messages by email, form, or WhatsApp
• date of the last sign-in or visit to your account (account security and information about relevant updates)

When reviewing prospects, members, and partners, we may also process the following data:

• information on creditworthiness, reliability, sector affiliation, delivery capability, and possible legal or reputational grounds for exclusion
• information from publicly accessible sources (for example commercial registers, company registers, company websites)
• information from specialized credit agencies or service providers where necessary for credit and risk assessment, such as details of company identity, legal form, VAT identification number, and register data

4Purposes of processing

We process personal data for the following purposes:

• handling inquiries and registrations
• reviewing and managing prospects, members, and business partners
• communication about Palettenring, especially via email, phone, and WhatsApp
• sending information about the platform, membership, waiting list, matching processes, and relevant B2B offers
• preparing and carrying out pre-contractual or contractual relationships
• improving the platform and ensuring technical operation
• fulfilling statutory retention and record-keeping obligations
• protecting against misuse, spam, fraud, and unauthorized use

In addition, we process data to carry out creditworthiness, reliability, and risk checks, to protect the integrity of the platform, to avoid reputational risks, and to decide whether prospects are admitted, blocked, or excluded as partners.

5Legal bases for processing

Processing is carried out on the basis of the GDPR, in particular:

• Art. 6(1)(b) GDPR where processing is necessary for pre-contractual measures or a contract
• Art. 6(1)(f) GDPR where we have a legitimate interest in B2B communication, platform operation, misuse prevention, and business development
• Art. 6(1)(a) GDPR where users expressly consent to a specific form of processing, in particular to receiving certain messages via WhatsApp
• Art. 6(1)(c) GDPR where legal obligations apply

Our legitimate interests within the meaning of Art. 6(1)(f) GDPR consist in particular of:

• communicating with the contact persons of our B2B customers
• preventing fraud, misuse, payment defaults, and other unlawful uses
• checking creditworthiness, reliability, and reputational risks relating to prospects and partners
• safeguarding the functionality and integrity of the platform

Where we use the data of contact persons within existing customer relationships to send information about our own similar offers, this is likewise based on our legitimate interests, and data subjects may object to such use at any time.

6Communication via WhatsApp

Palettenring may use WhatsApp to communicate with prospects, users, members, or business partners. This may take place in particular for the following purposes:

• confirming registrations or inquiries
• follow-up questions about the waiting list or membership
• information about the profile, matching process, or relevant platform features
• service, support, and transaction-related messages
• communication where users contact us via WhatsApp themselves

We send WhatsApp messages only where there has been a relevant contact request, inquiry, consent, or another legally permissible communication reason. Users may object to WhatsApp communication or withdraw consent at any time, for example by sending a message saying "STOP" or by emailing [email protected].

When WhatsApp is used, personal data such as phone number, profile information, message content, metadata, and technical information is processed by WhatsApp and Meta. Their own terms and privacy information also apply to that processing. Palettenring does not have full control over the data processing carried out by WhatsApp or Meta.

Depending on the configuration of the WhatsApp service used, data may be transferred to WhatsApp and Meta in countries outside the EU/EEA. Where possible, we base such transfers on appropriate safeguards (for example standard contractual clauses) or adequacy decisions. Further information can be found in the privacy information of WhatsApp and Meta.

If users do not want to communicate via WhatsApp, they can contact Palettenring at any time by email at [email protected].

7Sharing of data

Personal data is disclosed only where this is necessary for the stated purposes, where there is a legal obligation, where consent has been given, or where there is a legitimate interest. Recipients may include in particular:

• technical service providers, hosting providers, and IT service providers
• communication providers including WhatsApp and Meta where WhatsApp is used
• payment, tax, or accounting providers where necessary
• legal advisers, tax advisers, or public authorities where legally required
• potential business partners within the platform where this is necessary for an expressly requested introduction or contact

Personal data is not published or shared with third parties for advertising purposes without an appropriate legal basis or consent.

As part of creditworthiness and reliability checks, we may transfer personal data to, or obtain it from, specialized credit agencies or other service providers where this is necessary to assess credit and default risks or to prevent fraud and misuse. Where we rely on specific credit agencies, we will inform you separately about this or name them in an updated version of this Privacy Policy.

8International transfers

When service providers are used, especially WhatsApp, Meta, or technical infrastructure providers, personal data may be transferred to countries outside the European Union or the European Economic Area. Where required, this takes place on the basis of appropriate safeguards, especially standard contractual clauses, adequacy decisions, or other legally permitted mechanisms.

Users can obtain further information about the specific service providers used, the countries concerned, and the safeguards applied in each case on request or from the current version of this Privacy Policy.

9Storage period

We store personal data only for as long as necessary for the relevant purposes. Data from inquiries and registrations is deleted or restricted when it is no longer needed for processing and no statutory retention obligations apply. Contract and invoice data may be stored for longer due to statutory retention obligations.

WhatsApp communication is retained only as long as necessary to handle the matter, document the communication, or comply with legal obligations.

Data we receive as part of creditworthiness or reliability checks is stored only for as long as necessary to decide on the establishment or continuation of a business relationship and to document that decision, and is then deleted or anonymized unless statutory retention obligations apply.

10Cookies and technical data

The website may use cookies and similar technologies to provide core functions, ensure security, analyze website usage, or improve the user experience. Where cookies are not technically necessary, they are set only after consent.

Details on the nature, scope, purposes, and services used (for example analytics or marketing tools) in connection with cookies and similar technologies can be found in the cookie notice or the cookie banner on our website. There, users can also grant, manage, or withdraw their consent.

11Rights of data subjects

Under the GDPR, data subjects have the following rights in particular:

• right of access to processed personal data
• right to rectification of inaccurate data
• right to erasure
• right to restriction of processing
• right to data portability
• right to object to processing based on legitimate interests
• right to withdraw consent for the future
• right to lodge a complaint with a data protection supervisory authority

Requests can be sent to [email protected].

The data protection supervisory authority responsible for the seat of Logistics Publishing Limited is in particular the Irish Data Protection Commission ("Data Protection Commission", https://www.dataprotection.ie). However, data subjects may also contact the supervisory authority of their habitual residence or place of work.

12No obligation to use WhatsApp

Using WhatsApp is voluntary. Users can always contact Palettenring by email instead. Not using WhatsApp does not mean that an inquiry will not be processed.

13Changes to this Privacy Policy

We may update this Privacy Policy where technical, legal, or organizational changes require it. The current version is available at the URL published on the website.

Material changes that significantly affect the nature of the processing or the rights of data subjects will be communicated to users in an appropriate form (for example by email or a notice on the website).