1. Data controller
The data controller pursuant to Art. 4(7) EU General Data Protection Regulation (GDPR) is TWK-ELEKTRONIK GmbH (hereinafter TWK), represented by the Managing Directors Dipl. Ing. Johannes W. Steinebach, Dipl.- Wi.- Ing. Dr. Hannwelm Steinebach, Dipl.- Phys. Dr. Felix Steinebach, Bismarckstrasse 108, D-40210 Düsseldorf, FRG, Telephone: +49 (0)211 / 96117-0, Telefax: +49 (0)211 / 63 77 05 E-mail: email@example.com (see also our legal notice) - http://www.twk.de/en/legal-notice.
You can contact our Data Protection Officer at firstname.lastname@example.org or by writing to our postal address, marked ‘FAO Data Protection Officer’.
2. Information about the collection of personal data
We respect the privacy of all visitors to our website. Below, we will provide details about the collection of personal data when using our website. Personal data refers to any data that relates to you personally, e.g. your name, address, e-mail addresses or user behaviour. If we use contracted providers for individual functions of our website or use your data for advertising purposes, we will inform you about the details of the respective processes below. We will also outline the defined criteria for the data storage period. When processing personal data, unless otherwise stipulated in this privacy notice, stored data will be deleted as soon as it is no longer required for its intended purpose and provided that deleting it does not contradict any legal obligations to retain it. If data is not deleted, because it is still required for other purposes permitted by law, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons (six years pursuant to § 257(1) German Commercial Code [HGB] or ten years pursuant to § 147(1) German Tax Code [AO]).
3. Collection of personal data when visiting our website
When using the website for information purposes only, and during which you do not otherwise provide us with any information, we only collect the personal data that your browser transmits to our server. If you want to view our website, we will collect the following data, as this is technically necessary to enable us to display our website to you and to guarantee its stability and security (the legal basis for this is Art. 6(1)(1)(f) GDPR):
- IP address
- date and time of the request
- time zone difference from Greenwich Mean Time (GMT)
- content of the request (specific page)
- access status/HTTP status code
- respective volume of data transmitted
- website the request has come from
- operating system and its interface
- language and version of the browser software
- page from which the website was exited
- search terms used
- duration of the session
In addition to the aforementioned data, cookies are also stored on your computer when using our website. Cookies are small text files that are stored on your hard disk by the browser you are using and via which the body setting the cookie (us, in this case) receives specific information. Cookies cannot run programs or transfer viruses onto your computer. Their purpose is to make our internet presence more user-friendly and more effective. This website uses the following types of cookies, the scope and functionality of which are explained below:
- Transient cookies (see b)
- Persistent cookies (see c)
b) Transient cookies are deleted automatically when you close your browser. These include session cookies, in particular. These store a so-called session ID, which is used to assign various requests from your browser to the common session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after a specified time period, which can vary depending on the cookie. You can delete cookies in your browser’s security settings at any time.
You can configure your browser settings according to your preferences and, for example, decline third-party cookies or all cookies. However, please note that you may then not be able to use the full functionality of this website.
Any Flash cookies used are not stored by your browser, but by your Flash plug-in. We also use HTML5 storage objects for our learning units and these are stored on your end device. These objects store the required data independent of your browser and do not have an automatic expiry date. If you do not want any processing by Flash cookies, you will need to install a suitable add-on, e.g. ‘uBlock Origin’ for Mozilla Firefox (https://addons.mozilla.org/en/firefox/addon/ublock-origin/) or the Adobe Flash Killer Cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. We also recommend that you manually delete your cookies and browser history regularly. In addition to the aforementioned data, cookies are also stored on your computer when using our website. Cookies are small text files that are stored on your hard disk by the browser you are using and via which the body setting the cookie (us, in this case) receives specific information. Cookies cannot run programs or transfer viruses onto your computer. Their purpose is to make our internet presence more user-friendly and more effective.
Use of Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses so-called cookies. These are text files that are stored on your computer and which enable an analysis to be made of your website use. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. If IP anonymisation is activated on this website, then your IP address will be truncated by Google within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and truncated there. Google will use this information on our behalf as the website operator to evaluate your use of the website, to compile reports about website activity and to provide us with other services related to website and internet usage. The IP address transmitted by your browser for the purposes of Google Analytics will not be merged with any other data held by Google.
You can prevent the storage of cookies by selecting the appropriate settings in your browser software, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting any data generated by cookies and related to your use of the website (including your IP address), as well as the processing of this data by Google, by downloading and installing the browser plug-in available via the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
As an alternative to a browser add-on or within browsers on mobile devices, please click this link, to prevent collection of your data by Google Analytics in future on this website (the opt-out only works in that particular browser and only for this domain). This will store an opt-out cookie on your device. If you delete your cookies in this browser, you will have to click on the link again.
This website uses Google Analytics with the extension ‘_anonymizeIp()’. This means that IP addresses are truncated before further processing and prevents them from being directly linked to a specific person. If the data collected does make a personal reference to you, this will therefore be excluded immediately and the personal data deleted promptly; within 14 months at the latest by Google.
We use Google Analytics to enable us to analyse use of our website and to make regular improvements to it. The statistical data we gain can be used to improve our website and make it more interesting for you as a user. Where we have requested your consent for the use of Google Analytics, the legal basis for this is Art. 6(1)(1)(a) GDPR. Otherwise, it is our legitimate interest in accordance with Art. 6(1)(1)(f) GDPR. For the exceptional cases in which personal data is transferred to the USA, Google is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework, https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
5. Contacting us by e-mail or via a contact form
When you contact us by e-mail or via a contact form, the data you provide (your name, your e-mail address or postal address, your telephone number) is stored by us to enable us to respond to your enquiry. The legal basis for this is Art. 6(1)(1)(b) GDPR. We will delete the data concerned once there is no longer any requirement to store it or restrict the processing if there are statutory obligations to retain it. Objection and cancellation option – when you send an enquiry to us, you have the option to object at any time to our use of your data in the future. To do this, send an e-mail to email@example.com or write to TWK-ELEKTRONIK GmbH, FAO Data Protection Officer, Bismarckstrasse 108, D-40210 Düsseldorf, Germany or send a fax to +49 (0)211 / 63 77 05. Any (further) processing of your enquiry will cease as a result.
6. Inclusion of YouTube videos
We have included YouTube videos in our online presence which are stored on http://www.YouTube.com and are directly playable via our website. These are all embedded using the “Privacy Enhanced Mode”, i.e. none of your data is transferred to YouTube if you do not play the videos. Only when you play the videos will the data outlined in section 2 be transferred. We have no influence over this data transfer. When you visit the website, YouTube receives information that you have accessed the corresponding sub-page of our website. The data listed in section 3 of this notice is also transmitted. This occurs regardless of whether you have logged in via a user account provided by YouTube or no user account exists. If you are logged in via Google, your data will be associated directly with your account. If you do not want to be associated with your profile when using YouTube, you will need to log out before activating the button. YouTube will store your data as a user profile and use it for advertising and market research purposes and/or to influence the design of its website. Such an evaluation particularly takes place (even for users who are not logged in) for the purposes of providing customised advertising and to inform other social network users about activities on our website. You have the right to object to the creation of these user profiles, but you must contact YouTube directly to exercise this right.
Further information about the scope and purpose of data collection and processing by YouTube can be found in its privacy notice. You will also find additional information there about your rights and the setting options available to protect your privacy: https://www.google.com/intl/en/policies/privacy. YouTube also processes your personal data in the USA and is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of YouTube is Art. 6(1)(1)(f) GDPR.
7. Data processing as part of customer relationship management
We also process various data relating to our existing and future customers, as well as service providers, suppliers and third parties (particularly contact data, bank details and order-related data), in accordance with Art. 6(1)(b) GDPR, in order to provide them with our contractual or pre-contractual services, unless we have advised them separately about other uses. The required scope, nature and duration of the processing are determined by the underlying purpose of the particular contractual relationship. Data will only be passed to third parties if this is necessary to fulfil our contractual obligations or to execute a contract or if we are legally bound to do so, e.g. by public authorities. Unless otherwise agreed with our customers, we will delete all data collected in this regard once its storage is no longer required. This is usually at the end of any contractual or legal requirements on our part or that of our customers. If there are statutory obligations to retain it, we will restrict the processing of the data. To prevent unauthorised access to your personal data by third parties, particularly financial data, our order processes are encrypted using TLS technology.
8. Data processing for payment transactions
We use the services of financial institutions and of payment provider PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxemburg (PayPal) to facilitate the secure and convenient handling of payments within the framework of contractual or other legal relationships with customers or prospective customers. Our legitimate interests pursuant to Art. 6(1)(f) GDPR are the basis for this. In doing so, certain information that is required about the data subject for payment handling will be processed, including basic details (e.g. name and address), bank details (e.g. account or credit card numbers, passwords, TANs and checksums) and information relating to the contract, the sums concerned and the recipient. The data provided will not be processed or stored by TWK, but only by the financial institutions and PayPal. The data may also be transmitted by the financial institutions and Paypal to credit institutions for the purpose of identity and credit checks. Data subjects can obtain further information, in particular about their rights, such as right of access or revocation, in the terms and conditions or privacy notice of their credit institution. These are available on their respective websites, or for PayPal at https://www.paypal.com/en/webapps/mpp/ua/privacy-full?locale.x=en_EN.
9. Data processing as part of a job application
When you send us your application documents, you provide us with a range of personal data that is specially protected by law. We process personal data about you for the purpose of your employment application, insofar as this is necessary to make the decision about establishing an employment relationship between us. The legal basis for this is § 26(1) in conjunction with Para. 8(2) German Federal Data Protection Act (BDSG). If the need arises while considering your application, we may call, write or contact you by e-mail, provided you have supplied us with contact details to do so. We may also process personal data about you insofar as this is necessary to defend ourselves against claims asserted against us during the application process. The legal basis is then Art. 6(1)(f) GDPR. If an employment relationship is established between us, we may further process the personal data we have already received from you for the purposes of this employment relationship, pursuant to § 26(1) BDSG, where this is necessary for carrying out or terminating the employment relationship or for exercising or complying with any legal rights or obligations representing the interests of employees.
You are not bound by law or contract to provide personal data. However, it is necessary for you to provide personal data in order to conclude an employment contract with us. We process any data that is related to your application. This could be general data about you (like your name, address and contact details), information about your education and professional qualifications or professional development, or other information that you provide us with in connection with your application. Other than that, we may also process any work-related information you make publicly accessible, such as in profiles on professional social media networks. The employees assigned with this task are obliged to maintain confidentiality in accordance with Art. 5(1) GDPR. We do not pass your data to third parties. The data you provide to us will initially only be stored and processed while your application is reviewed and then deleted when the review is complete, unless it is needed for longer. The latter could be the case, for example, if we conclude after reviewing your candidate profile that your application could be of interest to us in the future. In this case, we will store your information for an initial period of 6 months, so that we are still able to contact you at a later date. If no employment relationship results between us, we may still continue to store your data, insofar as this is necessary for defending us against potential legal claims.
Right to information and deletion of application details
On request, we will inform you about which data we have stored about you. If you no longer wish us to store this and you notify us of this before the specified storage and deletion periods expire, we will then delete your data immediately. To do this, send an e-mail to firstname.lastname@example.org or write to TWK-ELEKTRONIK GmbH, FAO Data Protection Officer, Bismarckstrasse 108, D-40210 Düsseldorf, Germany or send a fax to +49 (0)211 / 63 77 05.
10. Your rights
You have the following rights with respect to your personal data:
As per Art. 7(3) GDPR, the right at any time to withdraw consent previously given to us. This means that we will no longer be permitted to process any data based on this content in the future;
As per Art. 15 GDPR, the right to request information about the personal data we have processed. In particular, you can request information about the purposes of the processing, the category of personal data concerned, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of the right to rectification, deletion, restriction of processing or objection, the existence of the right to appeal, the origin of your data, where this has not been collected by us, and also about the existence of automated decision-making, including profiling and, where necessary, any meaningful information about the details of this.
As per Art. 16 GDPR, the right to obtain immediate rectification of incorrect data or completion of incomplete data we are storing about you;
As per Art. 17 GDPR, the right to deletion of the stored personal data, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercising or defence of legal claims;
As per Art. 18 GDPR, the right to obtain restriction of the processing of your personal data, where you are either contesting the accuracy of the data, the processing is unlawful but you oppose its deletion, we no longer require the data, but you require it for the assertion, exercising or defence of legal claims or you have filed an objection to its processing in accordance with Art. 21 GDPR.
As per Art. 20 GDPR, the right to receive the personal data that you have provided to us in a structured, commonly-used and machine-readable format or to request that it is transmitted to another controller.
In addition to the opportunities for objection described already, you can also send an e-mail to email@example.com or write to TWK-ELEKTRONIK GmbH, FAO Data Protection Officer, Bismarckstrasse 108, D-40210 Düsseldorf, Germany or send a fax to +49 (0)211 / 63 77 05 if you wish to assert your data subject rights, in particular your right to object. You also have the right to complain to a data protection supervisory authority (North Rhine Westphalia) about our processing of your personal data.
11. Validity and amendment of this privacy notice
This privacy notice is valid and updated as at October 2019. It may become necessary to amend this privacy notice as we further develop our website or due to changes in statutory or regulatory provisions. You can access or print the current version of the privacy notice from our website at any time. It can be found in the menu under ‘Privacy’.
© 2019 TWK-ELEKTRONIK GmbH