Privacy Policy

1. General information

Thank you for your interest in what we offer. Data protection and data security have always been top priorities for us. That’s why we observe the provisions of the German Federal Data Protection Act (BDSG) and other legislation on data protection and privacy.

The subject of data protection is personal data. Pursuant to Article 4(1) of the EU General Data Protection Regulation (GDPR), “personal data” means any information relating to an identified or identifiable natural person. This includes identifiers such as name, mailing address, email address, phone number, and payment details.

The text below provides detailed information on how we handle your personal data.

 

2. Name and contact details of controller

The controller responsible for data processing on this website is:

FRIWO Gerätebau GmbH
Von-Liebig-Straße 11
48346 Ostbevern
Germany

Tel. +49 2532 81-0
Fax +49 2532 81-112

Executive management:
Rolf Schwirz
Oliver Freund
Dr. Walter Demmelhuber

 

3. Contact details of company data protection officer:

Our data protection officer, Mr. Heiner Niehüser, can be reached at the company address provided above and at

DSB Münster GmbH
Martin-Luther-King-Weg 42-44
48155 Münster
Germany
Tel.: +49 251 71879-0
email: datenschutz@dsb-ms.de

 

4. Scope and purpose of processing of personal data

4.1 When visiting this website

Server log files
When you access our website, the Internet browser you use automatically transfers data to the server for our website, which stores this data in a log file for a certain period. Up until the automatic erasure thereof, the following data is stored without further entry of the visitor:

  • IP address of the visitor’s device
  • Date and time of access by the visitor
  • Name and URL of the page accessed by the visitor
  • Website from which the visitor has accessed this site (“referrer URL”)
  • Browser and operating system of the visitor’s device and the name of the access provider used by the visitor

The processing of this personal data is justified pursuant to point (f) of Article 6(1) GDPR. Our company has a legitimate interest in data processing for the following purposes:

  • Promptly establishing a connection to the company’s website
  • Enabling user-friendly use of this website
  • Recognizing and ensuring the security and stability of the systems and facilitating and improving the administration of this website

Processing expressly does not take place for the purpose of gleaning insight into the identity of the visitor to this website.

The data is erased as soon as the purposes for which it has been collected have been achieved. In the case of data collection for the provision of the website, this is deemed to be the case when the relevant session has ended.

In the case of storage of the data in log files, this is deemed to be the case after three days at the most. It is possible that data may be stored beyond that. In this case, the users’ IP addresses are erased or anonymized with the result that it is no longer possible to associate them with the accessing client.

Cookies
Our website uses what are known as cookies. These are data packets exchanged between the server for this website and the visitor’s browser. They are stored by the devices used (desktop or notebook computer, tablet, smartphone, etc.) when this website is visited. In this regard, cookies cannot cause any harm to the devices used. In particular, they do not contain any viruses or other malware. Cookies are used to store information arising in conjunction with the specific device used in each case. Our company cannot use them by any means to directly identify any visitor to this website.

In the majority of cases, cookies are accepted according to a browser’s default settings. The browser settings can be adjusted in such a way that cookies are either not accepted on the devices used or the user receives a separate notification each time before a new cookie is placed.

However, please note that disabling cookies may make it impossible to use all of the features of this website optimally.

The use of cookies serves to make using the company’s website more convenient. For example, session cookies can be used to track whether the visitor has already visited individual pages of this website. After the visitor leaves the website, these session cookies are automatically erased.

Temporary cookies are used to improve user friendliness. These cookies are stored on the visitor’s device for a temporary period. If and when the visitor returns to this website, the site automatically recognizes that the visitor has been there before and which entries were made and settings selected at that time so the user does not have to repeat them.

Cookies are also used to analyze access to this website for statistical purposes and to improve our offerings. These cookies make it possible to automatically detect, on a return visit, that the visitor has already accessed the site itself or certain content on the website. In these cases, cookies are erased automatically after a pre-determined period.


Registering to receive our newsletter

1. Purposes of Processing
We send newsletter emails containing promotional information such as announcements of events and products, updates, and personnel changes within our company.

For newsletter sign-ups, we collect the email address along with timestamps of consent. The collection of email addresses is for the purpose of delivering the newsletter.

2. Legal Basis for Processing
The legal basis for processing data after signing up for the newsletter is your consent according to Art. 6 para. 1 lit. a) GDPR. The newsletter can generally only be received by you if you have a valid email address and have registered for newsletter delivery.

To ensure your proper newsletter sign-up, i.e., to prevent unauthorized sign-ups on behalf of third parties, we send you a confirmation email after your initial newsletter sign-up using the double opt-in procedure, requesting confirmation of registration.

3. Recipients of Data
The data is processed by the service CleverReach. CleverReach is a data processor and provides us with the ability to maintain, design, and schedule newsletter distribution lists.

CleverReach GmbH & Co. KG
Schafjückenweg 2
26180 Rastede
Germany

We have concluded a data processing agreement with CleverReach, obligating CleverReach to protect your data and not to disclose it to third parties.

Further information on CleverReach’s data analysis can be found here: www.cleverreach.com/en-de/newsletter-tool/newsletter-reporting/

You can view CleverReach’s privacy policy here: www.cleverreach.com/en-de/privacy-policy/

4. Duration of Data Storage
We only store your personal data until consent for processing is revoked unless longer storage is legally required or permitted.

The newsletter subscription can be canceled by you at any time. For this purpose, each newsletter contains a corresponding unsubscribe link. Alternatively, you can revoke your consent at any time via marketing@friwo.com.

5. Success Analysis
Purposes of Processing
We analyze the sending and receipt of our newsletter to continuously optimize its content. To do this, we collect, for example, how many users have opened our newsletter. The newsletters contain a small file for this purpose, which is retrieved from the sending server when the newsletter is opened.

The evaluations serve to recognize your reading habits and tailor our content to you.

6. Categories of Personal Data
As part of this retrieval, technical information such as browser and operating system information, as well as the IP address and time of retrieval, are initially collected.

Statistical surveys also include determinations of whether the newsletters are opened, when they are opened, and which links are clicked.

7. Your Rights
A separate revocation of the success measurement is unfortunately not possible; in this case, the entire newsletter subscription must be canceled or revoked. For this purpose, each newsletter contains a corresponding unsubscribe link. Alternatively, you can revoke your consent at any time via marketing@friwo.com.

8. Right of objection
If your personal data is processed by us on the basis of legitimate interests according to Art. 6 para. 1 lit. f) GDPR, you have the right, according to Art. 21 GDPR, to object to the processing of your personal data, provided that this is done for reasons that arise from your particular situation. If the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right to object without the requirement of specifying a particular situation.

If you wish to exercise your right of revocation or objection, an email to the contact address listed above is sufficient.

 

Using our contact form
If you have questions of any kind, you can contact us using a form provided on the website.

When you fill out this form, you are required to provide a name and valid email address so that we know who has sent the inquiry and can respond to it. Further information can be provided voluntarily.

The legal basis for processing is point (b) of Article 6(1) GDPR in the case of customer inquiries and point (f) of Article 6(1) GDPR in all other circumstances. The data processing takes place exclusively for the purpose of handling and responding to inquiries.

The personal data collected is automatically erased as soon as the inquiry has been settled and there is no legal basis for further storage.

Participation in webinars using GoToWebinar
A webinar is comparable to an in-person seminar, but it takes place on a computer-assisted or software-assisted basis via the Internet.

To hold webinars, FRIWO Gerätebau GmbH utilizes the software solution from provider GoToWebinar of LogMeIn Ireland Limited (Bloodstone Building Block C, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland). To participate in a webinar, you are required to have registered for the seminar on our website beforehand, using the relevant links. The following data is collected as part of the registration process: first name, last name, email address. This personal data is stored and processed by LogMeIn Ireland Limited.

The data is processed by LogMeIn Ireland Limited (in the role of processor) based on Article 28 GDPR. The data is processed in Germany, the European Union, and the United States within the scope permissible by law. An adequate level of protection has been established for the processing of data in the United States by agreeing on the EU standard contractual clauses in the current version thereof. In this context, please also see the privacy policy of LogMeIn Ireland Limited:

https://www.logmeininc.com/de/legal/privacy

To implement the webinar on an order-related basis, we transfer your registration and/or customer data to LogMeIn Ireland Limited.

Statistical data is transferred to FRIWO Gerätebau GmbH during and after the implementation of the webinar. If you participate in a webinar or ask or answer a question during the webinar, we also receive, in addition to your registration data, information about the duration of your participation, interest in the webinar, and the question asked or answer given for purposes of further customer care or to improve the user experience. As an option, it is possible to process documents and forms together with your contact person (customer guidelines). The webinars are recorded regularly in order to provide them to webinar participants and other customers of FRIWO Gerätebau GmbH for later access.

Questions asked by participants during the seminar and the relevant answers are also recorded and played back if and when the webinar is accessed later on. Statistical data is collected during and after implementation of the webinar. If you participate in a webinar, we also receive, in addition to your registration data, information about the duration of your participation, interest in the webinar, and questions asked or answers given for purposes of further customer care or to build the user experience. An encrypted connection between you and the webinar organizer is established. We do not record the audio or image information transmitted within the scope of this session. When you click “Participate,” you are confirming that you will not record the session or take any screenshots of the session, either.

You can end the session at any time by simply closing the browser window or quitting the program or app. If your contact person ends the session, your session participation will automatically be terminated as well.

The legal basis for processing is point (f) of Article 6(1) GDPR. Our legitimate interest consists of the effective implementation of online meetings. Should the online meeting be implemented within the scope of an existing contractual relationship or as part of the preparations to enter into such a relationship, point (b) of Article 6(1) GDPR applies as an additional legal basis. Online meetings are recorded only if and when we have notified you thereof in advance and you have consented to the recording thereof. In this case, the legal basis is point (a) of Article 6(1) GDPR.

We store your participant data, such as the name and email address provided, for one month. The data on your device remains stored until you clear your browser data. The period for which recorded online meetings are stored will be communicated to you before recording starts. Should you withdraw your consent, we will erase the data concerning you that we have stored.

Tracking tools:

a) General information on tracking tools
You as a user decide on the use of the tracking measures enumerated below and used by us based on your consent pursuant to point (a) of Article 6(1) GDPR.

If you agree to your data being stored and used by the relevant tracking tool, you can enable storage and use in our consent manager. The consent manager is a banner that is presented to you the first time you use our site. It allows you to specify in detail whether tracking tools can be used, and if so, which.

Our aim in the tracking measures we use is to ensure demand-driven design and the ongoing optimization of our website. We also use these tracking measures to collect statistical information on the use of our website and analyze it for the purpose of optimizing what we offer for you.

For the relevant purposes of data processing and categories of data, please see the descriptions of the specific tracking tools.

b) Usercentrics
This website uses a service from Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich, Germany. The service is a consent management service. Usercentrics is used to obtain your consent as required under data protection and privacy law to the use of the tracking tools enumerated below. In this context, the following data is processed:

  • Browser information
  • Date and time of visit
  • Device information
  • Geographic location
  • Opt-in or opt-out data
  • Page path for the website
  • Website URLs

The legal basis for processing is point (c) of Article 6(1) GDPR. The processing is necessary in order to comply with a legal obligation (obtaining and managing consent under data protection and privacy law).

This data (consent and withdrawal of consent) is stored as long as is necessary for processing purposes.

c) HubSpot
We use a service from a company called HubSpot for various purposes. HubSpot is a software company from the United States with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Tel.: +353 1 5187500.

With HubSpot, we can cover various aspects of our online marketing. These include but are not limited to the following:

  • Email marketing
  • Social media publishing
  • Reporting
  • Contact management (e.g., division into user groups & CRM)
  • Landing pages
  • Contact forms

The HubSpot login service allows you to learn more about our company, download content, and provide your contact details and further information, some of which constitutes personal data. This information and the content of our website are stored on servers of our software partner HubSpot. We may use them to contact visitors to our website and learn which of our services are of interest to you. All of the information we collect is subject to this privacy policy. We use all of the information collected exclusively to optimize our marketing measures.

More information from HubSpot on use under the GDPR: https://www.hubspot.de/data-privacy/gdpr

As part of our efforts to optimize our marketing measures, the following data may be collected and processed via HubSpot:

  • Aggregated use
  • Login information for the HubSpot subscription service
  • Websites accessed
  • Operating system and version
  • Browser type
  • Click stream data
  • Files displayed on site
  • Duration of visit
  • Domain names
  • Events occurring within the application
  • Geographic position
  • Device ID
  • Device model and version
  • Information on how often the application is used
  • Internet service provider
  • IP address
  • Performance data
  • Mobile apps data
  • Navigation information
  • Referrer URL
  • Where the application was downloaded from
  • Access times

 

We also use HubSpot to provide contact forms. For further information on this, please see the section titled “Using our contact forms.”

The legal basis for processing is your consent pursuant to point (a) of Article 6(1) GDPR. If you do not wish the data mentioned above to be collected and processed via HubSpot, you can refuse consent in the Consent Manager or withdraw consent at any time with effect for the future.

The personal data will be stored as long as it is needed in order to fulfill the purpose of processing. The data will be erased as soon as it is no longer needed to achieve this purpose.

Within the scope of processing via HubSpot, personal data is transferred to the United States.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries.

d) Google Tag Manager
This website uses the Google Tag Manager service. Tag Manager is a tool used to manage what are known as tags, which are used for tracking in online marketing. Tag Manager itself does not process any personal data, since it serves purely to manage other services, such as Google Analytics and others.

For further information on Tag Manager, please visit https://www.google.com/intl/de/tagmanager/use-policy.html.

e) Google Analytics
For demand-driven design of our website, we create pseudonymous use profiles using Google Analytics. For this purpose we use the analysis tool Google Analytics 4. The operator of this service is Google Ireland Limited, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

Google Analytics uses cookies, which are text files stored on your computer that make it possible to analyze your use of this website.

If you agree to your data being stored and used, you can enable storage and use by using our Consent Manager. The retention period of user and event data is limited to a storage period of 2 months. Beyond that, Google Signal is not used.

The following data is collected and processed using Google Analytics:

  • App updates
  • Pages visited
  • Browser information
  • Click path
  • Date and time of visit
  • Device information
  • Downloads
  • Flash version
  • IP address (anonymized)
  • JavaScript support
  • Purchase activity
  • Use data
  • Referrer URL
  • Location information
  • Widget interactions

When this function is activated in the Consent Manager, the processing of your personal data within the scope of Google Analytics cookies takes place on the basis of your consent pursuant to point (a) of Article 6(1) GDPR.

The information generated by the cookie concerning your use of our website is usually transferred to a Google server located in the United States and stored there. However, since we have activated IP anonymization on this website, your IP address will be truncated (shortened) by Google beforehand if you are located in any Member State of the European Union or any country in the European Economic Area.

Only in exceptional cases is the complete IP address transferred to a Google server in the United States and shortened there. Google will use this information to analyze your use of the website for us, compile reports on website activity, and provide us with further services related to website use or the use of the Internet in general. We use Google Analytics, for example, to analyze clicks from Google Ads for purely statistical purposes. For information on the use of data by Google, please visit

http://www.support.google.com/analytics/answer/6004245 and www.google.com/policies/privacy/partners/.

You can also prevent cookies from being stored by adjusting your browser settings accordingly.

If you do this, an opt-out cookie will be stored in your browser, preventing Google Analytics from storing use data.

If you clear your cookies, the Google Analytics opt-out cookie will be erased as well. The opt-out will need to be reactivated the next time you visit our site.

The information generated by the cookie relating to your use of the website, such as the following, is transferred to a Google server in the United States and stored there:

  • Website visitor’s browser type/version
  • Website visitor’s operating system
  • Referrer URL (the page visited beforehand)
  • Accessing computer’s host name (IP address)
  • Time of server query

The personal data will be stored as long as it is needed in order to fulfill the purpose of processing. The data will be erased as soon as it is no longer needed to achieve this purpose.

The data may be transferred to the following recipients in the United States within the scope of processing, in addition to Google Ireland Limited:

  • Google LLC
  • Alphabet Inc.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries.

The information is used to analyze the use of the website, compile reports on website activity, and provide further services related to website use or the use of the Internet in general for purposes of market research and demand-driven design of this website.

You can also prevent the data generated by the cookie and relating to your use of the website (including your IP address) from being collected and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).

As an alternative to the browser add-on, particularly in the case of browsers on mobile devices, you can also prevent the data from being collected by Google Analytics by clicking https://tools.google.com/dlpage/gaoptout. This will place an opt-out cookie that prevents your data from being collected on future visits to this website. The opt-out cookie is valid only in this browser and only for our website. It is stored on your device. If you clear cookies in this browser, you will have to place the opt-out cookie again.

For further information regarding data protection and privacy in connection with Google Analytics, please see the Google Analytics help pages (https://support.google.com/analytics/answer/6004245?hl=de).

f) Google Audiences / Remarketing
We use Google Audiences / Remarketing on this website. The operator of this service is Google Ireland Limited, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

The purpose of this service is to present personalized ads to you as a visitor on the basis of your interests, which are found by analyzing your website use. The cookies store anonymized or pseudonymized data relating to the use of the website. If you visit further websites that also use these services, then ads that match your interests to date will be presented to you.

The following data is collected and processed during this:

  • Pages visited
  • IP address
  • Duration of visit
  • Other information on website use
  • Content in which the user is interested

The legal basis for processing is your consent pursuant to point (a) of Article 6(1) GDPR. If you do not wish the data mentioned above to be collected and processed by Google Audiences/Google Remarketing, you can refuse consent or withdraw consent at any time with effect for the future.

Your data may be transferred to the United States within the scope of processing by Google Audiences/Remarketing.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries.

g) Google Ads and Google Ads Conversion Tracking
We use the Google Ads service on our website. The operator of this service is Google Ireland Limited, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. The purpose of this service is what is known as conversion tracking, which means we can see what has occurred after you click on one of our ads. To this end, cookies valid for a limited term are placed on your computer.

The following data is collected and processed using Google Ads:

  • Pages visited
  • Browser language
  • Browser type
  • Cookie ID
  • Cookie information
  • Duration of website visit
  • Ad clicked
  • Content in which the user is interested
  • IP address
  • Website use data
  • Referrer URL
  • Web queries

This processing takes place based on your consent in accordance with point (a) of Article 6(1) GDPR. If you do not wish the data mentioned above to be collected and processed by Google Ads, you can refuse consent or withdraw consent at any time with effect for the future.

The personal data will be stored as long as it is needed in order to fulfill the purpose of processing. The data will be erased as soon as it is no longer needed to achieve this purpose.

The data may also be transferred to the following recipients within the scope of processing, in addition to Google Ireland Limited:

  • Google LLC
  • Alphabet Inc.

Data may be transferred to the United States within the scope of processing by Google Ads.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries.

h) YouTube
Our website uses plugins of the video platform YouTube, which belongs to Google. The service and the plugins are operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

The operator in Europe is Google Ireland Limited, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

When you visit one of our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. The YouTube server is also told which of our sites you have visited.

If you are logged in to your YouTube account, you allow YouTube to associate your surfing habits directly with your personal profile. You can prevent YouTube from doing so by logging out of your YouTube account.

The use of YouTube is necessary for the purpose of an appealing and technically functional presentation of the video content of our online offerings.

This processing takes place based on your consent in accordance with point (a) of Article 6(1) GDPR. If you do not wish the data mentioned above to be collected and processed by YouTube, you can refuse consent or withdraw consent at any time with effect for the future.

The personal data will be stored as long as it is needed in order to fulfill the purpose of processing. The data will be erased as soon as it is no longer needed to achieve this purpose.

Please note that if you do not consent, you may not be able to use all of the functions of our website, particularly playing video content, in full.

The following data may be collected and processed through the use of YouTube:

  • Device information
  • Videos watched
  • IP address
  • Referrer URL

The data may be transferred to the following recipients, and thus to the United States, within the scope of processing, in addition to Google Ireland Limited:

  • Google LLC
  • Alphabet Inc.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries.

Please see YouTube’s privacy policy for more information on the handling of user data: https://www.google.de/intl/de/policies/privacy.

i) DoubleClick
As a result of the necessary use of YouTube plugins, our website also receives the DoubleClick tracker, an online marketing tool of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S.A. (“Google”). Among other things, this tool uses cookies, which are small text files stored locally in the interim cache of your Web browser on your device. Via a cookie ID, Google collects information on which ads are served in which Web browser. This prevents ads from being shown repeatedly.

DoubleClick can also use cookie IDs to collect information on conversions, which are related to ad queries. This is the case, for example, if you see a DoubleClick ad and later access the advertiser’s website using the same Web browser and purchase something there.

According to Google, the cookies mentioned above do not contain any personal data. Through the use of DoubleClick, your browser automatically establishes a direct connection to the Google server.

We have no influence over the scope or further use of the data collected by Google through the use of DoubleClick. As far as we know, Google receives the information that you have accessed the relevant part of our website or clicked one of our ads.

If you have a user account with Google and are logged in, Google can associate the visit with your user account. Even if you are not registered with Google or are not logged in, it is possible that Google will learn your IP address, compare it against data of Google’s own, and store your user behavior.

The use of YouTube is necessary for the purpose of an appealing and technically functional presentation of the video content of our online offerings, and DoubleClick for Publisher is associated by the provider with the use of YouTube.

You can consent to the use of YouTube, and thus of DoubleClick, by activating this function in our consent manager. The legal basis for the processing of your personal data is thus your consent pursuant to point (a) of Article 6(1) GDPR.

Please note that if you do not consent, you may not be able to use all of the functions of our website, particularly playing video content, in full.

You can prevent cookies from being installed by clearing existing cookies and disabling the storage of cookies in your Web browser settings.

Please note that if you do this, you may be unable to use all of the functions of our website in full. You can also prevent cookies from being stored by adjusting your Web browser settings to block cookies from the domain “www.googleadservices.com” (https://www.google.de/settings/ads).

Please note that this setting will be erased if you clear your cookies. You can also disable interest-based ads by visiting www.aboutads.info/choices. Please note that this setting will also be erased if you clear your cookies.

The data may be transferred to the following recipients, and thus to the United States, within the scope of processing, in addition to Google Ireland Limited:

  • Google LLC
  • Alphabet Inc.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries.

j) Facebook Custom Audiences and Facebook pixels
This website also uses the Facebook Custom Audiences service. Facebook pixels are placed on our website for this service.

Both services are operated by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin, D02, Ireland. Facebook Custom Audiences allows us to approach you with interest-related ads on the Facebook social network.

To make this possible, we have implemented the Facebook remarketing tag on our website. This tag establishes a direct connection with the Facebook servers when you visit the website. As a result, Facebook receives information on the pages of our site that you have visited. Facebook then matches these up with your Facebook user account. The next time you visit Facebook, you are then shown personalized, interest-related ads (Facebook ads). Custom Audiences is also used to personalize and optimize the website.

The following data is collected and processed using Facebook Custom Audiences:

  • Content viewed
  • Views and interactions with content and ads and services
  • User agent
  • Browser information
  • Browser type
  • Cookie ID
  • Device information
  • Success of marketing campaigns
  • Facebook user ID
  • Facebook cookie information
  • Geographic location
  • Device operating system
  • Hardware/software type
  • Information from third-party provider sources
  • IP address
  • Non-sensitive user-defined data
  • Use data/user behavior
  • Pixel ID
  • Pixel-specific data
  • Referrer URL
  • Social media friend network
  • Transaction information
  • Conversions

The legal basis for processing is your consent pursuant to point (a) of Article 6(1) GDPR. If you do not wish the data mentioned above to be collected and processed via Facebook Custom Audiences, you can refuse consent or withdraw consent at any time with effect for the future.

The personal data will be stored as long as it is needed in order to fulfill the purpose of processing. The data will be erased as soon as it is no longer needed to achieve this purpose.

The data may also be transferred to the following recipients within the scope of processing, in addition to Facebook Ireland Limited:

  • Facebook Inc.

Data may be transferred to the United States within the scope of processing via Facebook.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries.

k) LinkedIn and LinkedIn Analytics
We use the retargeting tool and conversion tracking from LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”).

To this end, our website also incorporates the LinkedIn Insight Tag, which enables LinkedIn to collect statistical data about your visit and the use of our website and, on this basis, to provide us with relevant aggregated statistics. Beyond that, the service allows us to display interest-specific and relevant advertising offerings to you after you have learned about certain services, information, and offerings on the website.

The information concerning this is stored in a cookie. Please see the LinkedIn privacy policy for more information on data processing.

The following data is collected and processed during this:

  • Browser information
  • Device information
  • IP address
  • Referrer URL
  • Timestamp

The legal basis for processing is your consent pursuant to point (a) of Article 6(1) GDPR. If you do not wish the data mentioned above to be collected and processed via LinkedIn, you can refuse consent or withdraw consent at any time with effect for the future.

The personal data will be stored as long as it is needed in order to fulfill the purpose of processing. The data will be erased as soon as it is no longer needed to achieve this purpose.

Data may be transferred to the United States and to Singapore within the scope of processing via LinkedIn.

Through your selection by means of which you give us your consent to the use of the service in our consent manager, you also consent in accordance with point (a) of Article 49(1) GDPR to this transfer of data to a third country and affirm that you are aware that it may be the case that an adequate level of data protection cannot be guaranteed in these third countries

Registration for our shop
To use our online shop on an ongoing basis, you are required to register and create a customer account, which requires that personal data be provided. A personal customer account is set up the first time you register.

This requires that you provide the following personal data:

  • Form of address, name (first and last)
  • Company name, street address, postal code, city/town, country
  • email address and password
  • Phone number
  • VAT ID

We store the transmitted data temporarily until you confirm the registration. We use the “double opt-in” procedure for registration. This means your registration has not been completed unless and until you have confirmed your registration via an email sent to you for this purpose by clicking the link contained in the email.

We process the data collected during registration in order to provide access and allow you to use this access.

The processing of your data takes place on the basis of point (b) of Article 6(1) GDPR to perform a contract or to take steps prior to entering into a contract.

You can erase your customer account at any time by sending an email to marketing@friwo.com. No particular form is required. After your customer account is deleted, your data will be restricted for further processing and erased after the retention periods that apply to us under commercial and tax law have elapsed.

In this case, the legal basis for this further data processing is our legal obligation within the scope of statutory retention obligations pursuant to point (c) of Article 6(1) GDPR.

Friendly Captcha
Our shop uses the Friendly Captcha service of Friendly Captcha GmbH, Am Anger 3-5, 82237 Woerthsee, Germany.

Friendly Captcha is used to check whether data us entered on data screens of our websites (such as in contact forms) by a human or an automated program.

To this end, Friendly Captcha analyzes the website visitor’s behavior based on various features and assesses various further items of information as part of the analysis. This includes website visitors’ IP address, but it is anonymized immediately by Friendly Captcha.

The data processing occurring in conjunction with the use of Friendly Captcha takes place for the purpose of being able to ensure the security of our websites. The legal basis for the data processing is our legitimate interest in fulfilling legal requirements in order to ensure the security of data processing pursuant to point (f) of Article 6(1) GDPR.

Further information on privacy with Friendly Captcha is available on the provider’s website and in its privacy policy at https://friendlycaptcha.com/de/legal/privacy-end-users/.

 

4.1 Within our company

Employee data
This data is processed to perform a contract within the scope of employment agreements and to comply with legal obligations. The data is regularly transferred to social insurance bodies, tax authorities, and further bodies to comply with legal obligations. The data is erased after the statutory retention periods have elapsed. There is no automated decision making, including profiling, for this purpose.

The processing of this personal data is justified in accordance with Article 88 GDPR in conjunction with Sec. 26 (1) of the new version of the German Federal Data Protection Act (BDSG). It takes place on the basis of points (b) and (c) of Article 6(1) GDPR (performance of contract and legal obligation).

Customer data
This data is processed within the scope of executing our contracts with customers and to take steps prior to entering into a contract. The purposes of the data processing are geared toward the customer’s needs and may also encompass sales discussions/consultations and similar. Furthermore, we process personal data to take steps prior to entering into a contract and to perform contracts with suppliers and service providers on the basis of point (b) of Article 6(1) GDPR.

Contact via email
You can contact our company by email. To process your inquiry, we need your last name, an email address, and a phone number.

The legal basis for the processing of the personal data is your consent pursuant to point (a) of Article 6(1) GDPR, which is granted when you send the email. If your contact with us is aimed at entering into a contract, then the legal basis for the processing is point (b) of Article 6(1) GDPR.

The data processing takes place exclusively for the purpose of handling and responding to inquiries. The personal data collected is automatically erased as soon as the inquiry has been settled and there is no legal basis for further storage.

 

5. Legal basis for data processing

Where the legal bases are not already specifically indicated in section 4 of this text, the following applies to the processing of data:

  • Where we obtain the consent of the data subject for processing operations involving personal data, point (a) of Article 6(1) GDPR serves as the legal basis.
  • If the processing of personal data is necessary to perform a non-gratuitous or gratuitous contract, point (b) of Article 6(1) GDPR serves as the legal basis. This also applies to processing operations that are necessary to take steps prior to entering into a contract.
  • If the processing is necessary to comply with a legal obligation to which we are subject, then point (c) of Article 6(1) GDPR serves as the legal basis.
  • If the processing is necessary for the purposes of a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override such legitimate interest, then point (f) of Article 6(1) GDPR serves as the legal basis for the processing.

 

6. Duration of storage

Unless otherwise indicated in the individual case in this policy, we store personal data only as long as is necessary to fulfill the purposes pursued.

Your personal data will be erased as soon as the purpose of data processing no longer applies.

Where legitimate reasons within the meaning of Article 17(3) GDPR, such as a statutory retention obligation, conflict with the erasure of the data, the processing of the data is restricted during this period. For example, there is a statutory retention obligation based on obligations of documentation under tax and commercial law. In these cases, the data is erased if and when the reason for the further storage thereof, such as the retention period required by law, ceases to apply.

 

7. Recipients or categories of recipients of the data

Within our company, only those departments that require your data to fulfill their obligations receive the data.

In principle, your personal data is not transferred to third parties. Exceptions apply only to the extent that this is necessary in order to perform and settle contractual relationships with you, your consent has been obtained, statutory provisions require this, or we are entitled to disclose the data.

This includes but is not limited to disclosure to service providers with whom or which we contract (such as processors) or other third parties whose activity is required in order to perform the contract (such as shipping companies, banks, collection agencies, attorneys, tax advisors, government agencies, courts, experts, etc.). These third parties are not permitted to use the data transferred except for the stated purposes.

 

8. Rights of data subjects

Within the scope of the applicable statutory provisions, you have the right of access to information, rectification or completion, erasure, data portability, and restriction of processing, and the right to object to the processing of your personal data.

We take protecting your data very seriously. To ensure that personal data is not disclosed to third parties, please address inquiries by email or mail, with clear identification, to the address stated above.

Right of access to information
You have the right to obtain from us access to information regarding your personal data that is processed by us. In particular, you can request information regarding the purposes of processing, the category of the personal data, the categories of recipients to whom or which the data is or has been disclosed, the planned duration of storage, the existence of a right of rectification, erasure, or restriction of processing or of the right to object, the existence of a right to lodge a complaint, the origin of your data where we have not collected it ourselves, and the existence of any automated decision making, including profiling, and, where applicable, meaningful information concerning the details thereof (Article 15 GDPR).

Right of rectification or completion
You have the right to obtain from us the rectification of inaccurate personal data concerning you that is stored by us, and the completion of any such personal data that is incomplete, without undue delay (Article 16 GDPR).

Right of erasure
You have the right to obtain from us the erasure of the personal data concerning you that is stored by us except where the further processing thereof is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defense of legal claims (Article 17 GDPR).

Right of restriction of processing
You have the right to obtain from us the restriction of processing of your personal data where you contest the accuracy of the data, the processing is unlawful but you oppose the erasure of the data, we no longer require the data but you require it for the establishment, exercise or defense of legal claims, or you have objected to the processing pursuant to Article 21 GDPR (Article 18 GDPR).

Notification obligation on the part of the controller
If you have asserted your right of rectification, erasure, or restriction of processing toward us, we are obligated to notify all recipients to which or whom we have disclosed your personal data of such rectification or erasure of the data or the restriction of processing thereof, unless this proves impossible or involves disproportionate effort. You have the right to be informed of these recipients (Article 19 GDPR).

Right of data portability
You have the right of data portability, meaning the right to receive the personal data concerning you that is stored by us in a commonly used and machine-readable format (Article 20 GDPR).

You also have the right to have your personal data that we process on the basis of your consent or to perform a contract and using automation turned over to another controller in a commonly used, machine-readable format.

Where you request the direct transfer of the data to another controller, this will take place only to the extent that it does not restrict the rights and freedoms of other persons.

Right of objection
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (f) of Article 6(1) GDPR (data processing on the basis of weighing of interests).

If you object, we will refrain from continuing to process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves for the establishment, exercise or defense of legal claims.

 

9. Right to withdraw consent to data processing

If we process your personal data on the basis of your consent, you have the right to withdraw this consent at any time with effect for the future.

In the event of withdrawal of consent, we will erase the data in question without undue delay unless further processing thereof can be justified on a legal basis that does not require consent (such as statutory retention periods).

Your withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

 

10. Right to lodge a complaint with the data protection supervisory authority

Without prejudice to other legal remedies, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged will inform you on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.

The supervisory authority with jurisdiction over us is the North Rhine-Westphalia State Commissioner for Data Protection and Freedom of Information, whom you can reach as follows:

Kavalleriestr. 2-4,
40213 Düsseldorf
Germany
poststelle@ldi.nrw.de
https://www.ldi.nrw.de/

For an overview of all supervisory authorities, please visit https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

 

11. Last update; updates to this privacy policy

This privacy police was last updated in June 2022.

We reserve the right to adjust the privacy policy at regular intervals to reflect the underlying data processing operations or changes in the legal situation.