I. Controller for the Processing of Personal Data
We, Secure 2 Fiber GmbH, are the provider of the services described below (hereinafter “we” or “provider”), including the associated processing of personal data. This privacy notice provides you, the user of the services (hereinafter “you”), with information about the relevant processing of personal data for all contact points at which you interact with us.
II. Our Data Protection Principles
In the course of providing the services described here and operating websites and other contact points, we process your personal data in various ways. We inform you comprehensively about the processing of personal data and about the principles according to which this processing takes place.
We take the protection of your personal data very seriously. We therefore process your data with great care and in strict compliance with the applicable data protection laws and any individual consents you may have given us. We have taken organizational and technical security measures to protect all our websites, apps and other (digital) contact points against the potential risks associated with the processing of personal data. Our partners who support us in providing the services must also comply with these provisions.
Please use the contact details provided in this privacy policy to contact us in general or with specific questions and/or requests regarding data protection.
Depending on the country you are in, different data protection laws apply. Based on the principles of the European General Data Protection Regulation (“GDPR”), we have established the following basic guidelines for processing and protecting your personal data when providing our website and services:
1. Lawfulness
We only use personal data where this is lawful, which is only the case if at least one of the following conditions is met:
• You have given your consent.
• The use of personal data is necessary for the performance of a contract to which you are a party.
• The use of personal data is necessary for compliance with a legal obligation, e.g. in the case of product safety measures where we are obliged to inform all our customers.
• The use of personal data is necessary to protect the vital interests of the individual, e.g. in cases where we inform individual customers about product safety issues.
• The use of personal data is based on a legitimate interest in using personal data, and our use does not unreasonably interfere with your data protection rights.
For all processing of personal data described here, we also state the legal basis for the processing at the end of each main section, as well as in the description of the specific third-party service providers we use in Section XII of this privacy notice.
2. Fairness and transparency
In this privacy policy, we inform you in a fair and transparent manner about which personal data we collect and why we collect it. You can access the privacy policy directly or via a link when you register and/or at any contact point at which you interact with us.
Users under the age of 16 should only submit personal data to us with the consent of their parent or guardian. The data protection law applicable in your country may result in different age limits.
3. Purpose limitation and data minimization
We only collect and use personal data that we really need and for the purpose for which you provided the personal data to us. If we can achieve the purpose with less personal data, we only use the minimum data required. Nevertheless, you are free to provide additional personal data at any time if this would improve your experience with the services offered.
4. Types of processing including third parties
In cases where we do not process your personal data directly as a controller (e.g. website hosting, technical services, etc.), we commission third parties who provide these services on our behalf as processors. These contracts oblige them to process your personal data in a lawful and secure manner. This is referred to as a controller-processor relationship and is defined in Art. 28 GDPR, whereby we are the controller and the respective third party is the processor. A list of the third-party providers commissioned by us can be found in Section XII.
Joint controllership describes the situation in which several parties, including us, jointly decide how data is used and managed (joint controllers, see Art. 26 GDPR). Joint controllers must provide clear information about who processes which personal data and which obligations each party has assumed with regard to the applicable data protection regulations. The joint controllers agree on their roles and ensure that the data subjects (persons to whom the data relates) are informed about these roles. If we use a third-party provider or partner that processes personal data as a joint controller, we will inform you about the relevant rights and roles in the list of third-party providers in Section XII at the end of this document.
Sometimes it is necessary to transfer personal data to a third party acting as an independent controller in its own name and on its own account, e.g. when we commission a shipping company to send products to you. In these cases, we have agreed minimum data protection standards with these independent controllers in order to protect your personal data.
Our website may also contain links to third-party websites whose content is not provided or controlled by us. In these cases, we have no control over the processing of your data on their websites or over their compliance with data protection regulations, but we will inform you, for example, when you leave our website. Please refer to the privacy notices that these third parties may provide.
5. Cross-border processing within and outside the EU
As some of the third parties providing services for us (as described in this document) are not based in your country, the processing of your personal data may also involve a cross-border transfer of your personal data. Our aim is to process personal data only within the European Union, which is why most third-party providers process personal data in European data centers.
If this is not technically possible, or if there is another reason why personal data may also be processed outside the European Union, we follow the principles set out in Art. 44 et seq. GDPR. We secure such transfers through contracts (based on specific legal transfer mechanisms) that we conclude with such providers, or on the basis of an adequacy decision of the European Commission, including the EU-US Data Privacy Framework (“DPF”). Information on whether a provider participates in the DPF and actively meets the requirements can also be found at:
https://www.dataprivacyframework.gov/s/participant-search
6. Security
We process your data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. If we commission a third party to process personal data, we also agree on an appropriate level of technical or organizational measures that these providers must comply with.
7. Rights of users
You have the following rights vis-à-vis us, which we will comply with promptly and appropriately after receiving your corresponding request as described below:
• Your right of access to your personal data pursuant to Art. 15 GDPR: We will inform you whether we have stored personal data about you and, if applicable, provide you with information about this data.
• Your right to rectification of your data pursuant to Art. 16 GDPR: We will correct inaccurate information or complete incomplete personal data, provided that this data is necessary for the intended purpose of processing your data.
• Your right to erasure of your data pursuant to Art. 17 GDPR: We will delete the personal data stored about you, provided that this data is not subject to retention periods or retention rights, for example because we must retain your data to fulfill our contractual obligations or due to legal requirements.
• Your right to restriction of the processing of your data pursuant to Art. 18 GDPR: In the cases mentioned in Art. 18 (1) GDPR, you can request that we block your data. We will only continue to process blocked data to a very limited extent, and only if this is necessary to provide services or to fulfill obligations whose fulfillment is necessary after the blocking of your data that you requested.
• Your right to withdraw consent pursuant to Art. 7 (3) GDPR: For data processing that requires your consent, you can withdraw your consent at any time in order to prevent the future processing of your data. Data processing carried out on the basis of your consent before your withdrawal remains valid and lawful.
• Your right to object to the processing of your data pursuant to Art. 21 GDPR: You can object to the future processing of your data if we process your data on the basis of one of the legal bases mentioned in Article 6 (1e or 1f) GDPR. If you object, we will stop processing your data unless we have compelling legitimate grounds for further processing that override your interests and rights, or the processing is necessary for the establishment, exercise or defense of legal claims. The processing of your data for direct marketing purposes never constitutes a compelling legitimate ground for us.
• Your right to data portability pursuant to Art. 20 GDPR: If the data processing is carried out by automated means and is based on consent or a contract, we can provide you with the data you have provided to us in a structured, commonly used and machine-readable format.
• Your right to lodge a complaint with a supervisory authority: You can contact a data protection authority with a complaint regarding data protection. To do so, please contact the data protection authority responsible for your place of residence or the data protection authority to whose jurisdiction we are subject (see Section XI Data Protection Authority).
If you wish to exercise your rights, please contact the following email address: datenschutz@secure2fiber.com
8. Deletion principles
We process your personal data only for specified, necessary purposes. As soon as the purpose of the processing has been fulfilled, we delete your personal data unless there is a retention obligation or a right to longer retention. This applies to all personal data, regardless of how and where it is stored.
There are various local laws, such as tax or commercial laws, that establish the legal requirements for the retention of data. In addition, we may retain personal data on the basis of legitimate interests, e.g. to comply with product safety laws to protect our customers. We may also retain personal data for business purposes if the GDPR recognizes these purposes as justification for retention, e.g. retaining customer data to defend against legal claims.
Access to personal data that is stored solely for the purpose of complying with statutory retention periods or retention rights is restricted as soon as the original purpose of the data collection no longer applies. This ensures that the personal data is no longer actively used in our business operations.
9. Data protection officer
If you have any questions about data protection or wish to exercise your rights, our data protection officer (DPO) will be happy to assist you. You can simply contact our DPO directly by sending a letter or email to the contact details given below. He will be happy to address your concerns and support you in exercising your rights under data protection law. Please contact:
Secure 2 Fiber GmbH
Attn: Data Protection
Am Brambusch 24,
D-44536 Lünen,
Germany
Email: datenschutz@secure2fiber.com
Phone: +49 (0)231 / 999 85 400
10. Changes to this privacy notice
This privacy notice reflects the current state of data processing on our website and other contact points (e.g. administration, ticket system, social media accounts, etc.). In the event of changes to data processing, this privacy notice will be updated accordingly. We always make the current version of this privacy notice available on our website so that you can inform yourself about the scope of data processing via this website.
III. Our Internet Contact Points
1. Websites
a) Provision of the websites themselves
To display the website correctly in your internet browser, we use various technical means to ensure that all content (texts, images, videos, etc.) is up to date and displayed correctly.
b) Categories of data
For technical reasons, your internet browser automatically sends information to our web server each time you access our website (so-called log data). We store some of this information in log files, such as:
• Date and time of access,
• URL and files of the accessed website, including the amount of data transferred
• Version of the HTTP protocol used, including the type of operating system
• Type and version of the internet browser
• IP address.
The above log data does not contain any personal data. We only analyze log data when necessary, for example to rectify faults in the operation of our website or to manage security incidents.
In addition, it may be necessary for us to record the full IP address of the device in addition to the log data in order to rectify faults or secure evidence in connection with security incidents.
We delete this data once the fault has been rectified, the security incident has been fully investigated or the original purpose of the processing no longer applies. In the event of a security incident, we transmit log data to the investigating authorities after examining each individual case, insofar as this is permissible and necessary.
2. Our social media pages
a) General information
Protecting your privacy when processing personal data is important to us. We treat the personal data transmitted to us that is collected during your visit to our respective social media page (e.g. LinkedIn) confidentially and only in accordance with the statutory provisions.
b) Categories of data
The social media service processes your personal data as soon as you use our respective social media page. The processing is related, for example, to the following usage operations:
• Viewing a page or a post or video from a page
• Subscribing to or unsubscribing from a page
• Marking a page or a post with “Like” or “Unlike” or similar functions
• Recommending a page in a post or comment
• Commenting on, sharing or replying to a page post (including the type of reply)
• Hiding a page post or reporting it as spam
• Clicking on a link that leads to the page, either on another website of the social media provider or on a website outside the social media provider
• Hovering the mouse over the name or profile picture of a page to see a preview of the page content
• Using functions of the social media provider, such as the website, the phone number, the “Get directions” button or other buttons on a page
• Information on whether the login takes place via a computer or a mobile device.
c) Recipients/categories of recipients
In addition to us, the respective operator of the social media page is responsible for processing your data via our social media page (see examples below). Insofar as the processing of this data takes place within our area of responsibility, we are available to answer all questions regarding data protection and the exercise of your rights in accordance with the information provided in this privacy notice. You can find out which personal data is collected by the social media provider, how it is processed and which data protection rights you have vis-à-vis the social media provider in the following privacy policies of the social media provider. We have no influence on the data processing carried out by the social media provider.
d) Data processing by us
On the website provided by us via the social media provider, the social media provider grants us access to the following categories of data:
• The social media provider grants us access to statistical evaluations that provide us with information about the use of our social media website. The evaluations visible to us do not allow us to analyze the usage behavior of individual persons. We can only view aggregated data (such as the number of visits, likes, followers, region of origin, age group, gender, etc.) that provides us with information about our system users and the use of our social media page. The data of the respective user on which the analyses are based is not transmitted to us.
• We can define the target group for the social media website or for individual published articles. The setting is based on general parameters (e.g. age group, language, region, interests) that allow us to tailor our content to specific groups. It is not possible for us to address or identify individual persons on the basis of the data made available to us by the social media provider.
• If you contact us directly via the social media provider or interact with us in any other way and consciously transmit personal data in the process (e.g. by connecting directly with our social media website), we store and process this personal data for the purposes for which you transmitted it to us.
• We process this data exclusively for the purpose of making content on our social media website known to the target group and to better understand and optimize the use of our social media website.
Beyond this, we have no influence on the data processing (for the provision of this data in advance) carried out by the social media provider within its area of responsibility.
Please check with the respective third-party provider which personal data it collects in detail, how it is processed and which data protection rights you have vis-à-vis the respective social media provider (see the list of third-party providers (Section XII)):
3. Social media plugins as hyperlinks
Some content on our website can be shared on social networks such as LinkedIn via integrated social media buttons. All social media buttons that enable content to be shared are integrated via simple hyperlinks and not via social plugins from the social network providers. This ensures that your data is not automatically transferred to the servers of the social networks as soon as you access our website. In addition, when you share content from our website, we only transmit to the social network the information required to share the relevant content (e.g. the link to the content you wish to share). We do not transfer any personal data in this context.
At the same time, you will also find direct links to our websites on social networks. If you follow a link from our website to a social network or log in to your social network to share content from our website, your data will be processed by the provider of the respective social network.
If you are registered and logged in to other networks or services that require registration while using our website or individual functions, the respective network/service may collect information about your use or apply settings, such as played videos/playback status. However, this data is collected exclusively by the respective network/service under its own data protection responsibility and processed by the respective provider.
For information about the purpose and scope of data collection, the further processing and use by the respective network operator, as well as your related rights and settings options for protecting your privacy, please refer to the privacy notices on the website of the respective provider.
4. User-generated content (UGC) from social media
UGC from social media enables us to share content created by customers and published on social media or other channels, such as texts, images, videos and reviews, on our social networks. We acquire the rights to your content through a separate license agreement. When using such UGC, various types of personal data may be associated with the UGC. This data may include:
• Profile information: This may include the username, the profile picture and any other information you have provided directly in your social media profile.
• Posts and comments: Content that you have posted or commented on, including text, photos, videos and links, may be processed.
• Location data: If you have activated location services in your social media account, the location information may be processed when you post or interact with content.
• Data from friends/followers: A user's connections or followers on social media may be processed if this is relevant to the user-generated content used.
Please note that the specific personal data processed may vary depending on the social media platform and the privacy settings you have chosen.
5. Legal basis for data processing
We base the above data processing operations on a legal permission pursuant to Art. 6 (1) (f) GDPR, with the exception of UGC, which is based on a legal permission pursuant to Art. 6 (1) (b) GDPR.
IV. Communication
1. Contacting us
If you contact us outside of a specific contractual relationship (e.g. to obtain information) or a registration, we offer you various contact options via our websites, including purely technical ones.
In order to process your specific request when you contact us, we may ask you to provide personal data. This includes, for example, your name and email address as well as other information such as the subject of your request and your message. You can optionally provide your postal address and/or telephone number. We collect the requested information in order to be able to process your request appropriately.
The personal data transmitted to us in this way is used exclusively for the purpose for which you provide it to us when contacting us, in particular for processing your request. The data will not be used for other purposes or passed on to third parties without your express consent. Excepted from this, insofar as this is necessary to fulfill your request, are the persons and companies (e.g. local service companies) involved in carrying out the communication and answering the request.
Unless there are statutory retention obligations, your personal data will be deleted after your request has been processed.
2. Contact by telephone
You can contact us by telephone. We do not operate a call center and do not use external call center services. Your call is always handled directly by our own employees.
When you call us, we may create a ticket in our internal ticketing system to document and process your request. The process depends on the type of call:
Direct calls to employees (no automatic ticket creation)
If you call one of our employees directly (e.g. via their extension or direct dial number), no ticket is created automatically in our internal ticketing system.
• A ticket is only created if this is necessary for processing your request, and then exclusively manually by the employee handling your call.
• In this case, the employee may enter your personal data into the ticketing system, such as:
o Name,
o Contact details,
o Date and time of the call,
o Reason for the call,
o relevant details discussed (e.g. technical issues, agreements, notes on next steps).
This serves the documentation and efficient processing of your request.
Further processing
• Ticket and call logging:
If a ticket is created (manually or automatically), we log information such as your name (if provided), your contact details, the date and time of the call, the reason for your call and relevant details discussed. This information is stored in the internal ticketing system in order to process your request and ensure that it is handled efficiently.
• Call recording (optional):
With your prior consent, we may record calls for quality assurance or training purposes. In this case, audio data is processed, which may contain personal data shared during the call. If a recording is made, it may be linked to the corresponding ticket.
• Internal forwarding:
Personal data may be processed in order to assign your ticket or request to the responsible employee or department, depending on the nature of your request or your preferences. For this purpose, we may also use technical systems, including artificial intelligence (AI), to categorize requests and assign them to the responsible team.
• Identity verification:
Our employees may need to process personal data (e.g. name, customer number, contact details) in order to verify your identity before providing account-specific information or making changes to your data or contracts.
• Problem resolution and support:
To help you resolve problems or answer your questions, our employees may access customer data or internal databases. In doing so, your personal data is processed as necessary to handle your request and document the outcome in the ticket.
For the technical provision and maintenance of our telephony and internal ticketing systems, we may use IT service providers who act on our behalf as processors. However, these service providers do not operate a call center and do not conduct any customer communication of their own; communication with you takes place exclusively through our own employees.
3. Chatbot
The chat function (where available) enables us to answer your questions about our products and services promptly. When you ask a question in the chat, an application attempts to answer your questions. Through the potential use of artificial intelligence (AI), the system can send you relevant links or forward your request to a customer service employee in the live chat. We use the chatbot to process your request and to improve our business and our services. We use the services of a technical service provider to enable the chatbot function on our websites and via other contact points.
The following personal data may be processed as part of the chat functionality:
• Mandatory information for initiating a chat
• Chat history as a transcript (“transcript”)
• IP address, approximate location, browser type and version, device type, visitor path
• Usage data (e.g. time of chat start, chat end, chat duration, chat performance data)
• Other content processed in the chat (e.g. phone number, email address)
4. Surveys
We conduct surveys on your satisfaction with our products and services. We may ask you for feedback, for example via a form on our websites, or send you an email. If we ask you to rate our products and services by email, you can rate them on a scale of up to ten points. In addition, you can leave comments in a free text field or, if applicable, provide your telephone number to receive a callback regarding your rating and your comments. Participation in these surveys is completely voluntary. We store the data you provide to us in such a survey together with your contact details and transaction data relating to the product or service we have provided to you. We use this data to improve our products and services. Your personal data is anonymized after 12 months.
When we conduct surveys on our website, they are generally anonymous. Should we exceptionally collect data from you as part of a survey, the preceding paragraph applies.
5. Newsletter
On our website you have the option of subscribing to our newsletter. We use a double opt-in procedure to verify that the owner of an email address has actually signed up to receive the newsletter. The newsletter subscription is only successfully completed once the owner of the email address has expressly confirmed the activation of the newsletter by clicking on the link in the confirmation email. We log the completion of the individual steps of the double opt-in procedure for verification purposes.
For this purpose, we collect and process data about your use of our email newsletter. When you open an email newsletter from us, a file contained in the email (a so-called web beacon) establishes a connection to our servers. This enables us to determine whether an email newsletter has been opened and, if so, which content has been clicked on. In addition, we collect technical information about the device you use to access the content of the email newsletter (e.g. time of access, browser type and operating system). We use this data exclusively for the statistical evaluation of our newsletter campaigns. If you subscribe to our newsletter and thereby consent to receiving it, your data will be used to send you the newsletter and to analyze your use of the email newsletter. You can withdraw this consent at any time. The corresponding link is included in every issue of our newsletter. We will note in our database that you have unsubscribed from the newsletter.
6. Legal basis for data processing
Depending on how you contact us, we base the above data processing operations on a legal permission pursuant to
• Article 6 (1) (a) GDPR, based on your consent, e.g. for telephone recordings, newsletters and surveys unrelated to a contractual relationship, as well as surveys for which you have actively registered to participate;
• Art. 6 (1) (b) GDPR for (pre-)contractual communication, e.g. via our telephone contact or chatbots, questions about the delivery or return of products;
• Art. 6 (1) (f) GDPR in the event that you contact us, e.g. for conducting surveys.
V. Analytics, Marketing and Tracking
1. Analytics
Analytics refers to the process of collecting, processing and analyzing data in order to gain insights and make decisions. For us, this is comparable to examining trends in order to better understand how you use our products and services. These insights enable us to make our products and services more user-friendly. They also allow us to identify areas in which our products and services can be improved and innovatively developed further. Our websites are integrated with analytics platforms. These platforms provide JavaScript code that is added to the website. This code interacts with cookies or similar technologies to collect data when users interact with our website. As users navigate the website, the analytics code collects data from the cookies/pixels. The data we collect includes information about page views, clicks, time spent on pages and other relevant metrics.
Analytics platforms aggregate the collected data and provide us with insights into user behavior and website performance. This aggregated data is used to understand audience demographics, popular content and areas that may need improvement.
2. Marketing and tracking (including re-marketing)
We may collect and use your personal data to send you relevant marketing communications. These communications may include product updates, promotional offers and newsletters. You can easily manage your communication preferences and unsubscribe if you wish.
We also carry out digital marketing activities, including retargeting. Retargeting, also known as remarketing, means displaying targeted advertising to users who have previously interacted with our website or our digital content but have not completed an action.
When a user visits our website and performs certain actions, a tracking pixel or cookie is placed on their device.
Further information on the providers, including information about their specific use and additional information on provider-specific data protection aspects, can be found in Section XII.
3. Cookies and similar technologies
4. Legal basis for data processing
All processing operations described above, in particular the setting of pixels and cookies to read information on the device used, are only carried out if you have given us your consent to do so. You can withdraw your consent at any time with effect for the future, as described above under “Cookie processing”. Alternatively, you can use the opt-out page for EU customers at http://www.aboutads.info/choices or http://www.youronlinechoices.eu/.
We base the above data processing operations on:
a) Your consent pursuant to Art. 6 (1) (a) GDPR:
• Web analytics and marketing via cookies and/or similar technologies
b) a legal permission pursuant to Art. 6 (1) (b) GDPR:
• Registration on our website
• Convenience registration (social sign-on option)
c) a legal permission pursuant to Art. 6 (1) (f) GDPR:
• Technical cookies required for the provision of the website
• Interactive digital assistants
• Technical cookies for displaying the website (e.g. security functions)
• Additional website functions (e.g. product videos)
• Log data
• Session cookies and persistent cookies for convenience functions
VI. Events and Competitions, Trade Fairs
1. Participation in events
When you register for an event, we store and use the information you provide in order to hold the event, including follow-up activities. The data we collect for this purpose depends on the registration form on the respective websites on which you register. Your data will be deleted as soon as it is no longer required for holding the event or for follow-up activities. As a rule, such a registration process includes a confirmation email about your participation, additional emails about the organization/changes and a follow-up email, which may also include the opportunity to give us feedback.
For some events, the participation fee is payable directly, or they are managed and conducted in whole or in part by our partners. In this case, you may be redirected to the website of the respective partner. In this case, the relevant payment data (surname, first name, postal address, number of participants and payment method) will be transmitted to our partner in order to carry out the payment process for the event, provided you have already provided this data.
2. Participation in prize draws/competitions
When you register for a prize draw or competition, we store and use the information you provide exclusively for the purpose of organizing and conducting the prize draw or competition and for any necessary follow-up measures. The specific data we collect depends on the registration form you fill out on the page for prize draws or competitions.
We delete your data promptly after the prize draw or competition has ended and all necessary follow-up measures have been completed. We only store your data for as long as is necessary for conducting the prize draw or competition and all related activities.
3. Trade fairs and similar events
We take part in both in-person and digital trade fairs. In this context, data processing, in particular of your contact details, takes place in the following cases:
• If you express the wish to receive further information from us by email or post
• Establishing a business relationship
• Your participation in prize draws
• Your request for newsletters and advertising materials
• Answering questions about our products
• Your order
Further information can be found in the sections “Communication”, “Business Partners” and “Customer Service” in this policy. How extensively we process your personal data depends on the context in which you provide your data.
4. Legal basis for data processing
We base the above data processing operations on a legal permission pursuant to Art. 6 (1) (b) GDPR.
VII. Customer Service
We offer you contact points through which you can purchase products or services directly, e.g. via our websites, technicians and telephone contact. With regard to the processing of personal data, the following interactions may take place when using these contact points.
1. Typical interactions
• Browsing and product selection: Customers browse various products or services, comparing features, prices and reviews before making a decision.
• Payment and order confirmation: Customers complete the payment process and receive a confirmation of their order, including an order number and the expected delivery date.
• Inquiries and support: Customers may have questions or need assistance regarding products, orders, shipping, returns or other topics. They can reach support via various channels such as telephone, email or chat.
• Problem resolution: Support staff help resolve customers' problems or concerns, e.g. product defects, delivery delays or billing discrepancies.
• Returns and exchanges: Customers can request returns or exchanges for products that arrived damaged. Support assists them in initiating the returns process and provides them with the necessary instructions.
2. Contract
In order to fulfill your orders and conclude a contract with you, we process the following personal data:
• Company name
• Salutation
• First and last name, department, full postal address
• Telephone number
• Email address
• Billing data
3. Payment and credit checks
Your payment data is transmitted to the respective payment service provider in order to process the payment. If you use paid services, billing data is processed. Your personal data may also be processed to investigate and prevent fraud, misuse, security-related incidents and other harmful activities, e.g. to combat money laundering and for criminal prosecution. This is based on compliance with applicable laws (e.g. on the prevention of money laundering) and on our legitimate interest in limiting the risk of payment defaults.
We commission external service providers with tasks related to payment processing, programming and data hosting. We have carefully selected these service providers and monitor them regularly, in particular with regard to their careful handling and protection of the data they store. All service providers are obliged by us to maintain confidentiality and to comply with the statutory provisions. Service providers may also be other companies of Trianis Holding GmbH.
During the ordering process, we may carry out credit checks depending on the payment method you have chosen. We work with providers/agencies for credit checks and transmit your order data in order to obtain information for such checks. Before we carry out credit checks, we will inform you specifically at the relevant contact point about how we handle your data.
4. Delivery, cancellation of an order and returns
As part of the delivery process, we work with logistics service providers, and your contact details are passed on to our logistics service providers so that they can carry out the delivery and contact you to arrange deliveries and inform you of any delivery problems that arise. We may also use your order information to plan delivery routes.
You may also be offered the option of selecting a day and time frame for the delivery of your orders that is convenient for you. In this case, our logistics service providers and suppliers receive your order information in order to offer you the available date. In some cases, you can also track the status of your products via the tracking link we send you.
The information required for returns may be a combination of your order number/order information and company information (e.g. company name/department/address or email address). After you have handed over your return package to our logistics service provider, you will receive emails on the status of your return and your refund.
5. Insurance/extended warranty
We collect your company data and optional personal data in order to enable the insurance service you have chosen and to improve your overall customer experience. This includes information required for creating policies, processing claims and communicating regarding your insurance coverage.
We may collect details such as your name, contact details, address and specific information about the product you have purchased. We pass this data on to our partners who offer the insurance or extended warranty. This ensures that our partners can tailor insurance solutions individually to your needs.
6. Debt collection agencies
Under certain circumstances, it may be necessary to pass on relevant information to a debt collection agency in order to facilitate the settlement of outstanding payments.
The transfer of data to a debt collection agency serves exclusively the purpose of collecting outstanding payments in connection with our products or services. This ensures the fair and lawful handling of financial transactions.
The information passed on to the debt collection agency may include details such as your company name, contact details, billing data and details of the outstanding payment. The information is processed exclusively to the extent necessary for the proper and effective provision of the debt collection agency's services.
7. Registration on our website / customer platform
You can register on our website to use our helpdesk services. As part of the registration process, we collect and process the following information:
Required information: company name, company address, VAT identification number, company telephone number, company email address, title, first and last name, business telephone number (mobile or landline), business email address, password.
We store the data of registered users until the user requests the deletion of the account or the account is no longer required for the collaboration.
8. Legal basis for data processing
We base the above data processing operations on:
a) A legal permission (performance of a contract) pursuant to Art. 6 (1) (b) GDPR:
• Registration on our website
• Insurance/extended warranty
• Delivery (including delivery arrangements, shipment tracking and returns)
• Customer service
• Product/service information by email
• Data processing for address verification
• Debt collection agencies
b) A legal permission (legitimate interest) pursuant to Art. 6 (1) (f) GDPR:
• Credit checks
VIII. Security Measures
1. Product recall
In the event of a product recall, we take proactive measures to ensure the safety of our customers. If you are affected by a product recall, we will notify you via the contact details you have provided, e.g. by email, in order to provide you with important information. To enable this communication, we use the contact details and associated product information stored in our customer database.
Please note that such a recall is a one-time data processing measure that serves exclusively the purpose of informing you about the product recall. Throughout the entire process, we attach the utmost importance to the security and confidentiality of your data. Your data will be used exclusively for the purpose of processing the product recall and will not be passed on or used for other purposes.
By notifying you promptly of product recalls, we want to ensure your safety and make sure that you have the necessary information to take appropriate action.
2. Security updates
We attach great importance to data protection and security and strive to continuously improve the security features of our products. To address potential vulnerabilities that may arise over time, we regularly offer security updates. These updates are crucial for maintaining the integrity and security of your products.
We strongly recommend that you regularly commission us to install these security updates. This way, you can ensure that your devices remain protected against potential security threats. If you do not have these updates installed, your personal data and connected devices may be exposed to unauthorized access or compromise.
3. Specific deletion period
Personal data relevant to product safety measures is subject to a centrally defined specific deletion period of 30 years. After the regular deletion period has expired, this data is transferred to a separate, access-restricted archive for further storage. If you submit a deletion request via our website (see Section I above), your data will also be deleted from this security archive regularly and promptly.
4. Legal basis for data processing
We base the above data processing operations on:
a) Your consent pursuant to Art. 6 (1) (b) GDPR:
• Security updates.
b) A legal permission pursuant to Art. 6 (1) (c) GDPR:
• Mandatory product recall.
c) A legal permission pursuant to Art. 6 (1) (d) GDPR:
• Voluntary product recall.
IX. Business Partners
1. General information
a) Contractual relationship with business partners
The following privacy notices apply to you if you are our business partner or a legal representative, employee, shareholder or beneficial owner of a business partner. Business partners are legal entities or natural persons who are in negotiations with us about entering into a business relationship or who already have such a business relationship with us. Contracts in connection with employment or training relationships are expressly excluded.
b) Categories of data
Which data is processed in detail depends heavily on the agreed services and the subject matter of our business relationship. Therefore, not all parts of this information are relevant to you.
As a rule, we collect your data from you directly. In certain constellations, however, due to legal requirements or legitimate interests (e.g. in the context of compliance checks of business partners), it may also be necessary to process personal data that we receive from other companies, tax offices, authorities, credit agencies, insolvency registers, publicly accessible sources (internet research) or other third parties. The relevant personal data may include:
• Personal data (e.g. first and last name, address and other contact details, date and place of birth, and nationality)
• Legitimation and authentication data (e.g. extracts from the commercial register, identification data, specimen signature)
• Company as well as position, function and department within the company, supervisor
• Data in the context of our business relationship (e.g. payment data, data on orders)
• Data on company structures and ownership
• Log data
• Username and identification, user ID
• Compliance-relevant data (e.g. information on references, information on insolvencies
• Negative reports, checks against sanctions lists
• Information on criminal investigations in connection with the subject matter of the service
• other data comparable to the aforementioned categories.
When concluding a contract, we may obtain data on your creditworthiness from credit agencies in order to fulfill the legitimate interests mentioned above. We use the data from the credit agencies for credit checks in order to verify your creditworthiness. The credit agencies store data that they receive, for example, from banks or companies. You can obtain information about the data stored about you directly from the credit agencies.
If you conclude a contract with us by means of a digital signature, we process the data associated with it (in particular your email address, IP address, and the times at which you edited the respective contract document). In addition, it is possible to sign certain contracts with a so-called qualified electronic signature. In this case, we also process the certificate data of your signature in addition to the categories mentioned. This data is accessible to all persons involved in the approval and signing of the contract.
c) Recipients/categories of recipients
Within our company, access to the data you provide is granted to those departments that need it to fulfill contractual or legal obligations or to safeguard legitimate interests, or that you have approved in the separate declaration of consent.
Within the framework of the contractual relationship, to fulfill legal obligations and to protect legitimate interests, authorities or service providers may also be given access to your personal data.
Compliance with data protection regulations is ensured by contract. The data may also be passed on to companies within Trianis Holding GmbH in order to fulfill contractual obligations.
If you, as an authorized service provider, have concluded a framework agreement with the entire Trianis Holding GmbH, the respective procurement and purchasing departments of Trianis Holding GmbH are given access to the business partner data relevant for contacting you, and the national compliance departments of the companies of Trianis Holding GmbH each have access to the data for the compliance check of business partners. Outside our group of companies, the data is only passed on if we are legally obliged to do so (e.g. in the case of official investigations).
2. Legal basis for data processing
We base the above data processing operations on:
a) a legal permission pursuant to Art. 6 (1) (b) GDPR:
• Use of our website as a business partner (pre-contractual and contractual use)
b) a legal basis pursuant to Art. 6 (1) (f) GDPR:
• Use of our website as a business partner (surveys, invitations to events, congratulations and Christmas cards)
• Selection of a suitable business partner (e.g. intermediary check)
X. Job Applicants
As an applicant for a job vacancy, you can use one of our contact points to submit your data to us. In addition to the information provided directly at the respective contact point (e.g. jobs page), we inform you below about our general handling of such personal data.
1. General information
We use your applicant data
• to identify you as an applicant
• to contact you
• to carry out the application process
Your personal data is transmitted to
• our employees responsible for your application
• where applicable, our service providers for the technical support of the application/applicant portal/job platform
• where applicable, our postal and logistics service providers.
Your personal data will be deleted as stated on the respective applicant website, unless we have received your consent to store your data for longer, e.g. for processing in an applicant pool. If there are legal or contractual obligations to retain such data, your data will be stored for as long as is necessary to fulfill these legal/contractual obligations, but access to your data will be restricted. For statistical purposes, some data originating, for example, from the application process is anonymized and processed further after the deletion of your personal data.
2. Legal basis for data processing
We base the above data processing operations on your consent pursuant to Article 6 (1) (a) GDPR for the retention of applicant data beyond the regular deletion period, or on a legal permission pursuant to Art. 6 (1) (b) GDPR for regular processing.
XI. Data Protection Authority
Germany: State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (Landesbeauftragte für Datenschutz und Informationsfreiheit NRW),https://www.ldi.nrw.de/
XII. List of Third-Party Providers and Their Use
Statistical evaluation of visits to this website (web trackers)
When this website or individual files of the website are accessed, we collect, process and store the following data: IP address, website from which the file was accessed, name of the file, date and time of access, amount of data transferred and notification of the success of the access (so-called web log). We use this access data exclusively in non-personalized form for the continuous improvement of our website and for statistical purposes. We also use the following web trackers to evaluate visits to this website:
Google
On our site, we use the Google service of the company Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland, email: support-deutschland@google.com, website: https://www.google.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision of the EU Commission on the EU-US Data Privacy Framework within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so the usual level of protection of the GDPR applies to the transfer.
The legal basis for the processing of the personal data is your consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, which you have given on our website.
We use Google in order to be able to load additional Google services on the website. The service is used to be able to provide additional Google services, such as the data processing required for the provision of streams and fonts and relevant content from Google Search. It is technically required in order to exchange the information about the site visitor already held by Google between the Google services and to provide the site visitor with individual content adapted to their Google account.
For the processing itself, the service or we collect the following data: background data stored in the Google user account or in other Google services about the site visitor, background data for the provision of Google services such as streaming data or advertising data, data on the site user's interaction with Google Search, information on the device used, the IP address and the browser of the user, and other data from Google services for the provision of the Google services in relation to our website.
If the service is activated on our website, our website establishes a connection to the servers of Google Ireland Limited and transfers the required data. As part of the commissioned processing, personal data may also be transferred to the servers of Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States. When the Google service is used on our website, Google may transmit and process information from other Google services in order to provide background services for the display and data processing of the services provided by Google. For this purpose, data may also be transferred to the Google services Google APIs, DoubleClick, Google Cloud, Google Ads and Google Fonts in accordance with the Google privacy policy. The certification under the EU-US Data Privacy Framework can be accessed at https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active.
You can withdraw your consent at any time. Further information on withdrawing your consent can be found either with the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also offers an opt-out option at https://support.google.com/My-Ad-Center-Help/answer/12155451?hl=de.
Google Maps
On our site, we use the Google Maps service of the company Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland, email: support-deutschland@google.com, website: https://www.google.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision of the EU Commission on the EU-US Data Privacy Framework within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so the usual level of protection of the GDPR applies to the transfer.
The legal basis for the processing of the personal data is your consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, which you have given on our website.
On our behalf, Google will use the information obtained via Google Maps to display the map to you. Google Maps allows you to find us more quickly and accurately than with a mere non-interactive sketch of directions. The corresponding data is also used to identify the site visitors who view our Google Maps map, where applicable with the aid of the Google advertising ID, and to link them with physical visits and views of further contact information listed on Google. In this way, Google can make an estimate of the expected visitor flows.
For the processing itself, the service or we collect the following data: data required for the visualization and display of location data in the form of a map, in particular IP address, information from Google background services such as Google APIs, search terms, IP address, coordinates, when using the route planner the starting point and destination, location data, Google advertising ID, Android advertising ID.
We have concluded a joint processing agreement with Google with regard to Google Maps. You can find its content at https://privacy.google.com/intl/de/businesses/mapscontrollerterms/. If the service is activated on our website, our website establishes a connection to the servers of Google Ireland Limited and transfers the required data. As part of the commissioned processing, personal data may also be transferred to the servers of Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States. When the Google service is used on our website, Google may transmit and process information from other Google services in order to provide background services for the display and data processing of the services provided by Google. For this purpose, data may also be processed by the Google services Google APIs, Google Cloud and Google Fonts in accordance with the Google privacy policy under Google's data protection responsibility. The certification under the EU-US Data Privacy Framework can be accessed at https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active.
You can withdraw your consent at any time. Further information on withdrawing your consent can be found either with the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also offers an opt-out option at https://support.google.com/My-Ad-Center-Help/answer/12155451?hl=de.
Gstatic
On our site, we use the Gstatic service of the company Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland, email: support-deutschland@google.com, website: https://www.google.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision of the EU Commission on the EU-US Data Privacy Framework within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so the usual level of protection of the GDPR applies to the transfer.
The legal basis for the processing of the personal data is your consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, which you have given on our website.
Gstatic is a background service used by Google to retrieve static content in order to reduce bandwidth usage and to preload required catalog files. In particular, the service loads background data for Google Fonts and Google Maps.
As part of the commissioned processing, personal data may also be transferred to the servers of Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States. The certification under the EU-US Data Privacy Framework can be accessed at https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active.
You can withdraw your consent at any time. Further information on withdrawing your consent can be found either with the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also offers an opt-out option at https://support.google.com/My-Ad-Center-Help/answer/12155451?hl=de.
Integration of external web services and processing of data outside the EU
On our website, we use active content from external providers, so-called web services. When you access our website, these external providers may receive personal information about your visit to our website. Data may be processed outside the EU in this context. You can prevent this by installing an appropriate browser plugin or deactivating the execution of scripts in your browser. This may result in functional restrictions on websites that you visit.
We use the following external web services:
CookieBot
On our site, we use the Cookiebot service of the company Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark, email: privacy@cookiebot.com, website: https://www.cookiebot.com/de/. Personal data is transferred exclusively to servers within the European Union.
The legal basis for the processing is Art. 6 (1) (c) GDPR. The use of the service helps us to comply with our legal obligations.
By integrating Cookiebot, we fulfill our legal obligation with regard to the consent management required for cookies.
You can find out which rights you have with regard to the processing at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://www.cookiebot.com/de/privacy-policy/.
Google Cloud APIs
On our site, we use the Google Cloud APIs service of the company Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland, email: support-deutschland@google.com, website: https://www.google.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision of the EU Commission on the EU-US Data Privacy Framework within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so the usual level of protection of the GDPR applies to the transfer.
The legal basis for the processing of the personal data is your consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, which you have given on our website.
We use Google APIs in order to be able to load additional Google services on the website. Google APIs is a collection of interfaces for communication between the various Google services used on our website. The service is used in particular to display the Google Fonts fonts and to provide the Google Maps map.
For the processing itself, the service or we collect the following data: IP address
If the service is activated on our website, our website establishes a connection to the servers of Google Ireland Limited and transfers the required data. As part of the commissioned processing, personal data may also be transferred to the servers of Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States. When the Google service is used on our website, Google may transmit and process information from other Google services in order to provide background services for the display and data processing of the services provided by Google. For this purpose, data may also be transferred to the Google services Google Cloud, Google Maps, Google Ads and Google Fonts in accordance with the Google privacy policy under Google's data protection responsibility. The certification under the EU-US Data Privacy Framework can be accessed at https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active.
You can withdraw your consent at any time. Further information on withdrawing your consent can be found either with the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also offers an opt-out option at https://support.google.com/My-Ad-Center-Help/answer/12155451?hl=de.
Google Fonts
On our site, we use the Google Fonts service of the company Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland, email: support-deutschland@google.com, website: https://www.google.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision of the EU Commission on the EU-US Data Privacy Framework within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so the usual level of protection of the GDPR applies to the transfer.
The legal basis for the processing of the personal data is your consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, which you have given on our website.
We use the Google Fonts service in order to be able to integrate attractive fonts on our site, so that we can display our website to you in a visually improved version. The service may also be used on our website when other Google services that require Google Fonts fonts to run are loaded on our website. This is the case, for example, if our website uses Google services that absolutely require Google Fonts to run.
For the processing itself, the service or we collect the following data: data on fonts, the IP address of the site visitor, statistics on the use of fonts and other data from Google services in relation to our website.
If the service is activated on our website, our website establishes a connection to the servers of Google Ireland Limited and transfers the required data. As part of the commissioned processing, personal data may also be transferred to the servers of Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States. When the Google service is used on our website, Google may transmit and process information from other Google services in order to provide background services for the display and data processing of the services provided by Google. For this purpose, data may also be transferred to the Google services Google APIs, Google Cloud and Google Ads in accordance with the Google privacy policy. The certification under the EU-US Data Privacy Framework can be accessed at https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active.
You can withdraw your consent at any time. Further information on withdrawing your consent can be found either with the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://policies.google.com/privacy.
The provider also offers an opt-out option at https://support.google.com/My-Ad-Center-Help/answer/12155451?hl=de.
Gravatar
On our site, we use the Gravatar service of the company Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, D02 AY86 Dublin, Ireland, email: privacypolicyupdates@automattic.com, website: https://de.gravatar.com/. Personal data is also transferred to the USA. With regard to the transfer of personal data to the USA, there is an adequacy decision of the EU Commission on the EU-US Data Privacy Framework within the meaning of Art. 45 GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so the usual level of protection of the GDPR applies to the transfer.
The legal basis for the processing of the personal data is your consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, which you have given on our website.
Gravatar is a service for providing avatars across websites.
The certification of the parent company Automattic Inc. under the EU-US Data Privacy Framework can be accessed at https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000CbqcAAC.
You can withdraw your consent at any time. Further information on withdrawing your consent can be found either with the consent itself or at the end of this privacy policy.
Further information on the handling of the transferred data can be found in the provider's privacy policy at https://automattic.com/privacy/.
The provider also offers an opt-out option at https://automattic.com/privacy/.
XIII. Last Updated
Last updated: February 10, 2026