Name and Contact Details of the Controller Under Article 4(7) of the General Data Protection Regulation
HWR Spanntechnik GmbH
Luxemburg Straße 5
Phone: +49 (0)4207 6887-0
Fax: +49 (0)4207 6887-15
Data Protection Officer
Wiener Straße 5
Phone: 0421 33 80 60 90
Fax.: 0421 33 80 60 59
Security and Protection of Your Personal Data
We consider safeguarding the confidentiality of and protecting personal data provided by you against unauthorized access to be our primary task. We therefore apply the utmost diligence and most modern security standards to ensure maximum protection of your personal data.
As a private-law company, we are subject to the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG). We implemented technical and organizational measures to ensure compliance with data protection regulations by us and by our external service providers.
“Personal data” means any information relating to an identified or identifiable natural person (“data subject’”; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of Processing
“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Filing system” means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or member state law, the controller or the specific criteria for its nomination may be provided for by European Union or member state law.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or member state law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Lawfulness of Processing
The processing of personal data is only lawful if there is a legal basis for the processing. Under Article 6(1) Letters a – f of the General Data Protection Regulation, legal bases may especially include:
- Consent the data subject has given to the processing of his or her personal data for one or more specific purposes.
- Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
- Processing 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.
- Processing is necessary for the purposes of the legitimate interests pursued by the controller 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, in particular where the data subject is a child.
Collection of Personal Data
(1) We will inform you hereafter about the collection of personal data when using our website. Personal data includes, e.g., your name, address, email addresses and user behavior.
(2) Contact form: If you send us enquiries using the contact form, your details from the enquiry form including the contact details you provided there will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. These data will not be passed on without your consent. The processing of the data entered in the contact form is therefore carried out exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time. For this purpose, an informal e-mail notification to us is sufficient. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation. The data entered by you in the contact form will remain with us until you request deletion, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.
Personal Data Collection When Visiting Our Website
When merely using our website for informative purposes, i.e., without registering or otherwise transferring information to us, we will only collect the personal data your browser transfers to our server. When viewing our website, we will collect the following technically necessary data to display our website and ensure its stability and security (the legal basis for this is Article 6(1) Sentence 1 Letter f of the General Data Protection Regulation):
- IP address
- Time and date of request
- Time zone difference to Greenwich Mean Time (GMT)
- Contents of request (specific page)
- Access status/HTTP status code
- Volume of data transferred
- Requesting website
- Operating system and surface
- Browser language and version
(1) In addition to the above-stated data, cookies will be saved on your computer when using our website. Cookies are small text files that are saved on your hard disk and assigned to your browser and through which the party that saved the cookie receives certain information. Cookies cannot execute programs or transfer viruses to your computer. Cookies merely serve to make our Internet offer more user-friendly and effective overall.
(2) This website uses the following types of cookies whose scope and function are explained hereafter:
- Transient cookies (see a)
- Persistent cookies (see b)
a. Transient cookies are automatically deleted when you close your browser. Transient cookies especially include session cookies. Session cookies save so-called session IDs through which various requests from your browser can be assigned to a joint session. This allows your computer to be recognized when you return to our website. Session cookies will be deleted when you log out or close your browser.
b Persistent cookies are automatically deleted after a specified period which may differ for each cookie. You may delete these cookies through your browser’s security settings at any time.
c. You may configure your browser settings to, e.g., disable all or third-party cookies. So-called “third-party cookies” are cookies saved by a third party, i.e., not by the actual website you are currently navigating. Please note that disabling cookies may prevent you from using every function of this website.
d. Flash cookies used are not recorded by your browser, but by your Flash plugin. We also use HTML5 storage objects that will be saved on your device. These objects save the necessary data irrespective of your browser and do not have an automatic expiration date. To disable processing by Flash cookies, you must install an according add-on, e.g., “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/en/firefox/addon/betterprivacy/) or the Adobe Flash killer cookie for Google Chrome. You may disable HTML5 storage objects by setting your browser to private mode. We also recommend regularly deleting your cookies and browser history manually.Change cookie preferences
Additional Functions and Offers of Our Website
(1) In addition to providing our website for purely informative purposes, we offer various services to you. These services normally require you to disclose personal data which we use to perform the respective service and to which the above-stated data processing principles apply.
(2) We may use external service providers for processing. These external service providers have been carefully selected and commissioned by us and are bound to our instructions and monitored regularly.
(3) We may transfer your personal data to third parties when participating in campaigns or sweepstakes or for contract conclusion or similar services offered by us with our partners. Further information will be provided when you disclose your personal data or in the offer description below.
(4) If our service providers or partners are based in a state outside of the European Economic Area (EEA), we will inform you about this in the offer description.
(1) With your consent, you may subscribe to your newsletter through which we will inform you about interesting current offers. The advertised goods and services will be specified in the declaration of consent.
(2) Subscriptions to our newsletter use so-called closed-loop authentication. This means that, after your registration, we will send you an email to your stated email address to ask you to confirm that you wish to subscribe to our newsletter. If you do not confirm your subscription within 24 hours, your information will be blocked and automatically erased after 1 month. Furthermore, we will save your IP addresses and time of subscription and confirmation. The purpose of this is to obtain proof of your subscription and to investigate any misuse of your personal data.
(3) Only your email address is required for receipt of our newsletter. Other separately marked information may be disclosed voluntarily and will be used to address you personally. Following confirmation, we will save your email address for the purpose of sending you our newsletter. The legal basis for this is Article 6(1) Sentence 1 Letter a of the General Data Protection Regulation.
(4) You may withdraw your consent to the receipt of and unsubscribe from our newsletter our at any time. You may declare your withdrawal by clicking on the link provided in every newsletter email, by email to email@example.com or by contacting us at the contact details in our imprint.
(5) Please note that we will assess your user behavior when sending our newsletter. For these assessments, emails we send include so-called web beacons or tracking pixels that are 1-pixel image files saved on our website. We will link the data under Section 3 and the web beacons to your email address and an individual ID to perform these assessments. This data is collected exclusively in pseudonymized form, i.e., the IDs are not linked to your other personal data and direct personal identification is excluded. You may object to this tracking at any time by clicking on the separate link in every email or by contacting us otherwise. The information will be saved for as long as you subscribe to our newsletter. If you unsubscribe, we will only save your data in anonymized form and for purely statistical purposes.
Our offer is aimed at adults. Persons under 18 years of age should not transfer personal data to us without their parents’ or legal guardian’s permission.
Data Subject Rights
(1) Withdrawal of Consent
Where personal data concerning you is processed on the basis of consent, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
You may contact us at any time to exercise your withdrawal rights.
(2) Right to Conformation
You have the right to obtain confirmation from the controller as to whether or not personal data concerning you is being processed. You may obtain such confirmation at any time by contacting us at the above-stated contact details.
(3) Right of Access
Where personal data concerning you is processed, you have the right to the following information at any time:
- The purposes of the processing.
- The categories of personal data concerned.
- The recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations.
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period.
- The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
- The right to lodge a complaint with a supervisory authority.
Where the personal data is not collected from you, any available information as to its source.
- The existence of automated decision-making, including profiling, referred to in Article 22(1 & 4) of the General Data Protection Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
If personal data is transferred to a third country or to an international organization, you have the right to be informed about the adequate safeguards under Article 46 of the General Data Protection Regulation related to the transfer. We will provide a copy of the personal data that represents the processing object. For all other copies you request, we may charge an appropriate fee based on administrative costs. If you submit your request electronically, the information will be provided in a commonly used electronic format, unless requested otherwise. The right to receive a copy under Subsection 3 may not impair the rights and freedoms of other persons.
(4) Right to Rectification
You have the right to obtain from us rectification of inaccurate data concerning you without undue delay. Taking into account the purposes of the processing, you also have the right to have incomplete data completed, including by means of providing a supplementary statement.
(5) Right to Erasure (“Right to be Forgotten”)
You have the right to obtain from the controller erasure of personal data concerning you without undue delay and we have the obligation to erase this personal data without undue delay where one of the following grounds applies:
- The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
You withdraw the consent on which the processing is based according to Article 6(1) Letter a or Article 9(2) Letter a of the General Data Protection Regulation, and where there is no other legal ground for the processing.
- You object to the processing pursuant to Article 21(1) of the General Data Protection Regulation and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the General Data Protection Regulation.
- The personal data has been processed unlawfully.
- The personal data has to be erased for compliance with a legal obligation in European Union or member state law to which the controller is subject.
- The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the General Data Protection Regulation.
Where the controller has made the personal data public and is obliged under Article 17(1) of the General Data Protection Regulation to erase the personal data, the controller, taking account of available technology and the cost of implementation, must take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, this personal data.
The right to erasure (“right to be forgotten”) does not apply to the extent that processing is necessary:
- For exercising the right of freedom of expression and information.
- For compliance with a legal obligation which requires processing by European Union or member state law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
- For reasons of public interest in the area of public health in accordance with Article 9(2) Letters h & i and Article 9(3) of the General Data Protection Regulation.
- For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the General Data Protection Regulation in so far as the right referred to in Article 17(1) of the General Data Protection Regulation is likely to render impossible or seriously impair the achievement of the objectives of that processing.
- For the establishment, exercise or defense of legal claims.
(6) Right to Restriction of Processing
You have the right to obtain from us restriction of processing where one of the following applies:
- You contest the accuracy of the personal data for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead.
- The controller no longer needs the personal data for the purposes of the processing, but the data is required by you for the establishment, exercise or defense of legal claims.
- You object to processing pursuant to Article 21(1) of the General Data Protection Regulation pending the verification whether the legitimate grounds of the controller override yours.
Where processing has been restricted under Article 18(1) of the General Data Protection Regulation, such personal data will, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a member state.
To exercise the right to restriction of processing, you may contact us at any time at the above-stated contact details.
(7) Right to Data Portability
You have the right to receive the personal data concerning you which you provided to the controller in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided where:
- The processing is based on consent pursuant to of Article 6(1) Letter a of Article 9(2) Letter a or on a contract pursuant to Article 6(1) Letter a or Article 9(2) Letter a or on a contract pursuant to Article 6(1) Letter b of the General Data Protection Regulation.
- The processing is carried out by automated means.
In exercising your right to data portability pursuant to Article 20(1) of the General Data Protection Regulation, you have the right to have the personal data transmitted directly from one controller to another, where technically feasible. The exercise of the right to data portability is without prejudice to the right to erasure (“right to be forgotten”). That right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
(8) Right to Object
You have the right to object at any time on grounds relating to your particular situation to processing of personal data concerning you which is based on Article 6(1) Letters e or f of the General Data Protection Regulation, including profiling based on those provisions. The controller will no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Where personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the General Data Protection Regulation, you have the right to, on grounds relating to your particular situation, object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You may exercise this right to object by contacting the respective controller at any time.
(9) Automated Individual Decision-Making, Including Profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or that similarly significantly affect you. This does not apply if the decision:
- Is necessary for entering into or performance of a contract between you and a data controller.
- Is authorized by European Union or member state law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests.
- Is based on your explicit consent.
The data controller will implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
You may exercise this right at any time by contacting the respective data controller.
(10) Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you to infringe on the General Data Protection Regulation.
(11) Right to Effective Judicial Remedy
Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 of the General Data Protection Regulation, you have the right to an effective judicial remedy if you consider your rights under the General Data Protection Regulation to have been infringed as a result of the processing of your personal data in non-compliance with the General Data Protection Regulation.
Use of Google Analytics
(1) This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses so-called “cookies,” text files saved on your computer that enable your use of our website to be analyzed. The information generated by the cookie on your use of our website will normally be transferred to a Google server in the US and saved there. However, if IP anonymization is activated on our website, your IP address will first be shortened by Google in a member state of the European Union or in other state party to the Agreement on the European Economic Area. Only in exceptions will your full IP address be transferred to a Google server in the US and shortened there. Google will use this information to assess your use of our website, compile reports about website activity and perform other services related to use of our website and the Internet on the website owner’s behalf.
(2) The IP address transferred by your browser when using Google Analytics will not be merged with other Google data.
(3) You may disable cookies through corresponding browser settings; however, please note that this may prevent you from fully using every function of our website. In addition, you may prevent the transfer to and processing by Google of the data generated by the cookie on your use of our website (including your IP address) by downloading and installing the following browser plugin: https://tools.google.com/dlpage/gaoptout?hl=en.
(4) This website uses Google Analytics with the extension “_anonymizeIp()” whereby IP addresses are processed in shortened form to exclude personal identification. Any personal identifiers are immediately excluded and the personal data is immediately erased.
(5) We use Google Analytics to analyze use of and regularly improve our website. The statistics obtained allow us to improve and make our offer more interesting to you as a user. For the exceptions in which personal data is transferred to the US, Google subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for our use of Google Analytics is Article 6(1) Sentence 1 Letter f of the General Data Protection Regulation.
(6) Information About the Third-Party Provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
Terms of Service: https://marketingplatform.google.com/about/analytics/terms/us/
Data protection overview: https://marketingplatform.google.com/about/
(7) In addition, this website uses Google Analytics to perform cross-device analyses of visitor streams through our user ID. You may disable cross-device analysis of your usage under “My Data” > “Personal Data” on your user account.
To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too. This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.
For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the
data for its own promotional purposes in compliance with the Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data.
The use of Facebook Pixel is based on Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in effective advertising campaigns, which also include social media. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement 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://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook. In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy
at: https://www.facebook.com/about/privacy/. You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook. If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: 10 / 13 http://www.youronlinechoices.com/de/praferenzmanagement/.
Analysis by WiredMinds
Our website uses counting pixel technology provided by WiredMinds GmbH (www.wiredminds.de) to analyze visitor behavior. In connection with this, the IP address of the visitor is processed. The processing occurs only for the purpose of collecting company based information such as company name, for example. IP addresses of natural persons are excluded from any further processing by means of a whitelist. An IP address is not stored in LeadLab under any circumstances.
While processing data, it is our outmost interest to protect the rights of natural persons. Our interest in processing data is based on Article 6(1)(f) GDPR. At no time is it possible to draw conclusions from the collected data on an identifiable person.
WiredMinds GmbH uses this information to create anonymized usage profiles of the visit behavior on our website. Data obtained during this process is not used to personally identify visitors of our website.
We use the lead generation service provided by Leadinfo B.V., Rotterdam, The Netherlands, which recognizes visits of companies to our website based on IP-addresses and shows us related publicly available information, such as company names or addresses. In addition, Leadinfo places two first-party cookies for providing transparency on how our visitors use our website and the tool processes domains from provided form inputs (e.g. “leadinfo.com”) to correlate IP addresses with companies and to enhance its services. For additional information, please visit www.leadinfo.com. On this page: www.leadinfo.com/en/opt-out you have an opt-out option. In the event of an opt-out, your data will no longer be used by Leadinfo”
Integration of Google Web Fonts
To display fonts uniformly, this website uses so-called web fonts provided by Google. When opening a page, your browser will load the required web fonts to your browser cache to display texts and fonts correctly.
To display web fonts, your browser must connect to Google’s servers whereby Google will learn that your IP address was used to open our website. Google web fonts are used in the interest of displaying our website in a uniform and appealing manner. This represents a legitimate interest in the sense of Article 6(1) Letter f of the General Data Protection Regulation.
If your browser does not support web fonts, a standard font will be used by your computer.
Information About the Third-Party Provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 4361001.
We use external service providers (processors), e.g., to send goods or our newsletter or to process payments. A separate processing agreement has been concluded with these service providers to ensure protection of your personal data.
We work with the following service providers:
- Google Ireland Ltd.
- 1&1 Internet SE