Privacy policy
Intorduction
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Status: June 06, 2023
Responsible
SPS & CAD AUTOMATION P.O.G. GmbH
Hans-Sachs-Str. 153
D-90765 Fürth
Phone: +49 (0) 911-21532904
Telefax: +49 (0) 911-21532905
Email: info@sps-cad.de
Processing overview
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of Processed Data
- Inventory data
- Payment data
- Location data
- Contact data
- Content data
- Contract data
- Usage data
- Meta/communication data
Categories of affected persons
- Customer
- Interested parties
- Communication partner
- Users
- Business and contractual partners
Data usage
- Provision of contractual services and customer service
- Contact requests and communication
- Security measures
- Direct marketing
- Reach measurement
- Tracking
- Office and organization procedures
- Conversion measurement
- Management and response to requests
- Feedback
- Marketing
- Profiles with user-related information
- Provision of our online offer and user friendliness
- Information technology infrastructure
Relevant legal bases
The following is an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 (1) p. 1 lit. a) DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
- Contract performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
- Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, 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 the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).Vorbehaltlich ausdrücklicher Einwilligung oder vertraglich oder gesetzlich erforderlicher Übermittlung verarbeiten oder lassen wir die Daten nur in Drittländern mit einem anerkannten Datenschutzniveau, vertraglichen Verpflichtung durch sogenannte Standardschutzklauseln der EU-Kommission, beim Vorliegen von Zertifizierungen oder verbindlicher internen Datenschutzvorschriften verarbeiten (Art. 44 bis 49 DSGVO, Informationsseite der EU-Kommission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Data deletion
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.
Our data protection notices may also contain further details on the retention and deletion of data, which take priority for the respective processing operations.Unsere Datenschutzhinweise können ferner weitere Angaben zu der Aufbewahrung und Löschung von Daten beinhalten, die für die jeweiligen Verarbeitungen vorrangig gelten.
Use of cookies
Business services
We process data of our contract and business partners, such as customers and prospects (collectively referred to as ‘contractual partners’), as part of contractual and similar legal relationships and associated measures, as well as in the context of communication with contractual partners (or pre-contractual), for example, to respond to inquiries.
We process this data to fulfill our contractual obligations. This includes, in particular, obligations to provide the agreed-upon services, any update obligations, and remedies for warranty and other performance disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and corporate organization. Additionally, we process the data based on our legitimate interests in proper and efficient business management, as well as security measures to protect our contractual partners and our business operations from misuse, data compromise, secrets, information, and rights (e.g., involving telecommunications, transportation, and other auxiliary services, subcontractors, banks, tax and legal advisors, payment service providers, or financial authorities). Under applicable law, we only disclose the data of contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of data processing, e.g., for marketing purposes, within the scope of this privacy policy.
We will inform the contractual partners which data is required for the aforementioned purposes before or as part of data collection, e.g., in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks), or personally.
We delete the data after the expiration of statutory warranty and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for archiving purposes due to legal requirements. The statutory retention period for tax-relevant documents, as well as for commercial books, inventories, opening balances, annual financial statements, the necessary instructions for understanding these documents, and organizational documents and booking vouchers, is ten years, and for received commercial and business letters and copies of sent commercial and business letters, it is six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance, the annual financial statement, or the management report was prepared, the commercial or business letter was received or sent, or the booking voucher was created, and the record was made or the other documents were created.
To the extent that we use third-party providers or platforms to provide our services, the terms and privacy policies of the respective third-party providers or platforms apply in the relationship between users and providers.
Processed data types: Inventory data (e.g., names, addresses); Payment data (e.g., bank account details, invoices, payment history); Contact data (e.g., email, phone numbers); Contract data (e.g., subject matter of the contract, duration, customer category)
Data subjects: Prospects; Business and contract partners.
Purposes of processing: Provision of contractual services and customer service; Contact inquiries and communication; Office and organizational procedures; Management and response to inquiries.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR); Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing processes, procedures, and services:
Agency services: We process the data of our customers as part of our contractual services, which can include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Contact and Inquiry Management
When contacting us (e.g., via contact form, email, telephone, or through social media), as well as within existing user and business relationships, the information of the requesting individuals is processed as far as necessary to respond to contact inquiries and any requested actions.
- Processed data types: Contact details (e.g., email, phone numbers); Content data (e.g., entries in online forms); Usage data (e.g., visited web pages, interest in content, access times); Meta/communication data (e.g., device information, IP addresses).
- Data subjects: Communication partners.
- Purposes of processing: Contact inquiries and communication; Management and response to inquiries; Feedback (e.g., collecting feedback via online form); Provision of our online services and user-friendliness.
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6(1)(b) GDPR)
Contact Form: When users contact us via our contact form, email, or other communication channels, we process the data provided to us in this context to handle the reported request; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
Advertising Communication via Email, Mail, Fax, or Telephone
We process personal data for the purpose of advertising communication, which can be conducted through various channels such as email, telephone, mail, or fax, in accordance with legal requirements.
Recipients have the right to revoke granted consent at any time or to object to advertising communication at any time.
Upon revocation or objection, we store the data necessary to prove the previous authorization for contact or sending for up to three years after the end of the year of revocation or objection, based on our legitimate interests. The processing of this data is limited to the purpose of potential defense against claims. Based on the legitimate interest of permanently considering the revocation or objection of users, we also store the data necessary to prevent further contact (e.g., email address, phone number, name, depending on the communication channel).
- Processed data types: Inventory data (e.g., names, addresses); Contact data (e.g., email, phone numbers).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g., via email or postal mail).
Legal bases: Consent (Art. 6(1)(a) GDPR); Legitimate interests (Art. 6(1)(f) GDPR).”
Web Analysis, Monitoring, and Optimization
Web analysis (also known as ‘reach measurement’) serves the purpose of evaluating the visitor traffic of our online offering and may include pseudonymous values such as behavior, interests, or demographic information about visitors, such as age or gender. Through reach analysis, we can, for example, identify the times at which our online offering or its functions or content are most frequently used or revisited. It also allows us to understand which areas require optimization.
In addition to web analysis, we may also use testing procedures to test and optimize different versions of our online offering or its components.
Unless otherwise specified below, profiles, i.e., data summarized for a usage process, can be created for these purposes, and information can be stored and read from a browser or device. The information collected includes, in particular, visited web pages and elements used on those pages, as well as technical information such as the browser used, the operating system used, and information about usage times. If users have consented to the collection of their location data to us or the providers of the services we use, location data may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization through IP address shortening) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, only the information stored in their profiles for the purposes of the respective procedures.
- Processed data types: Usage data (e.g., visited web pages, interest in content, access times); Meta/communication data (e.g., device information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles); Tracking (e.g., interest/behavior-based profiling, use of cookies); Provision of our online offering and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6(1)(a) GDPR).
Additional information on processing processes, procedures, and services:
Google Analytics 4: We use Google Analytics to conduct user analysis based on a pseudonymous user identification number. This identification number does not contain unique data such as names or email addresses. It is used to associate analytical information with an end device to recognize which content users have accessed within one or more usage processes, which search terms they have used, accessed again, or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users referring to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users with information from the use of various devices are created, with the possible use of cookies. In Analytics, data on the geographical location is provided at a higher level by capturing the following metadata through IP lookup: ‘City’ (and the derived latitude and longitude of the city), ‘Continent’, ‘Country’, ‘Region’, ‘Subcontinent’ (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The IP address of users is not logged and is automatically truncated by the last two digits. IP address truncation for EU users takes place on EU servers. Furthermore, all sensitive data collected from EU users is deleted before being recorded via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Standard Contractual Clauses (Ensuring Data Protection Level for Processing in Third Countries): https://business.safety.google/adsprocessorterms; Opt-out option (Opt-Out): Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Display Advertising Settings: https://adssettings.google.com/authenticated; Further Information: https://privacy.google.com/businesses/adsservices (Types of Processing and Processed Data).
- Google Tag Manager: Google Tag Manager ist eine Lösung, mit der wir sog. Website-Tags über eine Oberfläche verwalten und so andere Dienste in unser Onlineangebot einbinden können (hierzu wird auf weitere Angaben in dieser Datenschutzerklärung verwiesen). Mit dem Tag Manager selbst (welches die Tags implementiert) werden daher z. B. noch keine Profile der Nutzer erstellt oder Cookies gespeichert. Google erfährt lediglich die IP-Adresse des Nutzers, was notwendig ist, um den Google Tag Manager auszuführen; Dienstanbieter: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Rechtsgrundlagen: Einwilligung (Art. 6 Abs. 1 S. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Datenschutzerklärung: https://policies.google.com/privacy; Auftragsverarbeitungsvertrag: https://business.safety.google/adsprocessorterms; Standardvertragsklauseln (Gewährleistung Datenschutzniveau bei Verarbeitung in Drittländern): https://business.safety.google/adsprocessorterms; Weitere Informationen: https://privacy.google.com/businesses/adsservices (Arten der Verarbeitung sowie der verarbeiteten Daten).
Changes and Updates to the Privacy Policy
We kindly request you to regularly check the content of our privacy policy. We will adjust the privacy policy as soon as changes in the data processing we carry out require it. We will inform you if the changes require any action on your part (e.g., consent) or any other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that these addresses may change over time, and we recommend verifying the information before contacting them.
Rights of Data Subjects
You have various rights as data subjects under the GDPR, particularly arising from Articles 15 to 21 of the GDPR:
Right to Object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data under Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, including profiling related to such direct marketing.
Right to Withdraw Consent: You have the right to withdraw consent that you have given at any time.
Right to Access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and other information as per legal requirements.
Right to Rectification: You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed as per legal requirements.
Right to Erasure and Restriction of Processing: You have the right to obtain the erasure of personal data concerning you without undue delay as per legal requirements or to demand a restriction of the processing of the data as per legal requirements.
Right to Data Portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format as per legal requirements, or to request the transmission of that data to another controller.
Right to Lodge a Complaint with a Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement if you believe that the processing of your personal data violates the GDPR.”
Definitions
In this section, you will find an overview of the terminology used in this privacy policy. Many of the terms are derived from the law, especially in Article 4 of the GDPR. The legal definitions are binding, while the following explanations are primarily provided for understanding. The terms are sorted alphabetically.
Personal Data: ‘Personal data’ refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie), or one or more specific factors that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Profiles with User-related Information: The processing of ‘profiles with user-related information,’ or simply ‘profiles,’ includes any form of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects related to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Profiling is often used for purposes such as analyzing interests in specific content or products, click behavior on a website, or location data. Profiling often involves the use of cookies and web beacons.
Reach Measurement: Reach measurement (also referred to as web analytics) is used to evaluate visitor flows of an online offering and can include the behavior or interests of visitors in specific information, such as website content. With the help of reach analysis, website owners can, for example, determine when visitors access their website and what content interests them. This allows them to better tailor the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and obtain more accurate analyses of the use of an online offering.
Location Data: Location data is generated when a mobile device (or another device with the technical requirements for determining a location) connects to a radio cell, a Wi-Fi network, or similar technical means and functions for location determination. Location data indicates the geographically determinable position on Earth where the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
Tracking: ‘Tracking’ refers to the ability to track user behavior across multiple online offerings. Typically, behavior and interest information related to the used online offerings are stored in cookies or on servers of the providers of tracking technologies (known as profiling). This information can subsequently be used, for example, to display users advertisements that are likely to match their interests
Controller: The ‘controller’ is the natural or legal person, authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: ‘Processing’ refers to any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, including collecting, evaluating, storing, transmitting, or deleting.
