Privacy policy

1. data protection at a glance

General notes

The following notices provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data collection on this website

Who is responsible for the data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the responsible office” in this data protection declaration.

How do we collect your data?

On the one hand, your data is collected by you providing it to us. This may be, for example, data that you enter in a contact form.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. Internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time with regard to this and other questions on the subject of data protection.

Third-party analytics and tools

When visiting this website, your surfing behavior can be statistically analyzed. This is done mainly with so-called analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. hosting

We host the content of our website with the following provider:

Mittwald

The Provider is Mittwald CM Service GmbH & Co KG, Königsberger Straße 4-6, 32339 Espelkamp (hereinafter referred to as Mittwald).

For details, please refer to Mittwald’s privacy policy: https://www.mittwald.de/datenschutz.

The use of Mittwald is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in ensuring that our website is presented as reliably as possible. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Job processing

We have concluded a contract on order processing (AVV) for the use of the above service. This is a contract required by data protection law, which ensures that this processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. general notes and mandatory information

Privacy

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data are collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how this is done and for what purpose.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of the data against access by third parties is not possible.

Note on the responsible entity

The responsible party for data processing on this website is:

KIROTEC Ltd.
Margarete von Wrangell Street 23
63457 Hanau

Phone: +49 6181 3640-112
E-mail: info@kirotec.de

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage duration

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

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO, insofar as special categories of data pursuant to Art. 9 para. 1 DSGVO are processed. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of § 25 para. 1 TTDSG. The consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data insofar as this is necessary for the fulfillment of a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. The data processing may further be based on our legitimate interest according to Art. 6 para. 1 lit. f DSGVO shall take place. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Note on data transfer to third countries that are not secure under data protection law and transfer to US companies that are not DPF-certified

Among other things, we use tools from companies based in third countries that are not secure under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to and processed in these countries. We would like to point out that in third countries with insecure data protection laws, no level of data protection comparable to that in the EU can be guaranteed.

We would like to point out that the USA, as a safe third country, generally has a level of data protection comparable to that of the EU. Accordingly, a data transfer to the USA is permitted if the recipient has a certification under the “EU-US Data Privacy Framework” (DPF) or has suitable additional guarantees. Information on transfers to third countries, including data recipients, can be found in this Privacy Policy.

Recipients of personal data

As part of our business activities, we cooperate with various external entities. In some cases, this also requires the transfer of personal data to these external bodies. We only pass on personal data to external bodies if this is necessary in the context of fulfilling a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest according to Art. 6 Para. 1 lit. f DSGVO have in the transfer or if another legal basis allows the data transfer. When using processors, we disclose personal data of our customers only on the basis of a valid contract on commissioned processing. In case of joint processing, a contract on joint processing shall be concluded.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct marketing (Art. 21 DSGVO)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 ABS. 1 LIT. E OR F DSGVO, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS DATA PROTECTION DECLARATION. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS FOR THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION UNDER ARTICLE 21(1) DSGVO).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 DSGVO).

Right of complaint to the competent supervisory authority

In the event of breaches of the GDPR, data subjects shall have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. The right of appeal is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, correction and deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time with regard to this and other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restrict processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data happened/is happening unlawfully, you may request the restriction of data processing instead of erasure.
If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.
If you file an objection pursuant to Art. 21 para. 1 DSGVO, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to demand the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the browser address bar changes from “http://” to “https://” and by the lock symbol in your browser bar.

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

4. data collection on this website

Cookies

Our Internet pages use so-called “cookies”. Cookies are small data packets and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your terminal device. Session cookies are automatically deleted after the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or until they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies may be used to evaluate user behavior or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. When cookies are disabled, the functionality of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

Consent with Borlabs Cookie

Our website uses Borlabs Cookie Consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in accordance with data protection law. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg (hereinafter Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, which stores the consents you have given or revoked. This data is not shared with the provider of Borlabs Cookie.

The collected data will be stored until you request us to delete it or delete the Borlabs cookie yourself, or until the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

The use of Borlabs cookie consent technology is done in order to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.

Contact form

If you send us inquiries via the contact form, the information you provide in the inquiry form, including the contact data you enter there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not share this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b DSGVO, provided that your request is related to the performance of a contract or is necessary for the performance of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the requests addressed to us (Art. 6 (1) f DSGVO) or on your consent (Art. 6 (1) a DSGVO) if this has been requested; the consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions – in particular retention periods – remain unaffected.

Request by e-mail, phone or fax

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

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. analysis tools and advertising

Matomo

This website uses the open source web analytics service Matomo.

With the help of Matomo, we are able to collect and analyze data about the use of our website by website visitors. This allows us to find out, among other things, when which page views were made and from which region they come. We also collect various log files (e.g., IP address, referrer, browsers used, and operating systems) and can measure whether our website visitors perform certain actions (e.g., clicks, purchases, and the like).

The use of this analysis tool is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its web offering and its advertising. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

IP anonymization

We use IP anonymization for the analysis with Matomo. Your IP address is shortened before analysis so that it can no longer be clearly assigned to you.

Hosting

We host Matomo with the following third-party provider:

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

6. plugins and tools

iThemes Security

We have included iThemes Security on this website. The provider is iThemes Media LLC, 1720 South Kelly Avenue Edmond, OK 73013, USA (hereinafter “iThemes Security”).

iThemes Security is designed to protect our website from unwanted access or malicious cyberattacks. For this purpose, iThemes Security collects, among other things, your IP address, time and source of login attempts, and log data (e.g., the browser used). iThemes Security is installed locally on our servers.

iThemes Security transmits IP addresses of recurring attackers to a central database of iThemes in the USA (Network Brute Force Protection) to prevent such attacks in the future.

The use of iThemes Security is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its website against cyberattacks as effectively as possible. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

PRIVACY POLICY WHISTLEBLOWING SYSTEM (SUPPLEMENT)

Purpose

We provide an internal whistleblowing system to receive, process and manage information about potential misconduct, violations of the law and other misconduct within the company in a secure and confidential manner.

Whistleblower

Our internal whistleblowing system is available to employees and former employees of our company and third parties (e.g. customers, business partners, suppliers, employees of affiliated companies).

Type of Reports

In the case of an anonymous report, our whistleblowing system does not collect and process any personal data of the whistleblower.
In the case of a confidential report, only the external operator of our whistleblowing system Compliance.One has the contact details of the whistleblower, but these are not disclosed to us. In the case of a confidential report, we have the option of communicating directly with the whistleblower, e.g., to confirm receipt of the report, to ask questions about the facts, and to inform the whistleblower about the measures taken. However, we do not receive any information about the identity of the whistleblower. The external operator of our whistleblowing system Compliance.One acts as an “anonymization layer” between us and the whistleblowers.
In the case of a transparent report, the contact person responsible for handling reports in our company is given access to the data on the identity of the whistleblower and can communicate directly with the whistleblower. In accordance with the EU Whistleblower Directive, we are obliged to maintain the confidentiality of the identity of the whistleblower, i.e. only the employee(s) who handle the respective report know the identity of the whistleblower, no one else in the company.

Personal Data Processed

When a report is provided via the whistleblowing system, the following personal data is processed by us:

Name and contact details of the whistleblower, if provided in the case of a transparent report; in the case of a confidential report, the external operator of our whistleblowing system Compliance.One will not disclose the whistleblower’s personal data to us; in the case of an anonymous report, no personal data of the whistleblower will be processed at all
The IP address of the whistleblower is not stored for processing a message within the application. To ensure the availability, confidentiality and integrity of the server and the applications and interfaces connected to the server, accesses to the server are logged in order to be able to detect and deal with potential security breaches. Accesses that cannot be associated with any security breach are deleted after one calendar month at the latest due to maintenance intervals.
Company affiliation or function are processed if provided in a report
Personal data of persons named in a report are processed for the investigation or treatment of a report

Communication between the computer of the whistleblower and the whistleblowing system takes place via an encrypted connection (SSL). To maintain the connection between the computer and the whistleblowing system, a cookie is stored on the computer that only contains the session ID (so-called zero cookie). The cookie is only valid until the end of the respective session and is deleted when the browser is closed.

Confidential Treatment of Reports and Disclosure

Incoming reports are received and processed by a small number of authorized employees. These employees are expressly obliged to treat all reports confidentially at all times. These responsible employees examine the report and, if necessary, carry out further case-related investigations of the facts.
As part of the investigations of the facts and, if necessary, the subsequent initiation of measures, it may be necessary to pass on information to other employees of the company. This is done exclusively within the scope of what is necessary for the investigations or initiation of measures, and we always ensure that the relevant data protection provisions are complied with when passing on information.
In certain cases, there is an obligation under data protection law to inform the accused person of the allegations made against him or her. This is required by law if it is objectively determined that providing information to the accused person cannot (any longer) impair the specific investigation of the report. In this context, the identity of the whistleblower is not disclosed, insofar as this is legally possible, and it is ensured that no conclusions can be drawn about the identity of the whistleblower.
When knowingly providing false reports with the aim of discrediting a person (denunciation), the confidentiality of the whistleblower’s identity cannot be guaranteed.
In the event of a legal obligation or data protection law requirement for the investigation of reports, further categories of possible recipients are law enforcement authorities, antitrust authorities, other administrative authorities, courts, and law firms and auditing firms commissioned by us.

Setting Up an Account

Whistleblowers set up an account for their report. The account can be accessed via a QR code and/or an individual link. The account can be used for communication between the employees entrusted with handling the report and the whistleblower. No additional personal data is collected when creating and using the account. The use of the whistleblowing system can be tracked anonymously, but no conclusions can be drawn about individual users.
Individual reports are uniquely identified by an identification number. The identification number is in no way used to identify the whistleblower, but merely to logically separate different reports and whistleblowers from one another.
The personal data entered in the whistleblowing system can be viewed by the whistleblower in the account at any time. The whistleblowing system does not store any personal data other than the personal data specified in the account.
All data entered by the whistleblower is stored individually encrypted in a database.

Legal Basis

The processing of personal data within the whistleblowing system is based on the fulfillment of legal obligations and our overriding legitimate interest in the detection and prevention of wrongdoing and the associated prevention of damage and liability risks for the company. Accordingly, the legal basis is Art. 6 Para. 1 lit. c) and lit. f) GDPR in conjunction with Sections 30, 130 OWiG.
If a report relates to one of our employees, the processing also serves to prevent and detect criminal offenses or other legal violations that are related to the employment relationship. The legal basis in this case is § 26 (1) BDSG.

Retention and Deletion

Personal data will be retained for as long as is necessary for the internal investigations and the final assessment of a report, or if there is a legitimate interest on the part of the company, or if this is required by law.
Afterwards, the data is deleted in accordance with the legal requirements. The duration of storage depends in particular on the severity of the suspicion and the reported possible breach of duty.
The data collected is generally deleted within two months of the conclusion of the internal investigation.
If criminal, disciplinary or civil court proceedings are initiated as a result of misconduct within the meaning of this Policy or misuse of the whistleblowing system, the storage period may be extended until the respective proceedings have been finally concluded.
Personal data that is obviously not relevant for the processing of a specific report will not be collected or will be deleted immediately if it was collected unintentionally.

Service Provider

Our whistleblowing system is provided by the service provider Compliance.OneF GmbH in Germany on the basis of a data processing agreement pursuant to Art. 28 GDPR.