The security of personal data such as names, addresses, telephone numbers and email addresses is one of our key concerns. For this reason, we carry out all our online activities in accordance with data protection and data security laws. In the following, you will learn about which information we collect where necessary and how we treat said information.
1. Name and contact details of the controller in charge of data processing and of the data protection officer
This privacy notification applies to data processing by:
FRIWO Gerätebau GmbH
Phone +49 2532 81-0
Fax +49 2532 81-112
Rolf Schwirz, Tobias Tunsch
The data protection officer of FRIWO Gerätebau GmbH may be contacted at the address above or the following:
Data Protection Officer
DSB Münster GmbH
48155 Münster, Germany
Phone +49 251 71879-0
Fax +49 251 71879-290
2. Personal data
Personal data is defined as all information that relates to an identified or identifiable natural person. This includes information such as their real name, their address, their telephone number and their date of birth.
Because this data enjoys special protection, we only collect it if it is technically necessary. In accordance with our duties, we will explain in the following which information we collect while you visit our website and how this information is used.
3. Collection and storage of personal data, as well as the type and purpose of its use
a) When visiting the website
When you access our website www.friwo.com, the browser used on your device automatically sends information to our website’s server. This information is temporarily saved in a log file. The following details are recorded without any action on your part and stored until they are automatically deleted:
• IP address of the computer accessing the website
• the date and time of access
• the name and URL of the retrieved file
• the website from which access occurs (referrer URL)
• the browser used and, where applicable, the operating system of your computer, as well as the name of your access provider
We use the data described for the following purposes:
• to ensure the trouble-free establishment of a connection to the website
• to ensure the convenient use of our website
• to analyse system security and stability
• for administrative purposes
The legal basis for data processing is provided by Art. 6 (1) Clause 1 (f) of the General Data Protection Regulation (GDPR). Our legitimate interest stems from the data collection purposes listed above. In no instance do we use the collected data for identifying you as a person.
b) When registering for our newsletter
If you would like to receive the newsletter, we require a valid email address and information from you that allows us to verify that you are the owner of the email address / that its owner agrees to receiving the newsletter. Provided that you have given your express consent under Art. 6 (1) Clause 1 (a) GDPR, we use your email address to regularly send you our newsletter. The valid email address is only used to send the newsletter and is not passed on to any third parties.
We only use the data collected in our newsletter’s registration mask to send our newsletter, where we provide information about all of our services. Once you have registered, we will send you a confirmation email containing a link that you must click on to complete the registration process for our newsletter (double opt-in).
When you register for the newsletter, we save your IP address and the date of registration. The only purpose that saving this information serves is to provide proof in the event that a third party misuses an email address and registers to receive the newsletter without the knowledge of the authorised party.
You can, at any time, revoke the consent you have given us to save your data and email address and to use them to send the newsletter. You may unsubscribe at any time, for example by clicking on a link in the newsletter itself or in your profile area, or by sending a message to the points of contact named above.
c) When using our contact form
We provide you with the opportunity to contact us with questions of any kind using a form that is available on the website. In order to use this form, it is necessary for users to enter a valid email address so that we know who the enquiry is from and can respond to it. Other information may be provided voluntarily.
Data processing for the purpose of establishing contact with us is carried out in accordance with Art. 6 (1) Clause 1 (a) GDPR based on your consent, which you provide voluntarily.
The personal data that we collect in relation to the use of this contact form is automatically deleted once your enquiry has been addressed.
We use HubSpot for marketing activities on our website. HubSpot is a service provided by HubSpot Inc., 25 First Street, Cambridge, MA 02141, USA, with the branch office HubSpot Ireland Limited, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland. HubSpot has certified its compliance with the EU-U.S. Privacy Shield Framework.
HubSpot is an integrated software solution that we use to manage various aspects of our online marketing activities. We use HubSpot for our own marketing activities, for lead generation and for customer service purposes. Among other things, that includes email marketing, which covers the sending of newsletters and automated mailings, social media publishing and reporting, contact management including user segmentation and CRM, landing pages and contact forms. That involves recording e mail addresses, telephone numbers, the company name, the (company) address and the contact name.
HubSpot uses web beacons and cookies, small text files that are saved locally to your end-user device, in your web browser’s cache, and that allow your use of the website to be analyzed. HubSpot evaluates the information recorded (e.g. IP address, geographic location, type of browser, duration of the visit and pages accessed) on our behalf to allow us to generate reports about the visit and the pages viewed. Information recorded by HubSpot, as well as the content of our website, are saved on the servers of HubSpot’s service providers. Insofar as you have consented pursuant to Article 6 (1) (a) GDPR, processing on this website is carried out for the purpose of website analysis.
Our login service allows visitors to our website to find out more about our portal, download content, and provide their contact details and other demographic information. If you subscribe to the newsletter mentioned above, and download studies and other documents, we can use HubSpot to record your visits to our website and additional personal information (above all your name and email address) and, where applicable, offer you targeted information about your preferred topics. That information, and the content of our website, are saved on the servers of our software partner, HubSpot. We can use it to contact visitors to our website and determine which services and offers are of interest to them.
Data protection notice for webinars using GoToWebinar
A webinar is comparable to a face-to-face seminar and is conducted via the internet using computers and software. FRIWO Gerätebau GmbH uses the software solution GoToWebinar from LogMeIn Ireland Limited (Bloodstone Building Block C, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland) to conduct webinars. To participate in a webinar you must log in via https://register.gotowebinar.com/register/2596295905553744139. When you log in you are asked to enter the following information: first name, last name and e-mail address. That personal data is saved and processed by LogMeIn Ireland Limited.
The data is processed by LogMeIn Ireland Limited (the processor) on the basis of Article 28 of the EU General Data Protection Regulation (GDPR). The data is processed as permitted by law in Germany, the European Union and the USA. Data processing in the USA is subject to appropriate protections through the conclusion of EU standard contractual clauses. Please also note the privacy policies of LogMeIn Ireland Limited in this regard: https://www.logmeininc.com/legal/privacy
To conduct the webinar as instructed, we transmit your log-in and customer data to LogMeIn Ireland Limited. Statistical data is transmitted to FRIWO Gerätebau GmbH during and after the webinar. If you participate in a webinar, ask or answer a question during the webinar, in addition to your log-in details, we receive information about the period of participation, your interest in the webinar, and any questions asked and/or answers given for the purposes of customer support and to further improve the user experience. You have the option to edit documents and forms together with your contact persons (customer guide). Webinars are regularly recorded to make them available to participants and other FRIWO Gerätebau GmbH customers at a later time. Questions asked by participants, and the related answers, are also recorded and played when the webinar is accessed at a later time. Statistical data is collected during and after the webinar. If you participate in a webinar, in addition to your log-in details, we receive information about the period of participation, your interest in the webinar, and any questions asked and/or answers given for the purposes of customer support and to further improve the user experience.
The connection between you and the organizer of the webinar is encrypted. We do not record sound or images transmitted during the session. By clicking “Join” you confirm that you will not record the session, or save screen shots from it. You can end the session at any time by closing the browser window, or by closing the program or app. If your contact person ends the session, then your participation also ends automatically.
4. Forwarding of data
Your personal data is not transmitted to third parties for any purposes other than those listed below.
• We share your personal data with third parties only if:
• you have expressly consented to this in accordance with Art. 6 (1) Clause 1 (a) GDPR;
• the sharing of this data under Art. 6 (1) Clause 1 (f) GDPR is necessary for establishing, exercising or defending legal claims and there is no reason to assume that you have an overriding interest requiring protection in your data not being shared;
• there is a legal obligation to share the data under Art. 6 (1) Clause 1 (c) GDPR;
• it is legally permissible and necessary under Art. 6 (1) Clause 1 (b) GDPR for performance of a contract to which you are party.
The data processed by cookies is necessary for the purposes described for safeguarding our legitimate interests as well as those of third parties under Art. 6 (1) Clause 1 (f) GDPR.
Most browsers accept cookies automatically. However, you can configure your browser in such a way that no cookies are stored on your computer or a message appears before a new cookie is created. However, the complete deactivation of cookies may result in you not being able to use all of our website’s functions.
6. Analysis tools (tracking tools)
The tracking measures that we employ, which are listed below, are carried out on the basis of Art. 6 (1) Clause 1 (f) GDPR. We aim to design our website in line with users’ needs and ensure its ongoing optimisation through the tracking measures employed. We also employ tracking measures to compile statistics on the use of our website and analyse them for the purpose of optimising it. The interests are regarded as legitimate as per the provision cited above.
The respective data processing purposes and data categories may be found in the corresponding tracking tools.
We use Google Analytics, a web analytics service provided by Google Ireland Limited (https://www.google.de/intl/de/about/) (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; hereinafter referred to as “Google”) for the purpose of designing our web pages in line with users’ needs and the pages’ ongoing optimisation. In this context, pseudonymised user profiles are created and cookies (refer to Section 10) are used. The information generated by the cookie about your use of this website, such as
• browser type/version,
• operating system used,
• referrer URL (the previously visited page),
• host name of the computer accessing the site (IP address) and
• time of the server request
is transmitted to a Google server in the United States and stored there. The information is used to analyse use of the website, to compile reports about website activity and to perform other services related to website and internet use for the purposes of market research and designing these web pages in line with users’ needs.
This information may also potentially be transmitted to third parties if required by law or if third parties are charged with processing it. Under no circumstances is your IP address combined with other data by Google. IP addresses are anonymised so that linking it to a specific user is not possible (IP masking). You may refuse to allow the installation of cookies by selecting the appropriate settings in the browser software. However, please note that, in this case, it may not be possible to use all of the functions of this website to their full extent.
You can also prevent the collection of the information generated by the cookie pertaining to your use of the website (including your IP address) 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 with regard to browsers on mobile devices, you can also prevent the collection of data by Google Analytics by clicking on tools.google.com/dlpage/gaoptout. An opt-out cookie is created that prevents your data from being collected in future when visiting this website. The opt-out cookie applies only to this browser and only to our website, and is placed on your device. If you delete the cookies in this browser, you will need to set the opt-out cookie again. Additional information on data protection in connection with Google Analytics is available for example from Google Analytics support (https://support.google.com/analytics/answer/6004245?hl=de).
Google Tag Manager
This website uses Google Tag Manager. The service allows website tags to be managed via an interface. Google Tool Manager only implements tags. That means: no cookies are used and no personal data is recorded. Google Tool Manager applies other tags, which record data where applicable. However, Google Tag Manager does not access that data. If a deactivation was carried out at the domain or cookie level, it continues to apply to all tracking tags, insofar as they were implemented with Google Tag Manager.
7. Integration of social networks
We make use of services provided by the social networks Facebook, YouTube, Twitter, Instagram, LinkedIn, Xing and TikTok on the basis of Art. 6 (1) Clause 1 (f) GDPR in order to promote our company and our website through these channels and in order to engage with our target groups. The respective provider is responsible for ensuring that the provision of these services complies with the data protection guidelines. We integrate such services into our offerings solely by way of a link, giving the visitors to our website optimum control over their personal data.
On our website, certain content may be shared with Facebook for processing by Facebook by way of a direct link to the provider’s page via the Facebook symbol. Your browser will connect to Facebook’s servers when you click on a corresponding link on our website. The URL of the website you most recently accessed will then be transmitted directly to Facebook.
As a result, Facebook will be notified that your browser has accessed a specific page of our website even if you do not have a Facebook account or are not currently logged into Facebook. Your browser will transmit this information (including your IP address) directly to a Facebook server in the United States, where it will be stored. If you are logged into Facebook, Facebook will be able to directly match your visit to our website with your Facebook account.
Facebook may use this information for the purpose of advertising, market research and the customization of Facebook pages. To this end, Facebook will create use, interest and relationship profiles for a variety of purposes, such as analyzing your use of our website with regard to the advertisements shown to you on Facebook, notifying other Facebook users about your activities on our website and providing other services related to the use of Facebook.
Please log out of Facebook prior to visiting our website if you do not want Facebook to match the data collected through our website to your Facebook account. Please see Facebook’s data policy (https://www.facebook.com/about/privacy) for more information about the purpose and scope of data collection and the further processing and use of data by Facebook, as well as about your rights in this regard and settings options to protect your privacy.
aa) Facebook Conversion Tracking
We use the online advertising program Facebook Advertising to draw the attention of potential users and customers to our online offerings. Within the scope of Facebook Advertising, we use Conversion Tracking, an analysis service of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). As a result, Facebook will store a cookie on your computer (“Conversion Cookie”) if you accessed our website by clicking on a Facebook ad. These cookies will expire after 30 days and will not be used to identify you personally. If you visit certain pages of ours and the cookie has not yet expired, we and Facebook will be able to see that someone has clicked on the ad and has been forwarded to our page to take part in a campaign. The information obtained with the aid of the Conversion Cookie serves to draw up conversion statistics. We will be notified of the total number of users who have clicked on the ad in question and have been forwarded to a page with a conversion tracking tag. However, we will not obtain any information that may be used to identify users personally. If you wish to opt out of tracking, you can disable the storage of cookies by deactivating the browser settings that allow the automatic storage of cookies, among other options.
bb) Facebook remarketing
To provide the visitors to our website with an optimum selection of information that has been tailored to their interests, we use remarketing technology provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) in the form of a Facebook pixel that has been technically implemented on our website’s pages. This technology allows us to employ targeted advertising within Facebook’s social network to address users who have already visited our website and expressed their interest in our online offerings. Advertisements are displayed through the use of a pixel that is used to analyze user behavior during visits to our website and can subsequently be employed to make targeted product recommendations and show interest-based advertising. Please see Facebook’s data policy for more information about the purpose and scope of data collection and the further processing and use of data by Facebook, as well as about your rights in this regard and settings options to protect your privacy. More information about Facebook’s data protection provisions is available at https://www.facebook.com/about/privacy/. You can hide remarketing content by changing the respective settings on the corresponding page. To do so, visit http://www.facebook.de/settings/ads and deactivate the use of remarketing ads. However, you must be logged into Facebook to take advantage of this option. Alternatively, users can deactivate the use of third-party cookies by accessing the Network Advertising Initiative’s deactivation page at http://www.networkadvertising.org/choices/. By using our offerings, you consent to the processing of your personal data by Facebook as described here for the aforementioned purpose. We wish to point out that Facebook has its own data policy that is independent of ours. We assume no responsibility or liability for these guidelines and procedures.
Our website features plug-ins provided by the microblogging and social networking service Twitter Inc. (Twitter). The Twitter plug-ins (tweet button) are indicated by the Twitter logo on our website. An overview of tweet buttons is available here (https://about.twitter.com/resources/buttons). Your browser will connect to the Twitter server when you access a page of our website containing such a plug-in, notifying Twitter that you have visited our website from your IP address. You can link the content of our website to your Twitter profile by clicking on Twitter’s tweet button while you are logged into your Twitter account, thereby allowing Twitter to match your visit to our website with your user account. As the operator of the website, we wish to point out that Twitter will not share with us the content of the transmitted data or information pertaining to its use by Twitter. Please log out of your Twitter account if you do not want Twitter to be able to match your visit to our website with your user profile.
Our website also uses social plug-ins provided by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”). The plug-ins are indicated by an Instagram logo shaped like the “Instagram camera,” for instance. Your browser will connect to the Instagram server when you access a page of our website containing such a plug-in. Instagram will transmit the content of the plug-in directly to your browser and will embed it into the page. As a result, Instagram will be notified that your browser has accessed a specific page of our website even if you do not have an Instagram account or are not currently logged into Instagram. Your browser will transmit this information (including your IP address) directly to an Instagram server in the United States, where it will be stored. If you are logged into Instagram, Instagram will be able to directly match your visit to our website with your Instagram account. Information regarding any use of the plug-ins, such as by clicking the Instagram button, will also be transmitted directly to an Instagram server, where it will be stored. Such information will also be made public on your Instagram account and displayed to your contacts there. Please log out of Instagram prior to visiting our website if you do not want Instagram to match the data collected through our website to your Instagram account.
Our website uses functions provided by the network LinkedIn. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. When you visit one of our pages containing functions from LinkedIn, our website will connect to LinkedIn’s servers to notify it that you have accessed our website from your IP address. If you click on the “Recommend” button from LinkedIn and are logged into your LinkedIn account, LinkedIn will be able to match your visit to our website with you and your user account. As the operator of the website, we wish to point out that LinkedIn will not share with us the content of the transmitted data or information pertaining to its use by LinkedIn.
The LinkedIn plug-in is used on the basis of Art. 6 (1) Clause 1 (f) GDPR. The website operator has a legitimate interest in maximum visibility across social media.
Our website uses functions provided by the network XING. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. When you visit one of our pages containing functions from XING, our website will connect to XING’s servers. To the best of our knowledge, no personal data will be stored. In particular, no IP addresses will be stored and no information pertaining to user behavior will be analyzed. The XING plug-in is used on the basis of Art. 6 (1) Clause 1 (f) GDPR. The website operator has a legitimate interest in maximum visibility across social media.
Our website features social media plug-ins provided by the video-sharing service TikTok. The controller under data protection law is TikTok Inc., 10100 Venice Blvd., Culver City, CA 90232, USA; TikTok Inc.’s representative in the EU as defined by Art. 27 GDPR is News Republic SAS, Rue Robert Caumont, 33049 Bordeaux Cedex, France. The personal data collected during your use of the service is processed by TikTok Inc. and may be transmitted to countries outside the European Union. Such data may include your IP address (excluding GPS data), information pertaining to your device or other unique device identifiers, browser history, mobile communications provider, time zones and local settings, cell phone or device model, operating system, and information pertaining to your use of the app. This data will be matched with the data related to your TikTok account or your TikTok profile.
8. Google Maps
This website uses the Google Maps API to visually depict geographic information. When people use Google Maps, Google Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland) also collects, processes and uses data about the use of the map functions by web page visitors. When you use Google Maps, information about the way that you use FRIWO’s website, including your IP address, is transmitted to and stored by Google on a server in the United States. The transmission of data to the United States entails risks relating to data protection law, which is why you have the option to deactivate the Google Maps service and prevent data from being transmitted to Google.
9. Career portal
When you apply via our career portal, we collect personal data to process your application. The controller in charge of collecting this data is FRIWO as indicated in the legal notice.
If you use the portal to apply for an advertised position, your data is automatically transmitted to our human resources department. This does not constitute an automated or manual transmission to third parties as set out in the German Federal Data Protection Act.
If you submit an unsolicited application to our applicant database, your data is automatically transmitted to the appropriate subsidiary / human resources officer, based on your abilities. The purpose of transmitting the data in this case is for the responsible officer to evaluate your potential area of work at FRIWO.
If you apply through our career portal, we ensure that your data is deleted from our systems once the purpose for which we received your data has ended. Procedures are in place to this end to ensure that data is deleted after the purpose for collection has ended or once the underlying retention period has expired. In accordance with statutory principles, if you apply for an advertised position and the outcome is negative, we delete your data within three months of sending the rejection letter. In the event of a positive outcome, we enter your data into the ordinary human resources administrative process, where it is maintained, stored and protected in line with legal provisions.
If you submit an unsolicited application, your data will be saved for a period of six months once it has been entered into the system. After this period, if the outcome is not in your favour and you do not carry out any other activities on the website, your data will be deleted.
10. Rights of the data subject
You have the right:
• pursuant to Art. 15 GDPR to obtain information about your personal data that we process. In particular, you have the right to obtain information about the purposes of the processing; the category of personal data concerned; the categories of recipient to whom the personal data have been or will be disclosed; the envisaged period for which the personal data will be stored; the existence of the right to request rectification or erasure of personal data or restriction of processing or to object to such processing; the right to lodge a complaint; information as to the source of the personal data when we were not the ones to collect it; and the existence of automated decision-making, including profiling, and, where applicable, meaningful information about particulars;
• pursuant to Art. 16 GDPR to obtain without undue delay the rectification of inaccurate personal data that we have stored or to have incomplete personal data completed;
• pursuant to Art. 17 GDPR to obtain the erasure of your personal data that we have stored, to the extent that processing is not 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 defence of legal claims;
• pursuant to Art. 18 GDPR to obtain restriction of processing, insofar as you contest the accuracy of the personal data; the processing is unlawful, but you oppose the erasure of the personal data; we no longer need the personal data, but you require it for the establishment, exercise or defence of legal claims; or you have objected to processing pursuant to Art. 21 GDPR;
• pursuant to Art. 20 GDPR to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format or to have that data transmitted to another controller;
• pursuant to Art. 7 (3) GDPR to withdraw at any time the consent you gave to us. Doing so means that we will no longer be permitted in future to continue with the data processing based on this consent;
• pursuant to Art. 77 GDPR to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your habitual place of residence, place of work or our registered office.
11. Right to object
If your personal data is processed based on legitimate interests as defined under Art. 6 (1) Clause 1 (f) GDPR, you have the right pursuant to Art. 21 GDPR to object to the processing of your personal data insofar as there are grounds for doing so relating to your particular situation or are directed against direct marketing purposes. In the case of the latter, you have a general right to object that we will honour without you having to cite a particular situation.
To exercise your right to withdraw consent or to object, simply send an email to hello(at)friwo.com
12. Data security
For your visit to our website, we use the widespread Secure Socket Layer (SSL) method, together with the highest encryption level supported by your browser. This usually entails 256-bit encryption. If your browser does not support 256-bit encryption, then we use 128-bit v3 technology instead. You can tell whether an individual page of our website has been transmitted in encrypted fashion by the image of a closed key or lock symbol in the lower status bar of your browser.
We also employ appropriate technical and organisational security measures to protect your data against incidental or intentional manipulation, partial or complete loss, destruction and against unauthorised third-party access. We continually enhance our security measures in line with technological developments.
13. Links to other websites
The FRIWO websites contain links to other websites. FRIWO Gerätebau GmbH is not responsible for the data protection strategies or the content of those other websites.