Privacy Policy
The protection of the data of internet users is very important to us.
Privacy Policy, status: September 2023
The protection of data is very important to us. For this reason, we always observe the applicable legal provisions on data protection and data security. Below we explain which information we may collect and how we handle it.
Scope of this Privacy Policy
This Privacy Policy applies to all data that is collected and processed by BEWOTEC Software Entwicklungs- und Vertriebs-GmbH (hereinafter: “BEWOTEC”).
Applicability of this Privacy Policy
Our Privacy Policy on the general information regarding data protection and our data processing in accordance with Articles 13, 14 and 21 GDPR as well as the further supplementary information on data processing may change from time to time. You can access information on the Privacy Policy of BEWOTEC GmbH from any page of the BEWOTEC GmbH website via a hyperlink in the footer.
Part 1
General information on data protection and our data processing in accordance with Articles 13, 14 and 21 of the General Data Protection Regulation (GDPR)
We take data protection seriously and hereby inform you how we process your data and which claims and rights you are entitled to under the data protection regulations.
1. Controller responsible for data processing and contact details
Controller in the sense of data protection law:
BEWOTEC Software Entwicklungs- und Vertriebs- GmbH
Karl-Schiller-Str. 3
51503 Rösrath
E-Mail: info@bewotec.de
Contact details of our Data Protection Officer:
HEC Harald Eul Consulting GmbH
Datenschutzbeauftragte der BEWOTEC Software Entwicklungs- und Vertriebs- GmbH
Auf der Höhe 34
50321 Brühl
E-Mail: datenschutzbeauftragter@bewotec.de
2. Purposes and legal bases on which we process your data
We process personal data in accordance with the provisions of the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and other applicable data protection regulations (details below). Which data is processed in detail – possibly also with the use of artificial intelligence (AI) – and how it is used depends primarily on the services requested or agreed in each case.
Further details or supplements on the purposes of data processing can be found in the respective contractual documents, forms, a declaration of consent and/or other information provided to you (e.g. in the context of the use of our website or our Terms and Conditions). In addition, this data protection information may be updated from time to time, as you can see on our website www.bewotec.de.
2.1 Purposes for the performance of a contract or pre-contractual measures (Art. 6 (1) (b) GDPR)
The processing of personal data is carried out for the performance of our contracts with you and the execution of your orders as well as for the implementation of measures and activities in the context of pre-contractual relationships, e.g. with interested parties.
In particular, the processing serves the provision of software solutions for the travel and tour operator industry in accordance with your orders and wishes and includes the services, measures and activities necessary for this purpose. These essentially include contract-related communication with you, the corresponding billing and related payment transactions, the traceability of transactions, orders and other agreements as well as quality control through corresponding documentation, goodwill procedures, measures for steering and optimising business processes as well as for fulfilling general duties of care, management and control by affiliated companies (e.g. parent company); statistical analyses for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, billing and tax valuation of operational services, risk management, assertion of legal claims and defence in legal disputes; ensuring IT security (including system and plausibility checks) and general security, e.g. building and facility security, ensuring and exercising house rules (e.g. through access controls); ensuring the integrity, authenticity and availability of data, prevention and investigation of criminal offences; monitoring by supervisory bodies or control authorities (e.g. audit).
2.2 Purposes within the scope of a legitimate interest of us or third parties (Art. 6 (1) (f) GDPR)
Beyond the actual performance of the contract or pre-contract, we may process your data if this is necessary to safeguard legitimate interests of us or third parties, in particular for the following purposes:
advertising or market and opinion research, provided you have not objected to the use of your data;
obtaining information and exchanging data with credit agencies, insofar as this goes beyond our economic risk;
reviewing and optimising procedures for needs analysis;
further development of services and products as well as existing systems and processes;
training and (further) development of AI applications;
disclosure of personal data in the context of due diligence during corporate sale negotiations;
matching against European and international anti-terror lists, insofar as this goes beyond legal obligations;
enrichment of our data, including through the use or research of publicly accessible data;
statistical analyses or market analysis;
benchmarking;
assertion of legal claims and defence in legal disputes that are not directly attributable to the contractual relationship;
limited storage of data where deletion is not possible or only possible with disproportionately high effort due to the particular type of storage;
development of scoring systems or automated decision-making processes;
prevention and investigation of criminal offences, insofar as this is not exclusively for the fulfilment of legal requirements;
building and facility security (e.g. through access controls and video surveillance), insofar as this goes beyond general duties of care;
internal and external investigations, security reviews;
possible monitoring or recording of telephone calls for quality control and training purposes;
obtaining and maintaining certifications of a private or official nature;
ensuring and exercising house rules through appropriate measures, including video surveillance, to protect our customers and employees as well as to secure evidence in the event of criminal offences and their prevention, and to provide proof of fraud, theft or corruption.
2.3 Purposes on the basis of your consent (Art. 6 (1) (a) GDPR)
The processing of your personal data for specific purposes (e.g. use of your e-mail address for marketing purposes) may also be carried out on the basis of your consent. As a rule, you can revoke this consent at any time.
This also applies to the revocation of declarations of consent that were given to us before the GDPR came into force, i.e. before 25 May 2018. You will be informed separately in the respective text of the consent about the purposes and the consequences of a revocation or refusal to grant consent.
As a general rule, the revocation of consent only takes effect for the future. Processing carried out before the revocation is not affected by this and remains lawful.
2.4 Purposes for compliance with legal obligations (Art. 6 (1) (c) GDPR) or in the public interest (Art. 6 (1) (e) GDPR)
Like any entity involved in economic activities, we are also subject to a variety of legal obligations. These are primarily legal requirements (e.g. commercial and tax laws), but may also include supervisory or other official requirements.
The purposes of processing include, where applicable:
identity and age verification,
fraud and money laundering prevention,
prevention, combating and investigation of terrorist financing and property-threatening crimes,
matching against European and international anti-terror lists,
fulfilment of tax control and reporting obligations,
storage of data for purposes of data protection and data security,
audits by tax authorities and other public bodies.
Furthermore, the disclosure of personal data may be necessary in the context of official or judicial measures for purposes of evidence collection, criminal prosecution or enforcement of civil law claims.
3. Categories of data we process, insofar as we do not receive the data directly from you, and their origin
Where necessary for the provision of our services, we process personal data lawfully obtained from other companies or third parties (e.g. credit agencies, address providers).
We also process personal data that we have lawfully taken, received, or acquired from publicly accessible sources (such as telephone directories, commercial and association registers, resident registers, debtor registers, land registers, press, internet, and other media) and are permitted to process.
Relevant categories of personal data may include in particular:
personal data (name, date of birth, place of birth, nationality, marital status, occupation/industry and comparable data)
contact data (address, e-mail address, telephone number and comparable data)
address data (registration data and comparable information)
payment/coverage confirmations for bank and credit cards
information about your financial situation (creditworthiness data including scoring, i.e. data for assessing economic risk)
customer history
data about your use of the telemedia we offer (e.g. time of website visits, apps or newsletters, clicked pages/links, entries, and comparable data)
video data
4. Recipients or categories of recipients of your data
Within our company, those internal departments or organisational units receive your data that require it to fulfil our contractual and legal obligations or for the purposes of legitimate interests as described above.
Your data is only passed on to external recipients:
in connection with the execution of the contract
for the fulfilment of legal obligations requiring disclosure or where disclosure is in the public interest (see section 2.4)
where external service providers process data on our behalf as processors or functional subcontractors (e.g. external data centres, IT support/maintenance, archiving, document processing, call-centre services, compliance services, controlling, data screening for anti-money-laundering purposes, data validation or plausibility checks, data destruction, procurement, customer administration, letter shops, marketing, media technology, research, risk control, billing, telephony, website management, auditing, banks, printing companies, disposal companies, courier services, logistics)
on the basis of our legitimate interests or those of a third party for the purposes listed in section 2.2 (e.g. authorities, credit agencies, debt collection, lawyers, courts, experts, affiliated companies and corporate governance bodies)
if you have given consent for transmission to third parties
Your data is not transferred to third parties beyond this.
Where we engage service providers within the scope of commissioned data processing, your data is subject to the same security standards as at our own organisation.
In all other cases, recipients may only use the data for the purposes for which it was transmitted.
For reference, the relevant possible categories of data are the same as listed in section 3.
5. Duration of storage of your data
We process and store your data for the duration of our business relationship.
This includes the initiation of a contract (pre-contractual relationship) and its execution.
Beyond this, we are subject to statutory retention and documentation obligations, arising for example from the German Commercial Code (HGB) and the German Fiscal Code (AO).
These retention periods extend up to ten years beyond the end of the business relationship or the pre-contractual relationship.
Longer retention may also be required for legal reasons, such as preserving evidence under statutory limitation periods.
According to §§ 195 ff. of the German Civil Code (BGB), the regular limitation period is three years, but periods of up to 30 years may apply.
If data is no longer required to fulfil contractual or legal obligations, it is routinely deleted unless further processing is temporarily necessary for one of the purposes listed under section 2.2 due to an overriding legitimate interest.
Such an interest may exist where deletion is not possible or only possible with disproportionately high effort, and processing for other purposes is prevented through appropriate technical and organisational measures.
6. Processing of your data in a third country or by an international organisation
A transfer of data to recipients in countries outside the European Union (EU) or the European Economic Area (EEA) (“third countries”) occurs only if:
it is required for the fulfilment of a contract with you or for carrying out pre-contractual measures,
it is required by law (e.g. tax reporting obligations),
it is based on a legitimate interest of us or a third party, or
you have given your consent.
Processing in a third country may also occur when using service providers as processors.
If there is no adequacy decision by the EU Commission for the respective third country, we ensure appropriate safeguards in accordance with EU data protection requirements — typically via contractual arrangements — to ensure adequate protection of your rights and freedoms.
Further details are available from our Data Protection Officer upon request.
7. Your data protection rights
Under certain conditions, you may exercise the following rights against us:
Right of access (Art. 15 GDPR) — including any restrictions under § 34 BDSG
Right to rectification (Art. 16 GDPR) of incorrect or incomplete data
Right to erasure (Art. 17 GDPR) — unless opposing legal obligations or overriding interests apply
Right to restriction of processing (Art. 18 GDPR)
Right to object (Art. 21 GDPR) — particularly for reasons arising from your particular situation
Right to data portability (Art. 20 GDPR)
Right to withdraw consent at any time with future effect (Art. 7 GDPR)
Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)
Your requests should preferably be submitted in writing to the address indicated above or directly to our Data Protection Officer.
8. Extent of your obligations to provide data
You only need to provide the data that is required to establish and conduct a business relationship or a pre-contractual relationship with us, or data that we are legally required to collect.
Without this data, we will generally not be able to conclude or perform a contract with you.
This may also apply to data required later during the business relationship.
Where we request further data beyond this necessity, we will expressly indicate that such information is voluntary.
9. Existence of automated decision-making in individual cases (including profiling)
We do not use fully automated decision-making in accordance with Article 22 GDPR.
If such procedures are used in future individual cases, we will inform you separately, where legally required.
We may process your data partly to evaluate personal aspects (“profiling”).
This helps us provide you with targeted product information and advice through analytical tools, enabling needs-oriented product design, communication, and advertising — including market and opinion research.
Such procedures may also be used to assess your creditworthiness and to prevent money laundering and fraud.
For credit and risk assessment, so-called score values may be used, calculated using recognised mathematical-statistical methods on the basis of:
income situation,
expenses,
existing obligations,
profession, employer, employment duration,
experience from previous business relationships,
proper repayment of earlier credits,
information from credit agencies.
Nationality and special categories of personal data (Art. 9 GDPR) are not used in scoring.
Information about Your Right to Object under Article 21 GDPR
- You have the right to object at any time to the processing of your personal data which is carried out on the basis of Article 6(1)(f) GDPR (data processing on the basis of a balancing of interests) or Article 6(1)(e) GDPR (data processing in the public interest), if there are reasons arising from your particular situation.
This also applies to profiling based on these provisions within the meaning of Article 4(4) GDPR.
If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or unless the processing serves the establishment, exercise, or defence of legal claims.
- We may also process your personal data for direct marketing purposes.
If you do not wish to receive advertising, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling insofar as it is related to direct marketing.
If you object, we will no longer process your personal data for direct marketing purposes.
Your objection does not require any specific form and should preferably be addressed to:
BEWOTEC Software Entwicklungs- und Vertriebs-GmbH
Karl-Schiller-Str. 3
51503 Rösrath
Germany
Part 2
Additional information on data processing for online presences controlled by BEWOTEC
Data collection on this website
Who is responsible for data collection on this website?
The data processing on this website is carried out by the website operator. You can find the operator’s contact details in the section “Information on the Controller” in this privacy policy (above in Part 1).
How do we collect your data?
On the one hand, your data is collected by you providing it to us. This may, for example, be data that you enter into a contact form.
Other data is collected automatically or after your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system, or time of the page view). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Part of the data is collected in order to ensure the error-free provision of the website. Other data may be used to analyse your user behaviour.
Analysis tools and tools from third parties
When visiting this website, your surfing behaviour may be statistically evaluated. This is done primarily with so-called analysis programs. Detailed information on these analysis programs can be found below.
Hosting
We host the content of our website with the following provider:
Host Europe
The provider is Host Europe GmbH, Hansestraße 111, 51149 Cologne, Germany (hereinafter “Host Europe”). When you visit our website, Host Europe collects various log files including your IP addresses. For details, please refer to Host Europe’s privacy policy:
https://www.hosteurope.de/AGB/Datenschutzerklaerung/.
The use of Host Europe is based on Article 6(1)(f) GDPR. We have a legitimate interest in the most reliable presentation of our website possible.
Processing on our behalf
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract required under data protection law to ensure that this provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the lock symbol in your browser bar.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Cookies
Our internet pages use so-called “cookies”. Cookies are small data packages and do not cause any damage to your end device. They are either stored temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your end device. Session cookies are automatically deleted after your visit. Persistent cookies remain stored on your end device until you delete them yourself or your web browser automatically deletes them.
Cookies can be set by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies within websites (e.g. cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies can be used to evaluate user behaviour or for advertising purposes.
Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. for the shopping cart function) or to optimise the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Article 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services.
If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Article 6(1)(a) GDPR and Section 25(1) TTDSG); consent may be withdrawn at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.
You can find out which cookies and services are used on this website in this privacy policy.
Consent with Borlabs Cookie
Our website uses Borlabs Cookie consent technology to obtain your consent to store certain cookies in your browser or to use certain technologies and to document this in accordance with data protection requirements. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany (“Borlabs”).
When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the withdrawal of such consents are stored. These data are not passed on to the provider of Borlabs Cookie.
The collected data will be stored until you ask us to delete them, delete the Borlabs cookie yourself, or the purpose for data storage no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at:
https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.
The use of the Borlabs Cookie consent technology is carried out in order to obtain the legally required consents for the use of cookies. The legal basis for this is Article 6(1)(c) GDPR. You can find out which cookies and services are used on this website in this privacy policy.
Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
Browser type and browser version
Operating system used
Referrer URL
Host name of the accessing computer
Time of the server request
IP address
This data is not merged with other data sources.
The collection of this data is based on Article 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – the server log files must be collected for this purpose.
Enquiry by email, telephone or fax
If you contact us by email, telephone, or fax, your enquiry, including all personal data arising therefrom (name, enquiry), will be stored and processed by us for the purpose of dealing with your request. We will not pass on this data without your consent unless this is directly necessary for fulfilling your request.
The processing of this data is based on Article 6(1)(b) GDPR, provided that your request is related to the performance of a contract or necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of the enquiries sent to us (Article 6(1)(f) GDPR).
The data you send us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
Google Tag Manager
We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies on our website. Google Tag Manager itself does not create user profiles, does not store cookies, and does not carry out any independent analyses. It is only used for the management and display of the tools integrated via it. However, Google Tag Manager records your IP address, which may also be transmitted to the parent company of Google in the United States.
The use of Google Tag Manager is based on Article 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and management of various tools on its website. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be withdrawn at any time.
The company is certified under the “EU–US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at:
https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt000000001L5AAI&status=Active
Google Analytics
This website uses features of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyse the behaviour of website visitors. The website operator receives various usage data, such as page views, duration of visit, operating systems used, and the origin of the user. These data are assigned to the respective end device of the user. No assignment to a user ID takes place.
Furthermore, we can use Google Analytics, among other things, to record your mouse and scroll movements and clicks. Google Analytics uses various modelling approaches to supplement the collected datasets and employs machine-learning technologies in data analysis.
Google Analytics uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google about your use of this website is generally transmitted to a Google server in the USA and stored there.
The use of this service is based on your consent in accordance with Article 6(1)(a) GDPR and Section 25(1) TTDSG. Consent may be withdrawn at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified under the “EU–US Data Privacy Framework” (DPF). Further information is available from the provider at:
https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt000000001L5AAI&status=Active
Browser plugin
You can prevent the collection and processing of your data by Google by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=de.
More information on the handling of user data by Google Analytics can be found in Google’s privacy policy:
https://support.google.com/analytics/answer/6004245?hl=de.
Processing on our behalf
We have concluded a data processing agreement (DPA) with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Meta-Pixel
This website uses the visitor action pixel of Facebook/Meta for conversion measurement. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta, the data collected is also transferred to the USA and other third countries.
This allows the behaviour of site visitors to be tracked after they have been forwarded to the provider’s website by clicking on a Facebook advertisement. This enables the effectiveness of Facebook advertisements to be evaluated for statistical and market research purposes and to optimise future advertising measures.
The collected data is anonymous to us as the operator of this website; we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook Data Usage Policy (https://de-de.facebook.com/about/privacy/
). This enables Facebook to place advertisements on Facebook pages as well as outside of Facebook. We, as the site operator, cannot influence this data processing.
The use of this service is based on your consent in accordance with Article 6(1)(a) GDPR and Section 25(1) TTDSG. Consent may be withdrawn at any time.
We use the function of extended matching within Meta Pixel.
Extended matching allows us to transmit various types of data (e.g. place of residence, federal state, postcode, hashed email addresses, names, gender, date of birth, or telephone number) of our customers and prospects, which we collect via our website, to Meta (Facebook). By activating this function, we can tailor our Facebook advertising campaigns even more precisely to people who are interested in our offers. Extended matching also improves the attribution of website conversions and expands custom audiences.
Insofar as personal data is collected on our website using the tool described here and transmitted to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Article 26 GDPR). Joint responsibility is limited exclusively to the collection of the data and its transmission to Facebook. The processing by Facebook after transmission is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in an agreement on joint processing. The wording of this agreement can be found at:
https://www.facebook.com/legal/controller_addendum.
According to this agreement, we are responsible for providing the data protection information when using the Facebook tool and for the secure implementation of the tool on our website in accordance with data protection law. Facebook is responsible for data security with regard to Facebook products. You can assert data subject rights (e.g. requests for access) with regard to the data processed by Facebook directly with Facebook. If you assert data subject rights with us, we are obliged to forward them to Facebook.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum
and
https://de-de.facebook.com/help/566994660333381.
Further information on protecting your privacy can be found in Facebook’s privacy notes:
https://de-de.facebook.com/about/privacy/.
You can also deactivate the “Custom Audiences” remarketing function in the ad settings section at:
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
You must be logged in to Facebook to do this.
If you do not have a Facebook account, you can deactivate Facebook’s usage-based advertising on the website of the European Interactive Digital Advertising Alliance:
http://www.youronlinechoices.com/de/praferenzmanagement/.
The company is certified under the “EU–US Data Privacy Framework” (DPF). Further information is available from the provider at:
https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt0000000GnywAAC&status=Active
Facebook Conversion API
We have integrated Facebook Conversion API on this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta, the data collected is also transferred to the USA and other third countries.
Facebook Conversion API enables us to record the interactions of the website visitor with our website and to transmit them to Facebook in order to improve advertising performance on Facebook. For this purpose, in particular the time of access, the accessed website, your IP address and your user agent as well as, where applicable, further specific data (e.g. purchased products, value of the shopping cart, and currency) are collected. A complete overview of the data that can be collected can be found here:
https://developers.facebook.com/docs/marketing-api/conversions-api/parameters.
The use of this service is based on your consent in accordance with Article 6(1)(a) GDPR and Section 25(1) TTDSG. Consent may be withdrawn at any time.
Insofar as personal data is collected on our website using the tool described here and transmitted to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Article 26 GDPR). Joint responsibility is limited exclusively to the collection of the data and its transmission to Facebook. The processing by Facebook after transmission is not part of the joint responsibility.
The obligations incumbent on us jointly have been set out in an agreement on joint processing. The wording of this agreement can be found at:
https://www.facebook.com/legal/controller_addendum.
According to this agreement, we are responsible for providing the data protection information when using the Facebook tool and for the secure implementation of the tool on our website in accordance with data protection law. Facebook is responsible for data security with regard to Facebook products. You can assert data subject rights (e.g. requests for access) with regard to the data processed by Facebook directly with Facebook. If you assert data subject rights with us, we are obliged to forward them to Facebook.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum
and
https://de-de.facebook.com/help/566994660333381.
Further information on protecting your privacy can be found in Facebook’s privacy notes:
https://de-de.facebook.com/about/privacy/.
The company is certified under the “EU–US Data Privacy Framework” (DPF). Further information is available from the provider at:
https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt0000000GnywAAC&status=Active
Processing on our behalf
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract required under data protection law to ensure that this provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
Newsletter data
If you would like to receive the newsletter offered on the website, we require an email address from you as well as information which allows us to verify that you are the owner of the specified email address and that you agree to receive the newsletter. Further data is not collected or is only collected on a voluntary basis. For the handling of the newsletters, we use newsletter service providers as described below.
CleverReach
This website uses CleverReach for sending newsletters. The provider is CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany (“CleverReach”). CleverReach is a service which can be used to organise and analyse newsletter distribution. The data you enter for the purpose of subscribing to the newsletter (e.g. email address) is stored on CleverReach’s servers in Germany and/or Ireland.
Our newsletters sent with CleverReach enable us to analyse the behaviour of newsletter recipients. Among other things, it can be analysed how many recipients have opened the newsletter message and how often which link in the newsletter was clicked. With the help of so-called conversion tracking it can also be analysed whether a previously defined action (e.g. purchase of a product on this website) has taken place after clicking the link in the newsletter. Further information on data analysis by CleverReach newsletters can be found at:
https://www.cleverreach.com/de/funktionen/reporting-und-tracking/.
Data processing is based on your consent (Article 6(1)(a) GDPR). You may revoke this consent at any time by unsubscribing from the newsletter. The lawfulness of the data processing operations that have already taken place remains unaffected by the revocation.
If you do not want any analysis by CleverReach, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.
The data you have provided to us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe. Data stored by us for other purposes remains unaffected.
After you have unsubscribed from the newsletter distribution list, your email address may be stored in a blacklist by us or the newsletter service provider, provided this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements for newsletter sending (legitimate interest within the meaning of Article 6(1)(f) GDPR). Storage in the blacklist is not time-limited. You can object to the storage if your interests outweigh our legitimate interest.
Further details can be found in CleverReach’s privacy policy at:
https://www.cleverreach.com/de/datenschutz/.
Processing on our behalf
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract required under data protection law to ensure that this provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
YouTube with enhanced privacy mode
This website embeds videos from the YouTube website. The operator of the pages is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in enhanced privacy mode. According to YouTube, this mode means that YouTube does not store information about visitors to this website before they view the video. However, the transfer of data to YouTube partners is not necessarily excluded by the enhanced privacy mode. For example, YouTube establishes a connection to the Google Marketing Network – regardless of whether you watch a video or not.
As soon as you start a YouTube video on this website, a connection to YouTube’s servers is established. This informs the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.
Furthermore, YouTube can store various cookies on your end device after starting a video or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to record video statistics, improve user-friendliness, and prevent fraud attempts.
Additional data processing operations, over which we have no control, may be triggered once a YouTube video has been started.
The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be withdrawn at any time.
Further information on data protection at YouTube can be found in their privacy policy at:
https://policies.google.com/privacy?hl=de.
The company is certified under the “EU–US Data Privacy Framework” (DPF). Further information is available from the provider at:
https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt000000001L5AAI&status=Active
Vimeo without tracking (Do-Not-Track)
This website uses plugins of the video portal Vimeo. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.
When you visit one of our pages equipped with a Vimeo video, a connection to Vimeo’s servers is established. The Vimeo server is thereby informed which of our pages you have visited. Vimeo also obtains your IP address. However, we have configured Vimeo so that Vimeo will not track your user activities and will not set any cookies.
The use of Vimeo is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR; consent may be withdrawn at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here:
https://vimeo.com/privacy.
Further information on the handling of user data can be found in Vimeo’s privacy policy:
https://vimeo.com/privacy.
Google Maps
This site uses the Google Maps map service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To use the functions of Google Maps, it is necessary to store your IP address. This information is generally transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
When Google Maps is activated, Google may use Google Fonts for the uniform display of fonts. When you call up Google Maps, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.
The use of Google Maps is in the interest of an appealing presentation of our online offers and easy location of the places indicated by us on the website. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be withdrawn at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://privacy.google.com/businesses/gdprcontrollerterms/
and
https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.
More information on the handling of user data can be found in Google’s privacy policy:
https://policies.google.com/privacy?hl=de.
The company is certified under the “EU–US Data Privacy Framework” (DPF). Further information is available from the provider at:
Part 3 >br>Privacy information on our social media presences
This privacy policy applies to the following social media presences:
https://www.facebook.com/Bewotec01/
https://www.facebook.com/groups/myJack/
https://vimeo.com/user49349155
https://www.youtube.com/@bewotec
https://de.linkedin.com/company/bewotec-gmbh
Data processing by social networks
We maintain publicly accessible profiles in social networks. The social networks we use in detail are listed below.
Social networks such as Facebook, Twitter, etc. are generally able to comprehensively analyse your user behaviour when you visit their website or a website with integrated social media content (e.g. like buttons or advertising banners). Visiting our social media presences triggers numerous data protection-relevant processing operations.
In detail: If you are logged into your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. Your personal data may also be collected even if you are not logged in or do not have an account with the respective social media portal. In this case, data collection takes place, for example, via cookies that are stored on your end device or by collecting your IP address.
With the help of the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you inside and outside the respective social media presence. If you have an account with the respective social network, interest-based advertising can be displayed on all devices on which you are or were logged in.
Please also note that we cannot track all processing operations on the social media portals. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and privacy policies of the respective social media portals.
Legal basis
Our social media presences are intended to ensure the widest possible presence on the internet. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which are to be specified by the operators of the social networks (e.g. consent within the meaning of Article 6(1)(a) GDPR).
Controller and assertion of rights
If you visit one of our social media presences (e.g. Facebook), we and the operator of the social media platform are jointly responsible for the data processing operations triggered by this visit. You can generally assert your rights (access, rectification, erasure, restriction of processing, data portability, and complaint) both against us and against the operator of the respective social media portal (e.g. against Facebook).
Please note that, despite the joint responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are largely determined by the corporate policy of the respective provider.
Storage period
The data collected directly by us via the social media presence will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory provisions – in particular retention periods – remain unaffected.
We have no influence on the storage period of your data that is stored by the operators of the social networks for their own purposes. For details on this, please contact the operators of the social networks directly (e.g. in their privacy policies, see below).
Your rights
You have the right at any time, free of charge, to obtain information about the origin, recipient and purpose of your stored personal data. You also have the right to object, the right to data portability, and the right to lodge a complaint with the competent supervisory authority. Furthermore, you can request the rectification, blocking, erasure, and, under certain circumstances, restriction of the processing of your personal data.
Individual social networks
We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”). According to Meta, the data collected is also transferred to the USA and other third countries.
We have concluded an agreement on joint processing (Controller Addendum) with Meta. This agreement specifies which data processing operations we or Meta are responsible for when you visit our Facebook page. You can view this agreement at the following link:
https://www.facebook.com/legal/terms/page_controller_addendum.
You can adjust your advertising settings independently in your user account. To do so, click on the following link and log in:
https://www.facebook.com/settings?tab=ads.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum
and https://de-de.facebook.com/help/566994660333381.
For details, please refer to Facebook’s privacy policy:
https://www.facebook.com/about/privacy/.
We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://help.instagram.com/519522125107875
and
https://de-de.facebook.com/help/566994660333381.
For details on how they handle your personal data, please refer to Instagram’s privacy policy:
https://help.instagram.com/519522125107875.
We have a profile on XING. The provider is New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany. For details on how they handle your personal data, please refer to XING’s privacy policy:
https://privacy.xing.com/de/datenschutzerklaerung.
We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.
If you wish to deactivate LinkedIn advertising cookies, please use the following link:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.linkedin.com/legal/l/dpa
and
https://www.linkedin.com/legal/l/eu-sccs.
For details on how they handle your personal data, please refer to LinkedIn’s privacy policy:
https://www.linkedin.com/legal/privacy-policy.
Vimeo
We have a profile on Vimeo. The provider is Vimeo, Inc., 555 West 18th Street, New York, NY 10011, USA. Data transfer to the USA is based on the standard contractual clauses of the EU Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here:
https://vimeo.com/privacy.
For details on how they handle your personal data, please refer to Vimeo’s privacy policy:
https://vimeo.com/privacy.
YouTube
We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For details on how they handle your personal data, please refer to YouTube’s privacy policy:
https://policies.google.com/privacy?hl=de