Data Protection Notice of De Nora Deutschland GmbH

(for german click here)

We take the protection of personal data extremely seriously in our company.

The new Privacy Policy of the EU General Data Protection Regulation (DSGVO) and of other data protection regulations has been effective since 25 May 2018 imposing additional obligations on companies concerning the protection of personal data. The Privacy Policy aims at creating more transparency for the parties concerned. 

I.   Controller

This Data Protection Notice applies to data processing by:

De Nora Deutschland GmbH

Industriestraße 17

63517 Rodenbach

E-Mail: datenschutz@denora.com

II.   Data protection officer

If you require any further information, please contact our Data Protection Officer at datenschutz@advivari.de.  

III.   Gathering and storing personal data / kind of data / purpose

1. Data of interested bodies or contractual partners

If you conclude a contract with us or if you contact us on the basis of a memorandum of understanding or of a preliminary agreement, we will process the following information:

• form of address, first name, and surname
• a valid e-mail address
• address
• telephone number (landline and/or mobile), fax number
• any information we require to work out a proper quotation or to meet our contractual obligations
• banking details, if applicable

Such data is processed

• in order to be able to identify you as an interested body or as a contractual partner
• in order to be able to create the quotation you requested or to meet the contractual obligations of the agreement concluded with you
• in order to run proper correspondence with you
• in order to be able to create a proper invoice
• in order to be able to enforce our own claims and rights, if required

Data processing is required as per art. 6, para. 1, sentence 1, lit. b of the DSGVO for the purpose of proper execution of preliminary contractual actions based on your enquiry and mutually to meet the obligations arising from any contract concluded with you, as stated above.

Any personal data gathered will be saved until your enquiry has been fully dealt with or until the contract with you has expired taking the relevant tax-related and trade-related documentation requirements and storage regulations (as per German Commercial Code or German Fiscal Code) into account. The data will then be deleted unless there is legitimate interest for extended data storage as per art. 6, para. 1, lit. f of the DSGVO. Such legitimate interest is based on the execution of our further business interests in connection with your company, e.g. saving your contact details in case we intend to place another order with you. We will then delete your data as soon as this purpose has been served.

We will use your e-mail address to provide you with our Newsletter magazine and to invite you to our information meetings to inform you about any innovation concerning our products and our technologies. The provision of our Newsletter magazine and any invitation to an information meeting are to be regarded as direct advertising. Such direct advertising is to make our company more well-known and to increase our market share. This is our legitimate interest. The legal basis for data processing in this case is art. 6, para. 1, lit. f of the DSGVO. 

If you have been accepted as a participant to a video conference, your name and your e-mail address will be used to identify you as a participant and to grant you access to the particular digital conference. Running a video conference – either to avoid personal contact for health reasons or to avoid journeys for environmental and cost saving reasons – is also in our legitimate interest. We may point out that you are entitled at any time to deactivate the camera function on your computer so that collection of your personal image data is unfeasible. If it is necessary for business reasons to make the exact contents and full details of a video conference available to relevant bodies, such a video conference may be subjected to recording. Such recording would then be also in our legitimate interest. Please note that you will be informed by the system about the recording beforehand. In terms of legal compliance, running and recording a video conference is based on Art. 6 Paragraph 1 Sentence 1 Letter f of the DSGVO. The recorded video conference will be deleted as soon as the purpose of the recorded data has been fulfilled.

2. Data of corporate contacts

If you are the contact person of a company and have contacted us, we will process your personal data in order to establish communication with the company you are working for.

For this purpose, we will process the following information:

• form of address, first name, surname, position/job title
• a valid e-mail address
• the name of the company you are working for, also the name of your employer or client
• your business phone number (landline and/or mobile), fax number

This kind of data processing is legally based on art. 6, para. 1, lit. f of the DSGVO for the purpose of communication with the company you are working for or to exercise our further business interests in connection with the particular company, e.g. order acquisition or to place a new order with the company you are working for. Such purpose constitutes our legitimate interest. We will delete your personal data as soon as such processing purpose has been fulfilled taking the relevant tax-related and trade-related documentation requirements and storage regulations (as per German Commercial Code or German Fiscal Code) into account. 

We will use your business e-mail address to provide you with our Newsletter magazine and to invite you to our information meetings. This is to inform you about any news of the IT industry. Providing you with our Newsletter and inviting you to our information meetings are to be regarded as direct advertising and serve the purpose to make our company more well-known and to increase our market share. This is our legitimate interest. The legal basis for data processing in this case is art. 6, para. 1, lit. f of the DSGVO.
 
If you have been accepted as a participant to a video conference, your name and your e-mail address will be used to identify you as a participant and to grant you access to the particular digital conference. Running a video conference – either to avoid personal contact for health reasons or to avoid journeys for environmental and cost saving reasons – is also in our legitimate interest. We may point out that you are entitled at any time to deactivate the camera function on your computer so that collection of your personal image data is unfeasible. If it is necessary for business reasons to make the exact contents and full details of a video conference available to relevant bodies, such a video conference may be subjected to recording. Such recording would then be also in our legitimate interest. Please note that you will be informed by the system about the recording beforehand. In terms of legal compliance, running and recording a video conference is based on Art. 6 Paragraph 1 Sentence 1 Letter f of the DSGVO. The recorded video conference will be deleted as soon as the purpose of the recorded data has been fulfilled. 

3. Personal data of applicants

If you apply for a vacant position in our company, we will process the documents in support of your application containing your contact details, your personal data, your professional records, and your references and other documents. 

We will process such data in order to be able to run a proper application procedure on the legal basis of art. 6, para. 1, lit. b of the DSGVO. If the application procedure does not result in the conclusion of an employment contract, we will delete your personal data within three (3) months after the termination of the application procedure. The legal basis for saving your personal data for up to three (3) months after the termination of an application procedure is art. 6, para. 1, lit. f of the DSGVO. The purpose of such data storing and our legitimate interest in such data storing procedure are to have such data at hand in case you intend to make claims.

If you have been accepted as a participant to a video conference, your name and your e-mail address will be used to identify you as a participant and to grant you access to the particular digital conference. Running a video conference – either to avoid personal contact for health reasons or to avoid journeys for environmental and cost saving reasons – is also in our legitimate interest. We may point out that you are entitled at any time to deactivate the camera function on your computer so that collection of your personal image data is unfeasible. In terms of legal compliance, running a video conference is based on Art. 6 Paragraph 1 Sentence 1 Letter f of the DSGVO. The recorded video conference will be deleted as soon as the purpose of the recorded data has been fulfilled.

4. Data of another natural person

If you are neither a contractual partner nor an interested person, applicant, or contact of a company  but have contacted us for any other reason, we may process the following information:

• form of address, first name, surname
• a valid e-mail address
• address
• telephone number (landline and/or mobile), fax number
• any information required to fulfill our contact
• banking details, if applicable

Such data is processed

• in order to be able to identify you
• in order to be able to deal with your request or to initiate or to execute the contract with you
• in order to meet our legal obligations
• in order to be able to communicate with you properly
• in order to be able to create a proper invoice for you or to settle your invoice
• in order to be able to enforce our own claims and rights as per the existing legal relationship

Your request will be dealt with on the basis of your voluntary consent as per art. 6, para. 1, lit. a of the DSGVO. Data processing for contract initialization or performance of a contract is based on art. 6, para. 1, lit. b of the DSGVO. Data processing for the purpose of the fulfilment of a legal obligation is based on   the legal basis of art. 6, para. 1, lit. c of the DSGVO. 

As soon as your request has been dealt with, your personal data will be deleted taking any legal data storage requirements and regulations into account.

If you have been accepted as a participant to a video conference, your name and your e-mail address will be used to identify you as a participant and to grant you access to the particular digital conference. We may point out that you are entitled at any time to deactivate the camera function on your computer so that collection of your personal image data is unfeasible. In terms of legal compliance, running a video conference is based on Art. 6 Paragraph 1 Sentence 1 Letter f of the DSGVO. Running a video conference – either to avoid personal contact for health reasons or to avoid journeys for environmental and cost saving reasons – is also in our legitimate interest. The recorded video conference will be deleted as soon as the purpose of the recorded data has been fulfilled.

IV.   Passing on personal data

We will pass on your personal data to a third party only if:
• you have explicitly agreed to any such data transfer as per art. 6, para. 1, sentence 1, lit. a of the DSGVO

• passing on such data is required to enforce, to exercise, or to defend any legal right or to make direct advertising as per art. 6, para. 1, sentence 1, lit. f of the DSGVO and there is no reason to assume that you would have an interest primarily worthy of protection in your data being not transferred to a third party and you have not explicitly disapproved such data transfer for direct advertising purposes respectively

• passing on such data constitutes a legal obligation as per art. 6, para. 1, sentence 1, lit. c of the DSGVO, and

• passing on such data is permitted by law as per art. 6, para. 1, sentence 1, lit. b of the DSGVO for the purpose of the fulfilment of contractual obligations or to initiate a new contract with you.
Your personal data will be passed on to the following recipients / categories of recipient, if applicable: 
We have subcontracted certain IT services and telecommunication services to group companies or to service providers. Therefore, such companies or service providers may gain an insight into your personal data within the framework of their particular activities.

We will pass on your personal data to financial service providers in order to be able to make payments or to receive payments and to providers of shipping services in order to dispatch goods.

We collaborate with collection agencies and with providers of legal services in case you are subject to a delay in payment or if we have to enforce or defend our rights. The data will be passed on to a third party as per art. 6, para. 1, lit f of the DSGVO. The purpose of data transfer constitutes our legitimate interest.

As far as we need to meet our legal obligations, we also pass on personal data to tax advisors, auditors, and authorities.

As per art. 6, para. 1, lit. f of the DSGVO, we may also pass on your personal data to a provider of security services who is responsible for security on our premises and for controlled access to our premises. Our legitimate interest is to protect our company against unauthorized and unintended access or interference.

Personal data may be passed on or may be allowed insight into within the framework of an audit conducted by an external company as per art. 6, para. 1, lit. f of the DSGVO. Our legitimate interest is to consolidate and strengthen our relations to suppliers and customers and to obtain certifications which are crucial for a successful outside image of our company.

The participants of a video conference have the right to demand access to the recorded data in the aftermath of a video conference if the contents and the full details of the video conference need to be made available to the participants of the video conference for business reasons. The lawful basis for this right is Art. 6 Paragraph 1 Sentence 1 Letter f of the DSGVO. The purpose of such data access conforms to our legitimate interest in such access. As soon as the purpose of the data processing measure has been fulfilled, the possibility for the participants to access such data is terminated.

V.   Rights of a party concerned

You have the right:

• • as per art. 15 of the DSGVO, to request information on the personal data processed by us. This particularly applies to the purpose of data processing; to the category of personal data; to the categories of data recipient gaining insight into your personal data; to the intended data storing time; to the right to have personal data corrected, deleted, limited in processing, or contradicted; to the right to object; to the origin of your data unless such data was gathered by us; and to any automated decision-making including profiling. And you do have the right to claim provision of convincing information on any details related to the points as stated in this section;
  • as per art. 16 of the DSGVO, to request immediate correction of incorrect or incomplete personal data saved by us;
  • as per art. 17 of the DSGVO, to request the deletion of your personal data saved by us unless processing such data is required to exercise the right to freedom of speech and information, to meet any legal obligation, for public interest reasons, or to enforce, to exercise, or to defend any legal right;
  • as per art. 18 of the DSGVO, to request limitation of the processing of your personal data if the correctness of such data is denied by you; if processing such data is illegal but you reject deletion of such data and we do no longer require such data and you require such data to enforce, to exercise, or to defend any legal right; or if you have filed an objection against the processing of such data as per art. 21 of the DSGVO;
  • as per art. 20 of the DSGVO, to obtain your personal data you provided us with in a structured, customary, and machine-readable format or to request data transfer to another person in charge;
  • as per art. 7, para. 3 of the DSGVO, to revoke at any time the data processing consent you provided us with. As a consequence, we will no longer be authorized to continue the processing of your personal data as previously done based on your consent; and
  • as per art. 77 of the DSGVO, to complain to a regulatory body. Usually such a complaint can be filed with the regulatory body responsible for your regular place of residence, for your workplace, or for our headquarters.

 VI. Right to object and power of revocation

If your personal data is processed on the basis of legitimate interest as per art. 6, para. 1, sentence 1, lit. f of the DSGVO, you have the right to file an objection as per art. 21 of the DSGVO against the processing of your personal data based on reasons resulting from your special situation or based on objecting direct advertising. In the latter case, you have a general right to object which will be accepted by us without you having to indicate any special situation. 

If you have provided us with your consent to process your personal data, you have the right to revoke such consent at any time. Such revocation will then be effective for the future. 

If you wish to exercise your right to object or your power of revocation, please contact us via e-mail at datenschutz@denora.com.