Avisos legais

Privacy Policy

1. Field of Application

The SMF Holding GmbH is the parent company of the family-run GROUP SCHUMACHER (hereafter referred to as „GROUP SCHUMACHER“ or „we“). GROUP SCHUMACHER is particularly concerned about protecting your privacy and personal data. With this data protection declaration (privacy policy) we would like to provide you with extensive information about how we handle your personal data.

This data protection declaration applies to the handling of your personal data when you visit our websites or submit an application to us by electronic or postal means.

2. Who is responsible and who can I contact?

Die SMF-Holding GmbH, Siegener Straße 10, D-57612 Eichelhardt, Germany, which is registered at Montabaur District Court under HRB 14772, is responsible for the processing of your personal data as described below. You can contact the following address with respect to all data protection inquiries:

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller is:

SMF Holding GmbH
Siegener Straße 10
57612 Eichelhardt / Germany

Phone: +49 (0) 26 81 – 80 09 – 0
Telefax: +49 (0) 26 81 – 80 09 – 4914
E-Mail: info@groupschumacher.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Designation of a data protection officer

We have appointed a data protection officer for our company.

Boris Nicolaj Willm
Resilien[i]T GmbH
Monschauer Straße 12
40549 Düsseldorf

Phone: +49 (0) 211 695289 92
E-mail: dsb.groupschumacher@resilienit.de

3. Which data of yours do we process?

We collect and process various items of personal data from you according to the specific processing situations.

4. For what purposes do we process your data and on what legal basis?

We process your personal data exclusively in accordance with the provisions of the General Data Protection Regulation (“GDPR“) and the Federal Data Protection Act (“BDSG“). In certain situations we also process your personal data to fulfil other legal obligations or on the basis of your express consent.

For the fulfilment of contractual obligations

We process your personal data for the fulfilment of contractual or contract-like obligations or the establishment of a contract, for example in order to provide support to existing customers or answer questions.

If you apply to us by post or electronic means and provide us with personal data, we will process your personal data exclusively for the purpose of initiating a future employment relationship.

On the basis of legitimate interests

We also process your personal data to protect our legitimate interests, unless your interests or fundamental rights and fundamental freedoms which require the protection of your personal data prevail.

Subject to an appraisal decision to be taken in individual cases, we assume as standard that our legitimate interests prevail within the context of the following processing situations, although this list is not exhaustive:

Existing customer care;

Information about offers of services and products if we have received your name, email address or postal address from you in connection with the provision of our services and the sale of our products;

Optimisation of our offers and services;

Ensuring the confidentiality and integrity of our IT systems;

On the basis of your consent

If you have given us consent separately to process your personal data, we will process your personal data within the framework of and on the basis of this consent. Consent may, for example, relate to the forwarding of data to partner companies, the evaluation of your data for targeted advertising measures or the dispatch of newsletters.

Consent is always voluntary. Any refusal or revocation of consent will have no negative consequences for you.

5. Who do we forward your information to?

Companies, Agencies and Partners of the GROUP SCHUMACHER

As a matter of principle, we only forward your personal data to our affiliated companies or partners and agencies if this is necessary for the establishment, execution or termination of a contract or contract-like relationship. Our partners and agencies are in particular independent commercial agents for the distribution of our goods and services at home and abroad. For example, when you contact us, we share the information you provide to us with the GROUP SCHUMACHER company responsible for the region in each case so that they can offer you our products and services in accordance with your requirements and the region to which your enquiry relates.

The companies of the GROUP SCHUMACHER include:

SMF-HOLDING GmbH (Deutschland)

SCHUMACHER GmbH (Deutschland)

Schumacher Bergische Werke GmbH (Deutschland)

SCHUMACHER COMPANY LC (USA)

SCHUMACHER INDUSTRIAL LTDA (Brasilien)

OOO SCHUMACHER (Russland)

SCHUMACHER (China)

Transfer to Order Processors

For the processing of your data we also use external service providers to whom we forward your personal data and who only process the data on our behalf in a contractually secured manner. Order processors are also contractually obliged, for example, to optionally delete or return the data upon termination of the commissioning process.

6. Data recording

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

7. Hosting

Mittwald

We host our website with Mittwald. The provider is the Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, Germany (hereinafter referred to as Mittwald).

For details, please view the data privacy policy of Mittwald: https://www.mittwald.de/datenschutz.

We use Mittwald on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable depiction of our website possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

8. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Information on data transfer to the USA and other non-EU countries

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.

If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.

If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.

If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

9. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions, or for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

The type and version of browser used

The used operating system

Referrer URL

The hostname of the accessing computer

The time of the server inquiry

The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Microsoft Bookings

Our website gives you the option to schedule appointments with us. We use Microsoft Bookings to book these appointments. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, https://learn.microsoft.com/en-us/microsoft-365/bookings/?view=o365-worldwide.

To book an appointment, enter the requested data and the desired date in the form provided. The data entered will be used for planning, conducting and, if necessary, for the follow-up of the appointment. The appointment data will be stored for us on the servers of Microsoft Bookings, whose privacy policy you can view here: https://privacy.microsoft.com/de-de/privacystatement.

The data recorded in this manner will be stored until you ask us to delete them, revoke your consent to the archiving of your data or until the purpose of archiving the data no longer exists. This does not affect mandatory statutory provisions – in particular those governing retention periods.

The legal basis for the processing of the data is Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in ensuring that appointments with customers and prospective customers can be scheduled as easily as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be found here: https://learn.microsoft.com/en-us/compliance/regulatory/offering-eu-model-clauses.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000KzNaAAK&status=Active

10. Analysis tools and advertising

Matomo

This website uses the open-source web analysis service Matomo.

Through Matomo, we are able to collect and analyze data on the use of our website-by-website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

IP anonymization

For analysis with Matomo we use IP anonymization. Your IP address is shortened before the analysis, so that it is no longer clearly assignable to you.

Hosting

We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on.

11. Plug-ins and Tools

YouTube with expanded data protection integration

This website integrates videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalize browsing on YouTube. Ads that are played in extended data protection mode are also not personalized. No cookies are set in extended data protection mode. Instead, so-called local storage elements are stored in the user's browser, which contain personal data similar to cookies and can be used for recognition. Details on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780.

After activating a YouTube video, further data processing operations may be triggered over which we have no influence.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. With the means of this service, we can integrate map material on our website.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer. In case Google Maps has been activated, Google has the option to use Google Fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your browser will load the required web fonts into your browser cache, to correctly display text and fonts.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms and https://privacy.google.com/businesses/gdprcontrollerterms/sccs.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Podigee

We use the podcast player from Podigee (Podigee Player) on our website. The provider is Podigee GmbH, Schlesische Straße 20, 10997 Berlin.

The Podigee player embedded on our website primarily collects usage-related data such as your IP address, referrer URL, device information and the podcast accessed. This data is collected by the provider of Podigee.

The use of Podigee is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in making the integration of media content as uncomplicated as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

For more details, please refer to the provider's privacy policy: https://www.podigee.com/de/ueber-uns/datenschutz

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

12. Our social media appearances

Data processing through social networks

We maintain publicly available profiles in social networks. The individual social networks we use can be found below.

Social networks such as Facebook, Twitter etc. can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g., like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered. In detail:

If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to.

Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.

Legal basis

Our social media appearances should ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6 (1) lit. f GDPR. The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g., consent within the meaning of Art. 6 (1) (a) GDPR).

Responsibility and assertion of rights

If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g., Facebook).

Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.

Storage time

The data collected directly from us via the social media presence will be deleted from our systems as soon as you ask us to delete it, you revoke your consent to the storage or the purpose for the data storage lapses. Stored cookies remain on your device until you delete them. Mandatory statutory provisions - in particular, retention periods - remain unaffected.

We have no control over the storage duration of your data that are stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g., in their privacy policy, see below).

Individual social networks

Facebook

We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter Meta). According to Meta’s statement the collected data will also be transferred to the USA and to other third-party countries.

We have signed an agreement with Meta on shared responsibility for the processing of data (Controller Addendum). This agreement determines which data processing operations we or Meta are responsible for when you visit our Facebook Fanpage. This agreement can be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum .

You can customize your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381

Details can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy

Instagram

We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381

For details on how they handle your personal information, see the Instagram Privacy Policy: https://privacycenter.instagram.com/policy/.

We have a LinkedIn profile. The provider is the LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs

For details on how they handle your personal information, please refer to LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.

YouTube

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en

13. Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.

Data processing

14. Custom Services

Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

Job interviews

As part of the application process, we offer interested parties the opportunity to conduct job interviews via a video conferencing tool. This serves to enable contactless interaction and to overcome geographical distances. The video or audio material will not be recorded or stored at any time. Applicants are free to switch off the camera function in advance or during the interview. The applicant may refuse the video interview without giving reasons. In this case, a mutually acceptable alternative will be sought.

In the case of the use of a video conferencing tool, the transfer of data to a third country (in particular the USA) cannot be excluded. The legal basis for the processing is consent pursuant to (Article 6(1)(a) GDPR). The consent can be revoked at any time.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.

Admission to the applicant pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express agreement (Art. 6(1)(a) GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.

Data processing when using our whistleblower system

We offer you the opportunity to use our externally operated internal reporting system via the whistleblower system on our website. We would like to inform you about the possible processing of personal data in this context.

The provider and operator of the whistleblowing system is audatis Services GmbH, a company based in Germany (https://www.audatis-manager.de/impressum/).

The internal reporting centre is managed by us and the service provider Resilien[i]T GmbH. The reporting centre receives the reports and, after a preliminary qualification, coordinates the further processing (e.g. communication with the whistleblower, examination of reports, carrying out any necessary clarification of the facts of the case, documentation).

Contract processors and persons responsible

We have concluded a contract with the above-mentioned system provider for order processing (AVV). This contract regulates and ensures that personal data is only processed in accordance with our instructions and in compliance with the GDPR.

Depending on the type of measures required by the notification, non-instructional service providers may be entrusted with the specific implementation of the corresponding clarification. These service providers may include auditors, law firms or tax advisors. In these cases, the service providers act primarily as their own data protection officers within the meaning of Art. 4 No. 7 GDPR.

Scope and purpose of data collection

The whistleblower system is used to ensure that persons who, for example, have obtained information about (suspected) violations of the law or serious internal violations against our organisation in the course of their professional activities can be received and processed securely and confidentially.

The processing of personal data within the framework of the system used is based on the legal basis of the legitimate interest in uncovering and preventing abuses and the associated avoidance of damage and liability risks in accordance with Art. 6 Para. 1 lit. f GDPR in conjunction with §§ 30, 130 OWiG. Furthermore, the Whistleblower Directive (EU) 2019/1937 and the national HinSchG, which came into force on 2 July 2023, require implementation in companies on the legal basis of Art. 6 para. 1 lit. c GDPR.

Use of the whistleblower portal

Type of personal data collected

The whistleblower system is used on a voluntary basis. If you submit a report via the whistleblower system, we collect the following personal data and information:

Your name, provided you disclose your identity, and if applicable, your home address, home telephone number and home e-mail address.

whether you are employed by the [organisation] or what your relationship to our company is

if applicable, the names of persons and other personal data of the persons you name in your report.

In individual cases, special categories of personal data within the meaning of Art. 9 (1) GDPR may also be processed, e.g. if the information provided by a whistleblower already contains such data. This category of data will only be processed for the reasons stated in Art. 9 (2) GDPR or § 26 (3) BDSG and will be treated with particular confidentiality.

Possible recipients of the data

We ensure that personal data is only accessible to a limited number of authorised persons who require this data to carry out their tasks, including employees of the reporting centre and persons who support them in fulfilling their tasks. This also includes the service providers mentioned above, who are separately obliged to comply with data protection law. In certain cases, there may be a data protection obligation to inform the accused person of the allegations made against them. This is required by law if it is objectively established that providing the accused with information can no longer affect the specific clarification of the information. In doing so, your identity as a whistleblower will not be disclosed - as far as legally possible - and it will also be ensured that no conclusions can be drawn about your identity as a whistleblower.

As a matter of principle, data transfer to authorities in countries outside the European Union (so-called third countries) is not provided for in our whistleblower system. Should such a transfer nevertheless be necessary in an individual case (e.g. due to a report from a country outside the EU), a transfer will only take place if there is a legal basis and a suitable guarantee (e.g. adequacy decision, standard contractual clauses, explicit consent).

If there is a corresponding legal obligation or data protection requirement for the disclosure of information, the following additional categories of recipients may be considered:

law enforcement authorities,

cartel authorities,

other administrative authorities,

courts, lawyers, auditors

Any person who gains access to the data is or will be bound to confidentiality.

If false information is knowingly provided with the aim of discrediting a person (denunciation), confidentiality cannot be guaranteed.

Data security

Personal data and information entered into the whistleblowing system is encrypted and stored securely behind password protection. The whistleblowing system is operated in an ISO27001 certified data centre. Access to the data is only possible for authorised persons who are bound to confidentiality; other third parties do not have access to the data. The security of the procedure is guaranteed by comprehensive technical and organisational measures.

Retention period for personal data

All incoming reports must be documented in accordance with the confidentiality obligations under Section 11 of the HinSchG. The documentation is deleted 3 years after the conclusion of the procedure. Personal data is stored for as long as is necessary for the investigation and final assessment, or as long as the company has a legitimate interest in doing so, or as long as this is required by law.

Newsletter mailing to existing customers

If you order goods or services from us and enter your e-mail address, this e-mail address may subsequently be used by us to send you newsletters, provided we inform you of this in advance. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter. You can unsubscribe from this newsletter at any time. There is a corresponding link in every newsletter for this purpose. In this case, the legal basis for sending the newsletter is Art. 6 (1)(f) GDPR in conjunction with Section 7 (3) UWG.

After you unsubscribe from the newsletter distribution list, we may store your email address in a blacklist to prevent future mailings to you. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

Christmas and New Year greetings

We may send Christmas and New Year greetings to customers and business partners at the end of the year. Your name and address will be collected and processed in order to send you these.

The processing of the data is based on a business purpose in accordance with Art. 6 para. 1 lit. f GDPR. The controller has a legitimate interest in thanking you for the customer and business relationship and promoting it.

Your data will not be forwarded to third parties.

Last update 03th June 2024

Information about the responsible party (referred to as the “controller” in the GDPR)

Designation of a data protection officer

5. Who do we forward your information to?

Data processing through social networks

Legal basis

Facebook

Instagram

LinkedIn

YouTube