1. Introduction
With the following information, we would like to give you as a “data subject” an overview of the processing of your personal data by us and your rights under data protection laws. In principle, it is possible to use our Internet pages without entering personal data. However, if you want to use special services of our enterprise via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain your consent.
The processing of personal data, such as your name, address, or e-mail address, is always in line with the German Data Protection Regulation (Datenschutz-Grundverordnung – DS-GVO), and in accordance with the country-specific data protection regulations applicable to the “Gesellschaft für Wolfram Industrie mbH”. By means of this privacy policy, we would like to inform you about the scope and purpose of the personal data collected, used and processed by us.
As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are also free to transmit personal data to us by alternative means, for example by telephone or by mail.
You can also take simple and easy-to-implement measures to protect yourself against unauthorized access to your data by third parties. For this reason, we would like to provide you with some tips on how to handle your data securely:
Protect your account (login, user or customer account) and your IT system (computer, laptop, tablet or mobile device) with strong passwords.
Only you should have access to the passwords.
Make sure you use your passwords only for one account (login, user or customer account) at a time.
Do not use one password for different websites, applications or online services.
Especially when using publicly accessible or shared IT systems, be sure to log out each time you log in to a website, application or online service.
Passwords should consist of at least 12 characters and be chosen so that they cannot be easily guessed. Therefore, they should not contain common words from everyday life, your own name or names of relatives, but upper and lower case, numbers and special characters.
2. Responsible person
The responsible party in the sense of the DS-GVO is:
Gesellschaft für Wolfram Industrie mbH
Wolframstraße 1 / 83365 Nußdorf / Germany
3. Data protection officer
You can reach the data protection officer as follows:
Gesellschaft für Wolfram Industrie mbH
Klaus Eierschmalz
Wolframstr. 1 / 83365 Nußdorf / datenschutzbeauftragter@wolfram-industrie.de
You can contact our data protection officer directly at any time with all questions and suggestions regarding data protection.
4. Definitions
The data protection declaration is based on the terms used by the European Directive and Ordinance when issuing the General Data Protection Regulation (DS-GVO). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this data protection declaration:
a) Personal data
Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller (our company).
c) Processing
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
e) Profiling
Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
f) Pseudonymization
Pseudonymization is the processing of personal data in a way in which the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
h) Recipient
Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.
i) Third Party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
j) Consent
Consent means any freely given indication of the data subject’s wishes for the specific case in an informed and unambiguous manner, in the form of a statement or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.
5. Legal basis of the processing
Article 6 (1) lit. a DS-GVO (in conjunction with Section 25 (1) TTDSG) serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Article 6 (1) lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.
If our company is subject to a legal obligation by which a processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) lit. c DS-GVO.
In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party.
Then the processing would be based on Art. 6 (1) lit. d DS-GVO.
Finally, processing operations could be based on Art. 6(1)(f) DS-GVO. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (recital 47 sentence 2 DS-GVO).
Our offer is basically directed at adults. Persons under the age of 16 may not transmit any personal data to us without the consent of their parents or legal guardians. We do not request personal data from children and young people, do not collect them and do not pass them on to third parties.
6. Transmission of data to third parties
We do not transfer your personal data to third parties for purposes other than those listed below.
We only pass on your personal data to third parties if:
you have given us your express consent to do so in accordance with Art. 6 Para. 1 lit. a DS-GVO, the disclosure is permissible under Art. 6 (1) (f) DS-GVO to protect our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data, in the event that there is a legal obligation for the disclosure pursuant to Art. 6 (1) c DS-GVO, and this is legally permissible and necessary according to Art. 6 para. 1 lit. b DS-GVO for the processing of contractual relationships with you.
In order to protect your data and to allow us to transfer data to third countries (outside the EU/EEA) if necessary, we have concluded commissioned processing agreements based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent pursuant to Art. 49 (1) a) DS-GVO may serve as the legal basis for the transfer to third countries. This sometimes does not apply in the case of a data transfer to third countries for which the European Commission has issued an adequacy decision pursuant to Art. 45 DS-GVO.
A transfer of your personal data to third parties for purposes other than those listed below does not take place.
We will only disclose your personal data to third parties if:
you have given us your express consent to do so in accordance with Art. 6 (1) lit. a DS-GVO, the disclosure is permissible under Art. 6 (1) (f) DS-GVO to protect our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data, in the event that there is a legal obligation for disclosure pursuant to Art. 6 (1) c DS-GVO, as well as
this is legally permissible and necessary for the processing of contractual relationships with you according to Art. 6 para. 1 lit. b DS-GVO.
Within the scope of the processing operations described in this privacy policy, personal data may be transferred to the USA. The USA does not have an adequate level of data protection (ECJ: Schrems II ruling). In particular, US investigating authorities can oblige US companies to hand over or disclose personal data without the data subjects being able to effectively take legal action against this. Thus, in principle, there is a possibility that your personal data will be processed by U.S. investigative authorities. We have no influence on these processing activities. In order to protect your data, we have concluded commissioned processing agreements based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent pursuant to Art. 49 (1) a) DSGVO may serve as the legal basis for the transfer to third countries. This sometimes does not apply in the case of a data transfer to third countries for which the European Commission has issued an adequacy decision pursuant to Art. 45 DS-GVO.
7. Technology
7.1 SSL/TLS encryption
This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognize an encrypted connection by the fact that there is a “https://” instead of a “http://” in the address line of the browser and by the lock symbol in your browser line.
We use this technology to protect your transmitted data.
7.2 Data collection when visiting the website
When using our website for information purposes only, i.e. when not registering or otherwise transmitting information to us, we only collect data that your browser transmits to our server (in so-called “server log files”). Our website collects a series of general data and information with each call of a page by you or by an automated system. This general data and information is stored in the server log files. The following data may be collected
When using this general data and information, we do not draw any conclusions about your person. Rather, this information is required in order to
Therefore, the data and information collected is, on the one hand, statistically analyzed by us and, on the other hand, it is evaluated with the aim of increasing the data protection and data security of our enterprise so as to ultimately ensure an optimal level of protection for the personal data we process. The data of the server log files are stored separately from any personal data provided by a data subject.
The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DS-GVO. Our legitimate interest follows from the purposes for data collection listed above.
7.3 Hosting by PROVIDERNAME
We host our website at PROVIDER ADDRESS (hereinafter referred to as PROVIDER).
When you visit our website, your personal data (e.g. IP addresses in log files) are processed on Hetzner’s servers.
The use of Hetzner is based on Art. 6 para. 1 lit. f DS-GVO. We have a legitimate interest in the most reliable presentation and provision as well as safeguarding of our website.
We have concluded an order processing agreement (AVV) pursuant to Art. 28 DS-GVO with Hetzner. This is a contract required by data protection law, which ensures that Hetzner only processes the personal data of our website visitors in accordance with our instructions and in compliance with the DS-GVO. You can find more information on Hetzner’s data protection policy at: LINK
8. Cookies
8.1 General information about cookies
Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our site.
In the cookie, information is stored that results in each case from the context of the specific end device used. This does not mean, however, that we thereby gain direct knowledge of your identity.
The use of cookies serves to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your terminal device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognized that you have already been with us and which entries and settings you have made so that you do not have to enter them again.
On the other hand, we use cookies to statistically record the use of our website and to evaluate our offer for you for the purpose of optimization. These cookies enable us to automatically recognize that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period of time. The respective storage period of the cookies can be found in the settings of the consent tool used.
9. Contents of our website
9.1 Contacting / Contact form
Personal data is collected when contacting us (e.g. via contact form or e-mail). Which data is collected in case of using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request pursuant to Art. 6 (1) lit. f DS-GVO. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DS-GVO. Your data will be deleted after final processing of your request, this is the case if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and the deletion does not conflict with any statutory retention obligations.
10. Web analysis
10.1 Matomo
We have integrated the Matomo component of the provider InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, on this website. Matomo is a software tool for web analysis, i.e. for collecting, collating and evaluating data on the behavior of visitors to websites. Among other things, data is collected about the website from which a data subject has accessed a website (so-called referrer), which subpages of the website have been accessed or how often and for how long a subpage has been viewed. This is used to optimize the website and for cost-benefit analysis of Internet advertising.
The software is operated on the server of the controller, and the log files, which are sensitive under data protection law, are stored exclusively on this server.
Matomo sets a cookie on your IT system. By setting the cookie, we are enabled to analyze the use of our website. Each time one of the individual pages of this website is called up, the Internet browser on your IT system is automatically prompted by the Matomo component to transmit data to our server for the purpose of online analysis. As part of this technical procedure, we obtain knowledge of personal data, such as the IP address of the person concerned, which we use, among other things, to trace the origin of visitors and clicks.
By means of the cookie, personal information, for example the access time, the place from which an access originated and the frequency of visits to our website are stored. Each time you visit our website, this personal data, including the IP address of the Internet connection you are using, is transmitted to our server. This personal data is stored by us. We do not pass on these personal data to third parties.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a DS-GVO.
The privacy policy of Matomo can be viewed at: https://matomo.org/privacy/.
11. Plugins and other services
11.1 Google Maps
On our website, we use Google Maps (API). The operating company of Google Maps is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information. By using this service, our location can be displayed to you, for example, and a possible journey can be made easier.
Already when calling up those sub-pages in which the map of Google Maps is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there. In addition, Google Maps reloads the Google Web Fonts. The provider of the Google WebFonts is also Google Ireland Limited. When you call up a page that embeds Google Maps, your browser loads the web fonts required to display Google Maps into your browser cache. Also for this purpose, the browser you are using establishes a connection to Google’s servers. Through this, Google obtains knowledge that our website was accessed via your IP address. This occurs regardless of whether Google 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 assigned to your account. If you do not want the assignment with your profile at Google, you must log out of your Google user account. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.
If you do not agree to the future transmission of your data to Google in the context of the use of Google Maps, you also have the option of completely disabling the Google Maps web service by turning off the JavaScript application in your browser. Google Maps and thus also the map display on this website can then not be used.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 Para. 1 lit. a DS-GVO.
You can view Google’s terms of use at https://www.google.de/intl/de/policies/terms/regional.html, the additional terms of use for Google Maps can be found at https://www.google.com/intl/de_US/help/terms_maps.html.
You can view the privacy policy of Google Maps at: (“Google Privacy Policy”): https://www.google.de/intl/de/policies/privacy/.
11.2 YouTube (videos)
We have integrated components from YouTube on this website. The operating company of YouTube is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
YouTube is an Internet video portal that allows video publishers to post video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube permits the publication of all types of videos, which is why complete film and television programs, as well as music videos, trailers, and videos created by users themselves, can be accessed via the Internet portal. Each time you call up one of the individual pages of this website that is operated by us and on which a YouTube component (YouTube video) has been integrated, the Internet browser on your IT system is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. The Google WebFonts, Google Video and Google Photo services can also be downloaded from YouTube. Further information on YouTube can be found at https://www.youtube.com/yt/about/de/. Within the scope of this technical procedure, YouTube and Google receive information about which specific sub-page of our website is visited by you. If you are logged in to YouTube at the same time, YouTube recognizes which specific sub-page of our website you are visiting when you call up a sub-page that contains a YouTube video. This information is collected by YouTube and Google and assigned to your YouTube account.
YouTube and Google always receive information via the YouTube component that you have visited our website if you are logged into YouTube at the same time as calling up our website; this takes place regardless of whether you click on a YouTube video or not. If you do not want this information to be transmitted to YouTube and Google, you can prevent the transmission by logging out of your YouTube account before accessing our website.
These processing operations are only carried out if you have given your express consent in accordance with Art. 6 (1) lit. a DS-GVO.
You can view YouTube’s privacy policy at https://www.google.de/intl/de/policies/privacy/.
12.Your rights as a data subject
12.1 Right to confirmation
You have the right to request confirmation from us as to whether personal data concerning you is being processed.
12.2 Right to information Art. 15 DS-GVO
You have the right to receive from us at any time, free of charge, information about the personal data stored about you, as well as a copy of this data in accordance with the legal provisions.
12.3 Right to rectification Art. 16 DS-GVO
You have the right to demand that incorrect personal data concerning you be corrected. Furthermore, you have the right to request the completion of incomplete personal data, taking into account the purposes of the processing.
12.4 Deletion Art. 17 DS-GVO
You have the right to demand that we delete the personal data concerning you without undue delay, provided that one of the reasons provided for by law applies and insofar as the processing or storage is not necessary.
12.5 Restriction of processing Art. 18 DS-GVO
You have the right to demand that we restrict processing if one of the legal requirements applies.
12.6 Data portability Art. 20 DS-GVO
You have the right to receive the personal data concerning you, which has been provided to us by you, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO or on a contract pursuant to Art. 6(1)(b) DS-GVO and the processing is carried out with the aid of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
Furthermore, when exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to obtain that the personal data be transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.
12.7 Objection Art. 21 DS-GVO
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 carried out on the basis of Art. 6(1)(e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) DS-GVO.
This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 DS-GVO.
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 insofar as the processing serves the assertion, exercise or defense of legal claims.
In individual cases, we process personal data to conduct direct marketing. You may object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling, insofar as it is related to such direct advertising. If you object to us processing for direct marketing purposes, we will no longer process the personal data for these purposes.
In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you which is carried out by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the DS-GVO, unless such processing is necessary for the performance of a task carried out in the public interest.
You are free to exercise your right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.
12.8 Revocation of consent under data protection law
You have the right to revoke consent to the processing of personal data at any time with effect for the future.
12.9 Complaint to a supervisory authority
You have the right to complain about our processing of personal data to a supervisory authority responsible for data protection.
13. Routine storage, deletion and blocking of personal data.
We process and store your personal data only for the period of time required to achieve the purpose of storage or if this has been provided for by the legal provisions to which our company is subject.
If the storage purpose ceases to apply or if a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
14. Duration of storage of personal data
The criterion for the duration of storage of personal data is the respective statutory retention period. After expiration of the period, the corresponding data will be routinely deleted, provided that they are no longer required for the fulfillment or initiation of the contract.
15. topicality and change of the data protection declaration
This data protection declaration is currently valid and has the status: July 2023.
Due to the further development of our Internet pages and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. The current data protection declaration can be accessed and printed out by you at any time on the website at “https://wolfram-industrie.de/datenschutzerklaerung/“.