Privacy Policy
We thank you for your interest in our company. The management of PAW-GUARDIAN places great importance on data protection. In general, the use of the PAW-GUARDIAN website is possible without entering any personal data. However, the processing of personal data may become necessary if a data subject wishes to make use of specific services offered by our company via our website. If the processing of personal data is necessary and there is no legal basis for such processing, we generally seek the consent of the data subject.
The processing of personal data—such as the name, address, email address, or telephone number of a data subject—is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to PAW-GUARDIAN. With this privacy policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this privacy policy informs data subjects of the rights to which they are entitled.
As the data controller, PAW-GUARDIAN has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, such as by telephone.
• Definitions
The privacy policy of PAW-GUARDIAN is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy must be easily readable and understandable by the general public, as well as by our customers and business partners. Therefore, we would first like to explain the terminology used. In this privacy policy, we use, among others, the following terms:
1. a) Personal Data
Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
1. b) Data Subject
The data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
1. c) Processing
Processing is any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
1. d) Restriction of Processing
Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future.
1. e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of such data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
1. f) Pseudonymization
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
1. g) Controller or Data Controller
The controller or data controller is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
1. h) Processor
A processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
1. i) Recipient
A recipient is a natural or legal person, public authority, agency, or another body to whom the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
1. j) Third Party
A third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
1. k) Consent
Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Name and Address of the Data Controller
The controller for the purposes of the General Data Protection Regulation, as well as other applicable data protection laws and regulations within the European Union, is:
Ecom Paul
28 route de l’Anse Vata, 98800 Trianon, New Caledonia
Email: hello@paw-guardian.com
Website: https://paw-guardian.com
Data Protection Officer’s Address
The Data Protection Officer of the data controller is:
Ecom Paul
28 route de l’Anse Vata, 98800 Trianon, New Caledonia
Email: hello@paw-guardian.com
Website: https://paw-guardian.com
For any questions or suggestions regarding data protection, each data subject may contact our Data Protection Officer directly and at any time.
• Recipient
Within PAW-GUARDIAN, access to personal data is strictly limited to entities that require it to provide their services. Customer and user data is only shared with subcontractors so that they can install and integrate their products for the user. Our subcontractors are contractually bound to comply with data protection requirements and confidentiality.
Data of interested parties, customers, and users may also be shared with other service providers supporting Home Solutions NV, for example, in the following categories:
• IT services
• Logistics
• Printing services
• Archiving
• Postal and telecommunications
• Consulting, legal advice, audits, and consulting
• Compliance and data protection
• Marketing
• Communication and customer service
These service providers are also contractually obligated to respect data protection and confidentiality requirements.
• Cookies
The PAW-GUARDIAN website uses cookies. Cookies are text files that are placed and stored on your computer system. Many websites and servers use cookies. Many cookies contain a unique identifier called a cookie ID. A cookie ID is a unique identifier consisting of a string of characters through which websites and servers can be assigned to the specific browser in which the cookie was stored.
This allows visited websites and servers to distinguish the individual browser of the data subject from other Internet browsers that may contain different cookies. A specific browser can thus be recognized and identified by its unique cookie ID.
The use of cookies enables PAW-GUARDIAN to provide users of this website with more user-friendly services that would not be possible without the use of cookies. Through cookies, information and offers on our website can be optimized with the user in mind.
As already mentioned, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our site. For example, a website user who uses cookies does not have to re-enter their login details each time they visit, because this is handled by the website and the cookie stored on the user's computer system.
Another example is the shopping cart in an online store. The online store remembers the item a customer has placed in the virtual cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through the appropriate settings of the Internet browser used and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. However, if the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
• Collection of General Data and Information
The PAW-GUARDIAN website collects a series of general data and information each time the website is accessed by a data subject or an automated system. These general data and information are stored in the server log files.
The information collected may include:
(1) the types and versions of browsers used,
(2) the operating system used by the accessing system,
(3) the website from which the accessing system reaches our website (referrers),
(4) the sub-pages visited via an accessing system,
(5) the date and time of access to the website,
(6) an Internet protocol address (IP address),
(7) the Internet service provider of the accessing system, and
(8) any other similar data and information that may be used in the event of attacks on our IT systems.
When using these general data and information, PAW-GUARDIAN does not draw any conclusions about the data subject.
This information is needed to:
(1) properly deliver the content of our website,
(2) optimize the content and advertising of our website,
(3) ensure the long-term viability of our IT systems and website technology, and
(4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack.
Therefore, PAW-GUARDIAN analyzes anonymously collected data and information statistically, with the aim of enhancing data protection and data security in our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
• Registration on Our Website
Data subjects have the opportunity to register on the data controller’s website by providing personal data. The personal data transmitted to the controller is determined by the input fields used during the registration process.
The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may request transfer to one or more processors—such as a parcel delivery service—which will also use the personal data exclusively for an internal purpose attributable to the controller.
Registering on the controller’s website also stores the IP address assigned by the Internet service provider (ISP) to the data subject, as well as the date and time of the registration. This data is stored because it is the only way to prevent misuse of our services and, if necessary, to investigate committed offenses. In this respect, the storage of this data is necessary to protect the controller.
This data is not generally transmitted to third parties unless there is a legal obligation to transmit the data or the transmission serves the aim of criminal prosecution.
The registration of the data subject, which involves the voluntary provision of personal data, enables the controller to offer content or services to the data subject that may only be offered to registered users.
Registered individuals are free to modify their personal data specified during the registration at any time or to have them completely deleted from the data records of the controller.
The controller shall, at any time upon request, provide information to each data subject about what personal data is stored about the data subject. Furthermore, the controller shall correct or erase personal data at the request or indication of the data subject, as long as there are no statutory storage obligations.
In this regard, the data protection officer named in this privacy policy, as well as all employees of the controller, are available to the data subject as contact persons.
• Newsletter Subscription
The PAW-GUARDIAN website offers users the opportunity to subscribe to the company’s newsletter. The personal data transmitted to the data controller when subscribing to the newsletter is determined by the input form used for this purpose.
PAW-GUARDIAN regularly informs its customers and business partners about company offers through a newsletter. As a general rule, the newsletter can only be received by the data subject if (1) the person has a valid email address and (2) they register for the newsletter.
For legal reasons, a confirmation email will be sent to the email address provided by the data subject as part of the double opt-in process. This confirmation email is intended to verify whether the owner of the email address has authorized the subscription.
When subscribing to the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP), as well as the date and time of registration. This data is stored as a safeguard in case of misuse of the email address and serves as legal protection for the data controller.
The data collected during the newsletter registration is used exclusively for sending our newsletter. Subscribers may also be informed by email when necessary for the newsletter service or in case of changes to the service or technical conditions.
No personal data collected for the newsletter will be passed on to third parties. The subscription may be cancelled at any time by the data subject. Consent to store personal data can be revoked at any time. Each newsletter contains a link allowing for withdrawal of consent. It is also possible to unsubscribe directly via the website or by contacting the data controller through any other means.
• Newsletter Tracking
The PAW-GUARDIAN newsletters contain so-called tracking pixels. A tracking pixel is a tiny graphic embedded in emails sent in HTML format to enable log file recording and analysis. This allows for statistical analysis of marketing campaign success.
Using the embedded tracking pixel, PAW-GUARDIAN can see if and when an email was opened by a recipient and which links were clicked.
The data collected via tracking pixels is used to optimize newsletter delivery and adapt future content to the recipient’s interests. This data is not shared with third parties. Consent may be withdrawn at any time through the double opt-in procedure. Upon withdrawal, the data will be deleted. Unsubscribing from the newsletter is automatically considered as a withdrawal of consent.
• Contact via Website
Due to legal requirements, the PAW-GUARDIAN website contains information that enables quick electronic contact with our company, including a general email address.
If a data subject contacts the controller via email or a contact form, the personal data voluntarily provided is automatically stored for the purpose of processing the request or for contacting the individual. This data is not shared with third parties.
• Automatic Deletion and Blocking of Personal Data
The data controller processes and stores the personal data of the data subject only for the time necessary to achieve the purpose of storage, or as required by applicable laws or regulations.
If the purpose for storing the data is no longer applicable, or if a storage period prescribed by law expires, the data will be blocked or deleted in accordance with legal requirements.
• Rights of the Data Subject
2. a) Right to Confirmation
Each data subject has the right, granted by European regulations, to obtain confirmation from the controller as to whether personal data concerning them is being processed.
If a data subject wishes to exercise this right of confirmation, they may contact our Data Protection Officer or another staff member at any time.
2. b) Right of Access
Every data subject has the right to obtain, at any time and free of charge, information about their stored personal data from the controller, as well as a copy of that information.
The right of access includes the following information:
• The purposes of processing
• The categories of personal data concerned
• The recipients or categories of recipients to whom the data has been or will be disclosed—especially recipients in third countries or international organizations
• Where possible, the expected period of data storage, or, if not possible, the criteria used to determine that period
• The existence of the right to request rectification or deletion of personal data, or restriction of processing, or the right to object to processing
• The right to lodge a complaint with a supervisory authority
• Where the personal data is not collected directly from the data subject: any available information about its source
• The existence of automated decision-making, including profiling, under Article 22(1) and (4) GDPR, and—at least in such cases—meaningful information about the logic involved and the intended consequences for the data subject
Additionally, the data subject has the right to be informed whether personal data is transferred to a third country or international organization. If so, the data subject has the right to be informed about the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, they may contact our Data Protection Officer or another member of the controller’s staff at any time.
1.c) Right to Rectification
Every data subject has the right, as granted by the European legislator, to request the immediate rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject also has the right to have incomplete personal data completed—including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, they may contact our Data Protection Officer or another staff member of the controller at any time.
1.d) Right to Erasure ("Right to be Forgotten")
Every data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, provided that the processing is no longer necessary and that one of the following grounds applies:
• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The data subject withdraws the consent on which the processing is based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects pursuant to Art. 21(2) GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data were collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.
If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by PAW-GUARDIAN, they may contact our Data Protection Officer or another staff member of the controller at any time. The Data Protection Officer or another staff member will ensure the erasure request is fulfilled promptly.
If PAW-GUARDIAN has made personal data public and is obligated as the controller to erase the personal data pursuant to Art. 17(1) GDPR, PAW-GUARDIAN shall take reasonable steps—including technical measures—considering available technology and the cost of implementation, to inform other controllers processing the personal data that the data subject has requested the erasure of any links to, or copy or replication of, those personal data.
1.e) Right to Restriction of Processing
Every data subject has the right to obtain from the controller restriction of processing where one of the following applies:
• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
• The data subject has objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of these conditions is met and a data subject wishes to request the restriction of the processing of personal data stored by PAW-GUARDIAN, they may contact our Data Protection Officer or another member of staff at any time.
1.f) Right to Data Portability
Every data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance, where:
• The processing is based on consent pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR, or on a contract pursuant to Art. 6(1)(b) GDPR; and
• The processing is carried out by automated means; and
• The processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
In exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject also has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where it does not adversely affect the rights and freedoms of others.
To exercise this right, the data subject may contact PAW-GUARDIAN’s Data Protection Officer or another staff member at any time.
1.g) Right to Object
Every data subject has the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
In case of objection, PAW-GUARDIAN shall no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.
Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to such processing, including profiling related to direct marketing.
If the data subject objects to processing for direct marketing purposes, PAW-GUARDIAN shall no longer process the personal data for such purposes.
In addition, where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) GDPR, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact PAW-GUARDIAN’s Data Protection Officer or another staff member at any time. The data subject is also free to exercise their right to object using automated means with technical specifications, as per Directive 2002/58/EC.
1.h) Automated Individual Decision-Making, Including Profiling
Every data subject has the right not to be subject to a decision based solely on automated processing—including profiling—which produces legal effects concerning them or significantly affects them, unless the decision:
(1) is necessary for entering into, or the performance of, a contract between the data subject and the controller; or
(2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests; or
(3) is based on the data subject’s explicit consent.
If the decision is necessary for the performance of a contract or based on explicit consent, PAW-GUARDIAN shall implement suitable measures to safeguard the data subject’s rights and freedoms, including the right to obtain human intervention, to express their point of view, and to contest the decision.
If the data subject wishes to exercise the rights concerning automated decision-making, they may contact our Data Protection Officer or another staff member at any time.
1.i) Right to Withdraw Data Protection Consent
Every data subject has the right, granted by the European legislator, to withdraw consent to the processing of their personal data at any time.
If a data subject wishes to exercise their right to withdraw consent, they may contact our Data Protection Officer or any other staff member of the controller at any time.
Data Protection for Applications and Recruitment Procedures
The controller collects and processes personal data of applicants for the purpose of handling the recruitment process. The processing may also be carried out electronically, particularly if an applicant submits their application by email or via a web form on the website.
If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of managing the employment relationship in accordance with legal requirements.
If no employment contract is concluded, the application data will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interest of the controller justifies retention.
A legitimate interest could be, for example, evidence required in proceedings under the General Equal Treatment Act (AGG).
Privacy Policy on the Use of Affilinet
The controller has integrated components of Affilinet on this website. Affilinet is a German affiliate network that provides affiliate marketing services.
Affiliate marketing is an online-based form of sales that enables commercial website operators (advertisers) to display advertising—usually via commission-based banners or links—on third-party websites (affiliates or publishers).
The advertiser provides advertising material via the affiliate network, which is then integrated by affiliates on their own websites or via other channels, such as keyword advertising or email marketing.
The operating company of Affilinet is Affilinet GmbH, Sapporobogen 6–8, 80637 Munich, Germany.
Affilinet places a cookie on the data subject’s computer system. As previously mentioned, cookies are explained above. The tracking cookie from Affilinet does not store personal data. Only the affiliate ID (the referring partner), the order number of the visitor, and the clicked advertising material are recorded.
These data are used to process commission payments between the advertiser and the affiliate via the Affilinet network.
As mentioned earlier, the data subject may at any time prevent the installation of cookies through a setting in their internet browser and thus permanently deny cookie storage. Previously stored Affilinet cookies can also be deleted at any time via a browser or other software programs.
Affilinet’s privacy policy is available at:
https://www.awin.com/fr/cgv/privacy-policy
Privacy Policy for the Use of Facebook
The controller has integrated components of Facebook on this website. Facebook is a social network—a web-based platform that enables users to communicate and interact with each other in a virtual space.
Users can create private profiles, upload photos, connect with friends, share opinions, experiences, and more. The operator of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA.
If the data subject resides outside the United States or Canada, the controller responsible for personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Each time a page of this website that includes a Facebook plugin is accessed, the browser automatically downloads the corresponding Facebook component from Facebook’s servers.
A list of all Facebook plugins can be found here:
https://developers.facebook.com/docs/plugins/?locale=fr_FR
During this process, Facebook receives information about which specific subpage of our website the data subject visited. If the person is simultaneously logged into Facebook, Facebook detects this information and associates it with their Facebook account.
If the user clicks on a Facebook button integrated into the website—such as the "Like" button—or submits a comment, Facebook links this data to the user’s personal Facebook account.
Facebook is informed of each visit to our website by the data subject if they are logged into Facebook at the time of the visit—regardless of whether they interact with the plugin.
If the data subject does not want Facebook to collect this information, they should log out of their Facebook account before visiting our site.
Facebook’s current data policy, available at:
https://www.facebook.com/about/privacy/
...provides details on data collection, processing, and use by Facebook, as well as settings available to protect the user’s privacy.
Additionally, third-party applications are available that can block the transmission of data to Facebook.
Privacy Policy for the Use of Google Analytics (with Anonymization Function)
The controller has integrated components of Google Analytics (with the anonymization function) on this website. Google Analytics is a web analytics service. Web analytics involves the collection, gathering, and analysis of data about the behavior of website visitors. A web analytics service collects, among other things, data about the website from which a data subject came (the "referrer"), which subpages were visited, how often, and for how long.
Web analysis is primarily used to optimize a website and to carry out a cost-benefit analysis of online advertising.
The company operating Google Analytics is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.
For web analysis via Google Analytics, the controller uses the application "_gat._anonymizeIp". This application ensures that the IP address of the data subject is shortened and anonymized by Google when the access to the website comes from a member state of the European Union or from another contracting state to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze traffic on our website. Google uses the data and information collected to evaluate the use of our website, to compile online reports on website activity, and to provide other services related to website and internet usage.
Google Analytics sets a cookie on the data subject's device. Cookies have already been explained above. By placing the cookie, Google is able to analyze how our website is used.
Each time one of the pages of this website, which contains a Google Analytics component, is accessed, the browser on the data subject’s device automatically transmits data to Google for the purpose of online analysis. During this process, Google receives personal data such as the IP address of the user, which it uses to track the origin of visitors and clicks and to calculate commissions.
The cookie stores personal information such as the time of access, the location from which the access was made, and the frequency of visits to our website by the data subject.
With each visit to our site, such personal data—including the IP address of the device used—are transferred to Google in the United States and stored there. Google may share this data with third parties.
As stated above, the data subject can prevent the setting of cookies through a setting in their browser and thus permanently deny the setting of cookies. This also applies to cookies set by Google. Additionally, cookies already set can be deleted at any time via a browser or other software programs.
The data subject also has the possibility to object to and prevent the collection of data generated by Google Analytics and related to the use of this website, as well as the processing of this data by Google. For this, the data subject must download and install the browser add-on available at the following link:
👉 https://tools.google.com/dlpage/gaoptout
This browser add-on uses JavaScript to inform Google Analytics that no data and information about website visits may be transmitted to Google Analytics. Google considers the installation of the browser add-on as an objection.
If the data subject’s device is later deleted, formatted, or reinstalled, the browser add-on must be reinstalled to disable Google Analytics. If the browser add-on was uninstalled or disabled by the user or another person within their area of influence, it can be reinstalled or reactivated.
Further information and Google's current privacy policy can be found at:
👉 https://policies.google.com/privacy
and
👉 https://www.google.com/analytics/terms/fr.html
Detailed information about Google Analytics is available at:
👉 https://www.google.com/intl/fr/analytics/