1 Changes to this Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on our website, so please ensure that you are viewing the correct version.

Please contact us if you have any questions, comments or requests regarding this Privacy Policy.

2 General information

(1) Below, we provide information about the collection of personal data when using our website.

Personal data is any data that can be related to you personally, e.g. name, address, email addresses, user behaviour.

(2) The controller pursuant to Art. 4 (7) GDPR is:

Sanden International (Europe) GmbH
Am Taubenbaum 35–37
61231 Bad Nauheim
Telephone: +49 – 6032 – 80 30 100
[email protected]

(3) Name and address of the data protection officer

The data protection officer of the controller is:

Dipl.-Ing. Jörg Hagen

Jhcon Data Protection Consulting

Königstraße 50a

30175 Hanover

Email: [email protected]

3 Your rights and revocation

a) Your rights

(1) You have the right to obtain from the website operator information about the personal data concerning you (Art. 15 GDPR) that we process. You also have the right to rectification (Art. 16 GDPR), erasure (Art. 17 GDPR) or restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR).

(2) You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. In order to safeguard the rights and freedoms and legitimate interests of the data subject, there is therefore at least the right to express your own point of view and to contest the decision.

(3) You also have the right to lodge a complaint with the relevant data protection supervisory authority at any time. To do so, please contact the state data protection officer at the following address.

b) Changes to your personal data

It is very important that the personal information that we hold about you is accurate and current. Please tell us if your personal information changes during your relationship with us.

c) Right to withdraw your consent or to object to data processing

(1) If you have given your consent to the processing of your data (Art. 6 (1) (a) GDPR or Art. 9 (1) (a) GDPR), you have the right to revoke this consent at any time.

The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

(2) Right to object to data collection in specific cases and to direct marketing (Art. 21 GDPR)

If data processing is based on Art. 6 (1) (e) or (f) GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation. This also applies to profiling based on these provisions. The respective legal bases on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims (objection pursuant to Art. 21(1) GDPR). If your personal data 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 purposes; this also applies to profiling insofar as it is related to such marketing. If you object, your personal data will no longer be used for direct marketing purposes (objection pursuant to Art. 21 (2) GDPR).

(3) For any concerns of this nature, please contact the company using the contact details above.

4 Processing of personal data when visiting our website

(1) If you use the website for informational purposes only, i.e. if you do not log in, register, or otherwise provide us with information, we do not process any personal data, with the exception of the data that your browser transmits to our server. In accordance with Art. 6 (1) (f) GDPR, we process the following technically necessary data in order to display our website to you and to ensure its stability and security:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status / HTTP status code
• Amount of data transferred
• Website from which the request originates
• Browser
• Operating system and its interface
• Language and version of the browser software.

(2) If you contact us by email or via a contact form, your request, including all resulting personal data (name, request), will be stored and processed by us for the purpose of processing your request. We will only pass on this data to third parties without your consent if this is necessary to fulfil your request. This data is processed on the basis of Art. 6 (1) lit. b GDPR, provided that your request is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of inquiries addressed to us on the basis of Art. 6 (1) lit. f GDPR or on your consent pursuant to Art. 6 (1) lit. a GDPR, if this has been requested. The data you send us via contact requests will remain with us until you request us to delete it, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions—in particular statutory retention periods—remain unaffected.

(3) If we use contracted service providers for individual functions of our offer or wish to use your data for advertising purposes, we will inform you in detail about the respective processes below. We will also specify the criteria for the storage period.

5 Use of cookies

(1) Our websites use so-called “cookies.” Cookies are small text files for storing information about your use of the website. They are either stored temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser automatically deletes them.

Cookies have various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function). Other cookies are used to evaluate user behavior or display advertising. Cookies that are necessary for the electronic communication process (necessary cookies) or for the provision of certain functions you have requested (functional cookies) or for the optimization of the website (e.g., cookies for measuring the web audience) are stored on the basis of Art. 6 (1) lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services.

(2) However, cookies from third-party companies (third-party cookies) may also be stored on your device or cookies that are not technically necessary. These enable us or you to use certain services provided by the third-party company (e.g., cookies for processing payment services). The storage of the cookies in question is based exclusively on consent (§ 25 (1) TDDDG with Art. 6 (1) lit. a GDPR); consent can be revoked at any time.

(3) Cookies that are necessary for the operation of the website are set automatically when the website is accessed.

Other cookies and functionalities of the website operator and third parties that are not necessary for use may only be used after your consent has been obtained. To this end, you will be asked to select the cookies and functions you wish to allow when you visit the website. This selection is then stored in a cookie until you delete this cookie from your device.

You can correct your selection of permitted cookies and functions at any time via the Cookie-Banner for consenting to cookies.

(4) You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited. If cookies from third-party companies or for analysis purposes are used, we will inform you separately in this privacy policy and, if necessary, ask for your consent.

(5) Cookies are stored on the user’s computer and the information stored therein is transmitted to our servers. As a user, you have full control over the use of cookies. By changing the settings in your Internet browser, you can completely deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.

(6) Regardless of this, you can find further information about cookies at www.allaboutcookies.org. The website www.allaboutcookies.org can provide you with detailed instructions on how to set and delete cookies, depending on the browser type. At the bottom of this page, we have provided links to cookie settings in various browsers, where we are able to identify them.

(7) The Flash cookies used are not recorded by your browser, but by your Flash plug-in. We also use HTML5 storage objects, which are stored on your device. These objects store the necessary data independently of the browser you use and do not have an automatic expiry date. If you do not want Flash cookies to be processed, you must install an appropriate add-on, e.g., “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) 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 regularly delete your cookies and browser history manually.

6 Additional functions and offers on our website

(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. To do so, you will usually need to provide additional personal data, which we will use to provide the respective service and to which the aforementioned principles for data processing apply.

(2) In some cases, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions, and are regularly monitored.

(3) Furthermore, we may pass on your personal data to third parties if we offer promotions, competitions, contract conclusions, or similar services together with partners. You will receive more detailed information on this when you provide your personal data or in the description of the offer below.

(4) If our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this in the description of the offer.

7 Use of the Customer Login

(1) If you wish to use our portal, you must have your account activated by us and log in by providing a username and password. There is no requirement to use your real name; pseudonymous use is permitted. Providing the aforementioned information is mandatory; you may voluntarily provide any additional information through your use of our portal.

(2) When you use our portal, we store the data necessary for the performance of the contract. Furthermore, we store the voluntary data you provide for the duration of your use of the portal, unless you delete it beforehand. The legal basis is Art. 6 (1) lit. f of the GDPR.

(3) To prevent unauthorized access by third parties to your personal data, particularly financial data, the connection is encrypted using TLS technology.

8 Newsletter

(1) With your consent, you can subscribe to our newsletter, which we use to inform you about our current interesting offers. The advertised goods and services are named in the declaration of consent.

(2) If you subscribe digitally, we use the double opt-in procedure for registration for our newsletter. This means that after you register, we will send an email to the email address you provided, asking you to confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be blocked and later automatically deleted. In addition, we store your IP addresses and the times of registration and confirmation. The purpose of this procedure is to verify your registration and, if necessary, to be able to clarify any possible misuse of your personal data.

(3) The only mandatory information required for sending the newsletter is your email address. The provision of additional, separately marked data is voluntary and is used to address you personally. After your confirmation, we will store your email address for the purpose of sending the newsletter. The legal basis is Art. 6 (1) lit. a GDPR.

(4) You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can revoke your consent either by clicking on the link provided in every newsletter email, or by emailing [email protected].

(5) We would like to point out that we may evaluate your user behaviour when sending the newsletter. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. For the evaluations, we link the data mentioned in No. 3 and the web beacons with your email address and an individual ID.

We use the data obtained in this way to create a user profile in order to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click on in them, and deduce your personal interests from this. We link this data to the actions you take on our website.

You can object to this tracking at any time by clicking on the separate link provided in each email or by informing us via another contact channel. The information is stored for as long as you are subscribed to the newsletter. After you unsubscribe, we store the data purely for statistical and anonymous purposes.

Such tracking is also not possible if you have disabled the display of images in your email program by default. In this case, the newsletter will not be displayed in full and you may not be able to use all functions. If you display the images manually, the above-mentioned tracking will take place.

9 Google Tag Manager

(1) With your consent, we use Google Tag Manager from Google Inc. For the European region, Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. If personal data is to be transferred to the USA, Google has submitted to the EU-US Data Privacy Framework, https://www.dataprivacyframework.gov/s/. The legal basis for the use of Google Analytics is Art. 6 (1) lit. a GDPR. This only becomes active when you agree to the use of Google Analytics.

(2) Google Tag Manager is an organizational tool that allows us to integrate and manage website tags centrally via a user interface. Tags are small pieces of code that record (track) your activities on our website, for example. The tags often come from Google’s own products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Such tags perform various tasks. They can collect browser data, feed data to marketing tools, integrate buttons, set cookies, and also track users across multiple websites.

(3) We use Google Tag Manager to make our website as good as possible for you. To do this, we need various tracking tools such as Google Analytics. The data collected by these tools shows us what interests you most, where we can improve our services, and which people we should show our offers to.

The Tag Manager itself is a domain that does not set cookies or store data. It acts merely as an “administrator” of the implemented tags. The data is collected by the individual tags of the various web analysis tools, such as Google Analytics. Depending on the analysis tool, various data about your web behaviour is usually collected, stored, and processed with the help of cookies. For more information, please read our privacy policy for the individual analysis and tracking tools we use on our website.

(4) In the Tag Manager account settings, we have set it so that Google only receives anonymized data from us. However, this only applies to the use of our Tag Manager. We enable Google and others to receive selected data in anonymized form. Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking involves comparing your own results with those of your competitors. Processes can be optimized based on the information collected.

(5) Google stores the data on its own Google servers. The servers are located all over the world. Most of them are located in America. You can find out exactly where the Google servers are located at https://www.google.com/about/datacenters/inside/locations/?hl=de.

(6) You can find out how long the individual tracking tools store your data in our individual data protection texts for the individual tools.

(7) Google Tag Manager itself does not set any cookies, but manages tags from various tracking services. In our explanations of the individual tracking tools, you will find detailed information on the use of your data and how you can delete or manage it if necessary.

(8) As a legal basis for the correct and secure transfer of your personal data between us and Google, we have agreed on so-called EU standard contractual clauses with Google. If you would like to learn more about Google Tag Manager, we recommend the FAQs at https://www.google.com/intl/de/tagmanager/faq.html.

10 Use of Google Analytics

(1) We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offering and make it more interesting for you as a user. If personal data is to be transferred to the USA, Google has submitted to the EU-US Data Privacy Framework, https://www.dataprivacyframework.gov/s/. The legal basis for the use of Google Analytics is Art. 6 (1) lit. a GDPR.

(2) Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is activated on this website, your IP address will be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website activity and internet usage to the website operator.

(3) The IP address transmitted by your browser within the scope of Google Analytics will not be merged with other Google data.

(4) This website uses Google Analytics with the extension “_anonymizeIp()”. This means that IP addresses are truncated before being processed, thus ruling out the possibility of personal references. If the data collected about you is personal, it will be immediately excluded and the personal data will be deleted immediately.

(5) Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of use: http://www.google.com/analytics/terms/de.html, overview of data protection: http://www.google.com/intl/de/analytics/learn/privacy.html, and the privacy policy: http://www.google.de/intl/de/policies/privacy.

(6) You can prevent the storage of cookies 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. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information about cookies and individual providers on the website youronlinechoices.com. There you also have the option of objecting to usage-based online advertising by individual or all tools.

(7) This website also uses Google Analytics for cross-device analysis of visitor flows, which is carried out via a user ID. You can deactivate cross-device analysis of your usage in your customer account under “My data,” “Personal data.”

11 YouTube videos

(1) We have integrated YouTube videos into our online offering that are stored on http://www.YouTube.com and can be played directly from our website with your consent.

(2) When you access YouTube videos on the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data mentioned in No. 3 of this declaration is transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly associated with your account. If you do not want this assignment to your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research, and/or the needs-based design of its website. Such evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

(3) Google also processes your personal data in the USA. The legal basis for the processing of your data is Art. 6 (1) (a) GDPR. Further information on data protection at Google can be found here: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html.

12 Our LinkedIn offering

We are jointly responsible with LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, hereinafter referred to as the “platform operator.”

We only process your personal data, such as your first and last name, your email address, and IP address, etc., if there is a legal basis for doing so.  For more details on processing by the platform operator, please refer to the platform operator’s privacy policy.

In accordance with the provisions of the GDPR, we have concluded a contract with the platform operator to oblige them to comply with data protection regulations and thus to provide your data with the necessary protection.

Please note that the platform operator may also pass on your data to third parties, over which we have no influence.

For more details on processing by the platform operator, please refer to the platform operator’s privacy policy at https://de.linkedin.com/legal/privacy-policy.

We store all personal data that you provide to us only for as long as it is needed to fulfil the purposes for which you provided it to us, or for as long as required by law. Once the purpose has been fulfilled and/or the statutory storage periods have expired, we will delete or block the data, provided that this is technically possible. Information on data storage by the platform operator can be found in their privacy policy, see above.

This platform uses SSL encryption for security reasons and to protect the transmission of confidential content, such as requests you send to us or the platform operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. There is no separate indication within apps that SSL encryption is in place. When SSL encryption is activated, the data you transmit to us cannot be read by third parties.

When you visit the platform operator’s website, the browser used on your device or the app automatically sends information to the platform operator’s server. This information is temporarily stored by the platform operator in a so-called log file. The following information is collected without your intervention and stored until it is automatically deleted:

• IP address of the requesting device
• Date and time of access
• Type of device you are using
• Name and URL of the file accessed
• Website from which access is made (referrer URL)
• Browser used and, if applicable, the operating system of your computer and the name of your access provider

However, this data is only available to the platform operator. We do not have access to this data. Further information can also be found in the platform operator’s privacy policy mentioned above.

We do not collect any personal data about you in this context. However, it is possible to obtain pseudonymized data in the form of statistics about the users of our site over a certain period of time. The software for analyzing user statistics is usually provided by the platform operator itself, but in some cases it is also possible to integrate third-party software (e.g., Google Analytics). This allows data about the users of the site to be collected, such as age, gender, country of origin, browser used, and interests.

However, this data is always pseudonymized and we are unable to make any statements about individual users based on this data alone. We use this data exclusively on the basis of a legitimate interest in order to optimize the content we offer and its marketing and to adapt it to the respective user interests.

You can also interact with our account. You can do this, for example, by liking, sharing, or commenting on a post, or by writing to us directly.

When you interact with us, we will usually process your data, as this allows us to see your account and thus access your personal data, such as your username, profile picture, or the date and time of the interaction.

This data is also used to optimize the content we offer and its marketing and to adapt it to the respective user interests. Our legitimate interest stems from the above-mentioned reason of optimizing the content we provide on our profile. Furthermore, the data collected is information that is only made available to us through your interaction with our profile. This establishes a relevant and appropriate relationship between you and our profile.

If deletion by us is possible, we will delete personal data after 28 days at the latest, provided that there is no legal basis for further processing beyond this period.

Further information on data processing by the platform operator can be found in the above-mentioned privacy policy.

This platform uses cookies. We have no influence whatsoever on which cookies the platform operator uses. For more information, please refer to the platform operator’s cookie policy at https://de.linkedin.com/legal/privacy-policy.

To enforce your rights, you can contact the platform operator directly if the processing is carried out by them. The contact details of the platform operator as the data controller can be found here https://www.linkedin.com/help/linkedin/ask/ppq. Of course, you can also contact us to enforce your rights.

With regard to changes to the privacy policy by the platform operator, please refer to the above-mentioned privacy policy.

13 Our X offering

We use the technical platform and services of X Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A., for the short message service offered here. X International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, is responsible for data processing for persons living outside the United States.

We would like to point out that you use the X short message service offered here and its functions at your own risk. This applies in particular to the use of interactive functions (e.g., sharing, rating).

Information about which data is processed by X and for what purposes can be found in X’s privacy policy: https://X.com/de/privacy

We have no influence on the type and scope of data processed by X, the type of processing and use, or the transfer of this data to third parties. Nor do we have any effective means of control in this regard.

When you use X, your personal data will be processed by X Inc. in the United States, Ireland, and any other country in which X Inc. does business, regardless of your place of residence.

On the one hand, X processes the data you voluntarily enter, such as your name and username, email address, phone number, or the contacts in your address book when you upload or synchronize it.

On the other hand, X also evaluates the content you share to determine which topics you are interested in. It stores and processes confidential messages that you send directly to other users and can determine your location based on location data, wireless network information, or your IP address in order to send you advertising or other content.

X Inc. may use analysis tools such as X Analytics or Google Analytics for evaluation purposes. We have no influence on the use of such tools by X Inc. If tools of this kind are used by X Inc., we have neither commissioned nor approved this, nor do we support it in any other way. Furthermore, the data obtained from this analysis is not made available to us. Only certain non-personal information about tweet activity, such as the number of profile or link clicks by a specific tweet, is visible in our account. We have no way of preventing or stopping the use of such tools on your X account.

As X Inc. is a non-European provider with only one European branch in Ireland, it is bound by European data protection regulations. This applies, for example, to your rights to access, block, or delete data, or to object to the use of usage data for advertising purposes.

You can restrict the processing of your data in the general settings of your X account and under “Privacy and Security.” In addition, on mobile devices (smartphones, tablet computers), you can restrict X’s access to contact and calendar data, photos, location data, etc. in the settings options there. However, this depends on the operating system used.

Further information on these points is available on the following X support pages:

• https://support.X.com/articles/105576#
• https://help.X.com/de/search?q=datenschutz

You can find out more about the option of viewing your own data at X here: https://support.X.com/articles/20172711#

Information about the conclusions drawn about you by X can be found here: https://X.com/your_X_data

Information about the available personalization and data protection settings can be found here (with further references):

• https://X.com/personalization

You also have the option of requesting information using the X data protection form or archive requests:

• https://support.X.com/forms/privacy
• https://support.X.com/articles/20170320#

We do not collect any data about your X account ourselves. However, we do process the data you enter on X, in particular your username and the content published under your account, insofar as we may retweet or reply to your tweets or write tweets that refer to your account. The data you freely publish and distribute on X is thus included in our offering and made available to our followers.

Further information about X and other social networks and how you can protect your data can also be found at www.youngdata.de.

Our public relations work also takes place on X. With this usage concept, we as a non-public body assume responsibility for the use of social media. Please also note our privacy policy.

X is a social network for short messages, photos, and videos. Registered users can publish short messages free of charge via this service. These tweets have a limited length and are usually visible to everyone.

Users can “follow” other users so that they can read their messages in their own X feed.

The advantages of X are its wide reach and—unlike some other social networks—its readability without the need for users to register, as well as its usability without the use of a real name.

More information about X can be found here: https://about.X.com/de.html

The X channels complement existing communication channels such as our website, press releases, print products, and events. The X channels primarily inform users about the latest news from our business operations.

For some target groups, the “traditional” tools alone (print, website, mailing) were no longer sufficient. We have found that X allows us to reach a wide range of interested parties much more directly, quickly, and on a daily basis, especially since interested recipients can subscribe to relevant tweets. The X channel enables us to disseminate our news far and wide, network better with other institutions and sources of information, and respond immediately to events as they happen.

Furthermore, through direct dialogue with readers, we can gather opinions and receive feedback in order to optimize our business activities.

With our X account, we inform users about news from our business operations.

Responsibility for editorial management lies with our management and the associated communications and media team.

We would like to point out to users that the X channel is only an additional option for contacting us or receiving information from us. Alternatively, the information offered via X can also be accessed via the corresponding links on our website or on the other linked websites.
You can contact us with any inquiries. Please use the information provided above.

14 Web fonts

This website uses OpenSans Fonts. These fonts are installed on our own web server. This prevents requests to third-party server and prevents data from being transferred to third-party.

15 External links

For your optimal information, you will find links on our site that refer to third-party sites.

These links allow you to access websites that we consider helpful.

When you leave our website, we do not generally process any further personal data.

If this is not obvious, we will point out that it is an external link. We have no influence on the content and design of other providers’ websites and therefore refer you to their privacy policies. The guarantees in this privacy policy therefore do not apply to third-party websites.

16 Data Security

We have put in place measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those of our people and other third parties who have a business need to know. They will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place procedures to deal with any suspected data security breach and will notify you and the competent data protection regulator of a suspected breach where we are legally required to do so.

17 Where we store your personal data

We principally store data, both electronically and on file, at our offices, with archive storage for files locally.

Personal data may be transferred outside of the EEA by processors acting on our behalf. For transfers to countries not considered adequate by the European Community (EC), we will ensure that personal data is adequately protected, as required by the GDPR. This would include by use of the Standard Contractual Clauses adopted by the EC to protect personal data.

18 Information on the collection of personal data in accordance with Articles 13, 14 and 21 of the General Data Protection Regulation (GDPR) for customers

a.Responsible person and contact details

This information applies to the respective, but not jointly, responsible parties (Sanden):

Sanden International (Europe) GmbH, Am Taubenbaum 35-37, D – 61231 Bad Nauheim, Tel.: + 49 6032 8030 0.

Sanden Manufacturing Poland Sp. z o.o., ul. Fabryczna 11, 59-101 Polkowice, woj. dolnośląskie, Poland, tel. +48 (76) 72 49 114

Sanden Manufacturing Europe, Le Quilliou, 35190 Tinténiac, Tel : 02 99 45 58 58

You can contact the data protection officer of Sanden International (Europe) GmbH, Mr. Dipl.-Ing. Jörg Hagen, Jhcon Datenschutzberatung, Königstraße 50a, 30175 Hannover, Germany, by e-mail: [email protected].

If you have any questions about personnel and applicant issues, please use the e-mail address: [email protected] and if you have any questions about data protection, please either use [email protected] or contact the data protection officer directly.

b.Data and its origin

We may obtain personal data from you directly or from third parties such as intermediaries, other financial institutions, credit reference and anti-fraud agencies, sanctions and politically exposed person screening lists and public registers.

The following personal data is essentially processed:

• Surname, first name, etc.
• contact information, including business address, telephone number(s), email address

c. Data processing – purposes and legal bases

This section specifies the purpose for which Sanden uses the various categories of personal data it collects from you. For each use, we note the applicable legal processing grounds by which we justify each use of your personal data:

To conduct certain checks on you, such as know your customer (KYC) checks, anti-money laundering (AML) checks, and anti-fraud checks before we establish a relationship, and where required, during our relationship with you.

Use justification: legal obligations and rights, legitimate interests (to assist with the prevention of crime and fraud).

To manage our relationship with you and provide our services and products to you. Sanden requires your personal data for the performance of our contract with you or the company you represent. This includes use of your personal data to ensure that we can provide our services to you.

Use justification: contract performance, legal obligations and rights, legitimate interests (to enable us to provide our services and share personal data between Sanden legal entities where appropriate).

To comply with our legal obligations and cooperate with regulators.

Use justification: legal obligations and rights, legitimate interests.

For security purposes and to analyse and continuously improve the services we provide to our customers. We may use personal data for testing and improving our IT infrastructure and the security thereof and to optimise and improve our IT infrastructure and the services we provide to you.

Use justification: contract performance/ legal obligations and rights, legitimate interests (to enable us to ensure the security of our systems and further improve our services).

For marketing purposes. We may use personal data to contact our existing clients by email for marketing purposes. You may opt-out at any time from these marketing communications. We will only market our own products and services to you and not provide your contact details to any third party (with the exception of third parties processing personal data on our behalf).

Use justification: Your consent.

To defend our legitimate interests and to change our business structure. We may disclose personal data in connection with legal proceedings or investigations anywhere in the world to third parties, such as public authorities, law enforcement agencies, regulators and third party litigants (these third parties are not data processors on behalf of Sanden and will process personal data for their own purposes).

Use justification: contract performance, legal obligations and rights, legal claims, legitimate interests (to enable us to cooperate with law enforcement and regulators and to allow Sanden to change its business).

Sanden only processes your Personal Data for legitimate purposes. In addition, the use of your Personal Data will also be justified on the basis of one or more of the legal “processing grounds” that are provided for in the GDPR.

We do our utmost to ensure that your Personal Data is only used in an appropriate way. Use of Personal Data under the GDPR must be justified under one of a number of legal “grounds” that are specified in the GDPR and we are required to set out the grounds in respect of each use in this Privacy statement.

The paragraphs set out below contains an explanation of the scope of the various legal processing grounds available under the GDPR for processing of personal data on which Sanden relies.

• Contract performance: where Sanden requires your personal data in order to enter into a contract with you and provide our services to you.
• Legitimate interests: where we use your Personal Data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
• Legal claims: where your Personal Data is necessary for us to defend, prosecute or make a claim against you, us or a third party.
• Our legal obligations and rights: where we are required to process your personal data under a statutory obligation.
• Consent: where you have consented to our use of your personal data (in which case you will have been presented with a consent form in relation to any such use and you may withdraw your consent at any time by giving notice to us).

Generally, Sanden processes personal data on the basis that it is necessary to do so in connection with the performance of our contractual relationship with you and/or where we have a legal obligation to do so. Sanden may also process personal data when we have a legitimate interest to do so and provided specific conditions are met, such as to defend and prosecute legal claims and rights, and other business interests. Where we rely on this legal processing ground, we will mitigate the effect(s) this may have on your privacy by appropriately minimising our use and putting in place adequate access and security safeguards to prevent unauthorised use.

In order to implement the status of an authorized economic operator (AEO) in accordance with Article 76 of the Customs Code (Regulation (EEC) No. 2913/92) and Article 253 et seq. of the Customs Code (Regulation (EEC) No. 2454/93) and/or in compliance with the EU regulations on combating terrorism (EC 881/2002 and 2580/2001), random checks are carried out at irregular intervals to determine whether you are suspected of being a terrorist.

d. Data recipient and third country transfer or transfer to international organizations

Sanden has engaged various data processors for the processing of your personal data on our behalf, including IT service providers, marketing agencies and other business service providers. We may also share your personal data with other third parties as described in the “For what purposes does Sanden collect your personal data and what are our justifications of uses?” section set out above.

Some of these third parties are situated outside the EEA like the Sanden International (Europe) GmbH UK Branch, Rosewood, Crockford Lane, Chineham, Basingstoke, Hanmpshire RG24 8UT United Kingdom. Service providers accessing Sanden personal data act as data processors on behalf of Sanden. Where we engage data processors, we will ensure that transfers of personal data outside of the EEA take place in accordance with data protection legislation and that there will be an appropriate level of protection. In addition, we will implement legal safeguards governing such transfer, such as model contractual clauses, individuals’ consent, or other legal grounds permitted by applicable legal requirements.  Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections as EEA data protection laws. Applicable data protection laws allow Sanden to freely transfer personal data to such countries. Please contact us if you would like to see a copy of the safeguards we apply in relation to the export of your personal data.

e. Storage duration of your data

Your personal data will be deleted once the statutory retention periods have expired, as specified, for example, in the German Civil Code (BGB), the German Commercial Code (HGB), and the German Fiscal Code (AO).

If data is not subject to these retention periods, it will be deleted once the purpose for which it was collected no longer applies.

f. Your rights

You have the right vis-à-vis Sanden International (Europe) GmbH to:

• Information about your stored personal data (Art. 15 GDPR)
• Correction of data if it is incorrect, outdated or otherwise inaccurate (Art. 16 GDPR)
• erasure if the storage is unlawful, the purpose of the processing is fulfilled and the storage is therefore no longer necessary or you withdraw your consent to the processing of certain personal data (Art. 17 GDPR)
• Restriction of processing if one of the conditions listed in Art. 18 para. 1 lit. a) to d) GDPR is met
• Data portability of the personal data provided concerning you (Art. 20 GDPR)
• Withdrawal of a given consent, whereby the withdrawal does not affect the lawfulness of the processing carried out up to that point on the basis of the consent (Art. 7 para. 3 GDPR)
• Complaint to a supervisory authority (Art. 77 GDPR).

g. Possibilities of objection

If you have given your consent to the processing of your data (Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a) GDPR, you have the right to withdraw this consent at any time.

You can also object to other processing operations that we base on a legitimate interest within the meaning of Art. 6 para. 1 lit. f) GDPR at any time in accordance with Art. 21 GDPR for reasons arising from your particular situation, stating these reasons. In the event of a justified objection, we will generally no longer process the personal data for the purposes in question and delete the data unless we can prove compelling reasons for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

For concerns of this kind, please contact the respective responsible persons mentioned above or delete your account in the applicant portal.

h. Requirement to provide the personal data

If you, as a customer or business partner, are a natural person, your information is absolutely necessary for the proper fulfilment of the contract and for communicating with customers’ and business partners’ contacts in order to ensure the proper conduct of the business relationship. Without your information, the legal transaction (obligatory relationship) and the business relationship cannot be properly executed, which could lead to the termination of the contract or the non-payment of amounts due.