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Handling of Customers' Personal Information

Privacy policy (information on data protection regarding our data processing in accordance with Articles 13, 14 and 21 of the General Data Protection Regulation) for our website

Thank you for visiting our website and for your interest in our company. The protection of your personal data is important to us. Below we inform you in accordance with Art. 13, 14 and 21 of the General Data Protection Regulation (GDPR) about the handling of your personal data when using our website https://www.thk.com/eu/en/ .

1.Controller

THK CO., LTD
2-12-10 Shibaura, Minato-ku, Tokyo 108-8506, Japan
E-mail: privacy-info@thk.co.jp

2.Data Protection Officer

Mr. Miyoshi Koichi
E-mail: dpo@thk.co.jp

3.Purposes and legal bases of data processing when using the website

3.1 Informational use of the website

You can visit our website without providing any personal data. If you only use our website for information purposes, i.e. if you do not register, place an order or otherwise provide us with information about yourself, we do not process any personal data, with the exception of the data that your browser transmits to enable you to visit the website and information that is transmitted to us as part of the technical cookies used.

3.1.1 Technical provision of the website

For the purpose of the technical provision of the websites, our system (i.e. the web server) automatically collects information from your browser each time you access the websites. The temporary storage of your IP address by our system is necessary to enable delivery of the websites to your device. It also enables us to provide you with our website. For this purpose, the user's IP address must be stored for the duration of the session.
The IP address is stored in the log files in order to ensure the functionality of our website. We also use this data to optimize the website and to ensure the security of our information technology systems (e.g. attack detection).

The following information is collected:

  • IP address;
  • Browser type/version (e.g. Firefox 59.0.2 (64 bit));
  • Browser language (e.g. German);
  • Operating system used (e.g. Windows 10);
  • Inner resolution of the browser window;
  • Screen resolution;
  • Javascript activation;
  • Java On / Off;
  • Cookies On / Off;
  • Color depth;
  • Time of access
  • The previous website from which you reached us.

We also use cookies to make our websites available for you to use. Cookies are text files that are stored in the Internet browser or by the Internet browser on your computer system when you access a website. A cookie contains a characteristic string of characters that enables the browser to be uniquely identified when you revisit the website. We use these cookies to make our website and its technical functions available to you. Some functions of our website cannot be offered without the use of cookies.

We process your personal data for the technical provision of our website on the basis of the following legal basis:

  • for the purposes of our legitimate interests according to Article 6(1)(f) GDPR to be able to make our website technically available and safe to you. In this respect, our legitimate interest consists in being able to make an attractive, technically functional and user-friendly website available to you and in taking measures to protect our website from cyber risks and in preventing cyber risks to third parties from our website;
  • for the technical provision of website in accordance with Section 25 (2)(2) TDDDG (Telekommunikation-Digitale-Dienste-Datenschutzgesetz), as the processing of the abovementioned data is absolutely necessary so that we can enable you to use our website as expressly requested by you.

OneTrust Cookie Manager

On our website, we use a consent manager from OneTrust, LLC ("One Trust", 1200 Abernathy Rd, Suite 700 Atlanta, Georgia 30328), with which we obtain your consent to certain data processing requiring consent (e.g. analysis, tracking, etc.). By using this tool, we can inform you about the individual cookies and tools we use. You can use the Consent Manager to choose which cookies and tools you want to allow or reject individually or categorically. This enables you to make an informed decision about the transfer of your data and allows us to use cookies and tools in a transparent and documented manner that complies with data protection regulations.

The consent management provider One Trust processes your personal data in order to record your decision on the approval of cookies and tools and to save it for a return visit to our website. This includes the corresponding cookie with your consent decision as well as other usage data, such as your IP, the browser used, language and country, and the website visited.

We process your personal data for the technical provision of our website on the basis of the following legal basis:

  • for the technical provision of consent management in accordance with Section 25 (2)(2) TDDDG, as the processing of the above-mentioned data is absolutely necessary so that we can enable you to use our website (with or without cookies) as expressly requested by you;
  • to safeguard our legitimate interests in accordance with Art. 6 (1)(f) GDPR in order to make the website technically available to you,
  • to fulfill a legal obligation under the GDPR pursuant to Art. 6 (1)(c) GDPR, which lies in the provision of the consent option and the documentation of your decision.

OneTrust LLC is certified for the US-European data protection agreement "Privacy Shield", which guarantees compliance with the data protection level applicable in the EU.

Further information on data use by OneTrust can be found in OneTrust's privacy policy at https://www.cookiepro.com/privacy-notice/ .

3.1.2 Analyses and tracking and increasing reach

For the purpose of analyzing and tracking the use of our website, we or the service providers working for us use cookies that enable an evaluation of your surfing behavior. This enables us to improve the quality of our website and its content. We learn how the website is used and can thus constantly optimize our offer.

For more information about the cookies and tools we use, their purposes and functions, the data processed in each case, the data recipients, the place of processing or transfer to so-called third countries (outside the EU/EEA), as well as the storage periods, please find the information in our Consent Manager.

We process your personal and non-personal data on the basis of the following legal basis:

  • your consent in accordance with Section 25 (1) TDDDG with regard to the initial storage and reading of data and;
  • your consent in accordance with Article 6 (1)(a) GDPR.

You can withdraw or change your consent at any time by clicking on the “Manage Cookies” link in the footer of the website.

Google Analytics

On our website we use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use it. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on our website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area beforehand. Only in exceptional cases the full IP address will be transmitted to a Google server in the USA and shortened there. Google will use this information on our behalf to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can withdraw your consent once you have given it by

  • preventing the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of our website to their full extent;
  • downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de and clicking this link to prevent Google Analytics from collecting data on our website in the future. An opt-out cookie will be stored in your browser. Please note that you must activate the opt-out cookie in every browser you use on all your terminal devices and may also have to reactivate it if you delete all cookies in a browser.

You can find more information on the terms of use and data protection of Google Analytics at http://www.google.com/analytics/terms/de.html or at https://www.google.de/intl/de/policies/.

Double Click

In addition to Google Analytics, we also use a web analysis service provided by Google called “Double Click”. Double Click also uses cookies. Your data is processed in the same way as for Google Analytics.

With regard to Double Click, you can also prevent the storage of cookies by selecting the appropriate settings for this in your browser, thereby opting out of the use of cookies and tracking by our website. If you have consented to the use of cookies and tracking by our website, we use Double Click to analyze and regularly improve the use of our website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. Your personal data may also be transferred to third countries outside the EU/EEA.

Google Tag Manager

We use Google Tag Manager on our website. Google Tag Manager is a solution that allows marketers to manage website tags via an interface. The Google Tag Manager service itself (which implements the tags) is a cookie-less domain and only records your IP for the technically necessary playout of the cookies and similar tools you have selected. Otherwise, no personal data is processed via the Google Tag Manager.The Google Tag Manager service triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If deactivation has been carried out at domain or cookie level, this remains in place for all tracking tags that are implemented with Google Tag Manager.

Google Maps

We include maps from the Google Maps service provided by Google. To provide the map material, technically necessary data is processed by Google for this purpose. Google is responsible for this processing. Further information on the handling of your personal data by Google can be found at: https://policies.google.com/privacy?hl=de.
The integration of Google Maps is necessary for the user-friendly design of our website. This is also our legitimate interest in data processing in accordance with Art. 6 (1)(f) DSGVO. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG, 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 TDDDG. The consent can be revoked at any time.

Yahoo! Japan Retargeting

Yahoo! Japan Retargeting is an advertising technology that allows us to target ads to users who have already visited our website. This technology uses so-called retargeting tags that are installed on our website. These tags collect information about users' visits and allow us to show these users relevant ads when they later browse Yahoo! Japan or other partner sites. Through this method, we can make our advertising campaigns more effective by targeting our users who have already shown interest in our products or services.

Microsoft Clarity

We use Microsoft Clarity, an application of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052 USA ("Microsoft"). Microsoft Clarity collects and stores various user information for statistical analysis of your behavior and for optimization and marketing purposes. The following data is processed for this purpose:

  • visited websites;
  • Your behavior on the pages (e.g. time spent, clicks, scrolling behavior)
  • Your approximate location (country and city)
  • Your IP address (in a shortened form to prevent clear identification)
  • Technical details like internet provider, browser, end device and screen resolution
  • Source of origin of your visit (i.e. how you reached us, whether through a website or advertising medium).

The data mentioned above is provided to Microsoft and may also be transferred to and stored on servers in the EU and the US for the purpose of anonymous usage statistics. Microsoft may also use these usage statistics for its own advertising purposes and services. For the exceptional cases in which personal data is transferred to the USA, Microsoft Clarity has submitted to the EU-US Data Privacy Framework, https://www.dataprivacyframework.gov/s/.

StackAdapt

We also use the services of the provider StackAdapt Inc, 500 - 210 King St. East, Toronto, ON, Canada, M5A 1J7 ("StackAdapt") to collect and process your data for the purposes of advertising and ad enhancement, retargeting, performance evaluation, and analytics. We use StackAdapt to analyse and regularly improve the use of our website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. The subsequent data is processed for these purposes:

  • IP address;
  • Technical details like internet provider, browser;
  • cookie ID;
  • user agent URL, and referral page.

StackAdapt attempts to classify users into certain categories and thus present our users with the most relevant ads for these categories based on the individual user behavior and preference information. StackAdapt also collects third party IDs that are assigned to your browser or device and are used as part of StackAdapt´s internal processing operations and to present ads.

Microsoft Advertising

We also use the conversion tracking service of Microsoft “Microsoft Advertising”. When you visit our website, Microsoft sets a cookie on your computer, provided that you have given your consent for Microsoft cookies, which you can set in your individual browser settings. We use Microsoft Advertising to record and evaluate which advertisements brought you to our website and whether you visited a previously defined target page (conversion page). We only see the total number of users who clicked on an advertisement and were then redirected to the conversion page. No personal information about the user's identity is shared with us by Microsoft.

If you do not want information about your user behavior to be used by Microsoft as described above, you can refuse the setting of a cookie as required for this – for example, by using a browser setting that generally disables the automatic setting of cookies. You can also prevent the collection of data generated by the cookie and related to your use of the website and the processing of this data by Microsoft. To do this, you can use the following link: https://account.microsoft.com/privacy/ad-settings/signedout?ru=https%3A%2F%2Faccount.microsoft.com%2Fprivacy%2Fad-settings. Additional information on data protection and the cookies used by Microsoft Advertising can be found on the Microsoft website at https://privacy.microsoft.com/de-de/privacystatement.

YouTube

On our website you will find links to videos that we have made available on the YouTube video platform of the provider Google. If you click on our links, you will be redirected to the YouTube website. On the YouTube website, you will first be asked whether you consent to data processing by YouTube before you can play the respective video. We have no influence on YouTube's data processing.

Further information on the purpose and scope of data collection and its processing by YouTube can be found at: https://support.google.com/youtube/answer/7671399?hl=de&p=privacy_guidelines.

3.2 Active use of the website

Aside from the purely informational use of our website, you can also actively use our website to make use of our THK Online Services, download information, register for a newsletter or an event or to contact us. In addition to the above-described processing of your personal data, in the event of a purely informational use, we will then also process further personal data about you that we need to be able to handle your order or to process and answer your request.

3.2.1 User requests, etc.

In order to process and respond to your requests to us, e.g. via the contact form, via our e-mail address or via your user account, as well as your complaints, we process the personal data you provide in this context. In any case, this includes your name and your e-mail address in order to send you an answer as well as the other information that you send us as part of your message or that is stored in your member account (see section 3.2.2), via which your request is made or which we link to your request based on your details.

We process your personal data to respond to user inquiries on the basis of the following legal bases:

  • for the purposes of our legitimate interests according to Article 6 (1)(f) GDPR; our legitimate interest consists in properly answering customer requests and, if necessary, to forward your request to the responsible legal entities so that they can respond appropriately to your request;
  • if the request is aimed at the conclusion of a contract, the additional legal basis is Art. 6 (1)(b) GDPR.

3.2.2 Registration to the membership area for THK Online Services

If you would like to use THK Online Services on our website, you must register in our membership area. You can decide whether you want to register as a guest member or as a full member.

If you register as a full member, you will have access to all of the following THK Online Services:

  • Overview of your member account, creation of favorites;
  • THK Designer tool (currently still Optimal Product Selection Tool);
  • Computer-aided design (in 2D and 3D);
  • Service life calculator;
  • Product catalogs;
  • Instruction manuals;
  • FAQ and technical materials;
  • Certificates (e.g. Certificates of Non-Applicability);
  • Documents on safety data (SDS (MSDS) Safety data sheets).

If you have guest access, you can only use the following services:

  • Overview of your guest member account, creation of favorites;
  • Product catalogs;
  • Instructions manuals.

If you would like to register, please click on the mask "Registration form". A mask will open in which we will ask you for your e-mail address. Please enter an e-mail address with the domain of your organization. We will then send you a verification code to the e-mail address provided, which you must enter in the next registration step to verify your e-mail address. Your registration is only complete once you have confirmed your registration by clicking on the link contained in a confirmation e-mail sent to you for this purpose. In the next step you can set a password and fill in our registration form and send it to us.

If you want to register as a full member, we need the following contact details and information about you and your company:

  • E-mail address with the domain of your organization (company, association, etc.);
  • Name of the organization;
  • First and last name;
  • Country;
  • Department;
  • Occupation;
  • Company address;
  • Telephone number;
  • Preferred language;
  • Industry/sector;
  • Number of employees in the company.

When you register as a guest member, we request the following information from you:

  • E-mail address with the domain of your organization (company, association, etc.)
  • Name of the organization;
  • Department;
  • Phone number;
  • Preferred language;
  • Country;
  • First and last name.

As soon as you have submitted the registration form, we will check your membership request. Once we have approved it, you will receive a confirmation by e-mail. We reserve the right to reject your request (e.g. if the information provided in the registration form is incomplete; we cannot assign your request to a company/organization). Once you have successfully registered, you can log in and out of our member area at any time using your e-mail address and the password you have been given. You can change the data stored in your member account by clicking on “My page” and changing your data.

The following data is also stored at the time of login:

  • The IP address of the user;
  • Date and time of login.

We process your data for the above purposes on the basis of the following legal bases:

  • to fulfill a contract or to carry out pre-contractual measures in accordance with Art. 6 (1) (b) GDPR, since the registration and the login area are necessary for the fulfillment of the contract or the implementation of pre-contractual measures and constitute a separate user contract.

3.2.3 Data processing in the context of THK Online Services

If you use our THK Online Services, we process the personal data you provide in your member account as well as any additional data that you transmit to us when using the services. We process your data for the above purpose on the basis of the following legal basis:

  • to fulfill a contract pursuant to Art. 6 (1)(b) GDPR, if we provide you with our THK Online Services;
  • for the purposes of our legitimate interests according to Art. 6 (1)(f) GDPR; our legitimate interest lies in the proper response to and processing of customer inquiries, the provision of our THK Online Services, etc..

3.2.4 Marketing purposes, such as newsletters, downloads of documents

With your consent, we use your data for marketing purposes, such as sending you our newsletter or customer magazine, sending you information via download links or white papers, advertising surveys, sending you product information, inviting you to events of interest to you, follow-ups, status reports or we use your data for market research purposes. We collect mandatory information such as your e-mail address, but also information that you provide to us voluntarily. We use the voluntary information to continuously improve our customer relationship.
If you have provided us with your e-mail address in connection with the purchase of goods or services, we may subsequently use it to send you a newsletter. In this case, the newsletter will only be used to directly advertise our own, similar goods or services.

We process your data for the sending of newsletters, surveys, etc. and the personalization of the approach on the following legal bases:

  • if you have given us your consent, in accordance with Art. 6 (1)(a) GDPR;
  • if you have given us your email address in connection with the purchase of goods or services or we send you personalized advertising materials, for the purposes of our legitimate interests according to Article 6(1)(f) GDPR in conjunction with Section 7(3) German Act against Unfair Competition (UWG); our legitimate interest is based on our economic interest in taking promotional measures and in target group-oriented advertising.

Using data in the context of the conclusion of a contract and your right to object

If we receive your e-mail address in connection with the conclusion of the contract and the provision of our products/services and you have not objected to this, we reserve the right to regularly send you offers for similar products from our offering by e-mail. You can object to this use of your e-mail address at any time by sending a message to the contact details referred to below or via a link provided for this purpose in the marketing email without incurring any costs other than the base-rate transmission costs.

3.3 Complying with legal regulations

We will further process your personal data to comply with any other legal obligations to which we are subject in connection with the processing of your order. This particularly includes any retention periods under commercial, trade or tax law.

We process your personal data on the basis of the following legal basis:

  • for compliance with a legal obligation to which we are subject according to Article 6(1)(c) GDPR in conjunction with commercial, trade or tax law, to the extent we are obliged to gather, record and keep your data.

3.4 Enforcing rights

We will furthermore process your personal data to be able to assert our rights and enforce our legal claims. We will also process your personal data to be able to defend against legal claims. Finally, we will process your personal data to the extent necessary for the prevention or prosecution of criminal offences.

We process your personal data for this purpose on the basis of the following legal basis:

  • for the purposes of our legitimate interests according to Article 6(1)(f) GDPR, to the extent that we assert legal claims or defend ourselves in legal disputes or that we prevent or clarify criminal offences.

3.5 Company sale/merger, etc.

We may process your personal data in order to complete a (partial) sale of the company or a merger (or similar transactions such as a takeover in the context of liquidation, insolvency, dissolution, etc.) with another company. In the event that another company acquires or intends to acquire the assets/capital, which may include your personal data, from THK or THK carries out or seeks to carry out a merger with another company, we may have to grant this company access to your personal data stored with us or transfer it for the purpose of examining and carrying out the company sale/merger (e.g. to determine the company value, business risks, etc.).

We process your personal data on the basis of the following legal basis:

  • for the purposes of our legitimate interests according to Article 6(1)(f) GDPR in order to plan and implement a planned sale of the company or a planned merger.

4. Links

Some sections of our website contain links to third-party websites. Those websites are subject to their own privacy rules. We are not responsible for their operation, including how they handle data. If you send information to or via such third-party sites, you should check the data protection declarations of these sites before you send them information that can be assigned to you personally.

5. Categories of recipients

Initially, only our employees receive knowledge of your personal data.

Your data will only be passed on to third parties if this is permitted or required by law or if you have given your consent. We also share your data to the extent necessary with the service providers we use in order to provide our services. We limit the transfer of data to what is necessary to provide our services to you. In some cases, our service providers receive your data as processors and are then strictly bound by our instructions when handling your data. In some cases, the recipients act independently with your data that we transmit to them.
The categories of recipients of your data are listed below:

  • Affiliated companies within the THK Group, insofar as they work for us as processors or independently and provide IT services, for example, or insofar as this is necessary for the provision of our services,
  • Payment service providers and banks to collect outstanding payments from accounts or pay out refunds,
  • Call center and complaint processor to receive and process your inquiries and complaints,
  • Agencies, printers and lettershops that support us in the implementation of advertising measures, competitions, promotions, etc,
  • IT service providers who store data, support the administration and maintenance of systems, as well as file archivists and shredders;
  • Logistics service providers to deliver goods etc.,
  • Credit agencies when calling up a credit report,
  • Companies that acquire assets/capital from THK (e.g. in the event of a company acquisition, merger, liquidation/insolvency/dissolution, etc.),
  • Collection agencies and legal advisors in the assertion of our claims,
  • public bodies and institutions insofar as we are legally obliged to do so.

In addition, we may share your personal data within our global group of companies, e.g. with subsidiaries that require this data to fulfill our and/or their own contractual and legal obligations or on the basis of legitimate interests. This may be for economic, administrative or other internal business purposes; this only applies if your interests or fundamental rights and freedoms, which require the protection of personal data, do not outweigh these. Beyond this, we do not pass on your data to third parties.

6. Third country transfer

We are headquartered in Japan. The European Commission has issued an adequacy decision confirming that Japan implements an adequate level of data protection according to European data protection law, so that this third-country transfer is secured by sufficient guarantees in accordance with Art. 44 ff GDPR. We also do business worldwide. Therefore, your personal data may also be transferred to countries outside the European Union to other companies in the THK group of companies. Your personal data will only be transferred to countries outside the EU or the EEA (so-called third countries) if this is necessary in the context of processing our contractual relationships or is required by law (e.g. reporting obligations under tax law), if you have given us your consent or in the context of a processing agreement.

When transferring data to third countries, we ensure that a level of data protection within the meaning of Art. 44 et seq. GDPR is complied with.

If we use service providers in third countries and we have influence over them, they are obliged to comply with the level of data protection in the EU by agreeing to the EU Standard Contractual Clauses (in addition to instructions if necessary). Alternatively, we transfer the data on the basis of binding corporate rules or an adequacy decision. Further information can be obtained from our data protection officer.

Otherwise, we do not transfer your personal data to countries outside the EU or the EEA or to international organizations (see section 3.2.1).

7. Duration of storage

7.1 Informational use of the website

If you use our website purely for information purposes, we store your personal data on our servers exclusively for the duration of your visit to our website. After you have left our website, your personal data will be deleted within seven days.

7.2 Active use of the website

When you actively use our website, we initially store your personal data for the duration of the response to your inquiry or for the duration of our business relationship. This also includes the potential future and actual initiation of a contract (pre-contractual legal relationship) and the execution of a contract. The log files for the login are stored for 90 days for security reasons and for support requests and then deleted.
We process your data for the duration of your subscription to our newsletter or customer magazine or until you withdraw your consent to receive them. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.
In addition, we then store your personal data until any legal claims arising from the relationship with you become time-barred, in order to use it as evidence if necessary. The limitation period is usually between 1 and 3 years, but can also be up to 30 years.
We delete your personal data when the statute of limitations expires, unless there is a statutory retention obligation, for example from the German Commercial Code (Sections 238, 257 (4) HGB) or from the German Fiscal Code (Section 147 (3), (4) AO). Such retention obligations can last from two to ten years. During this period, the data is processed again solely in the event of an audit by the tax authorities.

8. Your rights as a data subject

If your personal data is processed, you are a "data subject" within the meaning of the GDPR. You have the following rights vis-à-vis us as the controller, which you can assert.

Your rights as a data subject are as follows:

  • Right to information: You can request information about whether we process your personal data. If this is the case, you have a right of access to this personal data and to further information related to the processing (Art. 15 GDPR). Please note that this right to information may be restricted or excluded in certain cases.
  • Right to rectification: In the event that personal data concerning you is not (or no longer) accurate or incomplete, you may request that this data be rectified and, if necessary, completed (Art. 16 GDPR).
  • Right to erasure or restriction of processing: If the legal requirements are met, you can request the erasure of your personal data (Art. 17 GDPR) or the restriction of the processing of this data (Art. 18 GDPR). However, the right to erasure pursuant to Art. 17 (1) and (2) GDPR does not apply if, among other things, the processing of personal data is necessary for compliance with a legal obligation (Art. 17 (3) (b) GDPR).
  • Right to object: For reasons arising from your particular situation, you can also object to the processing of your personal data by us at any time (Art. 21 GDPR). If the legal requirements are met, we will then no longer process your personal data.
  • Right to data portability: If the requirements stipulated in Article 20 GDPR are met, you may demand to receive from us the personal data in relation to you that you have provided to us, in a format that is structured, commonly used and machine-readable.
  • Right to revoke the declaration of consent under data protection law: You have the right to revoke your consent at any time. The revocation is only effective for the future; this means that the revocation does not affect the legality of the processing carried out on the basis of the consent until the revocation.
  • Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, a data subject (you) has the right to lodge a complaint with a supervisory authority - in particular in the Member State of your habitual residence - if you consider that the processing of your personal data by us infringes the GDPR.

    • State Commissioner for Data Protection and Freedom of Information
    North Rhine-Westphalia
    P.O. Box 20 04 44
    40102 Düsseldorf
    Phone: 0211/38424-0
    Fax: 0211/38424-10
    E-mail: poststelle@ldi.nrw.de

    However, we recommend that you always address a complaint to our data protection officer first.
    If possible, your requests to exercise your rights should be sent in writing to the address given above under Sec. 1 or directly to our data protection officer.

    9. Scope of your obligations to provide data

    You are not generally obliged to disclose your personal data to us. However, if you do not do so, we will be unable to make our website available to you, answer the requests that you address to us and enter into a contract with you. All personal data that is not absolutely needed by us for the aforesaid processing purposes is marked as voluntary by the addition “if applicable” or otherwise.

    10. Profiling / automated decision-making

    Due to legal requirements, we are obliged to combat money laundering and fraud. Data is also analyzed in this process. These measures also serve to protect you. Otherwise, we do not carry out any profiling and do not use any purely automated decision-making processes in accordance with Article 22 GDPR. Should we use further procedures in individual cases in the future, we will inform you of this separately.

    Right to object, Art. 21 GDPR

    You have the right to object at any time, on grounds relating to your particular situation, to the processing of your data which is carried out on the basis of Article 6(1)(f) GDPR (data processing based on balancing of interests) or Article 6(1)(e) GDPR (data processing carried out in the public interest). This also applies to profiling, as defined in Article 4(4) GDPR, based on said provisions.

    If you object, we will no longer process your personal data unless we can prove that there are compelling reasons worthy of protection for such processing which outweigh your interests, rights and freedoms, or unless such processing serves the purpose of establishing, exercising or defending legal claims.

    We will process your personal data in individual cases also for direct advertising purposes. If you do not wish to receive advertisements, you have the right to object at any time; this also applies to profiling, to the extent carried out in connection with such direct advertising. Your objection, once received, will apply with effect for the future.

    In addition, upon receipt of an objection to this effect, we will stop processing your data for direct advertising purposes.

    The objection does not need to be in any particular form but should be addressed to the address given in Section 1 above.

    11. Changes

    We amend this privacy policy from time to time, e.g. in the event of changes to data processing or legal requirements. Therefore, please check this privacy policy regularly to see the latest version.

    Last updated in March 2025