Data Protection Declaration


1) Purpose

Vaupel Group attaches great value to the safeguarding of your private sphere and undertakes to observe the statutory data protection regulations.
The Data Protection Declaration applies to all the websites of Vaupel Group and its affiliated company (“Horst Kind GmbH”). We subsequently inform you about the data that we may collect under certain circumstances and how this is handled.
The aim is to protect your personal data during processing in our affiliated companies. 
We retain the right to alter this Data Protection Declaration at any time. 

2) Scope

This Privacy Notice explains how we collect and use personal information. Personal Information means any information relating to an identified or identifiable natural person; one who can be identified, directly or indirectly, by reference to an identifier such as name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 
We collect personal information in a variety of ways through our normal business activities, both online and offline. This includes, for example, when you place orders or purchase products or services, enter into agreements or communicate with us, or visit and use our websites. We also receive personal information from our customers in order to perform services on their behalf.

3) Identity of Data Controller

To identify the Vaupel Group entity responsible for the processing of your personal information, you can ask your Vaupel Group business contact, consult the contact page on the Vaupel Group public website:
https://www.vaupel-group.com

or contact our Privacy Office:
privacy@vaupel-group.com .


4) Categories of Personal Information

Personal information that we may collect and process includes:

  • Contact Information that allows us to communicate with you, such as your name, job title, age and prefix, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages, company information and registration information you provide on our website.
  • Relationship Information that helps us do business with you, such as the types of products and services that may interest you, contact and product preferences, languages, creditworthiness, marketing preferences and demographic data.
  • Transactional information about how you interact with us, including purchases, inquiries, customer account information, order and contract information, delivery details, billing and financial data, details for taxes, transaction and correspondence history, and information about how you use and interact with our websites.
  • Security and Compliance Information that helps us to secure our interests, including information for conflict checks, fraud prevention and internal verification, as well as information necessary for the security of our premises, such as visual recordings.
  • Our products may collect system and event information relating to their setup, configuration and operation, as well as information collected by our products in their ordinary course of operation. This information may include sensor data, equipment data, data regarding building spaces, energy usage data, fault data, event data, environmental data, and other internal or external data as well as product usage information and product performance data. In some circumstances, this information may be Personal Data. In the case of video or security products, the information may also include video and audio signals and data. The nature and extent of the information collected by our products will vary based on the type and function of the product and the type of services for which they are used, subject to applicable laws.

5) Purposes of Processing

  • Fulfilling your orders for products or services and related activities, such as product and service delivery, customer service, account and billing management, support and training, product update and safety related notices, and to provide other services related to your purchase.
  • Managing our contractual obligations and your ongoing relationship with us, including interacting with you, analyzing and improving the products and services we offer, informing you about our products or services, as well as special offers and promotions.
  • Ensuring the security of our websites, networks and systems, and premises, as well as protecting us against fraud.
  • Managing our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, fulfillment, corporate governance, audit, reporting and legal compliance.

6) Recipients of Personal Information

  • We may use third parties to provide or perform services and functions on our behalf. We may make personal information available to these third parties, to perform these services and functions. Any processing of that personal information will be on our instructions and compatible with the original purposes.
  • We may also make personal information concerning individuals available to public or judicial authorities, law enforcement personnel and agencies as required by law, including to meet national security or law enforcement requirements, and including to agencies and courts in the countries where we operate. Where permitted by law, we may also disclose such information to third parties (including legal counsel) when necessary for the establishment, exercise or defense of legal claims or to otherwise enforce our rights, protect our property or the rights, property or safety of others, or as needed to support external audit, compliance and corporate governance functions.
  • Personal information may be transferred to a party acquiring all or part of the equity or assets of Vaupel Group or its business operations in the event of a sale, merger, liquidation, dissolution, or other.
  • We may also transfer and share such information to Vaupel Group affiliates in compliance with applicable law.

7) International Transfers

The third parties, subsidiaries and affiliates to which your personal information can be disclosed may be located throughout the world; therefore information may be sent to countries having different privacy protection standards than your country of residence. In such cases, we take measures to ensure that your personal information receives an adequate level of protection, which include our Binding Corporate Rules, which set forth our high standards for processing personal information collected and processed by us globally, and Standard Contractual Terms to protect your personal information.
Vaupel Group complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.


8) Retention

We will retain your personal information as long as necessary to achieve the purpose for which it was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law.


9) Protection of Personal Information

We apply appropriate technical, physical and organizational measures that are reasonably designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and against other unlawful forms of processing. Access to personal information is restricted to authorized recipients on a need-to-know basis. We maintain a comprehensive information security program that is proportionate to the risks associated with the processing. The program is continuously adapted to mitigate operational risks and to protect personal information, taking into account industry-accepted practices. We will also use enhanced security measures when processing any sensitive personal information. 
In some instances, we process personal information on behalf of our customers as a service (in a data processor capacity). We collect and process this personal information only as instructed by our customer and will not use or disclose it for our own purposes. We maintain information security controls to protect your information and will only disclose or transfer the personal information as instructed by the customer or to provide the requested service. Unless otherwise instructed by the customer, we treat the personal information we process on behalf of our customers in line with our commitments on disclosure and transfer as set forth in this notice.


10) Our websites

Cookies, usage data and similar tools

When you visit our websites, we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. In many cases, the information we collect using cookies and other tools is used in a non-identifiable way, without any reference to personal information. Cookies are small text files that a website transfers to your computer or other device’s hard drive through your web browser when you visit a website. We may use cookies to make website sign-in and usage more efficient, and to tailor your browsing preferences and improve the functionality of our websites. Cookies can be used for performance management, and for collecting information on how our website is being used for analytics purposes. They can also be used for functionality management, enabling us to make the user’s visit more efficient by, for example, remembering language preferences, passwords and log-in details. There are two types of cookies: session cookies, which are deleted from your device after you leave the website; and persistent cookies, which remain on your device for longer or until you delete it manually. We may use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience.

Our server logs may also collect information about how users utilize the websites (usage data). This data may include a user's domain name, language, type of browser and operating system, Internet service provider, Internet protocol (IP) address, the site or reference directing the user to the website, the website you were visiting before you came to our website and the website you visit after you leave our site, and the amount of time spent on the website. We may monitor and utilize usage data to measure the website's performance and activity, improve the website's design and functionality or for security purposes. 
We may also use pixel tags and web beacons on our website. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions. 
You can change your browser settings to block or notify you when you receive a cookie, delete cookies or browse our website using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our websites may not function properly if you do not accept cookies or these technologies 
Where required by applicable law, you will be asked to consent to certain cookies and similar technologies before we use or install them on your computer or other device. 
 

Data Sharing and Browser Do Not Track Requests

Because we do not (and do not permit others) to track our website visitors, we do not process web browser Do Not Track signals. To learn more about browser tracking signals and Do Not Track please visit:
http://www.allaboutdnt.org/.
 

Linked sites

We may provide links to third parties' websites (“linked sites”) from our websites. Linked sites are not necessarily reviewed, controlled or examined by us. Each linked site may have its own terms of use and privacy notice, and users must be familiar and comply with all such terms when using linked sites. We are not responsible for the policies and practices of any linked site, or any additional links contained in them. These links do not imply our endorsement of the linked sites or any company or service and we encourage users to read these linked sites’ terms and notices prior to using them. 
 

Children

Our websites are not directed at children and we do not use our websites to knowingly solicit personal information from or market to children. If we learn that a child has provided personal information through one of our websites, we will remove that information from our systems.
 

Web Analyze and User-Tracking

Our intention in employing the analysis and tracking measures that are used is to ensure that the design of our website is tailored to the users’ needs and that it is continually optimized. Another reason we employ the tracking measures is to record the statistics concerning the use of our website and to evaluate this for the purpose of optimizing our offer for you. These interests are to be regarded as legitimate within the meaning of the regulation specified above. The relevant data processing purposes and data categories can be found in the description of the corresponding analysis and tracking tools.
The analysis and tracking measures specified below and used by us are conducted on the basis of Article 6 (1) point f GDPR.
We may also use Google Analytics on our website to collect information about your online activity on our websites, such as the web pages you visit, the links you click, and the searches you conduct on our websites. We may use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the site from and the pages they visited. The information generated by those cookies and your current IP-address will be transmitted by your browser to and will be stored by Google on servers in the United States and other countries. Google will use this information on our behalf for the purpose of evaluating your use of our website as described above. The IP address collected through Google Analytics will not be associated with any other data held by Google. For more information about the information gathered using Google Analytics please visit: http://www.google.com/intl/de/analytics/privacyoverview.html .

You can prevent these cookies by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of our websites. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout .
 

Google Remarketing Technology

Our websites may use Google’s remarketing technology. This technology enables users who have already visited our online services and shown interest in our services to see targeted advertising on the websites of the Google partner network. Likewise users that are similar to the visitors of our website can be addressed. The information generated by the cookie about the website use will be transmitted to and stored on servers in the United States by Google. In the event that the IP address is transferred, it will be reduced by the last 3 digits. Using cookies, the user behavior on a website can be analyzed and subsequently utilized to provide targeted product recommendations and advertising based on the user’s interests. If you would prefer to not receive any targeted advertising, you can deactivate the use of cookies for these purposes through Google by visiting the website:  www.google.com/settings/ads/.

Alternatively, users can deactivate the use of cookies by third party providers by visiting the Network Advertising Initiative’s deactivation website : www.networkadvertising.org/choices/ . Please note that Google has its own data protection policy which is independent of our own. We assume no responsibility or liability for their policies and procedures. Please read Google’s privacy policy before using our websites: www.google.com/intl/de/policies/privacy/.
 


11) Your Rights

You may request to access, rectify, or update your inaccurate or out-of-date personal information by contacting our Privacy Office through the following link:  privacy@vaupel-group.com .

To the extent of applicable law, you may have the right to request erasure of your personal information, restriction of processing as it applies to you, object to processing and the right to data portability. You may also have the right to lodge a complaint with a supervisory authority.


12) Consent and Withdrawal of Consent:

By providing personal information to us, you understand and agree to the collection, processing, international transfer and use of such information as set forth in this Privacy Notice. Where required by applicable law we will ask your explicit consent. 
You may always object to the use of your personal information for direct marketing purposes or withdraw any consent previously granted for a specific purpose, free of charge by clicking on relevant links on our websites, following the directions contained in an email or by contacting our Privacy Office through the following link:  privacy@vaupel-group.com .


13) Automated Decision-Making

Vaupel Group respects your rights under law regarding automated decision-making.


14) How to contact us

If you would like to communicate with us regarding privacy issues or have questions, comments or complaints, please contact our Privacy Office, by clicking on the following link:  privacy@vaupel-group.com .

In compliance with the Privacy Principles, Vaupel Group commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy policy should first contact our Privacy Office at the above link.


15) Modifications to our Privacy Notice

We reserve the right to change, modify, and update this Privacy Notice at any time. Please check periodically to ensure that you have reviewed the most current notice.


16) Local addenda for certain countries

We have extended the Privacy Notice with specific information for certain countries where required by applicable local law.


17) Legal basis of data processing

Article 6 (1) a of the GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary to fulfil a contract of which the person concerned is a party, the processing is based on Article 6 (1) b of the GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.

If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Article 6 (1) c of the GDPR. In rare cases, the processing of personal data may be required to protect vital interests of the data subject or another natural person, such as would be the case in accidents on the business premises.
In addition, processing operations could be based on Article 6 (1) f of the GDPR if the processing is necessary to safeguard the legitimate interests of our company or a third party, insofar as the interests, fundamental rights and fundamental freedoms of the data subject do not prevail. The legitimate interest in particular includes efficient, customer friendly and high quality provision of service.


18) Rights of the data subject

Data subjects according to the GDPR are entitled to the following rights. If the data subject wishes to exercise the right to information, he/she may at any time contact our data protection team or another employee of the controller.
 

Right to withdraw consent under data protection law

As a data subject in the processing of personal data, you have the right to withdraw your consent to the processing of your personal data at any time with future effect. To do so, an email or other declaration in text form shall be sufficient. You can direct your withdrawal in writing to: 
 

Right to information

As a data subject of the processing of personal data, you have the right at any time to obtain free information from the party responsible for processing about your personal data which is stored and to receive a copy of your personal data. The right to information concerns the following information:

  • the purposes of processing
  • the categories of personal data processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • if possible, the planned duration for which the personal data shall be stored or, if this is not possible, the criteria for determining such duration
  • the right to correct or delete personal data concerning the data subject or to restrict the processing by the controller or a right of withdrawal to such processing
  • the right of appeal to a supervisory authority
  • if the personal data is not collected from the data subject: All available information on the origin of the data
  • the existence of automated decision making including profiling according to Article 22 (1) and 4 of the GDPR and, at least in these cases, meaningful information regarding the logic involved and the scope and intended effect of such processing with respect to the data subject
  • Furthermore, the data subject also has the right to know whether personal data has been transferred to a third country or to an international organization. In such a case, you are also entitled to obtain information on the relevant guarantees in connection with the transmission.
     

Right to rectification

As a data subject of the processing of personal data, you have the right to demand the immediate correction of incorrect personal data concerning you. You also have the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the purposes of processing.
 

Right to erasure ("Right to be forgotten")

As the data subject of the processing of personal data, you have the right to request that the personal data concerning you be deleted without delay, provided that one of the following reasons is satisfied and the processing is not required

  • The personal data was collected for such purposes or otherwise processed for which they are no longer necessary (the data is no longer needed).
  • The data subject withdraws his or her consent to the processing of personal data in accordance with Article 6 (1) a of the GDPR or Article 9 (2) a of the GDPR and there is no other legal basis for processing.
  • The data subject lodges an objection against the processing of data pursuant to Article 2 (1) 1 of the GDPR and there are no overriding legitimate reasons for processing, or the data subject lodges an objection against the processing of data pursuant to Article 2 (1) 2 of the GDPR.
  • The personal data was processed illegally.
  • Erasure of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States, to which the controller is subject.
  • The personal data were collected in relation to information society services offered pursuant to Article 8 (1) of the GDPR.

If the personal data of Vaupel Group were made public and our company as the controller is obligated in accordance with Article 17 (1) of the GDPR to the erasure of personal data, we shall take appropriate measures taking into account the available technology and implementation costs, we shall take reasonable steps to notify other data controllers who process the published personal data, in particular to delete all links to such personal data or copies or replications of such personal data, insofar as the processing is not required.
 

Right to restriction of processing

As a data subject of the processing of personal data, you have the right to request the restriction of processing if one of the following conditions is met:

  • The correctness of the personal data is contested by you for a period of time that enables the controller to verify the correctness of the personal data.
  • The processing is unlawful, you object to the erasure of personal data and instead demand that the use of personal data be restricted.
  • The controller no longer needs the personal data for the purposes of processing, you however need them to assert, exercise or defend legal claims.
  • You have objected to the processing pursuant to Article 2 (1) 1 of the GDPR and it is not yet clear whether the legitimate grounds of the controller outweigh yours.
     

Right to data portability

As a data subject of the processing of personal data, you have the right to receive the personal data relating to you which you provided to us in a structured, common and machine readable format. In addition, you have the right to transmit this data to another controller without hindrance from the current controller, insofar as the processing does not conflict with the consent pursuant to Article 6 (1) a of the GDPR or Article 9 (2) a of the GDPR, that it also does not conflict with a contract pursuant to Article 6 (1) b of the GDPR and the processing is performed with the aid of automated procedures, insofar as the processing is not necessary for the performance of a task in the public interest or in the exercise of official authority which was delegated to the party responsible for data processing.
Furthermore, in exercising your right to data portability pursuant to Article 22 (1) of the GDPR, you have the right to demand that the personal data be transmitted directly by us to a controller, insofar as this is technically feasible and insofar as this does not affect the rights and freedoms of other persons.
 

Right to object

As a data subject of the processing of personal data, you have the right, at any time for reasons arising from your particular situation, to object to the processing of personal data concerning you which takes place in order to safeguard a legitimate interest of the controller. This also applies to profiling based on these provisions, whereby Vaupel Group points out that no profiling is carried out. Vaupel Group shall no longer process personal data in the case of an objection unless we can prove compelling security reasons for such processing which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

Vaupel Group processes personal data to carry out direct advertising, therefore the data subject has the right at any time to object to the processing of personal data for the purpose of such direct advertising. This also applies to profiling insofar as it is associated with such direct advertising. If you object to Vaupel Group about the processing for direct marketing purposes, we shall no longer process your personal data for such purposes.
 

Automated individual decision making including profiling

As a data subject of the processing of personal data, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, insofar as the decision

  • is not necessary for the conclusion or performance of a contract between you and the controller or
  • is permitted by Union or Member State legislation to which the controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
  • is performed with your express consent.

With regard to the processing of personal data, Vaupel Group does not use purely automated decision making systems which have a legal effect on you or significantly affect you in a similar manner.
 

Right to lodge a complaint with a supervisory authority

As the data subject of the processing of personal data you have the right to complain to a supervisory authority, in particular, in the Member State of your place of residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you is contrary to data protection laws.