PHOENIX CONTACT on data protection

1. Introduction and scope

We are delighted that you are interested in our company, products, and services and would like to provide you with some key information regarding our data processing activities.

Protecting personal data is crucial, particularly for the future of Internet-based business models and the development of Internet-based economies. With this notice on data protection, we want to emphasize our commitment to protecting your privacy.

Our staff and our service providers are bound to confidentiality and to comply with the provisions of applicable data protection laws. We take the protection of your personal data seriously and strictly adhere to the rules of applicable data protection laws.

Definition: “Personal data” means any information relating to an identified or identifiable natural person (data subject), for instance, name, geographical address, contact data, user ID, IP address, photo and video recordings, location data, etc.

The following notice informs you about the data processing activities in relation to your Personal data.

2. Data controller / Data protection officer

Information on the entity responsible for the processing of your Personal data ("Controller"), including how to contact the appointed data protection officer ("DPO"), where applicable, can be found under the link below (the Controller hereinafter referred to "we", "us" or "our").

3. Purposes / Categories of data

3.1. Data processing on our websites

For security and technical reasons, we automatically process information transmitted by your device's browser to our system protocols. This includes:

  • Browser type/version,
  • Operating system used,
  • Requested URLs (website) on our systems,
  • Referrer URL (the website that referred to our website),
  • Host name and full IP address or unique ID of the device accessing the site,
  • Date and time of call, and
  • Data volumes and file types called.

These data will not be aggregated with data from other sources, nor do we carry out personalized statistical analysis on the basis of these data.

We process IP addresses in full length (i.e. withouth IP masking) only to the technically required extent.

The purpose of the processing of these data is to provide you with our websites and the services and functionalities available thereon.

The system log data processed in this context to offer you the requested service (e.g. IP address) is deleted after a maximum period of 6 months.

3.2. Registration for our web portal

Our websites offer services and functionalities to manage our business relationship with you, for example, permanent saving of wish lists and product comparisons or requesting and viewing quotes, which are only available to registered users.

The data required to complete a registration in our web portal are your name, a valid email address and your country of residence. You also have the option of providing additional Personal data about you (title, company, if relevant: your Phoenix Contact customer number, postal address, phone number). Some of these data are required in order to use certain services on our web portal, such as placing online orders, tracking your orders, generating individual price lists or processing order returns.

The processing of the above listed data serves the purpose of providing you with the services and functionalities of our websites available to registered users, such as the possibility of placing online orders.

We use the additional data provided to contact you personally following registration in the web portal as well as for advertising purposes. This includes updating our customer master database or providing you with information on our products and services to the extent permitted by law.

You can withdraw your consent to the processing of your Personal data for marketing purposes at any time by sending an email to our designated point of contact. You can also delete your account at any time by contacting our designated point of contact. We will erase your Personal data, provided that no statutory retention periods apply (see Section 6 below).

3.3. Newsletter

You have the option of subscribing to our newsletter. Subscription to our newsletter requires providing a valid email address. Beyond that, you can choose to provide us with additional Personal data about you (title, name, company, postal address). Following registration, you will receive an individual confirmation link per email (“double opt-in”). This is a means of verifying the email address used in the registration process and ensuring that no third parties have subscribed to the newsletter using your email address.

The purpose of the processing of your Personal data is to provide you with the requested newsletter. The additional data provided in the newsletter registration process is used to personally address the newsletter.

You can withdraw your consent for the newsletter subscription at any time with effect for the future by using the unsubscribe button of our newsletters. Alternatively, you can send an email to our designated point of contact stating that you wish to unsubscribe.

Our websites also offer you the option of creating a user profile when subscribing for the newsletter. To this end, we analyze your interactions with the newsletter (clickstream record, date and time, frequency and topics clicked on, the specific emails opened and when) so that we can subsequently send you information better tailored to your interests. You can withdraw your consent for the creation of a user profile at any time with effect for the future by sending an email to our designated point of contact.

We will keep your Personal data for the duration of your newsletter subscription. Once you unsubscribe, we will keep your Personal data until the applicable statute of limitations expires. For general information on retention periods see Section 6 below.

3.4. Contacting us

When you submit a contact request or a query to us (e.g. by calling or faxing our office, sending an email to us or using any of the contact forms on our websites), we process the Personal data you have provided us with (such as name, address, contact information, message, etc.).

The purpose of this processing activity is to deal with your specific request and/or query.

Personal data processed in connection with contact queries is deleted after a period of 12 months, provided that no statutory retention periods apply (see Section 6 below).

3.5. Events

We process Personal data about you when you register for a seminar or an event.

The categories of data processed in this context include your name, address, contact information, as well as event-related information such as location, date, travel options, hotels, etc. For travel arrangements we also process the following categories of data, where applicable: dietary preferences, passport details (e.g. for visa applications), etc. If you are an employee of ours we will process your staff number, organizational key, cost center.

The purpose of the processing is the overall management of the relevant seminar or event (including the planning, preparation and follow up thereof).

The Personal data processed in connection with events is deleted after a maximum period of 12 months, provided that no statutory retention periods apply (see Section 6 below).

3.6. Use of PROFICLOUD

In order to register for our PROFICLOUD, you are required to choose a username, and a password and to provide a valid email address.

The processing of your Personal data serves the purpose of using our PROFICLOUD and all its services and features.

One such feature is our PLCnext community, which you can also use after registration, includes functionalities such as the possibility to participate in our forum by creating and commenting on posts.

You can delete your user account at any time by clicking on the "Remove” button. When you remove your user account your email address is deleted and only the username is kept to ensure traceability in the customer account. Additionally, your posts in the community will be kept so as not to lose the context of a discussion.

The system log data processed in this context to offer you the requested service (e.g. IP address) is deleted after a maximum period of 6 months, provided that no statutory retention periods apply (see Section 6 below).

3.7. Use of our knowledge base (Empolis)

Data resulting from the analysis of the knowledge base use is anonymized. As an example, we analyze the search queries including the search terms and search filters, calls and runs of deci-sion trees including the answers given and solutions chosen, the download and display of documents, etc. It is not possible to assign these data to the respective user or identify the user. Further, any comments you choose to make on our documents cannot be assigned to you.

The purpose of this processing is to obtain information on the use of our knowledge base in order to be able to improve it in accordance with the users' needs.

The system log data processed in this context to offer you the requested service (e.g. IP address) is deleted after a maximum period of 6 months, provided that no statutory retention periods apply (see Section 6 below).

3.8. Participation in surveys

We process the Personal data you provide to us when you participate in a survey.

The data processed in this context consists of your name, email address, geographical address, country of residence, your survey answers and log data generated in the course of the survey (IP address, date and time of execution, etc.).

The purpose of the processing is to carry out surveys and analyze the survey results in order to further improve our services.

Personal data processed in connection with surveys is deleted after a period of 12 months, provided that no statutory retention periods apply (see Section 6 below).

3.9. Customer relationship management (CRM)

Customer relationship management requires processing Personal data related to our customer, provided that he or she is a natural person, and/or the designated contact person, where applicable.

The categories of data include name, title, business address, business contact information (email address, phone number), department, company position, contact history, marketing history (events attendances, communication profile), etc.

The purposes of the processing include communicating with our customers, carrying out advertising activities such as sending out invitations to events, informing about new products and services, etc.

Personal data in connection with customer relationship management is deleted after the business relationship ends, provided that no statutory retention periods apply (see Section 6 below).

3.10. Request for quotation/order processing

We process your Personal data in connection with a request for quotation, order processing, sample order, license processing, configuration, etc.

The categories of data include name, address (delivery address, billing address), contact information (email address, phone number), bank details, results from the sanctions screenings, etc.

The purpose of the processing is the performance of business transactions with our customer. The Personal data processed relates to the customer, provided that he or she is a natural person, and/or the designated contact person, where applicable.

Personal data in connection with quotation requests and order processing is deleted after the business relationship ends, provided that no statutory retention periods apply (see Section 6 below).

3.11. Supplier management/Purchase order processing

We process your personal data when you register in the supplier portal as well as in connection with the processing of purchase orders.

The categories of data concerned include name, title, business address, business contact information, title, department, company position, bank details, control data, VAT ID number, credit rating, risk report, supplier profile, etc.

The purpose of the processing is the performance of business transactions with our suppliers. The Personal data processed relates to the supplier, provided that he or she is a natural person, and/or the designated contact person, where applicable.

Personal data in connection with supplier management and purchase order processing is deleted after the business relationship ends, provided that no statutory retention periods apply (see Section 6 below).

3.12. Job applicant’s data

We process the Personal data you provide to us as part of a job application and/or registration in the Application Portal.

The categories of data include your name, title, address, contact details, date of birth, nationality, CV, certifications and qualifications and any other information you include in your job application.

We process your Personal data to communicate with you and only as part and for the purpose of our recruitment process.

Your application will be automatically deleted 6 months after the end of the application process, provided that no statutory retention periods apply (see Section 6 below).

3.13. Use of our blogs

Our blogs have comment functions for blog entries that you can only use if you provide a username of your choice as well as a valid email address.

The Personal data you provide to us in connection with the comment function is processed exclusively for the purpose of publication on the blog. You can withdraw your consent to the use of your Personal data at any time by sending an email to our designated point of contact. However, after removing your Personal data your comments will be kept so as not to lose the context of a discussion.

For general information on retention periods please see Section 6 below.

3.14. Cookies

Our websites use cookies. Cookies are small text files that are stored by your browser on your device. We use cookies to make our websites more userfriendly, effective, and secure. By way of an example, cookies enable the technical implementation of a user session in our online catalog.

Further, cookies provide information which enables us to optimize our websites to meet user requirements. Some of the cookies we use are session cookies. These are automatically deleted once you exit our websites. Some cookies are saved for a longer period of time. All cookies on our websites contain purely technical information in a pseudonymized or anonymized format, with no Personal data.

You can manage your cookie preferences in your browser settings, for example, by selecting “Do not accept cookies”. Please note that the scope of functions of our websites may be severely limited if the use of cookies is restricted. A number of functions may no longer be available. This may also be the case when visiting our websites using the so-called “Private Mode” of your browser.

We ourselves do not store any information in the LSO (Local Shared Objects) area of your computer, so we do not use so-called “Flash Cookies”. However, other services we may link to, such as YouTube, use this function for own purposes, where applicable.

We use the following cookies:

  • phoenixcontact.com
    • phoenixcontact.unique.token
    • Contains anonymously stored shopping carts
    • Contains a 32-character alphanumeric string
    • valid until 1 year
  • phoenixcontact.com
    • AMWEBJCT!%2F!JSESSIONID
    • Each time you log in for the first time within a session, the session ID is stored here, which allows convenient use of the shop and other functions of the website
    • Contains a 32-character alphanumeric string
    • valid only for the current session
  • phoenixcontact.com
    • AMWEBJCT!%2F!selectedLocale
    • ID of the currently selected language
    • Contains, for example, the value: “{de=de}”
    • valid for 1 year
  • phoenixcontact.com
    • cookieInfoText_xxxx.disabled
    • Flag that the cookie banner hint has been confirmed
    • Contains the term „true“
    • valid only for the current session
  • phoenixcontact.com
    • pxc.corporate.website.information.layer.rendered
    • Flag that the cookie banner hint has been confirmed
    • Contains the term „true“
    • valid only for the current session
  • phoenixcontact.com
    • PD-ID
    • Is set when registering in our portal and enables the safe and comfortable use
    • Contains a 32-character alphanumeric string
    • valid only for the current session
  • phoenixcontact.com
    • PD-S-SESSION-ID
    • Is set when registering in our portal and enables the safe and comfortable use
    • Contains a 32-character alphanumeric string
    • valid only for the current session
  • phoenixcontact.com
    • dtCookie
    • Required for technical stability and end user performance of the website
    • Contains an alphanumeric string (<serverID>| <sessionID>| <applica-tionID>| <applicationState>)
    • valid only for the current session
  • phoenixcontact.com
    • dtLatC
    • Measures server latency
    • Contains numeric value
    • valid only for the current session
  • phoenixcontact.com
    • dtPC
    • Required to identify proper endpoints for beacon transmission
    • Contains an alphanumeric string
    • valid only for the current session
  • phoenixcontact.com
    • dtSa
    • Intermediate store for page-spanning actions
    • Contains an alphanumeric string
      (<URL-encoded action name>)
    • valid only for the current session
  • phoenixcontact.com
    • rxVisitor
    • Random id (Session cookie)
    • Contains an alphanumeric string
    • valid only for the current session
  • phoenixcontact.com
    • rxvt
    • Session timeout
    • Contains an alphanumeric string (<timestamp>|<timestamp>)
    • valid only for the current session
  • qs.phoenixcontact.com
    • CTCNTNM_xxx
    • Web tracking
    • Contains a 32-character alphanumeric string
    • valid for 90 days
  • t.leadlab.click
    • CTCNTNM_xxx
    • Web tracking (xxx: website ID)
    • Contains a 32-character alphanumeric string
      (pseudonymous tracking ID of the user)
    • valid for 90 days
  • phoenixcontact.com
    • WM_DONT_COUNT_xxx
    • Website tracking opt-out (xxx: website ID)
    • Contains the number „1“ (true)
    • valid for 10 years
  • esc-eu-central-1.empolisservices.com
    • session
    • Session cookie 1, identification of a session
    • Contains an alphanumeric string
    • valid only for the current session
  • esc-eu-central-1.empolisservices.com
    • AWSELB
    • Session cookie 2, for system load balancing
    • Contains an alphanumeric string
    • valid only for the current session
  • Proficloud.net
    • Proficloud_c_a
    • Contains the information that the cookie disclaimer was displayed and confirmed
    • valid for 10 years
  • Proficloud.net
    • Proficloud_sess
    • Contains a reference to a server-side session. This session contains a user object that includes the ID and permissions of the user
    • valid for: Depending on the session
  • Proficloud.net
    • Proficloud_auth
    • Contains a token that can be used to check whether a user has already authenticated via login.
    • valid for an 1 hour
  • plcnextstore.com
    • x-jwt-token
    • Contains a token that can be used to check whether a user has already authenticated via login.
    • valid for an 1 hour
  • surveys.phoenixcontact.com
    • ASP.NET_SessionId
    • Is set when registering in our survey and enables the safe and comfortable use
    • Contains a 32-character alphanumeric string
    • valid only for the current session
  • phoenixcontact.com
    • _ga
    • Used to distinguish users.
    • Contains an alphanumeric string
    • valid for 15 months
  • phoenixcontact.com
    • _gid
    • Used to distinguish users.
    • Contains an alphanumeric string
    • valid for 24 hours
  • phoenixcontact.com
    • _gat
    • Used to throttle request rate
    • Contains a number
    • valid for 1 minute
  • phoenixcontact.com
    • AMP_TOKEN
    • Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service
    • valid for 30 seconds to 1 year
  • phoenixcontact.com
    • _gac_ <property-id>
    • Campaign related information for the user
    • Contains an alphanumeric string
    • valid for 90 days
  • phoenixcontact.com
    • _gaexp
    • Used to determine a user's inclusion in an experiment and the expiry of experiments a user has been included in
    • Contains an alphanumeric string
    • valid depending on the length of the experiment but typically for 90 days
  • phoenixcontact.com
    • _gcl_aw
    • _gcl_dc
    • Used to attribute conversions outside the landing page
    • Contains an alphanumeric string
    • valid for 90 days
  • phoenixcontact.com
    • _ga_opt_out
    • Used to attribute conversions outside the landing pageIs set when a user clicks the Google Analytics Opt-Out link in the privacy policy. Then prevents Google Analytics from collecting data
    • Contains a string
    • valid for 2 years

3.15. Social Media / Social Networks / External Links

We do not use any automatically activated plug-ins (e.g. iFrames) of social networks on our web-sites. Our social network buttons such as Facebook, Twitter, Xing, LinkedIn, YouTube, Instagram etc. are mere links to the respective sites of the provider. Once you click on these links, you will be redirected to the pages of the respective social network. Please note that once on the social network websites, their respective data protection notices are applicable.

In addition, we have an online presence in some of these social networks and platforms to promote our business, inform interested parties/users about our products and services and to communicate with them. Your Personal data is often used for the platform's own purposes, e.g. for market research and advertising purposes or to analyze user behavior for the creation of user profiles. To this end, cookies from these platforms are usually stored on the user's device.

Although we do not have access to the profile data processed by the platforms, we may be jointly responsible for the data processing under applicable data protection laws. For further information, please contact our designated point of contact](https://www.phoenixcontact.com/en-il/data-protection-officer "designated point of contact").

For detailed information on the processing of your Personal data and possible opt-out options, please refer to the following:

Facebook

Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy at: https://www.facebook.com/about/privacy,
Opt-out at: https://www.facebook.com/settings?tab=ads.

Instagram

Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy at: http://instagram.com/about/legal/privacy/
Opt-out at: http://instagram.com/about/legal/privacy/ (point VI.).

YouTube

YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA
represented by: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Privacy policy at: www.google.com/privacy,
Opt-out at: https://adssettings.google.com/authenticated.

Twitter

Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland
Privacy policy at: www.twitter.com/privacy ,
Opt-out at: https://twitter.com/personalization.

LinkedIn

LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
Privacy policy at: https://www.linkedin.com/legal/privacy-policy,
Opt-out at: https://www.linkedin.com/psettings/advertising.

XING

XING SE, Dammtorstr. 30, 20354 Hamburg, Deutschland
Privacy policy at: www.xing.com/privacy
Opt-out at: https://privacy.xing.com/en/privacy-policy .

3.16. Web analyses

Google Analytics

We use Google Analytics, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") for web analysis and range measurement. Google uses cookies. The information generated by the cookie about users' visits to our website is generally transmitted to and stored by Google on servers in the United States.

However, Google Analytics is used by us exclusively with activated IP anonymization (so-called IP masking). This means that the IP address of users is shortened by Google. Only in exceptional cases, e.g. if technical failures occur in Europe, the full IP address is transferred to a Google server in the USA and then shortened there. To the best of our knowledge, the IP address transmitted by the user's browser will not be merged with other data of the user held by Google.
Google uses the transmitted data on our behalf and on the basis of a data processing agreement, to evaluate the use of our website, to create reports on the activities within our online offering and to provide us with other services associated with the use of the website. With the help of these analysis results we can, for example, identify particularly popular areas of our website and the preferences of users and use the knowledge gained in this way to further improve our offer and make it more targeted and interesting for you as a user.

The determining reason for the use of Google Analytics is the fact that there is no equally suitable web analysis tool for our specific purposes. Google Analytics is not only the most widespread tool in the international context and is therefore particularly suitable for websites of internationally active groups of companies. Due to its wide distribution, Google Analytics unlike other web analysis tools also has standard interfaces to other software systems that we use. Furthermore, in your interest we implemented Google Analytics as data protection friendly as possible (in addition to IP masking, e.g. by not processing the user ID for cross-device analysis of visitor flows, by reducing the standard storage period, etc.).

The acceptance of cookies when using our website is not mandatory; if you do not wish cookies to be stored on your device, you can deactivate the corresponding option in the system settings of your browser. Additionally, you can delete saved cookies at any time in the system settings of your browser. If you do not accept cookies, however, this may lead to functional limitations. In addition, you can deactivate the use of Google Analytics cookies using a browser add-on if you do not wish the website analysis. You can download this add-on here: http://tools.google.com/dlpage/gaoptout?hl=en

You can use the Google Analytics opt-out browser add-on to prevent Google Analytics from using your information. To disable Google Analytics, download and install your web browser add-on. The Google Analytics opt-out add-on is compatible with all common browsers. For the add-on to work, it must be loaded and run correctly in your browser. To learn more about how to disable Google Analytics and correctly install the browser add-on, click here: https://support.google.com/analytics/answer/181881?hl=en.

As an alternative to the browser add-on, for example for mobile devices, you can also prevent Google Analytics from capturing data by clicking on the following link. An "opt-out cookie" will then be set to prevent your data from being collected in the future. The opt-out cookie applies only to the specific browser used when you set it and only to our website and is stored on your device. If you delete the cookies in your browser, you must set the opt-out cookie again. The common browsers also offer a "Do-Not-Track-Function". If this function is activated, your device informs the web analysis tool that you do not want to be tracked.

The data processed by Google Analytics is automatically deleted after a period of 14 months. Data whose retention period has been reached is automatically deleted once a month.

You can find out more about Google's use of data, setting and withdrawal options in Google's privacy policy: https://policies.google.com/privacy

3.17. Online Advertising (Retargeting / Remarketing)

For the purpose of optimizing our online offer we use third party retargeting and remarketing services on our website to help us analyze, improve and operate our online services in an economic way.

How Retargeting / Remarketing works

On our website, data are collected using cookie / tracking technology to improve our online offer. These data are not used to identify you personally, but solely to analyze the use of our website and to address users who are already interested in our content and offers with interest related advertising. We are convinced that the display of an interest related advertisement is generally more interesting for the user than advertising that has no such personal reference. The following section of this data protection notice informs you about the third parties we cooperate with, how your data are processed in this context, and how you can deactivate and opt out from such retargeting / remarketing technologies.

Google Ads

We use the online marketing tool Google Ads, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). We use the remarketing function within the Google Ad Service in order to place ads within the Google Advertising Network (e.g. in search results, videos, web pages, etc.) so that they are specifically displayed to users who have a sup-posed interest in the ads or the products and services advertised. For these purposes, so-called (re)marketing tags are integrated and executed on our website and other websites of the Google Advertising Network directly by Google. In this way an individual cookie is stored on the user's device (comparable technologies can also be used instead of cook-ies), this serves to recognize your browser. Google usually stores information about this cookie, such as which websites the user has visited, what content he is interested in and what offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visiting times and other information about the use of the online service.

Furthermore, we use the function of Ads Conversion. Using an individual "conversion cookie" we can track how many of our visitors are taking actions on our website resulting from an advertising campaign. The information collected with the help of the cookie is used by Google to compile conversion statistics for us. However, we only know the anonymous total number of users who clicked on our ad and were directed to a page with a conversion tracking tag. We do not receive any personally identifiable information.

The data processing associated with the services described above is carried out for analysis, optimization and marketing purposes, in particular in order to better measure and evaluate the success of our advertising campaigns and to provide you with offers and content that are as closely aligned with your interests as possible. If you do not wish such marketing cookies to be stored on your device, you can deactivate the corresponding option in the system settings of your browser. Already stored cookies can be removed at any time in the system settings of your browser. However, if you do not accept any cookies, this may lead to functional limitations. You can also prevent data processing by Google Ads by clicking on the link provided in the privacy menu of the webpage if that webpage uses Google Ads. An "opt-out cookie" will then be set to prevent your data from being collected in the future. The opt-out cookie applies only to the browser used when you set it and only to our website and is stored on your terminal device. If you delete the cookies in your browser, you must set the opt-out cookie again. The common browsers also offer a "Do-Not-Track-Function". If this function is activated, your de-vice informs the web analysis tool that you do not want to be tracked.

The pseudonymized data processed by Google Ads is deleted after 90 days. The deletion of data whose retention period has been reached takes place automatically once a month. Further information on the use of data by Google, setting and withdrawal options can be found in Google's privacy policy (https://policies.google.com/technologies/ads?hl=en) and in your personal settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

Google Tag Manager

In compliance with applicable law, we reserve the right to process your Personal data and any other data we hold about you for the purposes of investigating, preventing, or taking action in the event of illegal activities and/or suspected fraud.

3.18 Further purposes of Personal data processing

In compliance with applicable law, we reserve the right to process your Personal data and any other data we hold about you for the purposes of investigating, preventing, or taking action in the event of illegal activities and/or suspected fraud.

4. Recipients of data / Data transfers

We share your Personal data insofar as necessary for the purposes of the processing as described above. The Personal data is limited to what is strictly necessary to achieve the intended purpose of the processing. The recipients of data include:

  • Other group companies: you can find a list of the group companies here;
  • Service providers: we work with service providers for a variety of tasks such as the newsletter emailing, event management, customer service, etc.. Our service providers are contractually bound to confidentiality and to comply with applicable data protection laws. We do not sell, disclose or otherwise make available your Personal data to third parties for marketing purposes; and
  • Authorities or governmental bodies which require us to disclose data about you;
  • Lawyers and advisors: where necessary, we share your Personal data with these recipients in order to investigate, prevent, or take action regarding illegal activities, suspected fraud and violations of our terms of use, as well as for the establishment, exercise or defence of a legal claim.

5. Secure Internet communication

We make every effort to ensure that your Personal data is transferred and stored using technical and organizational measures to prevent access by unauthorized third parties.

As a general rule, the Internet is regarded as an insecure environment. In contrast to a telephone line, for instance, data transfers on the Internet can be more easily wiretapped, recorded or even modified by unauthorized third parties. To ensure the confidentiality of communications with you, we use an AES 256bit SSL/TLS encryption of our website. This encryption is regarded as secure, based on the latest technological advancements. Operating systems and browsers from earlier versions also achieve this security level. If necessary, you should update the operating system and the browser on your device to benefit from this high level encryption.

Email communication without encryption does not guarantee comprehensive data security. Therefore, we recommend using the regular postal mail for confidential information.

6. Retention period

The applicable retention period varies depending on the category of data and/or the purpose of the processing. Please refer to Section 3 above for more detailed information on the applicable retention periods depending on the purpose.

As a general rule, we keep your Personal data only as long as necessary for the purpose of the processing. We are, however, subject to statutory retention requirements. This means that we are required by law to store certain data for a certain period of time. This is usually the case for commercial- and tax-relevant data (such as bills and other transaction documents). Data stored because of applicable retention periods is not processed for further purposes.

To learn more about applicable retention periods please contact our designated point of contact.

7. Data subjects rights

Should you have any questions that have not been addressed in this data protection notice, in case you wish more detailed information regarding a specific point, or should you have any complaints or requests about the processing of your Personal data by us (e.g. a request for completion of incomplete Personal data or for rectification of inaccurate Personal data) please do not hesitate to contact our designated point of contact.

Please note that depending on the circumstances, we may require proof of identification to handle any requests regarding your Personal data.

8. Miscellaneous

In the event that we launch new services, alter our Internet procedures or if the legal requirements change or the Internet and IT security technology is further developed, this notice will be updated accordingly. In case of amendments, proper notice will be given on this website. The date of the last update of this notice can be found at the bottom of the page.

Our websites, their services and functionalities (such as the newsletter) may contain links or references to third party websites. Please be aware that this notice does not apply to these other websites. We encourage you to read the terms of use as well as the data protection notices of any third party websites you enter.

Updated: August 2019