Privacy Policy

For website visitors
For customers

For Website visitors

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e. the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information Required by Law” on this website.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time under the address disclosed in section “Information Required by Law” on this website if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast and efficient provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host:

Mittwald CM Service GmbH & Co. KG
Königsberger Straße 4-6
32339 Espelkamp

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection regulations, we have concluded an order processing contract with our host.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Westdeutscher Drahtseil-Verkauf
Dolezych GmbH & Co. KG
Hartmannstraße 8
44147 Dortmund
Postfach 10 09 09
44009 Dortmund

Phone: +49 (0)231 82 85 – 0
Fax: +49 (0)231 82 77 82
E-mail: info@dolezych.de

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

Designation of a data protection officer as mandated by law

We have appointed a data protection officer for our company.

Dr. Nils Helmke
AGAD Service GmbH
Waldring 43-47
44789 Bochum

Phone: +49 (0)234 282 533 20
Fax: +49 (0)234 282 533 10
E-mail: helmke@agad.de

Information on data transfer to the USA

Our website uses, in particular, tools from companies based in the USA. When these tools are active, your personal information may be transferred to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21 SECT. 2 GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimization of the website (e.g. cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

The type and version of browser used
The used operating system
Referrer URL
The hostname of the accessing computer
The time of the server inquiry
The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Request by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g. cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Demographic parameters provided by Google Analytics

This website uses the “demographic characteristics” function of Google Analytics, to be able to display to the website visitor compatible ads within the Google advertising network. This allows reports to be created that contain information about the age, gender and interests of the website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third-party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 month. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Conversion Tracking we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.

We use Google Conversion Tracking on the basis of Art. 6 Sect. 1 lit. et seq. GDPR. The operator of the website has a legitimate interest in the analysis of the user patterns with the aim of optimizing both, the operator’s web presentation and advertising. If a respective declaration of consent was requested (e.g. concerning the storage of cookies), processing shall occur exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR; the given consent may be revoked at any time.

For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en

6. Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

CleverReach

This website uses CleverReach for the sending of newsletters. The provider is the CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany. CleverReach is a service that can be used to organize and analyze the sending of newsletters. The data you have entered for the purpose of subscribing to our newsletter (e.g. e-mail address) are stored on servers of CleverReach in Germany or in Ireland.

Newsletters we send out via CleverReach allow us to analyze the user patterns of our newsletter recipients. Among other things, in conjunction with this, it is possible how many recipients actually opened the newsletter e-mail and how often which link inside the newsletter has been clicked. With the assistance of a tool called Conversion Tracking, we can also determine whether an action that has been predefined in the newsletter actually occurred after the link was clicked (e.g. purchase of a product on this website). For more information on the data analysis services by CleverReach newsletters, please go to: https://www.cleverreach.com/en/features/reporting-tracking/.

The data is processed based on your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

If you do not want to permit an analysis by CleverReach, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message. Moreover, you can also unsubscribe from the newsletter right on the website.

For more details, please consult the Data Protection Provisions of CleverReach at: https://www.cleverreach.com/en/privacy-policy/.

7. Plug-ins and Tools

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6 Sect. 1 lit. f GDPR. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. This declaration of consent may be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

8. eCommerce and payment providers

Processing of data (customer and contract data)

We collect process and use personal data only to the extent that they are necessary for the establishment, content or modification of the legal relationship (inventory data). This is done on the basis of Art. 6 para. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures. We collect, process and use personal data on the use of this website (usage data) only to the extent necessary to enable or charge the user for the use of the service.

The collected customer data will be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.

Data transmission upon conclusion of contract for online stores, dealers and dispatch of goods

We only transfer personal data to third parties if this is necessary for the execution of the contract. For example to the companies entrusted with the delivery of the goods or the credit institution commissioned with the handling of payments. A further transmission of the data is not carried out or only if you have expressly agreed to the transmission. Your data will not be passed on to third parties without your express consent, for example for advertising purposes.

The basis for data processing is Art. 6 Par. 1 letter b GDPR which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

Payment services

We integrate payment services of third party companies on our website. When you make a purchase from us your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6 para. 1 lit. b GDPR (contract processing) and in the interest of a smooth, convenient and secure payment transaction (Art. 6 para. 1 lit. f GDPR). Insofar as your consent is required for certain actions, Art. 6 para. 1 lit. a GDPR is the legal basis for data processing; consent may be revoked at any time in the future.

We use the following payment services / payment service providers within the scope of this website:

PayPal

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”). Details can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

For customers

Information on data protection about our data processing in accordance with Article 13 and Article 21 of the Data Protection Basic Regulation (GDPR)

We take data protection seriously and hereby inform you how we process your data and which claims and rights you are entitled to according to the data protection regulations.

1. Responsible person in terms of data protection law and contact details of the data protection officer

is responsible in the sense of data protection law:

West German Wire Rope Sales

Dolezych GmbH & Co. KG

Hartmannstr. 8

D-44147 Dortmund

Tel. 0231 82 85 0

Fax 0231 82 77 82

e-mail info@dolezych.de

You can reach our data protection officer at the following contact details:

Dr. Nils Helmke

AGAD Service GmbH

Forest ring 43-47

44789 Bochum

Phone: +49 (0)234 282 533 20

Fax: +49 (0)234 282 533 10

Please contact us by e-mail: antje.kater@dolezych.de

2. Purposes and legal basis on which we process your data

We process personal data in accordance with the provisions of the Basic Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and other applicable data protection regulations. Which data is processed in detail and how it is used depends largely on the services requested or agreed upon in each case. Further details or additions to the purposes of data processing can be found in the respective contract documents, forms, a declaration of consent and/or other information provided to you (e.g. in the context of the use of our website or our terms and conditions).

Purposes for the fulfilment of a contract or pre-contractual measures (Art. 6 para. 1 b GDPR)

The processing of personal data is carried out to execute our contracts with you and the execution of your orders as well as to carry out measures and activities within the framework of pre-contractual relations, e.g. with interested parties. In particular the processing serves to prepare invoices in accordance with your orders and includes the necessary services measures and activities. This essentially includes contract-related communication with you the traceability of transactions, orders and other agreements as well as quality control through appropriate documentation, measures for the management and optimization of business processes as well as for the fulfillment of general duties of care, management and control by affiliated companies (e.g. parent company); statistical evaluations for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, billing and tax evaluation of operational services, risk management, assertion of legal claims and defense in the event of legal disputes.

Purposes within the scope of a legitimate interest of us or third parties (Art. 6 para. 1 f GDPR)

Beyond the actual fulfillment of the contract or preliminary contract, we may process your data if necessary to protect legitimate interests of us or third parties,in particular for purposes

advertising or market and opinion research, provided that you have not objected to the use of your data;

the obtaining of information and data exchange with credit agencies, insofar as this exceeds our economic risk;

the examination and optimization of procedures for demand analysis;

the further development of services and products as well as existing systems and processes;

the enrichment of our data, including the use or research of publicly available data;

statistical evaluations or market analysis;

benchmarking;

the assertion of legal claims and defence in legal disputes which are not directly attributable to the contractual relationship;

the limited storage of data, if deletion is not possible or only possible at disproportionately high expense due to the special type of storage;

the prevention and clarification of criminal offences insofar as not exclusively for the fulfilment of legal requirements;

building and plant security (e.g. by means of access controls and video surveillance) insofar as this goes beyond the general duty of care;

internal and external investigations, security checks;

the securing and exercising of domiciliary rights through appropriate measures as well as through video surveillance for the protection of our customers and employees and for securing evidence in the event of criminal offences and their prevention.

Purposes within the scope of your consent (Art. 6 para. 1 a GDPR)

With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers. Your e-mail address is the only mandatory information for the sending of the newsletter. We store your e-mail address for the purpose of sending the newsletter. The legal basis is Art. 6 para. 1 p. 1 lit. a DS-GVO. You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can revoke your consent by clicking on the link provided in each newsletter e-mail or by sending a message to the contact details given above under Responsible.

Purposes to meet legal requirements (Art. 6 para. 1 c GDPR) or in the public interest (Art. 6 para. 1 e GDPR)

We are subject to a variety of legal requirements (e.g. commercial and tax laws), but also to regulatory or other official requirements. The purposes of processing may include identity and age verification, fraud and money laundering prevention, the prevention, combating and clarification of terrorist financing and asset-endangering crimes, comparisons with European and international anti-terrorist lists, the fulfilment of tax law control and reporting obligations and the archiving of data for data protection and data security purposes, as well as audits by tax and other authorities. In addition, the disclosure of personal data may become necessary within the scope of official/judicial measures for the purpose of gathering evidence, criminal prosecution or enforcement of civil law claims.

Recipients or categories of recipients of your data

Within our company those internal departments or organizational units receive your data that require it to fulfill our contractual and legal obligations or in the context of processing and implementing our legitimate interests. Your data will only be passed on to external parties

in connection with the contract execution;

for the purpose of fulfilling legal requirements according to which we are obliged to provide information, report or pass on data or if the passing on of data is in the public interest;

insofar as external service providers process data on our behalf as contract processors or function transferors (e.g. external computer centers, support/maintenance of IT/IT applications, archiving, document processing, call center services, compliance services, controlling, data screening for anti-money laundering purposes, data validation or -plausibility checks, data destruction, purchasing/procurement, customer management, lettershops, marketing, media technology, research, risk controlling, accounting, telephony, website management, auditing services, credit institutions, printing houses or companies for data disposal, courier services, logistics);

on the basis of our legitimate interest or the legitimate interest of the third party for the purposes mentioned in Section 2.2 (e.g. to authorities, credit agencies, collection agencies, lawyers, courts, experts, companies belonging to the Group and committees and supervisory bodies);

if you have given us your consent to transfer your data to third parties.

We will not pass on your data to third parties beyond this. If we commission service providers within the scope of order processing, your data is subject to the same security standards there as with us. In all other cases, the recipients may use the data only for the purposes for which they were transmitted.

3. Duration of the storage of your data

We process and store your data for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the German Commercial Code (HGB) and the German Fiscal Code (AO), among others. The periods of retention and documentation stipulated there are up to ten years beyond the end of the business relationship or the pre-contractual legal relationship.

Furthermore, special legal regulations may require a longer period of retention, such as the preservation of evidence within the framework of the statutory limitation regulations. According to §§ 195 ff. of the German Civil Code (BGB), the regular limitation period is three years, but periods of up to 30 years may be applicable under certain circumstances.

If the data are no longer required for the fulfilment of contractual or legal obligations and rights, they will be regularly deleted, unless their – temporary – further processing is necessary to fulfil the purposes listed under item 2.2 out of an overriding legitimate interest. Such an overriding legitimate interest also exists, for example, if deletion is not possible or only possible at disproportionately high expense due to the special type of storage and processing for other purposes is excluded by suitable technical and organizational measures

4. Processing of your data in a third country or by an international organization

Data will be transferred to countries outside the European Union (EU) or the European Economic Area (EEA) (so-called third countries) if it should be necessary for the execution of an order/contract from you, if it is legally required (e.g. tax reporting obligations), if it is in the scope of a legitimate interest of us or a third party or if you have given us your consent.

The processing of your data in a third country may also be carried out in connection with the involvement of service providers in the context of order processing. Unless the EU Commission has decided on an adequate level of data protection in the country in question, we will ensure that your rights and freedoms are adequately protected and guaranteed in accordance with EU data protection regulations by means of appropriate agreements.

5. Your privacy rights

You have the following rights towards us:

You have the right to receive information from us about your data stored with us according to the rules of Art. 15 GDPR (if necessary with restrictions according to § 34 BDSG).

At your request, we will correct the data stored about you in accordance with Art. 16 GDPR if it is incorrect or faulty.

Upon your request, we will delete your data in accordance with the principles of Art. 17 GDPR, provided that other legal regulations (e.g. legal storage obligations or the restrictions according to § 35 BDSG) or an overriding interest on our part (e.g. to defend our rights and claims) do not conflict with this.

Taking into account the requirements of Art. 18 GDPR, you can demand that we restrict the processing of your data.

You may object to the processing of your data in accordance with Art. 21 GDPR, on the basis of which we must stop processing your data. However, this right of objection only applies if there are special circumstances of your personal situation, whereby our rights may conflict with your right of objection.

You also have the right to receive your data in a structured, common and machine-readable format under the conditions of Art. 20 GDPR or to transfer it to a third party.

You also have the right to appeal to a supervisory authority (Art. 77 GDPR). You also have the right to contact our data protection officer.

Information about your right of objection Art. 21 GDPR

You have the right to object at any time to the processing of your data, which is carried out on the basis of Art. 6 Par. 1 f GDPR (data processing on the basis of a weighing of interests) or Art. 6 Par. 1 e GDPR (data processing in the public interest), if there are reasons for doing so that arise from your particular situation.

If you lodge an objection, we will no longer process your personal data unless we can prove compelling reasons for processing worthy of protection that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

We may also process your personal data in order to carry out postal advertising, mailings and, if applicable, direct advertising by e-mail. If you do not wish to receive advertising, you have the right to object to this at any time. We will observe this objection for the future and will no longer process your data for direct marketing purposes.

The objection can be made without form and should be addressed to

West German Wire Rope Sales

Dolezych GmbH & Co. KG

Hartmannstr. 8

D-44147 Dortmund

PO Box 10 09 09

44009 Dortmund