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1 General


wenglor sensoric elektronische Geräte GmbH takes the protection of your personal data very seriously. Your privacy is important to us. We process your personal data in accordance with the applicable legal data protection requirements for the purposes specified below. This data protection information defines personal data as all data related to your person.

In the following you will learn how we handle these data. For a better overview, we have divided our data protection information into chapters.


Responsible body and Data Protection Officer


The body responsible for data processing is:

wenglor sensoric elektronische Geräte GmbH
wenglor Str. 3
88069 Tettnang
Tel.: +49 (0)7542 5399-0
Fax: +49 (0)7542 5399-988
E-mail: info@wenglor.com 

If you have any questions or comments regarding data protection (e.g. regarding information and updating of your personal data), you can also contact our Data Protection Officer.

Contact details of the Data Protection Officer / Coordinator:

Mr. Stefan Fischerkeller / Mr. Florian Frick
Tel.: +49 (0)7542/5399-0
E-mail: GDPR(at)wenglor.com


2 Processing Framework


2.1 Source of data collection
We process personal data that we have collected directly from you.
If this is necessary for the provision of our services, we process personal data received legitimately from other companies or other third parties (e.g. credit agencies, address publishers). In addition, we process personal data that we have legitimately collected, received or acquired from publicly accessible sources and are entitled to process (e.g. telephone directories, trade and association registers, population registers, debtor registers, land registers, press, Internet and other media).

2.2 Origin and data categories of data not collected directly from you
If this is necessary for the provision of our services, we process personal data legitimately received from other companies or other third parties. In addition, we process personal data we have legitimately collected, received or acquired from publicly accessible sources and are entitled to process (press, Internet and other media). Relevant categories of personal data may include, in particular:

  • Personal data (name, date of birth, place of birth, nationality, marital status, occupation/industry and similar data)
  • Contact information (address, e-mail address, telephone number and similar data)
  • Payment/coverage confirmation for bank cards and credit cards, customer history
  • Data about your use of the telemedia offered by us (e.g. time of visiting our websites, apps or newsletters, our pages/links clicked on or entries and similar data)
  • Video and image recordings
  • Creditworthiness data

2.3 Purposes and legal bases of the processed data
We process personal data in accordance with the provisions of the General Data Protection Regulation (GDPR), the New Federal Data Protection Act (BDSG-neu) and other applicable data protection regulations (details below). Which data are processed in detail and how they are used depends largely on the services requested or agreed in each case. Further details or additions for the purpose of data processing can be found in the respective contractual 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 General Terms and Conditions).


Purpose for the fulfillment of a contract or pre-contractual measures (Art. 6(1) b GDPR)


The processing of personal data is carried out for the execution of our contracts with you and the fulfillment of your orders as well as for the execution of measures and activities in the context of pre-contractual relationships, e.g. with interested parties. This essentially includes: contract-related communication with you, the corresponding billing and associated payment transactions, the traceability of orders and other agreements as well as quality control through appropriate documentation, goodwill procedures, measures to monitor and optimize business processes and to fulfill general duties of care, control and monitoring by affiliated companies; statistical evaluations for corporate control, cost recording and controlling, reporting, internal and external communication, emergency management, accounting and tax assessment of operational services, risk management, assertion of legal claims and defense in the event of legal disputes; guarantee of IT security (e.g. system or plausibility tests) and general security, securing and exercising the right of admission (e.g. through access controls); guaranteeing the integrity, authenticity and availability of data, prevention and investigation of criminal offenses and monitoring by supervisory bodies or control bodies (e.g. auditors).


Purposes in the context of a legitimate interest for us or a third party (Art. 6(1) f GDPR)


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

  • advertising or market and opinion research, unless you have objected to the use of your data;
  • the testing and optimization of needs analysis procedures;
  • the further development of services and products as well as existing systems and processes;
  • the enhancement of our data, including through the use or researching of publicly accessible data;
  • statistical evaluations or market analysis; benchmarking;
  • the assertion of legal claims and defense in legal disputes which are not directly attributable to the contractual relationship;
  • the limited storage of data, if deletion is not possible or is only possible with a disproportionate amount of effort due to the special nature of the storage;
  • the development of scoring systems or automated decision-making processes;
  • the prevention and investigation of criminal offenses, if not exclusively for the fulfillment of legal requirements;
  • building and system security (e.g. through access controls), if this goes beyond the general duty of care;
  • internal and external investigations as well as security checks; the possible monitoring or recording of telephone conversations for quality control and training purposes;
  • the preservation and maintenance of certifications of a private-law or official nature;
  • securing and exercising the right of admission through appropriate measures (such as video surveillance) and to secure evidence of criminal offenses and to prevent such.


Purposes in the context of your consent (Art. 6(1a) GDPR)


Your personal data may also be processed for certain purposes with your consent (e.g. use of your e-mail address for marketing purposes). As a rule, you can withdraw this consent at any time. This also applies to the withdrawal of declarations of consent issued to us prior to the GDPR coming into force, i.e. before May 25, 2018. You will be informed separately of the purpose and consequences of withdrawal or non-issuance of consent in the corresponding consent text. In principle, the withdrawal of consent is only effective for the future. Processing that took place before the withdrawal is not affected and remains lawful.


Purposes for the fulfillment of legal requirements (Art. 6(1) c GDPR) or in the public interest (Art. 6(1) e GDPR)


Like everyone who participates in economic activities, we too are subject to a large number of legal obligations. These are primarily statutory requirements (e.g. commercial and tax laws), but also, where applicable, regulatory or other official requirements. The purpose of the processing may include the fulfillment of fiscal control and reporting obligations, the archiving of data for the purpose of data protection and data security, and the examination by fiscal and other authorities. Furthermore, the disclosure of personal data within the framework of official/judicial measures may become necessary for the purpose of collecting evidence, criminal prosecution or enforcement of civil law claims.


Scope of your obligations to provide us with data
You only have to provide us with data which are necessary for the establishment and implementation of a business relationship or for a pre-contractual relationship with us or which we are legally obliged to collect. Without these data, we will generally not be able to conclude or execute the contract. This may also refer to data required later in the course of the business relationship. If we request further data from you, you will be informed of the voluntary nature of the information separately.


Existence of automated decision making in individual cases (including profiling)
We do not use purely automated decision-making procedures pursuant to Article 22 GDPR. If we should nevertheless use such a procedure in individual cases in the future, we will inform you of this separately, if this is prescribed by law. We may process some of your data with the objective of evaluating certain personal aspects (profiling).
To provide you with targeted information and advice on products, we may use evaluation instruments. These enable demand-oriented product design, communication and advertising, including market and opinion research. Information on nationality and special categories of personal data pursuant to Art. 9 GDPR are not processed.


2.4 Consequences of failure to provide data
In the context of the business relationship, you must provide personal data which are necessary for the establishment, execution and termination of the legal transaction and the fulfillment of the associated contractual obligations or which we are legally obliged to collect. Without these data we will not be able to execute the legal transaction with you.


2.5 Recipients of data within the EU
Within our company, the internal departments or organizational units that receive your data are those which require these to fulfill our contractual and legal obligations or within the context of the processing and execution of our legitimate interest.


Your data will only be passed on to external bodies

 

  • in connection with the execution of the contract;
  • for the purpose of fulfilling legal requirements according to which we are obliged to provide information, to report or pass on data, or the passing on of data is in the public interest (see Section 2.4);
    if external service providers process data on our behalf as processors or function providers (e.g. computer centers, support/maintenance of EDP/IT applications, archiving, document processing, call center services, compliance services, controlling, data validation or plausibility checks, data destruction, purchasing/procurement, customer administration, letter shops, marketing, media technology, research, risk controlling, billing, telephony, website management, auditing services, credit institutes, print shops 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 (e.g. to authorities, credit agencies, debt collectors, lawyers, courts, experts, subsidiaries and bodies and control 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 context of order processing, your data are subject to the same security standards there as they are with us. In all other cases, recipients may only use the data for the purposes for which they were provided to them.


2.6 Recipients of data outside the EU
Data are transmitted to bodies in countries outside the European Union (EU) or the European Economic Area (EEA) (so-called third countries) if it should be necessary to execute an order/contract from or with you, if it is required by law (e.g. fiscal reporting obligations), if it is within our or a third party’s legitimate interest or if you have given us your consent.


The processing of your data in a third country may also take place in connection with the involvement of service providers for order processing. If there is no decision by the EU Commission regarding an appropriate level of data protection for the country concerned, we guarantee that your rights and freedoms will be adequately protected and guaranteed pursuant to EU data protection regulations by means of appropriate contracts. We will provide you with detailed information on request. Information on the appropriate or adequate guarantees and the possibility of obtaining a copy of these may be requested from the company’s Data Protection Officer.


2.7 Storage duration
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 pursuant to the German Commercial Code (HGB) and the German Tax Code (AO), among others. The periods for storage and documentation specified therein are up to ten years beyond the end of the business relationship or the pre-contractual legal relationship to the end of the calendar year.


Furthermore, special legal regulations may require a longer storage period, e.g. the preservation of evidence within the framework of the legal statute of limitations. Pursuant to Sections 195 et seq. of the German Civil Code (BGB), the regular limitation period is three years, but limitation periods of up to 30 years may also apply.


If the data are no longer required for the fulfillment of contractual or legal obligations and rights, they are deleted on a regular basis, unless their – limited – further processing is necessary to fulfill the purposes for an overriding legitimate interest. Such an overriding legitimate interest also exists, for example, if erasure is not possible or only possible with a disproportionate amount of effort due to the special nature of the storage, and processing for other purposes by suitable technical and organizational measures is excluded.

2.8 Your rights
Under certain conditions you can assert your data protection rights against us.

  • You thus have the right to receive information from us about your data stored by us pursuant to the rules of Art. 15 GDPR (possibly with restrictions pursuant to Section 34 Federal Data Protection Act).
  • At your request, we will correct the data stored about you pursuant to Art. 16 GDPR if they are inaccurate or incorrect.
  • If you wish, we will erase your data pursuant to the principles of Art. 17 GDPR, provided that other legal regulations (e.g. legal storage obligations or the restrictions pursuant to Section 35 Federal Data Protection Act) or an overriding interest on our part (e.g. to defend our rights and claims) do not oppose this.
  • You may ask us to restrict the processing of your data, taking into account the requirements of Art. 18 GDPR.
  • Furthermore, you may object to the processing of your data pursuant to Art. 21 GDPR, which requires us to stop processing your data. However, this right to object only applies in the event of very special circumstances regarding your personal situation, whereby our company’s rights may conflict with your right to object.
  • 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 transmit them to a third party.
  • In addition, you have the right to withdraw the consent to the processing of personal data you granted at any time with future effect (see Section 2.3).
  • You also have a right of appeal to a data protection supervisory authority (Art. 77 GDPR). However, we recommend that you always address a complaint to our Data Protection Officer initially.
  • If possible, your applications for the exercising of your rights should be addressed in writing or by e-mail to the above address or directly in writing or by e-mail to our Data Protection Officer.

Special reference to your right to object pursuant to Art. 21 GDPR

You have the right to object at any time to the processing of your data on the basis of Art. 6(1) f GDPR (data processing on the basis of a balance of interests) or Art. 6(1) e GDPR (data processing in the public interest), if reasons for this exist arising from your particular situation.

This also applies to profiling based on this provision as defined by Art. 4 No. 4 GDPR. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend a legal claim.

We may also process your personal data for direct advertising purposes. If you do not wish to receive advertising, you have the right to object to it at any time; this also applies to profiling, if this is associated with such direct advertising. We will take this objection into account in the future. We will no longer process your data for direct advertising purposes if you object to processing for these purposes.

The objection may be lodged informally and should be addressed to:

wenglor sensoric elektronische Geräte GmbH
wenglor Str. 3
88069 Tettnang
E-mail: GDPR@wenglor.com

You also have the option of contacting the  Data Protection Officer above or a data protection supervisory authority with a complaint.

The data protection supervisory authority responsible for us is:

State Representative for Data Protection and Freedom of Information Baden-Württemberg
P.O. Box 10 29 32
70025 Stuttgart
E-mail: poststelle(at)lfdi.bwl.de