Privacy Policy
Effective Date: 22 August 2025
We are very delighted that you have shown interest in our enterprise. Data protection and privacy is of the highest priority within the r2p Group.
1. Important information and who we are
1. Important information and who we are
Privacy Policy
This privacy policy gives you information about how the r2p Group collects and uses your personal data through your use of this website, including any data you may provide when you register with us or purchase a product or service.
This policy explains how we collect use, disclose and protect your personal data when you visit our website, in accordance with:
- The UK General Data Protection Regulation (UK GDPR);
- The EU General Data Protection Regulation (EU GDPR); and
- The Data Protection Act 2018 (UK)
Controller
The r2p Group is made up of different legal entities, which includes r2p GmbH, r2p ApS and r2p UK Systems Limited.. This privacy policy is issued on behalf of the Group so when we mention, „we“, „us“ or „our“ in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO or us using the information set out in the contact details section (paragraph 9).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you interact with and use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals‘ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy for further details.How we use your personal data
7. Data protection for applications and the application procedures
You can apply to our company electronically, e.g. via e-mail or web forms. Please note that unencrypted e-mails will not be transmitted without access protection. Your details will be used for processing your application and deciding whether to establish an employment relationship. The legal basis is § 26 (1), (8) BDSG. Furthermore, your personal data may be processed insofar as this should be necessary for the defence of asserted legal claims against us arising from the application process. The legal basis for this is Art. 6 (1) lit. f GDPR. The stated purposes also constitute the legitimate interest in the processing.
Insofar as an employment relationship arises between you and us, we may, in accordance with § 26 (1) BDSG, further process the personal data already received from you for the purposes of the employment relationship if this is necessary for the implementation or termination of the employment relationship or for the exercise or fulfilment of the rights and obligations of the representation of the interests of employees resulting from a law or a collective agreement, a works agreement or a service agreement (collective agreement).
Your application data will not be processed beyond the described use.
Your personal data will be deleted after completion of the application process after 6 months at the latest, provided that no other legitimate interests on our part oppose deletion or you have not given us your consent for longer storage. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).
8. Data protection provisions about the application and use of YouTube (two-click option)
We use services from YouTube, LLC, 901 Cherry Ave, 94066 San Bruno, CA, USA, a subsidiary of Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA, on our website. For users who are habitually resident in the European Economic Area or Switzerland, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, is the data controller for your data.
We use a two-click solution to protect your personal data. When you call up a page in which a YouTube video is embedded, a connection to the YouTube servers is not established until you click on the „Confirm“ button. In this case, YouTube will set cookies and use your visit data for its own purposes. If you are logged in to YouTube at this time, the information about the videos you have viewed will be assigned to your member account with YouTube. You can prevent this by logging out of your member account before visiting our website.
Insofar as data is processed outside the European Economic Area (EEA) / the EU, where there is no level of data protection equivalent to the European standard, Google states that it uses standard contractual clauses.
Further information on YouTube’s data protection is provided by Google under the following link: Google Privacy Policy.
9. Legal basis for the processing
Art. 6 (1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Art. 6 (1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.
If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6 (1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) lit. d GDPR.
Finally, processing operations could be based on Art. 6 (1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
4. Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
| Purpose/use | Type of data | Legal basis and retention period |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identify (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business). |
Direct marketing
During the registration process on our website when your personal data is collected, you will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product/service warranty registration, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see r2p’s cookies policy.
5. International transfers
If your personal data is transferred outside the UK or European Economic Area (EEA), we will ensure it is protected by appropriate safeguards, such as:
- UK / EU adequacy decisions
- Standard Contractual Clauses (SCCs)
- Binding Corporate Rules
6. Data security
We have put in place appropriate technical, organisational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include secure hosting, encryption, firewalls and access controls. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data rentention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data and in some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
Under the UK and EU GDPR, you have the following rights in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a „subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us see Contact details (paragraph 9).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).
This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. Contact Details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact [our DPO] or us in the following ways:
Germany
r2p GmbH, Marie-Curie-Ring 31, 24941 Flensburg
Phone: +49 461 995 73-0
Email: Datenschutz@r2p.com
Denmark:
r2p ApS, Lundborgvej 10 8800 Viborg
Phone: +45 585 502 00
Email: databeskyttelse@r2p.com
United Kingdom:
r2p UK
Unit 1, Charlwood Court County Oak Way
Crawley, West Sussex,
RH11 7XA, United Kingdom
Phone: +44 1293 8873 08
Email: dataprotection.uk@r2p.com
10. Complaints
We take all privacy complaints seriously and will respond to your request as soon as possible.
If you are not satisfied with our response or believe that we are not processing your personal data in accordance with data protection laws, you have the right to lodge a compliant with your relevant supervisory authority;
In the United Kingdom:
Information Commissioner’s Office (ICO)
Website: https://ico.org.uk
Helpline: 0303 123 1113
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 5AF, United Kingdom
In the European Union:
If you reside in an EU member state, you can contact your local Data Protection Authority (DPA). A full list of national authorities is available at:
https://edpb.europa.eu/about-edpb/board/members_en
11. Changes to the privacy policy and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
We may update this privacy policy from time to time. Any changes will be posted on this page with an updated “Last Updated” date. We encourage you to review it regularly.
12. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
