Privacy Policy

We are very delighted that you have shown interest in our enterprise. Data protection is of a
particularly high priority for the management of the FTW Fluidtechnik Walter. The use of the Internet
pages of the FTW Fluidtechnik Walter is possible without any indication of personal data; however, if a
data subject wants to use special enterprise services via our website, processing of personal data
could become necessary. If the processing of personal data is necessary and there is no statutory
basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of
a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in
accordance with the country-specific data protection regulations applicable to the FTW Fluidtechnik
Walter. By means of this data protection declaration, our enterprise would like to inform the general
public of the nature, scope, and purpose of the personal data we collect, use and process.
Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to
which they are entitled.

As the controller, the FTW Fluidtechnik Walter has implemented numerous technical and
organizational measures to ensure the most complete protection of personal data processed through
this website. However, Internet-based data transmissions may in principle have security gaps, so
absolute protection may not be guaranteed. For this reason, every data subject is free to transfer
personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of the FTW Fluidtechnik Walter is based on the terms used by the
European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data
protection declaration should be legible and understandable for the general public, as well as our
customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a)    Personal data

Personal data means any information relating to an identified or identifiable natural person (“data
subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular
by reference to an identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.

b)   Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the
controller responsible for the processing.

c)    Processing

Processing is any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure or
destruction.

d)    Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their
processing in the future.

e)    Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal
data to evaluate certain personal aspects relating to a natural person, in particular to analyse or
predict aspects concerning that natural person's performance at work, economic situation, health,
personal preferences, interests, reliability, behaviour, location or movements.

f)     Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no
longer be attributed to a specific data subject without the use of additional information, provided that
such additional information is kept separately and is subject to technical and organisational measures
to ensure that the personal data are not attributed to an identified or identifiable natural person.

g)    Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority,
agency or other body which, alone or jointly with others, determines the purposes and means of the
processing of personal data; where the purposes and means of such processing are determined by
Union or Member State law, the controller or the specific criteria for its nomination may be provided for
by Union or Member State law.

h)    Processor

Processor is a natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller.

i)      Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal
data are disclosed, whether a third party or not. However, public authorities which may receive
personal data in the framework of a particular inquiry in accordance with Union or Member State law
shall not be regarded as recipients; the processing of those data by those public authorities shall be
in compliance with the applicable data protection rules according to the purposes of the processing.

j)      Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject,
controller, processor and persons who, under the direct authority of the controller or processor, are
authorised to process personal data.
k)    Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the
data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection
laws applicable in Member states of the European Union and other provisions related to data
protection is:

FTW Fluidtechnik Walter
Heuweg 7
72275 Alpirsbach
Deutschland
Tel.: 0049-7444-916709
E-Mail: info@ftw-walter.de
Website: www.ftw-walter.de

3. Collection of general data and information

The website of the FTW Fluidtechnik Walter collects a series of general data and information when a
data subject or automated system calls up the website. This general data and information are stored
in the server log files. Collected may be (1) the browser types and versions used, (2) the operating
system used by the accessing system, (3) the website from which an accessing system reaches our
website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site,
(6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system,
and (8) any other similar data and information that may be used in the event of attacks on our
information technology systems.

When using these general data and information, the FTW Fluidtechnik Walter does not draw any
conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our
website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the
long-term viability of our information technology systems and website technology, and (4) provide law
enforcement authorities with the information necessary for criminal prosecution in case of a cyber-
attack. Therefore, the FTW Fluidtechnik Walter analyzes anonymously collected data and information
statistically, with the aim of increasing the data protection and data security of our enterprise, and to
ensure an optimal level of protection for the personal data we process. The anonymous data of the
server log files are stored separately from all personal data provided by a data subject.

4. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period
necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or
other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or
another competent legislator expires, the personal data are routinely blocked or erased in accordance
with legal requirements.

5. Rights of the data subject

a)    Rights of the data subject

Each data subject shall have the right granted by the European legislator to obtain from the controller
the confirmation as to whether or not personal data concerning him or her are being processed. If a
data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact
any employee of the controller.

b)    Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller
free information about his or her personal data stored at any time and a copy of this information.
Furthermore, the European directives and regulations grant the data subject access to the following
information:

o the purposes of the processing;
o the categories of personal data concerned;
o the recipients or categories of recipients to whom the personal data have been or will
be disclosed, in particular recipients in third countries or international organisations;
o where possible, the envisaged period for which the personal data will be stored, or, if
not possible, the criteria used to determine that period;
o the existence of the right to request from the controller rectification or erasure of
personal data, or restriction of processing of personal data concerning the data
subject, or to object to such processing;
o the existence of the right to lodge a complaint with a supervisory authority;
o where the personal data are not collected from the data subject, any available
information as to their source;
o the existence of automated decision-making, including profiling, referred to in Article
22(1) and (4) of the GDPR and, at least in those cases, meaningful information about
the logic involved, as well as the significance and envisaged consequences of such
processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are
transferred to a third country or to an international organisation. Where this is the case, the data
subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact
any employee of the controller.

c)    Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller
without undue delay the rectification of inaccurate personal data concerning him or her. Taking into
account the purposes of the processing, the data subject shall have the right to have incomplete
personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any
employee of the controller.

d)    Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller
the erasure of personal data concerning him or her without undue delay, and the controller shall have
the obligation to erase personal data without undue delay where one of the following grounds applies,
as long as the processing is not necessary:
o The personal data are no longer necessary in relation to the purposes for which they
were collected or otherwise processed.
o The data subject withdraws consent to which the processing is based according to
point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR,
and where there is no other legal ground for the processing.
o The data subject objects to the processing pursuant to Article 21(1) of the GDPR and
there are no overriding legitimate grounds for the processing, or the data
subject objects to the processing pursuant to Article 21(2) of the GDPR.
o The personal data have been unlawfully processed.
o The personal data must be erased for compliance with a legal obligation in Union or
Member State law to which the controller is subject.
o The personal data have been collected in relation to the offer of information society
services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of
personal data stored by the FTW Fluidtechnik Walter, he or she may, at any time, contact any
employee of the controller. An employee of FTW Fluidtechnik Walter shall promptly ensure that the
erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase
the personal data, the controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to inform other controllers
processing the personal data that the data subject has requested erasure by such controllers of any
links to, or copy or replication of, those personal data, as far as processing is not required. An
employees of the FTW Fluidtechnik Walter will arrange the necessary measures in individual cases.

e)   Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller
restriction of processing where one of the following applies:

o The accuracy of the personal data is contested by the data subject, for a period enabling the
controller to verify the accuracy of the personal data.
o The processing is unlawful and the data subject opposes the erasure of the personal data and
requests instead the restriction of their use instead.
o The controller no longer needs the personal data for the purposes of the processing, but they
are required by the data subject for the establishment, exercise or defence of legal claims.
o The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending
the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of
the processing of personal data stored by the FTW Fluidtechnik Walter, he or she may at any time
contact any employee of the controller. The employee of the FTW Fluidtechnik Walter will arrange the
restriction of the processing. f)     Recht auf Datenübertragbarkeit

f)    Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data
concerning him or her, which was provided to a controller, in a structured, commonly used and
machine-readable format. He or she shall have the right to transmit those data to another controller
without hindrance from the controller to which the personal data have been provided, as long as the
processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article
9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the
processing is carried out by automated means, as long as the processing is not necessary for the
performance of a task carried out in the public interest or in the exercise of official authority vested in
the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the
data subject shall have the right to have personal data transmitted directly from one controller to
another, where technically feasible and when doing so does not adversely affect the rights and
freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee
of the FTW Fluidtechnik Walter.

g)    Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds
relating to his or her particular situation, at any time, to processing of personal data concerning him or
her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based
on these provisions.

The FTW Fluidtechnik Walter shall no longer process the personal data in the event of the objection,
unless we can demonstrate compelling legitimate grounds for the processing which override the
interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of
legal claims.

If the FTW Fluidtechnik Walter processes personal data for direct marketing purposes, the data
subject shall have the right to object at any time to processing of personal data concerning him or her
for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If
the data subject objects to the FTW Fluidtechnik Walter to the processing for direct marketing
purposes, the FTW Fluidtechnik Walter will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to
object to processing of personal data concerning him or her by the FTW Fluidtechnik Walter for
scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the
GDPR, unless the processing is necessary for the performance of a task carried out for reasons of
public interest.

In order to exercise the right to object, the data subject may contact any employee of the FTW
Fluidtechnik Walter. In addition, the data subject is free in the context of the use of information
society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by
automated means using technical specifications.

h)    Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a
decision based solely on automated processing, including profiling, which produces legal effects
concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is
necessary for entering into, or the performance of, a contract between the data subject and a data
controller, or (2) is not authorised by Union or Member State law to which the controller is subject and
which also lays down suitable measures to safeguard the data subject's rights and freedoms and
legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data
subject and a data controller, or (2) it is based on the data subject's explicit consent, the FTW
Fluidtechnik Walter shall implement suitable measures to safeguard the data subject's rights and
freedoms and legitimate interests, at least the right to obtain human intervention on the part of the
controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he
or she may, at any time, contact any employee of the FTW Fluidtechnik Walter.

i)      Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her
consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time,
contact any employee of the FTW Fluidtechnik Walter.

6. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent
for a specific processing purpose. If the processing of personal data is necessary for the performance
of a contract to which the data subject is party, as is the case, for example, when processing
operations are necessary for the supply of goods or to provide any other service, the processing is
based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are
necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning
our products or services. Is our company subject to a legal obligation by which processing of personal
data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c
GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests
of the data subject or of another natural person. This would be the case, for example, if a visitor were
injured in our company and his name, age, health insurance data or other vital information would have
to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art.
6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal
basis is used for processing operations which are not covered by any of the abovementioned legal
grounds, if processing is necessary for the purposes of the legitimate interests pursued by our
company or by a third party, except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection of personal data. Such
processing operations are particularly permissible because they have been specifically mentioned by
the European legislator. He considered that a legitimate interest could be assumed if the data subject
is a client of the controller (Recital 47 Sentence 2 GDPR).

7. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to
carry out our business in favor of the well-being of all our employees and the shareholders.

8. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory
retention period. After expiration of that period, the corresponding data is routinely deleted, as long as
it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

9. Provision of personal data as statutory or contractual requirement; Requirement necessary
to enter into a contract; Obligation of the data subject to provide the personal data; possible
consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also
result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be
necessary to conclude a contract that the data subject provides us with personal data, which must
subsequently be processed by us. The data subject is, for example, obliged to provide us with
personal data when our company signs a contract with him or her. The non-provision of the personal
data would have the consequence that the contract with the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject must contact any employee.
The employee clarifies to the data subject whether the provision of the personal data is required by law
or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide
the personal data and the consequences of non-provision of the personal data.

10. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.
This Privacy Policy has been generated by the Privacy Policy Generator of the External Data
Protecton Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW.