Notes on data protection

Personal data refers to individual details regarding the personal or material circumstances of an identified or identifiable natural person. This includes information such as your name, address and telephone number.

We take the protection of your personal data very seriously. The personal data collected during your visit to or use of our site is protected in accordance with legal requirements.

Data collection and storage

Each web server automatically logs visits to the websites hosted there and stores this information for system security reasons. The following information is stored: the visitor’s IP address, data and time of the visit, the URL requested and information on the data transmitted. This information remains anonymous to us, meaning it is not possible to trace it back to individual users. Additional personal data is only collected if the user has freely provided it, for example in the course of registration or an order. Where personal data is submitted to us, we only use it in responding to requests, in processing orders and for technical administration. Personal data is not disclosed to third parties, unless we are obliged to do this by mandatory legal requirements. Our site may provide links to other websites. We have no influence on the other operator’s data protection provisions.

Cookies

Cookies are files which are intended to make your visit to our site more user-friendly. Your browser automatically stores these cookies when you visit our site. If you don’t want your browser to store them, you can prevent this using the corresponding setting in your browser.

Use of the website

Users of our website must confirm before submitting personal data that they consent to this data being stored and used. This consent can be revoked at any time. Each user has a right to information on the personal data we store. He or she also has the right to rectification of incorrect data and to blocking and erasure of such data. Your personal data will not be disclosed, sold or otherwise transferred to third parties.

Security

twp lage gmbh takes all the necessary technical and organisational security measures to protect your personal data from loss and abuse. Accordingly, your data is stored in a secure operational environment which is not accessible to the public.

Should you wish to contact twp lage gmbh by email, we wish to point out that we cannot guarantee the confidentiality of the information you send us. The contents of emails may be viewed by third parties. We would therefore recommend that you arrange for confidential information to be sent to us by post.

 

Right to information

At your written request, we will inform you as to which data we have stored on your person (e.g. name, address).

Contact

Please feel free to contact us for information on the processing of your personal data at Datenschutz@twp.group.

Changes to our data protection notice

Please bear in mind that this data protection notice may be changed at any time in accordance with applicable data protection regulations. The version that is retrievable at the time of your visit always applies.

Privacy policy

We appreciate your interest in our company. Data protection is very important to twp lage gmbh’s company management. It is generally possible to use twp lage gmbh’s website without providing any personal data at all. If a data subject wishes to use particular services provided by our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we will typically ask for the consent of the data subject.

The processing of a data subject's personal data, such as name, address, email address or telephone number, will always be carried out in accordance with the European General Data Protection Regulation and the country-specific data protection provisions that apply to twp lage gmbh. Through this privacy policy, our company would like to inform the public of the type, scope and purpose of the personal data which we collect, use and process. This privacy policy will also provide data subjects with clarity on their rights.

As the controller responsible for the processing, twp lage gmbh has implemented a variety of technical and organisational measures to ensure the most complete protection possible for personal data processed through this website. Nevertheless, gaps in protection can always appear when data is transferred via the internet, meaning absolute security cannot be guaranteed. For this reason, the data subject is also free to submit personal data to us in alternative ways, such as over the phone.

eder betroffenen Person frei, personenbezogene Daten auch auf alternativen Wegen, beispielsweise telefonisch, an uns zu übermitteln.

1. Definitions

The privacy policy is based on terminology used by EU Directives and Regulations when adopting the European General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy for both the general public and our customers and business partners to read and understand. In order to ensure this, we would like to first define the terminology used. We use the following terms, among others, in the data protection statement:

  • a) Personal data
    ‘Personal data’ refers to any information that relates to an identified or identifiable natural person (hereinafter referred to as the “data subject”). 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’ refers to any identified or identifiable natural person whose personal data is being processed by the controller.
  • c) Processing
    ‘Processing’ refers to any operation or set of operations performed upon personal data, with or without the help of automated procedures, such as collection, capture, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or another form of provision, comparison or combination, restriction, erasure or destruction.
  • d) Restriction of processing
    ‘Restriction of processing’ refers to the labelling of stored personal data with the intention of limiting its processing in the future.
  • e) Profiling
    ‘Profiling’ refers to any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  • f) Pseudonymisation
    ‘Pseudonymisation’ refers to the processing of personal data in such a way that the data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is stored separately and the technical and organisational measures are in place to ensure that the personal data cannot be attributed to an identified or identifiable natural person.
  • g) Controller
    ‘Controller’ refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by EU or Member State law, the controller or the specific criteria for its nomination may be prescribed by Union or Member State law.
  • h) Processors
    ‘Processor’ refers to a natural or legal person, authority, agency or other body which processes personal data on behalf of the controller.
  • i) Recipient
    ‘Recipient’ refers to a natural or legal person, public authority, agency or another body to which the personal data is disclosed, whether or not it is a third party. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with EU or Member State law shall not be regarded as recipients.
  • j) Third parties
    ‘Third party’ refers to a natural or legal person, authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
  • k) Consent
    ‘Consent’ refers to any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

2. Name and address of the controller

The controller in accordance with the European General Data Protection Regulation as well as other data protection laws and other provisions with the character of data protection law that are applicable in the Member States of the European Union, is:

twp lage gmbh
Ehlenbrucher Straße 45
32791 Lage-Kachtenhausen
Germany
Tel.: +49 5232 96110
Email: info@twp.group
Website: www.twp.group

3. Name and address of the data protection officer

The data protection officer of the controller is:
Mr Geoffrey Wittland
twp lage gmbh
Ehlenbrucher Straße 45
32791 Lage-Kachtenhausen
Germany
Tel.: +49 178-8500558
Email: datenschutz@twp.group
Website: www.twp.group

Data subjects can address all questions and suggestions relating to data protection directly to our data protection officer at any time.

 

4. The collection of general data and information

twp lage gmbh’s website collects a range of data and information every time a data subject or an automated system calls up the website. This general data and information is saved in the server log files. The information that may be collected includes (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which the accessing system reaches our site (the so-called referrer), (4) the sub-websites via which an accessing system is led to our website, (5) the date and time of access to our website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information to help mitigate risk in the event of attacks on our IT systems.

twp lage gmbh does not trace this general data and information back to the data subjects when using it. Rather, this information is needed in order to (1) correctly deliver the content of our website, (2) optimise the content of our website and advertising for it, (3) guarantee the long-term functionality of our IT systems and the technology used on our website and (4) provide law enforcement agencies with the information required for prosecution in the even of a cyberattack. This anonymously collected data and information
is analysed by twp lage gmbh both for statistical purposes and with the objective of increasing the level of data protection and security within our company, in order ultimately to ensure an optimal level of data protection for the personal data we process. The anonymous data in server logfiles is stored separately from all personal data provided by a data subject.

 

5. Contact via the website

As per legal requirements, the twp lage gmbh website contains information which allows for fast electronic contact to be established with our company as well as direct communication with us, which also includes our general email address. Should a data subject establish contact with the controller via email or a contact form, the personal data transmitted by the data subject will be saved automatically. Such personal data, transmitted voluntarily by the data subject to the controller, will be saved for the purposes of processing or contacting the data subject. This personal data will not be disclosed to third parties.

6. Routine deletion and blocking of personal data

The controller only processes and stores the data subject’s personal data for the period required to reach the storage purpose or where this has been prescribed by EU Directives and Regulations or other laws or regulations applying to the controller. If the storage purpose ceases to apply or a storage period prescribed by EU Directives and Regulations or other applicable law expires, the personal data is routinely blocked or deleted in accordance with the legal regulations.

7. Data subject rights

  • a) Right to confirmation
    Every data subject has the right as granted by EU Directives and Regulations to demand confirmation from the controller as to whether his or her personal data is being processed. Should the data subject wish to exercise this right to confirmation, he or she can contact our data protection officer or another employee of the controller at any time.
  • b) Right of access
    Each data subject of personal data processing has the right, as granted by EU Directives and Regulations, to receive free information from the controller on the personal data stored in relation to his or person, and to receive a copy of this information. In addition, EU Directives and Regulations have granted the data subject information on the following:
    • the purposes of processing
    • the categories of personal data that are being processed
    • the recipients or the categories of recipients to whom the personal data has been or will be disclosed, especially recipients in third countries or international organisations
    • where possible the planned period for which the personal data will be stored, or where this is not possible, the criteria for the determining this period
    • the existence of a right to rectification or erasure of the personal data pertaining to him or her, or to restriction of the processing thereof by the controller, or the right to object to such processing
    • the existence of a right to lodge a complaint with a supervisory authority
    • where the personal data have not been obtained from the data subject: all available information about the origin of the data
    • the existence of automated decision making including profiling in accordance with Article 22(1) and (4) GDPR and — at least in these cases — meaningful information on the logic involved as well as the scope and envisaged effects of such processing for the data subject

In addition, the data subject has the right to information on whether personal data has been transferred to a third country or international organisation. If this is the case, the data subject also has the right to receive information on the appropriate safeguards in connection with the transfer.
Should the data subject wish to exercise this right to rectification, he or she can contact our data protection officer or another employee of the controller at any time.

  • c) Right to rectification
    Each data subject affected by the processing of personal data has the right, granted by EU Directives and Regulations, to demand the immediate rectification of incorrect personal data relating to him or her. In addition, the data subject also has the right, taking the purposes of the processing into account, to demand the completion of incomplete personal data, including by means of a supplementary explanation. Should the data subject wish to make use of this right to rectification, he or she can contact our data protection officer or another employee of the controller.
  • d) Right to erasure (Right to be forgotten)
    Each data subject affected by the processing of personal data has the right, granted by EU Directives and Regulations, to demand from the controller the immediate erasure of personal data relating to him or her, provided one of the following reasons applies and as long as the processing is not necessary:
    • The personal data was collected or otherwise processed for purposes for which it is no longer required.
    • The data subject revokes his or her consent, which was the basis of the processing in accordance with Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no
      other legal basis for the processing.
    • The data subject raises an objection against the processing according to Article 21(1) GDPR,
      and there is no precedent legitimate grounds for the processing, or the data
      subject raises an objection against the data processing according to Article 21(2) GDPR.
    • The personal data was processed illegally.
    • The erasure of the personal data is required in order to fulfil a legal obligation according to
      EU or Member State law applying to the
      controller.
    • The personal data was collected in relation to information society services offered in accordance with Article 8(1) GDPR.

If any of the above reasons apply and a data subject wishes to erase personal data stored by twp lage gmbh, he or she can contact our data protection officer or another employee of the controller at any time. The twp lage gmbh employee will arrange for the erasure request to be fulfilled without undue delay.
If the personal data was made public by twp lage gmbh and if our Group as controller is obliged to erase the personal data in accordance with Article 17(1) GDPR, twp lage gmbh shall take appropriate measures giving due consideration to the technologies available and the implementation costs, including those of a technical nature, to inform other controllers processing the published data that the data subject has demanded that these other controllers erase all links to their personal data or copies or replicas of this personal data, provided that the processing is not necessary. The twp lage gmbh employee will make the arrangements which are necessary in the individual case.

  • e) Right to restriction of processing
    Every data subject affected by the processing of personal data has the right, granted by EU Directives and Regulations, to demand that the controller restrict processing if one of the following conditions applies:
    • The accuracy of the personal data is contested by the data subject; the restriction in this case shall be for a period of time that enables the controller to verify the accuracy of the personal data.
    • The processing is illegal, the data subject has not consented to the erasure of the personal data and demands instead that the use of the data be restricted.
    • The controller no longer requires the personal data for processing purposes, but the data subject needs it to assert, exercise or defend his or her rights.
    • The data subject has raised an objection to the processing according to Article 21(1) GDPR
      and it has not yet been determined whether the controller’s legitimate grounds outweigh those of the data subject.
      If any of the above conditions apply and a data subject wishes to request the restriction of the personal data stored by twp lage gmbh, he or she can contact our data protection officer or another employee of the controller. The twp lage gmbh employee will arrange for the processing to be restricted.
  • f) Right to data portability
    Each data subject affected by the processing of personal data has the right, granted by EU Directives and Regulations, to obtain the personal data he or she provided to the controller in a structured, common and machine-readable format. He or she also has the right to transfer this data to another controller, without being hindered by the controller to whom he or she made the personal data available, provided that the processing is based on the consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR and the processing is performed by automated procedures, unless the processing is necessary for the performance of a task that is in the public interest or for the exercise of official authority which has been assigned to the controller. In addition, when exercising his or her right to data portability in accordance with Article 20(1) GDPR, the data subject has the right to demand that his or her personal data be transmitted directly from one controller to another, provided that this is technically feasible and that this does not affect the rights and freedoms of other persons.
    The data subject may contact a twp lage gmbh employee at any time to assert the right to data portability.
  • g) Right to object
    Each data subject affected by the processing of personal data has the right, granted by EU Directives and Regulations, to raise objection at any time to the processing of his or her data being carried out under Article 6(1)(e) or (f) GDPR for reasons related to his or her particular situation. This also applies to any profiling based on these provisions.
    In the case of an objection, twp lage gmbh will no longer process the personal data, unless there are compelling and legitimate grounds for processing which outweigh the interests, rights and freedoms of the data subject, or processing serves to assert, exercise or defend legal claims. If twp lage gmbh processes data for the purposes of direct marketing, the data subject has the right to object to the processing of his or her personal data at any time. This also applies for profiling connected with direct marketing. If the data subject objects to twp lage gmbh processing data for the purposes of direct advertising, twp lage gmbh will no longer process the personal data for these purposes. The data subject also has the right to object, for reasons arising from his or her particular situation, to the processing of his or her personal data for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) GDPR, unless such processing is necessary to fulfil a task which is in the public interest. In order to assert the right to object, the data subject can contact twp lage gmbh and its employees at any time using the above contact details. Notwithstanding Directive 2002/58/EC, the data subject is also entitled in the context of the use of information society services to exercise his or her right to object by means of automated procedures for which technical specifications are used.
  • h) Automated decision-making in the individual case, including profiling
    Each data subject affected by the processing of personal data has the right, granted by EU Directives and Regulations, to object to being subject to a decision based exclusively on automated processing which has a legal impact on him or her or adversely affects him or her in a similar manner, provided that the decision (1) is not necessary to fulfil a contract between the data subject and controller, or (2) is permissible on the grounds of EU legislation or Member State law to which the controller is subject, and this legislation contains reasonable measures to protect the rights and freedoms as well as legitimate interests of the data subject, or (3) it
    occurs with the express consent of the data subject. If the decision is (1) necessary for the conclusion or fulfilment of a contract between the data subject and the controller or (2) it occurs with the express consent of the data subject, twp lage gmbh shall take reasonable measures to protect the rights and freedoms as well as the legitimate interests of the data subject, which will at the very least include the right for the controller to seek his or her involvement, the right to express his or her own viewpoint and to challenge the decision. Should the data subject wish to make use of his or her rights in relation to automated decision-making, he or she can contact our data protection officer or another employee of the controller at any time.
  • i) Right to revoke consent in relation to data processing
    Each data subject affected by the processing of personal data has the right, granted by EU Directives and Regulations, to revoke consent his or her to the processing of personal data relating to him or her at any time. If the data subject wishes to exercise his or her right to revoke such consent, he or she may
    contact an employee of the controller for this purpose at any time.

 

8. Legal basis of processing

Article 6 (1)(a) GDPR serves our company as the legal basis for those processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the fulfilment of a contract whose parties include the data subject, as is the case for example with processing operations necessary for the delivery of goods or the performance of another service or return service, the processing shall be based on Article 6(1)(b) GDPR. The same applies to processing operations which are necessary to carry out pre-contractual measures, such as enquires about our products or services. If our company is under a legal obligation which makes the processing of personal data necessary, for example to fulfil tax obligations, this processing shall be based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be required to protect the vital interests of the data subject or another natural person. This would for example be the case should a visitor to our company be injured and subsequently his or her name, age, health insurance details or other vital information need to be shared with a doctor, hospital or other third party. In this case, processing would be based on Article 6(1)(d) GDPR. Ultimately, the processing operations could be based on Article 6(1)(f) GDPR. Processing operations not covered by any of the previously mentioned legal bases will rest on this legal basis, if the processing is necessary for the protection of a legitimate interest of our company or a third party, provided that this is not outweighed by the interests, fundamental rights and freedoms of the data subject. We are permitted to perform such processing operations in particular because they have been specifically mentioned by EU law. The legislator formed the view in this respect that a legitimate interest can be assumed if the data subject is a customer of the controller (Recital 47 (2) GDPR).

 

9. Legitimate interests in processing that are pursued by the controller or a third party

If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest lies in the performance of our business for the welfare of all our employees and shareholders.

10. Period for which the personal data will be stored

The storage period for personal data is based on the relevant statutory retention period. When this deadline expires, the corresponding data will be routinely erased provided it is no longer required to fulfil the contract or to initiate a contract.

11. Legal or contractual regulations on the provision of personal data; necessity for conclusion of a contract; data subject’s obligation to provide personal data; possible consequences of non-provision

We hereby inform you that the provision of personal data is sometimes prescribed by law (e.g. tax regulations) or may arise from contractual regulations (e.g. details on the contracting party). It may be necessary, for example for the conclusion of a contract, for the data subject to provide us with personal data that we must subsequently process. The data subject is, for example, obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide personal data could result in the contract with the data subject failing to be concluded. Before the data subject provides personal data, her or she must contact one of our employees. Our employee will explain to the data subject on a case-by-case basis whether the provision of personal data is legally or contractually prescribed or necessary for the conclusion of the contract, whether there is an obligation to provide personal data, and what the consequences of failure to provide personal data would be.

12. Existence of automated decision-making

As a responsible company, we do not use an automated decision-making or profiling.

13. Google Maps

This website uses the Google Maps service via an API. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

It is necessary to store your IP address in order to use the features of Google Maps. This information is usually transferred to a Google server in the USA and stored there. The provider of this website does not have any influence on this transfer of data.

We use Google Maps to ensure the attractive presentation of our online service and to make it easy to find the locations specified on our website. This represents a legitimate interest within the meaning of Article 6(1)(f) GDPR.

You can find more information on handling of user data in Google’s privacy policy: https://policies.google.com/privacy?hl=en&gl=ZZ.

 

14. Font Awesome

In order to ensure the uniform display of fonts, this website uses so-called Web Fonts provided by Fonticons, Inc. When you visit a page, your browser loads the necessary web fonts in your browser cache in order to display texts and fonts correctly.

In order to do this, the browser you are using must connect to the Fonticons, Inc. server. This informs Fonticons, Inc. that a visit to our website was carried out via your IP address. We use web fonts in the interest of displaying our online platform in a consistent, appealing way. This represents a legitimate interest within the meaning of Article 6(1)(f) GDPR.

If your browser does not support web fonts, your computer will use a standard font.

You can find more information on Font Awesome at https://fontawesome.com/help and in the Fonticons, Inc. privacy policy: https://fontawesome.com/privacy.