I. Name and address of the responsible party

The responsible parties within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations are:

1.Römerturm Feinstpapier GmbH & Co. KG

Commercial Register
District Court of Cologne
HRA 17968 HRA / HRB 42 710
Managing Director:
Wolfgang Stemmer
Contact options:
Telephone number: +49 (0) 2273 95106-0
Fax number: +49 (0) 2273 95106-66
Postal address:
Römerturm Feinstpapier GmbH & Co. KG
Kerpener Straße 154
50170 Kerpen
VAT
VAT ID number: DE 123506 967

2.MAY+SPIES GMBH

Commercial Register
Registration Court Düren
HRB 2925
Managing Director
Dr. Heinrich Spies
Contact options:
Telephone: +49 2421 5907 500
Fax: +49 2421 5907 8500
E-mail: info@mayspies.com
Postal address:
Renkerstr. 32
52355 Düren
Germany
VAT
VAT ID No.: DE 217 702 304
3.Reflex GmbH & Co. KG
Commercial Register
Registration Court District Court of Düren
HRA 3410
Managing Director:
Dr.-Ing. Tiemo Arndt
Contact options:
Telephone: +49 2421 4970
Fax: +49 2421 497421
E-mail: info@reflex-paper.com
Postal address:
Veldener Straße 121 – 131
52349 Düren
Sales tax
VAT ID no.: DE297834656

II. General information on data processing

1. Scope of processing of personal data

It goes without saying that we handle your personal data responsibly and in compliance with the applicable national and European data protection regulations. As the operator of our website, we process our users’ personal data as soon as you send us an inquiry by email or via the existing contact forms or place an order via our shop. Our users’ personal data is usually only processed with the user’s consent. An exception applies in cases where prior consent cannot be obtained for actual reasons and the processing of the data is permitted by law.

2. Legal basis for the processing of personal data

If we obtain consent from the data subject for processing personal data, Art. 6 (1) lit. a of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

If personal data is required to fulfill a contract to which the data subject is a party, Art. 6 (1) lit. b of the GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

If processing of personal data is required to fulfill a legal obligation to which our company is subject, Art. 6 (1) lit. c of the GDPR serves as the legal basis.
If processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) (f) GDPR serves as the legal basis for processing.

3. Data deletion and storage period

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract.

4. Server location
The servers we use are located in Europe. All data that you enter on our website will be transmitted there and stored there – subject to the exceptions mentioned in this declaration. There is a data processing agreement with the server operators within the meaning of Art. 28 Para. 3 GDPR, i.e. the data may only be used in accordance with our instructions and we remain the controller of the data as the responsible body within the meaning of Art. 4 No. 7 GDPR.

III. Provision of the website and creation of log files

1. Description and scope of data processing

Every time our website is accessed, our system automatically records data and information from the computer system of the accessing computer.

The following data is collected:

(1) Information about the browser type and version used

(2) The user’s operating system

(3) The user’s Internet service provider

(4) The user’s IP address

(5) Date and time of access

(6) Websites from which the user’s system accesses our website

(7) Websites accessed by the user’s system via our website

2. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 Para. 1 lit. f GDPR.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this purpose, the user’s IP address must be stored for the duration of the session.
The data is stored in log files to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context. These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 Paragraph 1 Letter f of GDPR.

4. Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. If the data is collected to provide the website, this is the case when the respective session has ended.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the users’ IP addresses are deleted or altered so that it is no longer possible to assign the client accessing the website.

5. Possibility of objection and removal
The collection of data to provide the website and the storage of data in log files is essential for the operation of the website. There is therefore no possibility for the user to object.

technically necessary cookies is Art. 6 Para. 1 lit. f GDPR.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 Para. 1 lit. f GDPR.

3.) Duration of storage, possibility of objection and removal
Cookies are stored on the user’s computer and transmitted from there to our site. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to fully use all of the website’s functions.

V. Contact form and email contact

1. Description and scope of data processing
There is a contact form on our website that can be used to contact us electronically. If a user takes advantage of this option, the data entered in the input mask is transmitted to us and stored. This data is:
• Name, first name
• Company
• Email address
• Telephone
• Reason for contacting us
Alternatively, you can contact us using the email address provided. In this case, the user’s personal data transmitted with the email will be saved. Data will be

2. Legal basis for data processing
If the user has given their consent, the legal basis for processing the data is Art. 6 (1) lit. a GDPR.
The legal basis for processing the data transmitted when sending an email is Art. 6 (1) lit. f GDPR. If the email contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) lit. b GDPR.

3. Purpose of data processing
The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by email, this also represents the necessary legitimate interest in processing the data.

4. Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those that were sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

5. Possibility of objection and removal

If the user contacts us by email, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.

You can contact us for this purpose at any time using the contact details provided. All personal data that was stored in the course of contacting us will be deleted in this case.

VI. Registration

1. Description and scope of data processing
On our website we offer users the opportunity to register by providing personal data. The data is entered into an input mask and sent to us and stored. The data is not passed on to third parties. The following data is collected as part of the registration process:
• Surname, first name,
• Place of residence, postcode, street, house number
• Email address
• Telephone number
2. Legal basis for data processing
The legal basis for processing the data is Art. 6 Para. 1 lit. a GDPR if the user has given their consent.
If the registration serves to fulfill a contract to which the user is a party or to carry out pre-contractual measures, the additional legal basis for processing the data is Art. 6 Para. 1 lit. b GDPR.

3. Purpose of data processing

A user must register in order to fulfill a contract with the user or to carry out pre-contractual measures. Registration also serves to create a customer account.

4. Duration of storage
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected.
This is the case for the data collected during the registration process if the registration on our website is cancelled or changed. For data collected during the registration process to fulfil a contract or to carry out pre-contractual measures, this is the case if the data is no longer required for the execution of the contract. Even after the conclusion of the contract, there may be a need to store the personal data of the contractual partner in order to fulfil contractual or

to comply with legal obligations.
Continuing obligations require the storage of personal data during the contract term. In addition, warranty periods and the storage of data for tax purposes must be observed. The storage periods to be observed cannot be set across the board, but must be determined on a case-by-case basis for each contract and contracting party.

5. Possibility of objection and removal
As a user, you have the option of canceling your registration at any time. You can have the data stored about you changed at any time by closing your customer account.
If the data is required to fulfill a contract or to carry out pre-contractual measures, early deletion of the data is only possible if there are no contractual or legal obligations that prevent deletion.

VII. Ordering via online shop
1. Description and scope of data processing
If you place an order via our website, the order is sent to us. As part of the ordering process, we collect the following data:
• Title, first name, last name,
• Company name (if applicable)
• A valid email address,
• Address (if applicable, different delivery address)
• Products ordered
We will only pass on your personal data to third parties to the service partners involved in the contract processing, such as the logistics company commissioned with the delivery and the credit institution commissioned with payment matters.

If you pay via PayPal, credit card via PayPal, direct debit via PayPal or “purchase on account” via PayPal, we will pass on your payment data to PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”) as part of the payment processing. PayPal reserves the right to carry out a credit check for the payment methods credit card via PayPal, direct debit via PayPal or “purchase on account” via PayPal. PayPal uses the result of the credit check in relation to the statistical probability of default for the purpose of deciding on the provision of the respective payment method. The credit report may contain probability values ​​(so-called score values). Insofar as score values ​​are included in the result of the credit report, these are based on a scientifically recognized mathematical-statistical procedure. Address data, among other things, is included in the calculation of the score values. Further information on data protection can be found in the PayPal data protection principles: https://www.paypal.com/de/webapps/mpp/ua/privacy-full

2. Legal basis for data processing
The legal basis for the processing of users’ personal data for the purpose of contract processing is Art. 6 Para. 1 lit. b GDPR.
Insofar as users’ personal data is stored due to tax and commercial law retention and documentation obligations, the legal basis for the processing of the data is Art. 6 Para. 1 lit. c GDPR.

3. Purpose of data processing
The data is collected as part of the ordering process in order to be able to identify you as our customer and to process, fulfill and handle your order. Your data is passed on to the shipping service provider for the purpose of delivering your order, and it is passed on to the payment service provider for the purpose of processing and fulfilling the payment obligations arising from the contractual relationship.

4. Duration of storage
The personal data collected by us for the purpose of processing your order will be stored until the statutory retention period expires and then deleted, unless we are obliged to store it for a longer period in accordance with Article 6 Paragraph 1 Clause 1 Letter c of GDPR due to retention and documentation obligations under tax and commercial law (from the German Commercial Code, the German Criminal Code or the German Fiscal Code).

6. Possibility of objection and removal
If the data is required to carry out contractual or pre-contractual measures, early deletion of the data is only possible if there are no contractual or legal obligations that prevent deletion.

VIII. Newsletter
1. Description and scope of data processing
The newsletter is sent based on the user registering on the website:
On our website, you have the option of subscribing to a free newsletter. When you register for the newsletter, the data from the input mask is sent to us. This is the following data:
– E-mail address
Your consent is obtained for the processing of the data during the registration process and reference is made to this data protection declaration.
If you purchase goods or services on our website and provide your e-mail address, this can be stored in the

We will then use your data to send you a newsletter. In such a case, the newsletter will only be used to send direct advertising for our own similar goods or services.
However, in order to keep you as up to date as possible, we use a third party to carry out mailing campaigns. For this purpose, it is necessary that the data required to receive the emails, which you enter in the respective order form, is passed on to the executing company. However, we assure you that your data will also be treated with the utmost care and will only be used for the purpose of sending the newsletter.
The service provider commissioned by us to send the newsletter is based in the USA (The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308). There is a data processing contract with the service provider within the meaning of Art. 28 Para. 3 GDPR, i.e. they may only use the data in accordance with our instructions, and we remain the controller of the data as the responsible body within the meaning of Art. 4 No. 7 GDPR.
The data is used exclusively for sending the newsletter.

2. Legal basis for data processing
The legal basis for processing the data after the user has registered for the newsletter is Art. 6 Para. 1 lit. a GDPR if the user has given their consent.

The legal basis for sending the newsletter as a result of the sale of goods or services is Section 7 Para. 3 UWG.

3. Purpose of data processing
The user’s email address is collected to deliver the newsletter.

4. Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. The user’s email address is therefore stored for as long as the newsletter subscription is active.

5. Possibility of objection and removal
The newsletter subscription can be canceled by the user concerned at any time. For this purpose, there is a corresponding link in every newsletter.

IX. Counting page views

1. Description and scope of data processing
This website uses Google Analytics, a web analysis service provided by Google Inc. (Google). Google Analytics uses cookies, text files that are stored on your computer and that enable an analysis of your use of the website. The information generated by the cookie about your use of this website (including your IP address) is transmitted to a Google server in the USA and stored there. Google will use this information to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services related to website activity and internet usage. Google may also transfer this information to third parties if this is required by law or if third parties process this data on Google’s behalf. Google will never associate your IP address with other Google data.
The website also uses the “etracker” service to analyze usage data. The data generated in this way is processed and stored by etracker on our behalf exclusively in Germany.

2. Legal basis for data processing
The legal basis for processing users’ personal data is Art. 6 (1) (f) GDPR.
With regard to the Google Analytics service, there is a data processing agreement with Google within the meaning of Art. 28 (3) GDPR, i.e. Google may only use the data in accordance with our instructions, and we remain the controller of the data as the responsible body within the meaning of Art. 4 No. 7 GDPR.

3. Purpose of data processing
The processing of users’ personal data enables us to analyze our users’ surfing behavior. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. Our legitimate interest in processing the data in accordance with Art. 6 (1) (f) GDPR also lies in these purposes. By anonymizing the IP address, the user’s interest in the protection of their personal data is sufficiently taken into account.

4. Duration of storage
The data will be deleted as soon as it is no longer required for our recording purposes.

5. Possibility of objection and removal
Cookies are stored on the user’s computer and transmitted from there to our site. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Already saved

Saved cookies can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.
You also have the option of preventing the collection of data generated by the cookies and related to your use of the website (including IP address) and the processing of the data by Google by downloading and installing the following browser plug-in:
http://tools.google.com/dlpage/gaoptout?hl=de
In detail, the cookies listed under the following link are stored when using Google Analytics:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

X. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the responsible party:

1. Right to information
You can request confirmation from the responsible party as to whether personal data concerning you is being processed by us.
If such processing takes place, you can request information from the controller about the following:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data that are processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) all available information about the origin of the data if the personal data are not collected from the data subject;
(8) the existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information as to whether the personal data concerning you will be transferred to a third country or to an international organization. In this context, you can request to be informed of the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transfer.
In the case of data processing for scientific, historical or statistical research purposes:
This right to information can be restricted to the extent that it is likely to make the realization of the research or statistical purposes impossible or seriously compromises it and the restriction is necessary for the fulfillment of the research or statistical purposes.

2. Right to rectification
You have the right to have the data rectified and/or completed by the controller if the personal data concerning you that are processed are incorrect or incomplete. The responsible party must carry out the rectification immediately.
When processing data for scientific, historical or statistical research purposes:
Your right to rectification can be restricted to the extent that it is likely to make the realisation of the research or statistical purposes impossible or seriously compromises it and the restriction is necessary to fulfil the research or statistical purposes.

3. Right to restriction of processing
Under the following conditions, you can request the restriction of the processing of personal data concerning you:
(1) if you contest the accuracy of the personal data concerning you for a period that enables the responsible party to verify the accuracy of the personal data;
(2) the processing is unlawful and you refuse to delete the personal data and instead request the restriction of the use of the personal data;
(3) the controller no longer needs the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims, or
(4) if you have objected to processing pursuant to Art. 21 Para. 1 GDPR and it has not yet been determined whether the controller’s legitimate reasons outweigh your reasons.
If the processing of personal data concerning you has been restricted, these data – apart from being stored – may only be

with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
For data processing for scientific, historical or statistical research purposes:
Your right to restriction of processing can be restricted to the extent that it is likely to make the realization of the research or statistical purposes impossible or seriously compromises it and the restriction is necessary to fulfill the research or statistical purposes.

4. Right to erasure
a) Obligation to erase
You can request that the controller erase the personal data concerning you immediately, and the controller is obliged to erase this data immediately if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You withdraw your consent on which the processing was based pursuant to Art. 6 (1)(a) or Art. 9 (2)(a) GDPR, and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
(4) The personal data concerning you have been processed unlawfully.
(5) The deletion of the personal data concerning you is necessary to fulfill a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to delete them in accordance with Art. 17 (1) GDPR, he shall take appropriate measures, including technical ones, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as the data subject, have requested that they delete all links to these personal data or copies or replications of these personal data.

c) Exceptions
The right to deletion does not apply if the processing is necessary
(1) to exercise the right to freedom of expression and information;
(2) to fulfill a legal obligation that requires processing under Union or Member State law to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the area of ​​public health in accordance with Art. 9 (2)(h) and (i) and Art. 9 (3) GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Art. 89 (1) GDPR, insofar as the right referred to in section a) is likely to make the realization of the objectives of this processing impossible or seriously compromises it, or
(5) to assert, exercise or defend legal claims.

5. Right to information
If you have asserted the right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to inform all recipients to whom the personal data concerning you was disclosed of said rectification, erasure or restriction of processing, unless doing so should prove impossible or involve disproportionate expenditure.
You have the right to be informed by the controller of these recipients.

6. Right to data portability
You have the right to receive the personal data concerning you that you have made available to the controller in a structured, common and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was made available, provided that
(1) the processing is based on consent in accordance with Art. 6 Para. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR or on a contract in accordance with Art. 6 Ab

s. 1 lit. b GDPR and
(2) the processing is carried out using automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, insofar as this is technically feasible. The freedoms and rights of other persons must not be impaired by this.
The right to data portability does not apply to the processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right of objection
You have the right to object at any time to the processing of personal data concerning you based on Art. 6 Para. 1 lit. e or f GDPR for reasons arising from your particular situation; this also applies to profiling based on these provisions.
The controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is associated with such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
In connection with the use of information society services, you have the option of exercising your right of objection by means of automated procedures that use technical specifications, regardless of Directive 2002/58/EC.
When data is processed for scientific, historical or statistical research purposes:
You also have the right to object, for reasons related to your particular situation, to the processing of personal data concerning you for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 (1) GDPR.
Your right of objection can be restricted to the extent that it is likely to make the realization of the research or statistical purposes impossible or seriously compromises it and the restriction is necessary to fulfill the research or statistical purposes.

8. Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.

9. Automated decision in individual cases including profiling
You have the right not to be subjected to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This shall not apply if the decision
(1) is necessary for entering into or fulfilling a contract between you and the controller,
(2) is permitted by Union or Member State law to which the controller is subject, and this law contains appropriate measures to safeguard your rights and freedoms as well as your legitimate interests, or
(3) is made with your explicit consent.
However, these decisions must not be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2)(a) or (g) GDPR applies and appropriate measures to protect your rights and freedoms as well as your legitimate interests have been taken.
In the cases referred to in (1) and (3), the controller shall take appropriate measures to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

The supervisory authority to which the complaint was submitted shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.