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Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process for which purposes and to what extent. The privacy policy applies to all personal data processing carried out by us, both in the context of providing our services and particularly on our websites, in mobile applications, as well as within external online presences, such as our social media profiles (collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: July 21, 2023

Controller

Friedrich Brauer
OptiSteel GmbH
Alte Wiesenstraße 12
51580 Reichshof

Authorized representatives:
Friedrich Brauer

Email address:
info@opti-steel.de

Imprint:
https://www.opti-steel.de/en/imprint/

Relevant Legal Bases

Relevant legal bases under the GDPR: The following provides an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the GDPR regulations, national data protection provisions may apply in your or our country of residence. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6(1) sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request.
  • Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR) – The processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests or fundamental rights and freedoms of the data subject that require the protection of personal data do not override these interests.

National data protection regulations in Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific regulations, especially on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making on a case-by-case basis, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Overview of Processing

The following overview summarizes the types of processed data, the purposes of their processing, and refers to the data subjects involved.

Types of processed data

  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.

Categories of data subjects

  • Customers.
  • Communication partners.
  • Users.

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact inquiries and communication.
  • Security measures.
  • Reach measurement.
  • Tracking.
  • Conversion measurement.
  • Management and response to inquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.

Security Measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, considering the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of the processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, transmission, ensuring availability, and separation of the data. We also have procedures in place to ensure the exercise of data subject rights, deletion of data, and response to data threats. Furthermore, we consider the protection of personal data already during the development or selection of hardware, software, and procedures according to the principle of data protection through technology design and through data protection-friendly default settings.

TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission of Personal Data

In the course of our processing of personal data, it may occur that the data is transmitted to other entities, companies, legally independent organizational units, or persons or disclosed to them. The recipients of this data may include service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transmission within the organization: We may transmit personal data to other entities within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and economic interests or is carried out if it is necessary for the fulfillment of our contractual obligations or if consent from the data subjects or legal permission is present.

International Data Transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of using third-party services or disclosing or transmitting data to other persons, entities, or companies, this will only occur in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission (see Art. 49 GDPR), we process or allow the data to be processed only in third countries with a recognized level of data protection (Art. 45 GDPR), based on contractual obligations through so-called standard protection clauses of the EU Commission (Art. 46 GDPR) or in the presence of certifications or binding internal data protection regulations (see Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Trans-Atlantic Data Privacy Framework (TADPF): Under the so-called “Data Privacy Framework” (DPF), the level of data protection in the EU has also been recognized for certain companies from the USA. You can find the list of certified companies and further information on the DPF on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). Information in German and other languages can be found on the EU Commission’s website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_de We also inform you about the companies we use that are certified under the Data Privacy Framework.

Deletion of Data

The data we process will be deleted in accordance with the legal requirements as soon as their consent allowed for processing is revoked or other permissions cease to apply (e.g., if the purpose of the processing of this data has ceased to exist or they are not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means 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 law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Our privacy notices may also include further information on the retention and deletion of data that take precedence for the respective processing operations.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

 

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1) lit. e or f GDPR, including profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the law, to request the completion or correction of data concerning you.
  • Right to deletion and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be deleted immediately, or alternatively, in accordance with the law, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or to request its transmission to another controller, in accordance with the law.
  • Complaint to supervisory authority: You have the right to lodge a complaint with a supervisory authority, without prejudice to any other administrative or judicial remedy, 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 concerning you infringes the GDPR.

Use of Cookies

Cookies are small text files or other storage notes that store information on end devices and read information from end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the accessed content, or used functions of an online offer. Cookies can also be used for different purposes, such as ensuring the functionality, security, and comfort of online offers, as well as creating analyses of visitor flows.

Information on consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users unless this is not required by law. Consent is particularly not necessary if storing and reading the information, including cookies, is strictly necessary to provide the user with a telemedia service explicitly requested by them (i.e., our online offer). Typically, strictly necessary cookies include cookies with functions that serve to display and run the online offer, load balancing, security, storing user preferences and choices, or similar purposes related to providing the main and secondary functions of the online offer requested by users. The revocable consent is clearly communicated to users and includes information on the respective cookie use.

Information on data protection legal bases: The legal basis on which we process the users’ personal data using cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the processed data using cookies is based on our legitimate interests (e.g., in the commercial operation of our online offer and its improvement) or, if necessary for fulfilling our contractual obligations, when the use of cookies is required to meet our contractual obligations. The purposes for which the cookies are processed are explained in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: Regarding storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Similarly, the data collected using cookies may be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and the storage duration can be up to two years.

General information on withdrawal and objection (so-called “opt-out”): Users can withdraw their given consents at any time and object to processing in accordance with legal requirements. Users can restrict the use of cookies in their browser settings (whereby the functionality of our online offer may be limited). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ .

Cookie settings/objection options: Withdraw consents

  • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); consent (Art. 6(1) sentence 1 lit. a) GDPR).

Further information on processing, procedures, and services:

  • Processing of cookie data based on consent: We use a cookie consent management procedure, in which the consents of users for the use of cookies or the processing and providers mentioned in the context of the cookie consent management procedure are obtained, managed, and revoked by the users. In this context, the consent declaration is stored to avoid having to repeat its request and to be able to prove consent according to the legal obligation. The storage can be server-side and/or in a cookie (so-called opt-in cookie or using comparable technologies) to be able to assign the consent to a user or their device. Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this process, a pseudonymous user identifier is created and stored with the time of consent, details on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used; Legal bases: Consent (Art. 6(1) sentence 1 lit. a) GDPR).

Provision of the Online Offer and Web Hosting

We process the users’ data to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the contents and functions of our online services to the user’s browser or end device.

  • Processed data types: Usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time details, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures; provision of contractual services and customer service.
  • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Further information on processing, procedures, and services:

  • Provision of online offer on rented storage space: For providing our online offer, we use storage space, computing capacity, and software, which we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the accessed web pages and files, the date and timeof access, the amount of data transferred, the message of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, for example, to avoid server overload (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure server stability and performance; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data, whose further retention is necessary for evidence purposes, are excluded from deletion until the respective incident is finally clarified.
  • 1&1 IONOS: Services in the field of provision of information technology infrastructure and associated services (e.g., storage space and/or computing capacities); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy; Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, phone, or via social media) and within existing user and business relationships, the information of the requesting persons is processed as far as necessary to answer the contact inquiries and any requested measures.

  • Processed data types: Contact data (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time details, identification numbers, consent status).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact inquiries and communication; management and response to inquiries; feedback (e.g., collecting feedback via online form); provision of our online offer and user-friendliness.
  • Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR).

Further information on processing, procedures, and services:

  • Contact form: If users contact us via our contact form, email, or other communication channels, we process the data communicated to us in this context to handle the communicated request; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR), legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Web Analysis, Monitoring, and Optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offer and may include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize when our online offer or its functions or content are most frequently used or invite for reuse. Similarly, we can understand which areas need optimization.

In addition to web analysis, we may use test procedures, for example, to test and optimize different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e., data compiled for a usage process, and information stored in a browser or end device are created and read for these purposes. The collected information includes, in particular, visited web pages and used elements as well as technical information such as the used browser, the used computer system, and information on usage times. If users have consented to the collection of their location data, this may also be processed.

IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of users (such as email addresses or names) are stored within web analysis, A/B testing, and optimization procedures, but pseudonyms. This means we, as well as the providers of the used software, do not know the actual identity of the users, but only the information stored in their profiles for the respective procedures.

  • Processed data types: Usage data (e.g., visited web pages, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time details, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creating user profiles); provision of our online offer and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6(1) sentence 1 lit. a) GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Further information on processing, procedures, and services:

  • Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer based on a pseudonymous user identification number. This identification number does not contain any clear data such as names or email addresses. It serves to assign analytical information to a device to recognize which content the users have accessed within one or more usage processes, which search terms they have used, accessed again, or interacted with our online offer. The time of use and its duration as well as the sources of users referring to our online offer and technical aspects of their devices and browsers are also stored. Pseudonymous profiles of users with information from the use of various devices are created, using cookies if necessary. In Google Analytics, data on geographic location at a higher level is processed by capturing the following metadata via IP lookup: “City” (and the derived latitude and longitude of the city), “Continent”, “Country”, “Region”, “Subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The IP address of users is not logged and is truncated by the last two digits by default. The truncation of the IP address takes place on EU servers for EU users. Furthermore, all sensitive data collected from users in the EU is deleted before being collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy policy: https://policies.google.com/privacy