Data privacy policy

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

Using our website is generally possible without providing personal data. Where personal data (such as name, address, or email addresses) is collected on our pages, this is always done on a voluntary basis wherever possible. These data will not be passed on to third parties without your express consent.

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

1. Newsletter Tracking

If the website uses newsletter tracking, the associated data processing must be addressed separately. A legal basis for this data processing can be found in Art. 6 para. 1 lit. f GDPR.

2. Blog with Comment Function

When operating a blog with a comment function, additional personal data (example: pseudonyms) are stored. It must also address the possibility of subscribing to comments. Commenting should only be possible after obtaining consent for the processing of personal data. In this case, justification according to Art. 6 para. 1 lit. a GDPR is possible.

3. Processing of Special Categories of Personal Data, Art. 9 GDPR

The processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the unique identification of a natural person, health data, or data concerning a natural person's sex life or sexual orientation is generally prohibited. However, Art. 9 para. 2 GDPR contains a list of exceptions. If website operators process such data on their website, a prior assessment must be carried out. The corresponding legal basis must then be stated in the privacy policy.

4. E-Commerce

If the website operator offers users a platform for concluding contracts (e.g., purchase or service contracts), personal data of the contracting partner is generally collected as part of the conclusion of the contract. The website operator must point out this data processing separately and in detail. If the data processing is necessary for the conclusion of the contract, Art. 6 para. 1 lit. b GDPR serves as the legal basis for the data processing.

5. Disclosure of Personal Data to Third Parties

A large number of websites use third-party extensions. Often, personal data is passed on to or automatically transmitted to third parties in such implementations. The type, scope, purpose, and duration of this processing of personal data can vary in each case. A comprehensive list of all situations in which personal data is passed on to third parties would go beyond the scope of this privacy policy. The website operator must therefore examine in each individual case which third-party services are used on their website and whether personal data is transferred.
Accordingly, this data processing must be included in the privacy policy as specified (A.II.).

Examples of disclosure of personal data to third parties may include:

a) Disclosure to service providers

In particular, when concluding contracts via the website, personal data is often passed on to service providers (e.g., suppliers). However, service providers may also act solely in the interest of the website operator (e.g., technical service).

b) Payment services and payment procedures

A special case of disclosure to service providers is the disclosure of data to payment services.

c) Third-party cookies

The use of own cookies is part of the privacy policy (B.V.). In addition, cookies from third parties are often used. These must be described in detail. Users must be informed about the use of third-party cookies when accessing the website. There is a way to prevent the storage of these cookies in the browser settings. The legal basis for the use of third-party cookies is Art. 6 para. 1 lit. f GDPR. A legitimate interest for the use of the cookie must also be stated in each individual case.

d) Use of social media plugins

When using social media plugins, users' personal data is transmitted to the providers of social networks. According to previous legal practice, it was advisable to use such plugins only within the framework of a “two-click solution.” This meant data was transmitted only after the user had previously given consent. Even after the introduction of the GDPR, this approach is possible and legally sound. The legal basis for processing data after user consent is Art. 6 para. 1 lit. a GDPR.

e) Website analytics services

Website analytics services (e.g., Google Analytics or Adobe Analytics) to improve the efficiency of your own website, which are operated by third parties, require the transfer of data about website visitors to the third-party providers. Usually, user consent is not obtained for this. Justification can be provided under Art. 6 para. 1 lit. f GDPR, if a legitimate interest of the website operator can be demonstrated. To protect users’ interest in the security of their personal data, it is advisable to pseudonymize the data. In this case, there is usually nothing against the use of analytics services and the associated transfer of pseudonymized data. The exact use must be documented in the privacy policy.

f) Advertising and marketing services

If advertising is placed on the website, this is usually done involving third-party providers (e.g., Google AdSense or AdWords). In most cases, personal data of users, such as the IP address, is transmitted to intermediaries. If advertising is necessary to finance the website, justification under Art. 6 para. 1 lit. f GDPR appears possible.

II. Requirements for Adding Further Elements

When supplementing the privacy policy with additional elements, the type, scope, purpose, duration, and options for withdrawal of the respective data processing must be specified. The structure could be as follows:

1. Scope of Processing of Personal Data

This section describes in as much detail as possible which personal data is processed on the website, by whom, and in what way.

2. Legal Basis for the Processing of Personal Data

This section states the legal basis for processing personal data. As a rule, this will be found in the catalog of Art. 6 para. 1 GDPR.

3. Purpose of Data Processing

This section describes in detail the purposes for which the website operator processes personal data. If the processing is based on Art. 6 para. 1 lit. f GDPR, the legitimate interest in the processing is generally also stated here. In such cases, it must always be checked whether there are milder means of achieving the purpose that would have less impact on the interests of users in the protection of their personal data.

4. Duration of Storage

As a rule, data is deleted as soon as the purpose for which it was collected has been fulfilled. However, in individual cases, it is necessary to specify more precisely when this will occur in the specific case. If no exact information can be provided, at least criteria should be mentioned that make it easier for the user to determine the time of deletion.

5. Objection and Removal Options

For each data processing operation, users must be informed about how they can prevent the processing of their data or have data that has already been processed deleted early. If the user has given their consent to processing, it must be possible to withdraw this consent at any time. The process for withdrawal must not be more difficult than giving consent. The procedure for withdrawing consent must be described.

B Privacy Policy According to the GDPR

I. Name and Address of the Controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:

HANTECH GmbH Daimlerstraße 6 76185 Karlsruhe Germany Tel.: 0721 / 90996879 Email: info@hantech.eu Website: www.hantech.eu

II. Name and Address of the Data Protection Officer

The data protection officer of the controller is:

Zaim Demirhan Daimlerstraße 6 76185 Karlsruhe Germany Tel.: 0721 / 90996879 Email: info@hantech.eu Website: www.hantech.eu

III. General Information on Data Processing

1. Scope of Processing of Personal Data

We only process the personal data of our users insofar as this is necessary to provide a functional website and our content and services. The processing of our users' personal data is regularly only carried out after obtaining the user's consent. An exception applies in those cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

2. Legal Basis for the Processing of Personal Data

If we obtain the consent of the data subject for processing operations involving personal data, Art. 6 para. 1 lit. a of the EU General Data Protection Regulation (GDPR) serves as the legal basis. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual measures. If processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis. If the processing is necessary to protect the vital interests of the data subject or another natural person, Art. 6 para. 1 lit. d GDPR serves as the legal basis. If processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, and such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

3. Data Deletion and Storage Duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may take place beyond this if this is provided for by the European or national legislator in EU regulations, laws, or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a necessity for further storage of the data for the conclusion or fulfillment of a contract.

IV. Provision of the Website and Creation of Log Files

1. Description and Scope of Data Processing

Every time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:

• Information about the browser type and version used
• The user's operating system
• The user's Internet service provider
• The user's IP address
• Date and time of access
• Websites from which the user's system accesses our website
• Websites accessed by the user's system via our website

The data is also stored in the log files of our system. This does not include the IP addresses of the user or other data that would enable the data to be assigned to a user. Storage of this data together with other personal data of the user does not take place.

2. Legal Basis for Data Processing

The legal basis for the temporary storage of the data is Art. 6 para. 1 lit. f GDPR.

3. Purpose of Data Processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

This purpose also constitutes our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.

4. Duration of Storage

The data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of data collection for the provision of the website, this is the case when the respective session has ended.

5. Objection and Removal Possibility

The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Therefore, there is no possibility of objection on the part of the user.

V. Use of Cookies

a) Description and Scope of Data Processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string that allows the browser to be uniquely identified when the website is accessed again.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

• Language settings
• Items in a shopping cart
• Log-in information

b) Purpose of Data Processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary for the browser to be recognized even after a page change.

We need cookies for the following applications:

• Shopping cart
• Adoption of language settings
• Remembering search terms

The user data collected by technically necessary cookies is not used to create user profiles.

This purpose also constitutes our legitimate interest in processing personal data according to Art. 6 para. 1 lit. f GDPR.

c) Duration of Storage, Objection and Removal Possibility

Cookies are stored on the user's computer and transmitted from there to our site. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it may no longer be possible to use all the functions of the website to their full extent.

VI. Newsletter

1. Description and Scope of Data Processing

On our website, it is possible to subscribe to a free newsletter. When registering for the newsletter, the data from the input form is transmitted to us.

• Email address

The following data is also collected during registration:

• IP address of the accessing computer
• Date and time of registration

During the registration process, your consent for data processing is obtained and reference is made to this privacy policy.

If you purchase goods or services on our website and provide your email address in the process, we may subsequently use it to send you a newsletter. In such a case, the newsletter will only contain direct advertising for our own similar goods or services.

No data is passed on to third parties in connection with data processing for sending the newsletter. The data is used exclusively for sending the newsletter.

2. Legal Basis for Data Processing

The legal basis for processing data after the user subscribes to the newsletter, provided there is user consent, is Art. 6 para. 1 lit. a GDPR.

The legal basis for sending the newsletter as a result of the sale of goods or services is § 7 para. 3 UWG.

3. Purpose of Data Processing

The collection of the user's email address serves to deliver the newsletter.

The collection of other personal data as part of the registration process is intended to prevent misuse of the services or the used email address.

4. Duration of Storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. The user's email address is therefore stored as long as the newsletter subscription is active.

Other personal data collected during the registration process is generally deleted after a period of seven days.

5. Objection and Removal Option

The subscription to the newsletter can be canceled by the affected user at any time. For this purpose, a corresponding link can be found in every newsletter.

This also enables the withdrawal of consent to the storage of personal data collected during the registration process.

VII. Registration

1. Description and Scope of Data Processing

On our website, we offer users the opportunity to register by providing personal data. The data is entered into an input form, transmitted to us, and stored. The data will not be passed on to third parties. The following data is collected during the registration process:

• Email address
• First and last name
• Address

At the time of registration, the following data is also stored:

• The user's IP address
• Date and time of registration

As part of the registration process, the user's consent to process this data is obtained.

2. Legal Basis for Data Processing

The legal basis for processing the data is, if the user has given consent, Art. 6 para. 1 lit. a GDPR.

If the registration serves the fulfillment of a contract to which the user is a party or the implementation of pre-contractual measures, the additional legal basis for data processing is Art. 6 para. 1 lit. b GDPR.

3. Purpose of Data Processing

User registration is required to provide certain content and services on our website.

• Ordering goods
• Newsletter

4. Duration of Storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected.

This is the case for the data collected during the registration process when the registration on our website is cancelled or changed.

5. Objection and Removal Option

As a user, you have the option at any time to cancel your registration. You can have the data stored about you changed at any time.

Changes and deletions can be requested in writing at info@hantech.eu.

VIII. Contact Form and Email Contact

1. Description and Scope of Data Processing

Our website contains a contact form which can be used for electronic contact. If a user makes use of this option, the data entered in the input form will be transmitted to us and stored. This data is:

• Name
• Email address
• Telephone number
• Message

At the time the message is sent, the following data is also stored:

• The user’s IP address
• Date and time of registration

During the submission process, your consent for data processing is obtained and reference is made to this privacy policy.

Alternatively, it is possible to contact us via the provided email address. In this case, the user’s personal data transmitted with the email will be stored.

There is no disclosure of data to third parties in this context. The data will be used exclusively for processing the conversation.

2. Legal Basis for Data Processing

The legal basis for processing the data is, if the user has given consent, Art. 6 para. 1 lit. a GDPR.

The legal basis for processing data transmitted in the course of sending an email is Art. 6 para. 1 lit. f GDPR. If the email contact is aimed at concluding a contract, an additional legal basis for processing is Art. 6 para. 1 lit. b GDPR.

3. Purpose of Data Processing

The processing of personal data from the input form is solely for the purpose of processing the contact request. In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data.

Other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of Storage

The data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For the personal data from the contact form input fields and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is considered ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

Other personal data collected during the submission process will be deleted at the latest after a period of seven days.

5. Objection and Removal Option

The user has the right at any time to withdraw their consent to the processing of personal data. If the user contacts us by email, they may object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

Withdrawal must be made in writing by email to info@hantech.eu and applies to all data from the contact form and/or email contact.

All personal data stored in the course of contacting us will be deleted in this case.

IX. Rights of the Data Subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights with respect to the controller:

1. Right to Information

You may request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing exists, you can request information from the controller about the following:

• The purposes for which the personal data is being processed;
• The categories of personal data being processed;
• The recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
• The planned duration of the storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage period;
• The existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
• The existence of a right to lodge a complaint with a supervisory authority;
• All available information about the origin of the data if the personal data was not collected from the data subject;
• The existence of automated decision-making, including profiling, in accordance with Art. 22 paras. 1 and 4 GDPR, and – at least in these cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

2. Right to Rectification

You have the right to rectification and/or completion by the controller if the personal data processed concerning you is incorrect or incomplete. The controller must make the correction without delay.

3. Right to Restriction of Processing

You may request the restriction of the processing of your personal data under the following conditions:

• If you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data;
• The processing is unlawful and you oppose the erasure of the personal data and instead request the restriction of the use of the personal data;
• The controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise, or defense of legal claims; or
• If you have objected to processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.

If the processing of your personal data has been restricted, such data – apart from their storage – may only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right to Erasure

a) Obligation to Erase

You may request the controller to erase your personal data without undue delay, and the controller is obliged to erase this data without undue delay if one of the following reasons applies:

• Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing was based according to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal ground for the processing.
• You object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR.
• Your personal data has been processed unlawfully.
• The erasure of your personal data is required for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• Your personal data has been collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

b) Information to Third Parties

If the controller has made your personal data public and is obliged to erase it according to Art. 17 para. 1 GDPR, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers who are processing the personal data that you, as the data subject, have requested the erasure by such controllers of any links to, or copies or replications of, those personal data.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary

• For exercising the right of freedom of expression and information;
• For compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• For reasons of public interest in the area of public health pursuant to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 GDPR;
• For archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
• For the establishment, exercise, or defense of legal claims.

5. Right to Notification

If you have exercised your right to rectification, erasure, or restriction of processing against the controller, the controller is obliged to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

You have the right to be informed by the controller about those recipients.

6. Right to Data Portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, provided that

• The processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR, and
• The processing is carried out by automated means.

In exercising this right, you also have the right to have your personal data transmitted directly from one controller to another, where technically feasible. The freedoms and rights of others must not be adversely affected by this.

The right to data portability does not apply to processing personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to Object

You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data based on Art. 6 para. 1 lit. e or f GDPR, including profiling based on those provisions.

The controller will no longer process your personal data unless they can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or the processing is for the establishment, exercise, or defense of legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by automated means using technical specifications.

8. Right to Withdraw Data Protection Consent

You have the right to withdraw your data protection consent declaration at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

9. Automated Decision-Making in Individual Cases Including Profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

• Is necessary for entering into, or performance of, a contract between you and the controller,
• Is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
• Is based on your explicit consent.

However, such decisions shall not be based on special categories of personal data referred to in Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests have been taken.

With regard to the cases referred to in (1) and (3), the controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

10. Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the progress and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.