Privacy Policy
The following statement informs you about the type of personal data we collect as the responsible body, the purpose for which we collect it, and the extent to which this data is made available to third parties.
1 General information
The following statement informs you about the type of personal data we collect as the responsible body, the purpose for which we collect it, and the extent to which this data is made available to third parties.
1.1 Responsible body and data protection officer
Dr. Otto Suwelack Nachf. GmbH & Co. KG
Josef-Suwelack-Straße 1
48727 Billerbeck
Phone: +49 (0) 2543 72-0
Email: info@suwelack.de
Data Protection Officer
Carola Sieling
Technologiewerft GmbH c/o Kanzlei Sieling
Gurlittstraße 24, 20099 Hamburg
Phone: +49 (0) 40 419 239-21
Email: datenschutz@suwelack.de
1.2 Legal basis for the processing of your personal data
The processing of personal data requires a legal basis, which we would like to present to you below.
When processing personal data for which we obtain the consent of the data subject, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6(1)(b) GDPR serves as the legal basis. This also includes processing operations that are necessary for the implementation of pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Article 6(1)(c) GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights, and freedoms of the data subject do not outweigh the former interest, Article 6(1)(f) GDPR serves as the legal basis for processing. The legitimate interest of our company lies in the performance of our business activities and in the analysis, optimization, and maintenance of the security of our online offering.
1.3 Rights of the data subject
You have the right to obtain information about the personal data we have stored about you. In particular, you may request information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data if it was not collected by us, and the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details.
According to the legal provisions, you also have the right to correct inaccurate data, restrict processing, data portability, and deletion of your personal data. To do so, send us an email with the subject line Data Protection.
You also have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates the legal provisions.
For reasons arising from your particular situation, you may object at any time to the processing of personal data concerning you by us on the basis of Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions (Art. 21 GDPR). If the legal requirements are met, we will no longer process your personal data.
In the case of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Your objection will result in the personal data no longer being processed for these purposes.
If you have given your consent, you have the right to revoke this consent at any time. This does not affect the legality of the processing carried out on the basis of the consent until revocation.
We do not currently carry out automated decision-making, including profiling.
If you exercise any of the above rights as a data subject, we will process your personal data collected in this context in order to respond to your request. The processing of your personal data is carried out in order to fulfill a legal obligation.
In the event of an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing of such data that override your interests, rights, and freedoms, or your personal data serves to assert, exercise, or defend legal claims.
1.4 Storage period for personal data
Unless we have provided specific information on storage, the following applies: We store personal data for the duration of the respective statutory retention period or for as long as the purpose of the collection exists. After the retention period has expired, the data is routinely deleted, unless it is necessary for the initiation or fulfillment of a contract. If the user data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted as far as possible. The data will be blocked accordingly and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.
2 Contractual processing
If you enter into a contractual relationship with us or request one, we generally collect the following data: title, first and last name, email address, postal address, telephone/mobile phone number, information necessary for the execution and initiation of the contract.
We need this data so that we can identify you as a contractual partner, execute the contract, contact you, and for invoicing purposes. Data processing is carried out at your/our request or on your/our behalf and is necessary for the aforementioned purposes for the mutual fulfillment and obligation arising from the contractual relationship.
We may also process data on the basis of a legitimate interest, e.g., when asserting or defending claims arising from the contractual relationship. The personal data collected will be stored until the end of the contractual relationship and then deleted, unless we are obliged to store it for a longer period in accordance with legal obligations based on tax and commercial law retention and documentation requirements (from the German Commercial Code, Criminal Code, or Fiscal Code).
We use the data of our (future) contractual partners and employees (first name, last name, and address, if applicable) to check against so-called sanctions lists. Sanctions lists are centrally compiled and maintained lists of persons, associations, or companies against whom state economic or legal restrictions have been imposed. Various regulations require us to take measures to prevent support being provided to business partners, suppliers, and our (potential) employees if they are included on these lists. We use the data solely to ensure that these individuals are not included on any of the sanctions lists. We require this information in order to fulfill our legal obligations and to avoid potential sanctions. This is also in our legitimate interest.
3 Application data
When you apply for a job with us, we receive data from you. We process the data you have sent us in connection with your application in order to assess your suitability for the position and to carry out the application process. Please note that your data will be accessible to our HR department and the departments relevant to the position to be filled. For data protection reasons, we ask you to ensure that you only provide the data necessary for the application. The legal basis for the processing of your personal data in application procedures is § 26 BDSG (Federal Data Protection Act) or Art. 6 (1) b) GDPR. According to this, the processing of data that is necessary in connection with the decision to establish an employment relationship is permissible. If the data is required for legal purposes after the application process has been completed, data processing may take place on the basis of the requirements of Art. 6 (1) lit. f) GDPR in order to safeguard legitimate interests. Our interest then lies in asserting or defending claims.
Applicants’ data will be deleted after 6 months at the latest in the event of rejection. If you have consented to the further storage of your personal data, we will transfer your data to our applicant pool. The data will be deleted after two years. If you are offered a position as part of the application process, the data will be stored permanently for the purpose of implementing the employment relationship. You can change or delete your application at any time and revoke any consent you have given at any time.
Additional information can also be found in our data protection information for applicants (m/f/d).
4 Data processing in connection with the website 4.1 Log files, hosting
The server statistics automatically store data that the browser transmits to us as part of our legitimate interest in analysis and for security reasons (so-called “log files”).
This includes the following data:
- Language and version of the browser software
- Operating system used and its interface
- Referrer URL (the previously visited page)
- Host name of the accessing computer (IP address)
- Date and time of the server request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Amount of data transferred
- Access status/HTTP status code
4.2 Contact
When you contact us by email or via a contact form, we store your details in order to answer your questions.
Your information will not be passed on to third parties unless applicable data protection regulations justify such a transfer or we are legally obliged to do so. You can revoke your consent at any time with future effect. In the event of revocation, your data will be deleted immediately, provided that there is no legal exception for further processing. Otherwise, your data will be deleted once we have processed your request or the purpose of storage no longer applies and there are no other conflicting legal exceptions.
4.3 Cookies
Cookies are small text files that are stored on your device and through which the entity that sets the cookie receives certain information. They serve to make the website more user-friendly and effective and/or to facilitate navigation on our website.
We only set cookies that are not absolutely necessary with your consent. You can revoke this consent at any time for future use.
Consent is voluntary and you can also use our website without accepting cookies. You can also configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies, or delete cookies that have already been stored. If you do not accept cookies, please note that in this case our website may not function properly. Unless we provide other information on the individual topics mentioned in this privacy policy or in the cookie banner, the lifetime of cookies is 24 months.
You can find out which functions on our website set cookies in the individual function descriptions in our privacy policy and in the cookie banner.
5 Advertising mailings and information to interested parties 5.1 Advertising mailings
You can also confirm that you would like to receive information and news about our company.
We only send advertising messages with your consent or legal permission.
You can revoke your consent to the storage of data, your email address, and its use for sending advertising at any time. To do so, simply send us an email to the contact address provided.
5.2 Information to existing customers
If you have concluded a contract for our services as our contractual partner, we will offer you further information about our own similar services via the email address provided when the contract was concluded (§ 7 III UWG). You can object to this mailing at any time.
These mailings are sent on the basis of our legitimate advertising interest.
6 Disclosure of data: General and contractual purpose
We pass on data to third parties if this is necessary for the fulfillment of the contract and/or if we are legally obliged and/or entitled to do so in individual cases. The data is typically passed on to contracted service providers, including, among others, hosting, operation, maintenance, and support of IT systems, communication systems, and disposal under certain circumstances. In addition, your data may also be transmitted to postal or delivery services, your bank, tax advisors/auditors, and lawyers.
6.1 Use of audio and video conferencing
We use and offer online conferencing tools for our communication and for conducting online meetings. This is done on the basis of your consent to participate in online meetings and communications.
When you communicate with us via video or audio conference over the Internet, your personal data is collected and processed by us and the provider of the conference tool.
The scope of the data also depends on the information you provide before or during participation. The following personal data is subject to processing, depending on the information you provide:
User information: first name, last name, telephone number, email address, password, profile picture, department
Meeting metadata: Topic, description (optional), participant IP addresses, device/hardware information
For recordings: video, audio, and presentation recordings, text file of the online meeting chat.
When dialing in by phone: Information about the incoming and outgoing phone number, country name, start and end time. Additional connection data, such as the IP address of the device, may also be stored.
Text, audio, and video data: You may have the option of using the chat, question, or survey functions in an online conference. In this respect, the text entries you make will be processed in order to display them in the online conference and, if necessary, to log them. To enable the display of video and the playback of audio, the data from the microphone of your end device and from any video camera of the end device will be processed for the duration of the meeting. You can switch off or mute the camera or microphone yourself at any time.
To participate in an online conference or enter the “meeting room,” you must at least provide your name. This can generally be pseudonymized.
For further information on data processing by the conference tools used, please refer to the privacy policies of the respective tools.
7 Weitergabe der Daten: Tools im Rahmen des Betriebs der Webseite
Teilweise bedienen wir uns im Rahmen Ihrer Einwilligung bzw. unserer berechtigten Interessen im Hinblick auf Analyse, Optimierung und wirtschaftlichen Betrieb des Onlineangebotes externer Dienstleister. Sofern Sie Ihre Einwilligung bei für den Betrieb der Webseite nicht notwendigen Tools gegeben haben können Sie diese Einstellungen auch jederzeit wieder ändern lassen. Im Folgenden listen wir Ihnen unsere Dienstanbieter auf.
Sollen Ihre Daten für andere Zwecke verwendet werden, werden wir Sie zuvor informieren und die Daten nur verwenden, soweit Sie vorher ausdrücklich Ihre weitere Einwilligung dazu erklärt haben.
7.1 Service provider Google
With your consent, we use services for the optimization and economic operation of our online offering for which Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) is responsible.
Google LLC is certified under the Data Privacy Framework and EU standard contractual clauses have been concluded, so that possible measures to ensure European data protection law have been taken.
7.1.1 Google Analytics
This website uses Google Analytics as a web analysis service based on your consent. Google Analytics uses so-called “cookies,” text files that are stored on your computer and 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.
We would like to point out that this website uses Google Analytics with IP anonymization and therefore IP addresses from Google in member states within the European Union or in other signatory states to the Agreement on the European Economic Area are truncated before transmission in order to exclude any direct personal reference. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there.
On behalf of the provider, 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 required by law or if third parties process this data on behalf of Google. To the best of our knowledge, Google will not associate your IP address with any other data held by Google.
You can revoke your consent at any time with future effect by accessing the cookie settings on our website and changing your selection there. The legality of the processing carried out on the basis of the consent until revocation remains unaffected. You can also prevent the installation of cookies in advance by adjusting your browser software settings accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. The collection and storage of data by Google can also be objected to at any time with effect for the future in connection with the use of this link:
https://tools.google.com/dlpage/gaoptout?hl=de
Google Analytics 4 sets a maximum retention period of 14 months for data storage. For the purpose and scope of data collection and the further processing and use of data by Google, as well as your rights in this regard and setting options for protecting your privacy, please refer to Google’s privacy policy at https://marketingplatform.google.com/about/analytics/terms/de/ and at https://policies.google.com/?hl=de.
https://marketingplatform.google.com/about/analytics/terms/de/
and
https://policies.google.com/?hl=de.
7.1.2 Youtube
We use YouTube, a Google service, to embed videos.
These videos are stored on www.youtube.com and can be played directly from our site. YouTube uses cookies for data collection and statistical data analysis. YouTube uses cookies, among other things, to collect reliable video statistics, prevent fraud, and improve user-friendliness. The information generated by the cookie about your use of this website (including your IP address) is transmitted to YouTube servers in the US and stored there. Your IP address cannot be assigned unless you have logged in to YouTube or another Google service before visiting the site or are permanently logged in. If you do not want this to happen, you must log out of your YouTube account and your other Google accounts.
YouTube cookies provide us with statistical values for the retrieval of individual videos embedded in the website without any reference to the respective user.
The embedded YouTube videos are used within the scope of YouTube’s permitted use, which all users must accept. If you believe that copyrights have been infringed, please report this directly to YouTube. We use embedded YouTube videos in extended privacy mode. This means that YouTube does not store cookies for a user who views a website with an embedded YouTube video player but does not click on the video to start playback. If the YouTube video player is clicked, YouTube may store cookies on the user’s computer. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by YouTube. For more information on YouTube’s official privacy policy, please visit https://www.google.de/intl/de/policies/privacy/
https://www.google.de/intl/de/policies/privacy/
and https://support.google.com/youtube/answer/171780?hl=de.
https://support.google.com/youtube/answer/171780?hl=de.
7.1.3 Google Web Fonts
Google Web Fonts are used to improve the visual presentation of various information on this website. When the page is accessed, the web fonts are transferred to the browser’s cache so that they can be used for display. If the browser does not support Google Web Fonts or prevents access, the text will be displayed in a standard font. No cookies are set when the page is accessed by the website visitor.
Data transmitted in connection with the page request is sent to resource-specific domains such as fonts.googleapis.com or fonts.gstatic.com. This transmits which of our Internet pages you have visited. Google also stores the IP address of the browser on the visitor’s device. This information is not associated with any data that may be collected or used in connection with the parallel use of authenticated Google services such as Gmail.
You can set your browser so that the fonts are not loaded from Google’s servers. Information on the privacy policy of Google Web Fonts is available at: https://developers.google.com/fonts/faq#Privacy
General information on data protection is available in the Google Privacy Center at: http://www.google.com/intl/de-DE/privacy/
7.2 Meta (Facebook)
With your consent, we use the services of Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (“Facebook” or “Meta”) for the analysis, optimization, and economic operation of our online offering.
The US company Meta Platforms Inc. is certified under the Data Privacy Framework, meaning that measures have been taken to ensure compliance with European data protection law.
7.2.1 Facebook Social Plugins
Our website uses social plug-ins (“plug-ins”) from Facebook. The plug-ins are marked with a Facebook logo (white “f” on a blue tile, the terms “Like,” “I like it,” or a “thumbs up” sign) or the addition “Facebook Social Plug-In.” When you visit a page on our website that contains such a plug-in, your browser establishes a direct connection to Facebook’s servers.
The content of the plug-in is transmitted directly from Facebook to your browser and integrated into the website. This transmits personal information, such as your IP address, URL, date and time, and other browser-related information to Facebook and stores it in the USA, although according to Facebook, only an anonymized IP address is collected in Germany.
If you are logged into Facebook, Facebook can assign the visit to your Facebook account. If you interact with the plug-ins, for example by clicking the “Like” button or posting a comment, the corresponding information is transmitted directly from your browser to Facebook, stored there, and shared with your Facebook contacts depending on your Facebook settings. If you do not want this to happen, please log out of your Facebook account (before clicking the opt-in button).
Facebook stores your data as usage profiles and uses them for advertising, market research, and/or the needs-based design of its website and other websites. Facebook uses cookies and similar technologies to show you advertisements on Facebook services and outside of them, regardless of whether you have a Facebook account and are logged in. Facebook already sets cookies for this purpose when you visit the www.facebook.com website and forwards your data to third parties.
We would like to point out that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by Facebook. You can prevent the installation of these cookies by adjusting your Internet browser settings to reject all third-party cookies; however, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. For the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your rights in this regard and setting options for protecting your privacy, please refer to Facebook’s privacy policy at http://www.facebook.com/about/privacy/, and specifically for Facebook social plug-ins at https://de-de.facebook.com/help/443483272359009/.
You can also change your privacy settings on Facebook in your account settings.
7.3 LinkedIn
Our websites integrate plug-ins from the social network LinkedIn, which is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”).
The US company LinkedIn is certified under the Data Privacy Framework, meaning that measures have been taken to ensure compliance with European data protection law.
You can recognize the “LinkedIn” plug-ins by the LinkedIn logo or the “Recommend” button on our site. When you visit our pages, the plug-in establishes a direct connection between your browser and the LinkedIn server with your consent. LinkedIn thereby receives the information that you have visited our site with your IP address. LinkedIn stores this information in the USA. LinkedIn places cookies on LinkedIn members’ computers when they visit our site, unless they reject this function in their LinkedIn settings. If you visit our website and are logged in as a LinkedIn member, LinkedIn uses this information to recommend content that is specifically relevant to you. This information is used to personalize the features provided to you by LinkedIn on third-party websites. If you click on the LinkedIn “Recommend” button while logged into your LinkedIn account, you can link the content of our pages to your LinkedIn profile. This allows LinkedIn to associate your visit to our pages with your user account. If you do not want this to happen, you must log out of your LinkedIn account. Please note that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by LinkedIn. Details on data collection (purpose, scope, further processing, use) and your rights and setting options can be found in LinkedIn’s privacy policy. LinkedIn provides this information at https://www.linkedin.com/legal/privacy-policy. Further information on the cookies used by LinkedIn can be found at https://www.linkedin.com/legal/cookie-policy.
7.4 TikTok
This website uses the “TikTok pixel” from the social network TikTok, which is operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (“TikTok”), in accordance with your consent.
With the help of the TikTok pixel, TikTok is able to identify you as a visitor to our online offering as a target group for the display of advertisements (so-called “TikTok ads”). We therefore use the TikTok pixel to display the TikTok ads we create only to those TikTok users who have also shown an interest in our online presence or who have certain characteristics (e.g., interests in certain topics or products, which are determined based on the websites visited) that we transmit to TikTok (so-called “custom audiences”). With the help of the TikTok pixel, we also want to ensure that our TikTok ads correspond to the potential interests of users and do not appear intrusive. With the help of the TikTok pixel, we can further track the effectiveness of TikTok ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a TikTok ad (so-called “conversion”). Specific information and details about the TikTok pixel and how it works can be found in the TikTok help section.
7.5 Complianz
We use the Complianz cookie consent tool on our website, which we store locally in order to comply with our legal obligations. The cookie consent tool stores and provides information about the individual settings of the site visitor regarding cookie consent and implements these settings.
8 Data storage outside the EU/EEA
As indicated in the individual tool descriptions, we use tools from US third-party providers. Insofar as this is necessary for the purposes stated, your IP address may be processed outside the European Economic Area, where a level of data protection in line with European standards is not always guaranteed and confirmed (e.g., by appropriate safeguards within the meaning of Art. 46 GDPR or an adequacy decision by the European Commission). In particular, it cannot be ruled out that security authorities in a third country may gain access to your IP address without you being able to take legally effective action against this.
The transfer of the IP address to these third-party providers is carried out in accordance with Art. 49 (1) (a) GDPR on the basis of your express consent given in the consent banner. This consent is voluntary. You can revoke it at any time with effect for the future. This will not result in any disadvantages for you.
In the opinion of some US third-party providers, the conclusion of so-called standard contractual clauses and additional measures taken in accordance with the Schrems II ruling already guarantee a level of protection that meets European standards. However, as the suitability of such measures to ensure an adequate level of data protection is controversial, we have decided to transmit your IP address exclusively with your consent.
The certification of some companies under the Data Privacy Framework (DPF) serves to ensure the level of protection and can be queried here for the companies: https://www.dataprivacyframework.gov/s/. This certification is sufficient as a measure to ensure an adequate level of data protection.
9 Our presence on social media
You can find us on social networks and platforms. We use these platforms to communicate with our customers, interested parties, and users who are active there and to inform them about our services and our company.
The processing of the personal data of users active there is based on our legitimate interests in communicating and providing information to and with users. If consent to data processing has been given by users within the framework of the respective social platform, processing is carried out on the basis of this consent.
When you visit one of our social media sites, we are jointly responsible with the operator of the social platform for the data processing operations triggered during this visit. You can assert your rights (information, correction, deletion, restriction of processing, data portability, and complaint; see the following section, “Rights of the data subject”) both against us and against the operator of the respective social media platform.
We would like to point out that, despite our joint responsibility, we do not have full control over the data processing operations of the social platform and may forward the rights request to the respective operator in order to better process the rights of the data subject. Our options are generally based on the corporate policy of the respective provider.
Our information on storage can be found below. We have no influence on the storage period of your data, which is stored by the operator of the social platform for their own purposes. For details, please contact the operators of the social networks directly (e.g., in their privacy policy, see below).
Depending on the social platform named below, user data may also be processed outside the European Union. EU standard contractual clauses have been agreed with the US companies, or they are certified under the Data Privacy Framework (DPF), so that possible measures to ensure European data protection law have been taken.
User data is usually processed by the platforms for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that are presumed to correspond to the interests of the users. For this purpose, cookies are usually stored on users’ computers, in which the usage behavior and interests of users are stored. Data can also be stored in the usage profiles independently of the devices used by users. This occurs in particular when users are members of the respective platforms and are logged in to them.
For a detailed description of the respective processing and the options for objection, we refer to the information provided by the providers linked below.
9.1 Facebook (Meta)
(Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland)
The basis for this is an agreement on joint processing of personal data: https://www.facebook.com/legal/terms/page_controller_addendum
Privacy policy: https://www.facebook.com/about/privacy/
Opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com
9.2 Instagram (Meta)
(Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland)
Privacy policy/opt-out: http://instagram.com/about/legal/privacy/
9.3 LinkedIn
(LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland)
Privacy policyhttps://www.linkedin.com/legal/privacy-policy
Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
9.4 Xing
(New Work SE, Am Strandkai 1, 20457 Hamburg)
Privacy policy/opt-out: https://privacy.xing.com/de/datenschutzerklaerung
This privacy policy was provided by Technologiewerft GmbH.