SHW Performance Manufacturing line

Our privacy policy

According to Art 13 of the GDPR

Thank you for your interest in the information on our website!

With the help of this Privacy Policy we would like to inform the users of our website about the type, scope and purpose of the personal data processed. Personal data in this context are all information with which you can be personally identified as a user of our website, including your IP address and information that is stored in cookies.

In a general section of this Privacy Policy, we provide you with information on data protection, which generally applies to our processing of data, including data collection on our website. In particular, you as a data subject will be informed about the rights to which you are entitled.

The terms used in our Privacy Policy and our data protection practice are based on the provisions of the EU General Data Protection Regulation ("GDPR") and other relevant national legal provisions.

Controller according to the GDPR

SHW AG
FN HRB 726621
Stiewingstraße 111
73433 Aalen
Germany

e: datenschutz@shw.de
t: +49(0)7361-502-448
f: +49(0)7361-52790-20-448 

Data Protection Officer:
Mr. Bernd Hammerlindl

Data collection on our website

On the one hand, personal data is collected from you when you expressly communicate such data to us, on the other hand, data, especially technical data, is automatically collected when you visit our website. Some of this data is collected to ensure that our website functions without errors. Other data may be used for analysis. However, you can use our website without a need to provide personal information.

Technologies on our website

Applicants

On our website you have the possibility to inform yourself about open positions and to apply online at the same time. 

We process the data you have provided to us in the context of an application only for the purpose of and within the scope of the application process in accordance with the statutory provisions. If your application refers to a specific job advertisement, we process the data only for the purpose of processing for this specific job. The processing of your applicant data is carried out for the implementation of pre-contractual measures at the request of an applicant in accordance with Art 6 paragraph 1 lit. b GDPR. 

Beyond the conclusion of the application process for a specific position, we process your application data only to the extent that this is necessary to safeguard our legitimate interest in accordance with Art 6 paragraph 1 lit. f GDPR (e.g. for the defense against unjustified claims) or if you have expressly consented to the processing of your application data for future job advertisements in accordance with Art 6 paragraph 1 lit. a GDPR. The same applies to unsolicited applications after comparison of your job requirements and your qualification profile with our job offers.

The absolutely necessary applicant data are marked as such or result from the respective job description. Furthermore, applicants may voluntarily provide us with additional information.

By submitting your application to us, you agree to the processing of your data for purposes of the execution of the application process in accordance with the type and scope described in this Privacy Policy.

Insofar as special categories of personal data as defined in Art. 9 paragraph 1 GDPR are disclosed as part of the application process, they will be processed in accordance with Art. 9 paragraph 2 lit. b GDPR (e.g. health data, such as severely disabled status) or on the basis of your consent in accordance with Art. 9 paragraph 2 lit. a GDPR (e.g. health data to the extent necessary for the assessment of suitability to practice the profession).

The data provided to us in an online-form will be transmitted to us in encrypted form according to the state of the art. You can also send us your application by e-mail. In this case, however, we would like to point out that e-mails are generally not sent encrypted and that you would have to provide for encryption yourself, in order to protect yourself optimally. 

In the event of a successful application, the data provided by you can be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted after the legal deadlines have expired or, if you have expressly consented to a longer-term storage for a specific purpose, after this period has expired. 

If you have not given your consent for a longer storage, the data will basically be deleted after a period of seven months so that we can answer any follow-up questions regarding the application and fulfil our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Cookies

We use cookies to make our website as user-friendly and functional as possible for you. Some of these cookies are stored on the device you use to access the site. 

Cookies are small packages of data that are exchanged between your browser and our web server whenever you visit our website. They do not cause any damage and are used solely to recognise website visitors. Cookies can only store information provided by your browser, e.g. information that you have entered into your browser or that is available on the website. Cookies cannot execute code and cannot be used to access your terminal device. 

The next time you access our website using the same device, the information stored in the cookies can then either be sent back to us (“first-party cookie”) or to a web application of third party to whom the cookie belongs (“third-party cookie”).  The information that is stored and sent back allows each web application to recognise that you have already accessed and visited the website using the browser on your device. 

Cookies contain the following information:

  • Cookie name

  • Name of the server from which the cookie originates

  • Cookie ID number

  • An expiry date, after which the cookie will be automatically delete

We classify cookies in the following categories depending on their purpose and function:  

  • Technically necessary cookies, to ensure the technical operation and basic functions of our website. These types of cookies are used, for example, to maintain your settings while you navigate our website; or they can ensure that important information is retained throughout the session (e.g. login, shopping cart). 

  • Statistics cookies, to understand how visitors interact with our website by collecting and analysing information on an anonymous basis only. In this way we gain valuable insights to optimize both the website and our products and services. 

  • Marketing cookies, to provide targeted promotional and marketing activities for users on our website.

  • Unclassified cookies are cookies that we are trying to classify together with individual cookie providers.

Depending on the storage period, we also divide cookies into session and persistent cookies. Session cookies store information that is used during your current browser session. These cookies are automatically deleted when the browser is closed. No information remains on your device. Persistent cookies store information between two visits to the website. Based on this information, you will be recognized as a returning visitor on your next visit and the website will react accordingly. The lifespan of a persistent cookie is determined by the provider of the cookie.

The legal basis for using technically necessary cookies is our legitimate interest in the technically fault-free operation and smooth functionality of our website as described in Art. 6 paragraph 1 lit. f of the GDPR. The use of statistics and marketing cookies is subject to your consent, in accordance with Art. 6 paragraph 1 lit. a of the GDPR.  You can withdraw your consent for the future use of cookies at any time in accordance with Art. 7 paragraph 3 of the GDPR.  Your consent is voluntary. If consent is not given, no disadvantages arise. For more information about the cookies we actually use (specifically, their purpose and lifespan), refer to this Privacy Policy and to the information in our cookie banner about the cookies we use.

You can also set your web browser so that it does not store any cookies in general on your device or so that you will be asked each time you visit the site whether you accept the use of cookies. Cookies that have already been stored can be deleted at any time. Refer to the Help section of your browser to learn how to do this.
 
Please note that a general deactivation of cookies may lead to functional restrictions on our website. 

Facebook-Pixel

We use the Facebook-Pixel provided by the social network Facebook on our website for purposes of analysis and optimisation and for the commercial operation of our website. This tool is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (‘Facebook’).

ATTENTION: Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

Facebook-Pixel makes it possible for Facebook to identify visitors of our website as target groups for displaying ads (‘Facebook ads’). Therefore, we use Facebook-Pixel to display our Facebook ads only to Facebook users who have shown interest in our online product offering, or who show certain characteristics (e.g. interests in specific topics or products that are determined based on the websites they have visited), which we share with Facebook (i.e. ‘custom audiences’). By using Facebook-Pixel, we also want to ensure that our Facebook ads match the potential interests of users and do not cause any inconvenience. Furthermore, by using Facebook-Pixel, we can evaluate the effectiveness of Facebook ads for statistical and market research purposes by seeing whether the user was redirected to our website after clicking on a Facebook ad (i.e. ‘conversion’).

Your actions are stored in one or more cookies. These cookies enable Facebook to match your user data (such as IP address, user ID) with the data of your Facebook account. The collected data is anonymous and not visible to us and can only be used in the context of advertisements. You can prevent the linking with your Facebook account by logging out before you take any action.

The processing of your data is based on your consent within the meaning of Art 6 paragraph 1 lit. a GDPR. You can revoke this consent at any time with effect for the future.

Further information on how Facebook processes personal data, including the legal basis on which Facebook relies and the possibilities for exercising the rights of data subjects vis-à-vis Facebook, can be found in the Facebook Data Policy at https://www.facebook.com/policy.php

If you want to control what kind of adverts are displayed to you on Facebook, you can go to the page Facebook has set up for this purpose and follow the instructions on configuring user-targeted adverts:  https://www.facebook.com/settings?tab=ads 

The settings chosen will be applied across all platforms, meaning that they will apply to all devices from your desktop to mobile.

Facebook processes data in accordance with its privacy policy. For general information about the presentation of Facebook ads, refer to: https://www.facebook.com/policy.php 

You can find more specific, detailed information about Facebook-Pixel and how it works on Facebook’s Help pages: https://en-gb.facebook.com/business/help/742478679120153?id=1205376682832142

Google Analytics

We use the functions of the web analytics service Google Analytics on our website to analyse user behaviour and to optimise our website. The provider of this service is Google Ireland Limited, Barrow Street, Dublin 4, Ireland ("Google"). 

ATTENTION: Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

Google Analytics uses cookies that enable an analysis of the use of our website.

In general, information about your use of the website is transferred to a Google server and stored there, such as the type and version of browser you used, the operating system you used, the site you visited prior to accessing our site, the host name of the computer (IP address) you used to access the site, and the time of your server request. For this purpose, we have entered into a contract with Google for contractual processing of your data in accordance with Art. 28 of the GDPR.

At our request, Google will use this information to analyse the use of our website, to create reports on the activities within our website and to render additional services related to the use of our website and of the internet. According to Google, the IP address submitted by your browser will not be added to other data held by Google. 

We use Google Analytics only with IP anonymisation activated, which means we have expanded this website to include the code ‘anonymizeIP’. This ensures that your IP address is masked, so that all data is collected anonymously. Only under exceptional circumstances will a full IP address be transmitted to a Google server and truncated there.

During the website visit, the following data is collected:

  • the pages you call up, your "click path"

  • Achievement of "website goals" (conversions, e.g. newsletter registrations, downloads, purchases)

  • Your user behavior (for example clicks, duration of stay, bounce rates)

  • Your approximate location (region)

  • Your IP address (in shortened form)

  • technical information about your browser and the end devices you use (e.g. language settings, screen resolution)

  • Your internet provider

  • the referrer URL (via which website / via which advertising medium you came to our website)

The data about the use of our website is immediately deleted after expiration of the storage limits that we have set. Google Analytics gives us the following options for the storage limits: 14 months, 26 months, 38 months, 50 months or no automatic deletion. You can ask us any time for the current storage limit that we have set.

The processing of your data using Google Analytics is subject to your explicit consent in the sense of Art 6 paragraph 1 lit. a of the GDPR. You can revoke your consent at any time with effect for the future.

You can also block the collection of data by downloading and installing the browser plugin available through the link below: http://tools.google.com/dlpage/gaoptout

You can find out exactly where Google data centres are located here: https://www.google.com/about/datacenters/inside/locations/ 

For more information about how Google uses your data, and about options for settings and withdrawal of consent, refer to the Google Privacy Policy at https://policies.google.com/privacy

Google Doubleclick

We use the service Doubleclick provided by Google on our website for purposes of analysis and optimisation and for the commercial operation of our website. This tool is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). 

ATTENTION: Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

This service works by means of a pseudonymous identification number (pID), which is received by and assigned to your browser. This pID enables the service to detect which ads have already been displayed to you and which have been accessed. 

This data is used to display ads throughout a website be enabling Google to identify which pages you have visited. The information collected is transferred to a Google server in the USA and stored there for analysis. Google is only allowed to transfer data to third parties in accordance with legal regulations or in the context of contractual data processing. Under no means is Google permitted to add your data to other data that it has collected. 

The processing of your data is subject to your consent in the sense of  Art 6 paragraph 1 lit. a of the GDPR. You can withdraw this consent at any time, with effect for the future.

You can find out exactly where Google data centres are located here: https://www.google.com/about/datacenters/inside/locations/

For more information about how Google uses your data, and about options for settings and withdrawal of consent, refer to the Google Privacy Policy at https://policies.google.com/technologies/ads as well as the settings for Google ad display under https://adssettings.google.com/authenticated

Google reCAPTCHA

Our website uses the reCAPTCHA service of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") to protect against abuse by non-human visitors (bots) and to prevent spam.

ATTENTION: Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

When reCAPTCHA is started, your browser establishes a connection to Google's servers. This enables Google to know that our website has been accessed via your IP address.

The purpose of reCAPTCHA is to check whether the data entry on our website is made by a human or by an automated programme. To do this, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters our website. For the analysis, reCAPTCHA evaluates various information.

According to our information, the following data is processed by Google:

  • the address of the page from which the visitor comes

  • IP address

  • Information about the operating system

  • Cookies

  • Mouse and keyboard behavior

  • Date and language settings

  • All Java-Script Objects

  • Screen resolution

The data collected during the analysis is forwarded to Google and used by Google. The reCAPTCHA analyses run completely in the background. 

Cookies are used for the execution of the service. These cookies require a unique identifier for tracking purposes. According to Google, the IP address is not merged with other data from other Google services unless you are logged into your Google account while using the reCAPTCHA plug-in.

You can find out exactly where Google data centres are located here: https://www.google.com/about/datacenters/inside/locations/

Further information on Google reCAPTCHA can be found here: https://developers.google.com/recaptcha/

For Google's privacy policy, please see the following link: https://policies.google.com/privacy

Google Tag Manager

We use the service Google Tag Manager on our website. This service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

ATTENTION: Within the scope of this service, data transfer to the USA takes place or cannot be ruled out. 

When the Tag Manager is started, your browser establishes a connection to Google's servers. This informs Google that our website has been accessed via your IP address.

Google Tag Manager is used to manage website tags via an interface. This enables us to embed code snippets such as tracking codes or conversion pixels into our website without interfering with the source code. In this process, Tag Manager data is only transferred; it is not collected or stored. The Tag Manager itself is a cookie-less domain and does not process any personal data, because it is used solely to manage other services used on our website. The Tag Manager triggers other tags which in turn collect data under specific circumstances. However, the Tag Manager has no access to this data. If you have chosen to deactivate cookies on our site in general or to deactivate specific cookies, this will remain in effect for all tracking tags that are implemented using the Tag Manager.

You can find out exactly where Google data centres are located here: https://www.google.com/about/datacenters/inside/locations/

For more information about data protection, refer to the following Google websites:

Privacy Policy: https://policies.google.com/privacy


FAQ Google Tag Manager: https://www.google.com/intl/de/tagmanager/faq.html


Use Policy Google Tag Manager: https://marketingplatform.google.com/intl/de/about/analytics/tag-manager/use-policy/

Hosting

In the process of hosting our website, we store all data related to the operation of our website. This is necessary for enabling operation of our website. Therefore, we process this data on the legal grounds of our legitimate interest in optimising our website as described under Art. 6 paragraph 1 lit. f of the GDPR. To provide access to our website, we use the services of web hosting providers, to whom we supply the aforementioned data within the context of contractual processing in accordance with art. 28 of the GDPR.

Instagram Social-Plugins

To improve our online presence, the functions and content of the Instagram service are integrated into our website. The provider of these functions and services is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").

ATTENTION: Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

For these data processing we are jointly responsible with Facebook according to Art 26 GDPR. 

The information required for joint responsibility in accordance with Article 13 paragraph 1 lit. a) and b) GDPR can be found in the Facebook data policy at https://www.facebook.com/about/privacy. The addition for responsible persons, which we have concluded with Facebook in order to determine the fulfillment of the obligation under the GDPR with regard to joint responsibility, applies. In this regard, it has been agreed with Facebook that Facebook is responsible for fulfilling the rights of data subjects in accordance with Articles 15-20 of the GDPR regarding personal data stored by Facebook after joint processing.

Users of our website have the opportunity to share the content of our website within Instagram.

We have taken precautions on our website to ensure that such a plugin does not cause your browser to establish a direct connection to Facebook's servers when you view a page.

Only when you interact with the plug-ins, for example when you confirm the button with the Instagram camera, will your IP address and the corresponding information be transmitted directly to a Facebook server and stored there. However, an active action on your part is required, which is why the data processing in this case is based on your consent according to Art. 6 paragraph 1 lit. a GDPR.  

If you are logged in to Instagram, Instagram can assign your visit to our website directly to your Instagram account. The information is also published on your Instagram account and displayed to your contacts there. If you do not want Instagram to associate the data collected via our website directly with your Instagram account, you must log out of Instagram. 

For more information about privacy, please refer to Instagram's Privacy Policy: http://instagram.com/about/legal/privacy/.

Contact

Whenever you contact us, your information is used to process and handle your contact request in the course of fulfilling pre-contractual rights and obligations in accordance with Art. 6 paragraph 1 lit. b of the GDPR. To handle and answer your request it is necessary for us to process your data; otherwise we are unable to answer your request or only able to partially answer it. Your information can be stored in a database of customers and leads on the grounds of our legitimate interest in direct marketing as described in Art. 6 paragraph 1 lit. f of the GDPR.

We delete your request and contact information when your request has been definitively answered and there is no legally required time limit for storing this data prior to deletion (e.g. pursuant to a subsequent contractual relationship). This is usually the case when there is no further contact with you for three years in a row.

LinkedIn Social-Plugins

On our website functions and content of LinkedIn are used to improve our online presence. This service is provided by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland ("LinkedIn"). 

ATTENTION: Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

Users of our website have the opportunity to share the content of our website within LinkedIn.

We have taken precautions on our website to ensure that such a plugin does not cause your browser to connect directly to LinkedIn's servers when a page is viewed.

Only when you interact with the plugins, for example by clicking the "Recommend" button, your IP address and the corresponding information will be transmitted directly to a LinkedIn server and stored there. However, an active action on your part is required, therefore the data processing in this case is based on your consent according to Art. 6 paragraph 1 lit. a GDPR.

If you are logged in to your LinkedIn account, it is possible for LinkedIn to assign your visit to our website to you and your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn. If you do not agree, you must log out of your LinkedIn account.

The latest data protection information on LinkedIn can be found on this website: https://www.linkedin.com/legal/privacy-policy?_l=en_EN

Newsletter

On our website we offer the possibility to register for a newsletter. Our newsletter contains information about our products or services as well as accompanying information, offers or promotions.

The consent to our newsletter is given in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with a foreign e-mail address. The registrations for the newsletter are logged in accordance with Art 6 paragraph 1 lit. f GDPR on the basis of our legitimate interest in verifiability. This includes the storage of the time of registration and confirmation as well as the IP address. Changes to your stored data are also logged.

The newsletter is sent on the basis of your consent in accordance with Art. 6 paragraph 1 lit. a GDPR or, if consent is not required, on the basis of our legitimate interest in direct marketing for similar products and services in accordance with Art. 6 paragraph 1 lit. f GDPR. In the context of sending the newsletter, we also process your reaction behaviour on the basis of our legitimate interest in accordance with Art. 6 paragraph 1 lit. f GDPR.

You can unsubscribe from receiving our newsletter at any time by withdrawing your consent with effect for the future in accordance with Art. 7 paragraph 3 GDPR or by submitting an objection to the processing. You will find a relevant option in the respective newsletter itself or simply contact us by email. In the event of revocation or objection, we may store your e-mail address for up to three years on the basis of our legitimate interests in accordance with Art. 6 paragraph 1 lit. f GDPR before we delete it in order to be able to prove that you have previously given your consent.

Newsletter Tracking

We would like to point out that we evaluate your user behavior when the newsletter is sent. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which we store. For the evaluations we link the mentioned data and the web beacons with your email address. Links received in the newsletter also contain these tracking IDs. The legal basis is Art. 6 paragraph 1 lit. f GDPR.

The information is stored for as long as you have subscribed to the newsletter. After unsubscribing, we only save the data purely statistically and anonymously.

Such tracking is not possible if you have deactivated the display of images by default in your email program. In this case, the newsletter will not be displayed in full and you may not be able to use all functions. If you display the images manually, the above-mentioned tracking takes place.

Server Log Files

For technical reasons, particularly to ensure a functioning and secure website, we process the technically necessary data about accesses to our website in so-called server log files which your browser automatically sends to us. 

The access data we process includes:

  • The name of the website you are accessing  

  • The browser type (including version) you use

  • The operating system you use

  • The site you visited before  accessing our site (referrer URL)

  • The time of your server request

  • The amount of data transferred

  • The host name of computer (IP address) you are using to access the site

This data cannot be traced back to any natural person and is used solely to perform statistical analyses and to operate and improve our website while also optimising our site and keeping it secure. This data is sent exclusively to our website operator. The data is neither connected nor aggregated with other data sources. In case of suspicion of unlawful use of our website, we reserve the right to examine the data retroactively. This data processing takes place on the legal grounds of our legitimate interest in maintaining a technically fault-free and optimal website, as described under Art. 6 paragraph 1 lit. f of the GDPR.

The access data is deleted within a short period of time after serving its purpose (usually within a few days) unless further storage is required for evidence purposes. In such cases, the data is stored until the incident is definitively resolved.

SSL Encryption

Within your visit to our website, we use the widespread SSL procedure (Secure Socket Layer) in conjunction with the highest level of encryption supported by your browser. You can tell whether an individual page of our website is transmitted in encrypted form by the closed representation of the key or lock symbol in the lower status bar of your browser. We use this encryption procedure on the basis of our justified interest in the use of suitable encryption techniques in accordance with Art. 6 paragraph 1 lit. f GDPR.

We also make use of suitable technical and organisational security measures in accordance with Art. 32 GDPR to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments and kept state-of-the-art.

WebCare

In order to obtain consent for the use of cookies on our website in accordance with data protection regulations, we use the Consent Banner of DataReporter WebCare. This is a service provided by DataReporter GmbH, Zeileisstraße 6, 4600 Wels, Austria ("DataReporter"). More information about this company can be found at www.datareporter.eu. The Consent Banner records and stores the consent to cookie use for the respective user of our website. Our Consent Banner ensures that statistical and marketing cookies are only set when the user has given his express consent to their use. 

We store information on the extent to which the user has confirmed the use of cookies. The user's decision can be revoked at any time by calling up the setting for cookies and managing the declaration of consent. Existing cookies will be deleted after revocation of the consent. A cookie is also set to store information on the status of the user's consent, which is indicated in the cookie details. Furthermore, the IP address of the respective user is transmitted to DataReporter's server for calling this service. The IP address is neither stored nor associated with any other data of the user, it is only used for the correct execution of the service. The use of the above data is therefore based on our legitimate interest in the legally compliant design of our website in accordance with Art. 6 paragraph 1 lit. f GDPR.

Further information can be found in the DataReporter data protection declaration at https://www.datareporter.eu/datenschutz. Please feel free to send your enquiries about this service to office@datareporter.eu.

Youtube

On our website, the "YouTube" service is used to embed videos into the site. The operator of the necessary software and plugin is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("YouTube"). 

When you visit a site with embedded YouTube videos, a connection is established to YouTube servers. This will tell YouTube which pages you are visiting.

ATTENTION: Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

YouTube's applicable privacy policy can be found at https://www.google.com/policies/privacy/, Opt-Out option: https://adssettings.google.com/authenticated

General information on data protection

The following provisions in its principles apply not only to the data collection on our website, but also in general to other processing of personal data.

Personal data

Personal data is information that can be assigned to you individually. Examples include your address, name, postal address, email address or telephone number. Information such as the number of users who visit a website is not personal data because it is not assigned to a person.

Legal basis for the processing of personal data

Unless more specific information is provided in this Privacy Policy (e.g. in the case of the technologies used), we may process personal data from you on the basis of the following legal principles:

  • consent in accordance with Art. 6 paragraph 1 lit. a of the GDPR - The data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes.

  • Fulfillment of a contract and pre-contractual measures pursuant to Art. 6 paragraph 1 lit. b of the GDPR - Processing is necessary for the fulfillment of a contract to which the data subject is a party or for the implementation of pre-contractual measures.

  • Legal obligation pursuant to Art. 6 paragraph 1 lit. c of the GDPR - Processing is necessary for the performance of a legal obligation.

  • Protection of vital interests pursuant to Art. 6 paragraph 1 lit. d of the GDPR - Processing is necessary to protect the vital interests of the data subject or of another natural person.

  • Reasonable interests pursuant to Art. 6 paragraph 1 lit. f of the GDPR - The processing is necessary to protect the legitimate interests of the controller or of a third party unless the interests or fundamental rights and freedoms of the data subject prevail.

Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our home country.

Transfer of personal data

Your personal data will not be transferred to third parties for purposes other than those listed in this Privacy Policy.

We will only transfer your personal data to third parties if:

  • you have given your express consent in accordance with Art. 6 paragraph 1 lit. a of the GDPR,

  • the transfer pursuant to Art. 6 paragraph 1 lit. f of the GDPR is necessary to safeguard reasonable interests, as well as to assert, exercise or defend legal claims and there is no reason to assume that you have a prevailing interest worthy of protection by not disclosing your data,

  • there is a legal obligation to transfer the data in accordance with Art. 6 paragraph 1 lit. c of the GDPR, as well as this is legally permissible and / or

  • it is required according to Art. 6 paragraph 1 lit. b of the GDPR for the processing of contractual relationships with you.

Cooperation with processors

We carefully select our service providers who process personal data on our behalf. If we commission third parties to process personal data on the basis of a data processing agreement, this is done in accordance with Art. 28 of the GDPR.

Transfer to third countries

If we process data to a third country or if this is done in the context of using the services of third parties or disclosure or transfer of data to other persons or companies, this is only done for the reasons described above for the transfer of data.

Subject to express consent or contractual necessity, we process or allow data to be processed only in third countries with a recognized level of data protection or on the basis of special guarantees, such as contractual obligations through so-called standard contractual clauses of the EU Commission, the existence of certifications or binding corporate rules in accordance with Art. 44 - 49 of the GDPR.

Data transfer to the US / Discontinuation of the Privacy Shield

We would like to expressly point out that as of July 16, 2020, due to a legal dispute between a private individual and the Irish supervisory authority, the so-called "Privacy-Shield", an adequacy decision of the EU Commission according to Art 45 GDPR, which confirmed an adequate level of data protection for the US under certain circumstances, is no longer valid with immediate effect.

The Privacy Shield therefore no longer constitutes a valid legal basis for the transfer of personal data to the United States!

If a transfer of data by us to the US takes place at all or if a service provider based in the US is used by us, we refer to this explicitly in this Privacy Policy (see in particular the description of the technologies used on our website).

What can the transfer of personal data to the US mean for you as a user and what risks are involved?

Risks for you as a user are at any rate the powers of the US secret services and the legal situation in the US, which, in the opinion of the European Court of Justice, no longer ensure an adequate level of data protection. Among other things, this concerns the following points:

  • Section 702 of the Foreign Intelligence Surveillance Act (FISA) does not provide for any restrictions on the surveillance measures of the secret services or guarantees for non-US citizens.

  • Presidential Policy Directive 28 (PPD-28) does not provide effective remedies for those affected against actions by U.S. authorities and does not provide barriers to ensuring proportionate measures.

  • The ombudsman provided for in the Privacy Shield does not have sufficient independence from the executive; he cannot issue binding orders to the U.S. secret services.

Legally compliant transfer of data to the US on the basis of standard contractual clauses?

The standard contractual clauses adopted by the Commission in 2010 (2010/87/EU of 05.02.2010), Art. 46 paragraph 2 lit. c GDPR, are still valid, but a level of protection for personal data must be ensured which is equivalent to the level in the European Union. Therefore, not only the contractual relationships with our service providers are relevant, but also the possibility of access to the data by U.S. authorities and the legal system of the U.S. (legislation and jurisdiction, administrative practice of authorities).

The standard contractual clauses cannot bind authorities in the US and therefore do not yet provide adequate protection in cases in which the authorities are authorized under the law in the US to intervene in the rights of the data subjects without additional measures by us and our service provider.

Legally compliant transfer of data to the US on the basis of your consent?

It is currently controversial whether informed consent and thus a deliberate and knowingly restriction of parts of your basic right to data protection is legally possible at all.

What measures do we take to ensure that a data transfer to the US complies with the law?

Insofar as US providers offer the option, we choose to process data on EU servers. This should technically ensure that the data is located within the European Union and cannot be accessed by US authorities.

Furthermore, we carefully examine European alternatives to US tools used. However, this is a process that does not happen overnight, as it also involves technical and economic consequences for us. Only if the use of European tools and / or the immediate switch off of the US tools is impossible for us for technical and / or economic reasons, US service providers are currently still used.

For the further use of US tools we take the following measures:

As far as possible, your consent will be asked for before using a US tool and you will be informed in advance in a transparent manner about the functioning of a service. The risks involved in transferring data to the USA can be found in this section.

We make every effort to conclude standard contract clauses with US service providers and to demand additional guarantees.  In particular, we require the use of technologies that do not allow access to data, e.g. the use of encryption that cannot be broken even by US services or anonymization or pseudonymization of data, where only the service provider can make the assignment to a person.  At the same time, we require additional information from the service provider if data is actually accessed by third parties or the service provider exhausts all legal remedies until access to data is granted at all.

Storage period

If no explicit storage period is specified during the collection of data (e.g. in the context of a declaration of consent), we are obliged to delete personal data in accordance with Art. 5 paragraph 1 lit. e of the GDPR as soon as the purpose for processing has been fulfilled. In this context, we would like to point out that legal storage obligations represent a legitimate purpose for the processing of personal data.

Personal data will be stored and retained by us in principle until the termination of a business relationship or until the expiry of any applicable guarantee, warranty or limitation periods, in addition, until the end of any legal disputes in which the data is required as evidence, or in any event until the expiry of the third year following the last contact with a business partner.

Rights of data subjects

Data subject have the right:

  • in accordance with Art. 15 of the GDPR, to request information about your personal data processed by us. In particular, you may request information on the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned duration of storage, the existence of a right of rectification, deletion, restriction of processing or opposition, the existence of a right of appeal, the origin of your data, if not collected by us, as well as the existence of automated decision making including profiling and, where applicable, meaningful information on the details thereof;

  • in accordance with Art. 16 of the GDPR, to demand without delay the correction of incorrect or incomplete personal data stored by us;

  • in accordance with Art. 17 of the GDPR, to demand the deletion of your personal data stored with us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;

  • in accordance with Art. 18 of the GDPR, to demand the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you refuse to delete it and we no longer require the data, but you require it for the assertion, exercise or defense of legal claims or you have lodged an objection to the processing in accordance with Art. 21 of the GDPR;

  • in accordance with Art. 20 of the GDPR, to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller;

  • in accordance with Art. 21 of the GDPR, if your personal data are processed on the basis of our legitimate interest, to object to the processing of your personal data for reasons arising from your specific situation or if the objection is directed against direct advertising. In the latter case, you have a general right of objection, which we will implement without indicating a specific situation.

  • in accordance with Art. 7 paragraph 3 of the GDPR, you may at any time revoke your consent to us. As a result, we may no longer continue the data processing based on this consent in the future. Among other things, you have the option of revoking your consent to the use of cookies on our website with effect for the future by calling up our Cookie Settings.

  • in accordance with Art. 77 of the GDPR to complain to a data protection authority regarding the illegal processing of your data by us. As a rule, you can contact the data protetion authority at your usual place of residence or workplace or at the headquarters of our company.

The responsible data protection authority for SHW AG is:

Der Landesbeauftragte für Datenschutz in Baden- Württemberg
Königstraße 10 a, 70173 Stuttgart, Deutschland
Tel.: +49 711 615541-0, poststelle@lfdi.bwl.de

Assertion of rights of data subjects

You yourself decide on the use of your personal data. Should you therefore wish to exercise one of your above-mentioned rights towards us, you are welcome to contact us by email at datenschutz@shw.de or by post, as well as by telephone.

Together with your application, please send us a copy of an official photo ID for clear identification and support us in concretizing your request by answering questions from our responsible employees regarding the processing of your personal data. In your request, please state in which role (employee, applicant, visitor, supplier, customer, etc.) and in which period of time you have been in contact with us. This enables us to process your request promptly.

Security of personal data

The security of your personal data is of particular concern to us. Therefore, in accordance with Art. 32 of the GDPR and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures shall include, but not be limited to, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted, and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware and software, in accordance with the principle of privacy by design and through data protection-friendly pre-settings in accordance with Art. 25 of the GDPR.

Our understanding of security is also requested from the processors we use.

Actuality of this Privacy Policy

Due to further developments or changes in legal requirements, it may become necessary to adapt this Privacy Policy from time to time. The current Privacy Policy can be found and printed out by you at any time here on this website.

For questions regarding data privacy, you can reach us at datenschutz@shw.de or at the other contact details stated in this Privacy Policy.

Aalen, on  10. May 2021

Last update:  10. May 2021