Below, we would like to inform you, pursuant to Art. 13 GDPR, about how your “personal data” are processed. Personal data, pursuant to Art. 4 GDPR, 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;
1. Party responsible for data processing (“Controller”)
LUBRIX GmbH, represented by its General Manager
Am Hegelesberg 6
73230 Kirchheim Teck
Phone: +49 7021 4829 000
Fax: +49 7021 720 950
2. Nature and purpose of data processing
a) Visits to our website
When you visit our website, information used by the browser on your end device is automatically transmitted to our website’s server. This information is stored temporarily in a so-called log file.
At the same time, the following information is recorded without any activity on your part and stored until such times as it is erased automatically:
- IP address of the computer sending the request;
- date and time of access;
- name and URL of the retrieved file;
- website from where the access is made (referrer URL);
- browser used and,
- where applicable, the computer’s operating system; as well as
- the name of your access provider.
We process the aforementioned data for the following purposes:
- to ensure that the connection to the website is smooth;
- to ensure that our website is convenient to use;
- to evaluate system security and stability; and
- for other administrative purposes.
The legal basis for the processing of data is Art. 6, Para. 1, Point (f) GDPR. Our legitimate interest follows from the data collection purposes mentioned above. Under no circumstances will we use the collected data for the purpose of making inferences about your identity.
Our website cookies, as well as analytics services, are used when you visit our website. Further details can be found under Items 4 and 5 of this Privacy Notice.
b) Contact via e-mail
You are welcome to contact us by e-mail, though we wish to point out that all communication via this channel is insecure as it occurs via unencrypted e-mail. It is comparable to sending someone a postcard. Confidential information should never be transmitted by unencrypted e-mail. Your e-mail and your e-mail address are saved to our e-mail program. No data are forwarded to third parties in this process. The data are solely used for the purpose of processing the conversation.
The legal basis for processing data is the user’s consent, pursuant to Art. 6, Para. 1, Point (a) GDPR, and/or the existence of a agreement.
The legal basis for processing data that are transmitted by e-mail is Art. 6, Para. 1, Point (f) GDPR. If the purpose of any contact by e-mail is to conclude a contract, the legal basis for processing data will also include Art. 6, Para. 1, Point (b) GDPR.
The processing of data from your e-mail is solely for the purpose of processing the e-mail itself.
We erase data as soon as they cease to be required in order to fulfil the purpose for which they are collected. With respect to personal data transmitted by e-mail, this is the case when the relevant conversation with the user has come to an end. The conversation is deemed to have ended when circumstances indicate that the matter in question has been resolved once and for all.
The user may, at any time, withdraw their consent for personal data to be processed. Should the user contact us by e-mail, they may, at any given time, withdraw their consent to their personal data being stored. In such instances, the conversation will be discontinued as of that point.
To exercise your right of withdrawal, simply send an e-mail to the address shown above.
All personal data stored in connection with your contact with us will then be erased.
c) Contact by phone
You can reach us by phone at the number shown on the website. In this case, we will only note down your phone number if this is necessary in order for you to continue using our services. This could be to agree on an appointment for initial talks, for example, during which you will be informed about how we process data.
3. Forwarding of data
Your personal data will only be forwarded in the event that:
- this becomes necessary in order to fulfil the conditions of a contract with you;
- we are required by law to do so;
- you have given your express consent for data to be forwarded;
- data need to be forwarded in order to establish, exercise or defend against legal claims and there are no grounds to assume that you have an overriding interest worth protecting in your data not being forwarded.
Under no circumstances will we forward your data to third parties for advertising purposes without first asking you or without first obtaining your consent.
A cookie stores information that is generated in connection with the end device used in each specific instance.
Session cookies are used to enhance your visit to our website as they detect which pages your browser has already visited. Session cookies are erased automatically when you end your browser session.
We also employ temporary cookies to make our website more user-friendly, by saving you time when re-entering data, for example.
Cookies are also used to create statistical records on how our website is being used and to evaluate the recorded data in order to optimise what we offer there. These cookies enable us to detect automatically that you have previously visited our website. These cookies are erased automatically after a defined period of time.
The legal basis for processing data using cookies pursuant to Art. 6, Para. 1, Point (f) GDPR is our legitimate interest in achieving the aforementioned purposes.
The majority of browsers accept cookies automatically.
However, you may also configure your browser so that cookies are never saved to your computer or you are always notified before a cookie is created. Fully disabling cookies may, however, result in you not being able to enjoy all of the features available on our website.
5. Google Maps
We use Google Maps on our Contact page to make it easier for you to find your way to us. The legal basis for this is our legitimate interest as defined in Art. 6, Para. 1, Point (f) GDPR. Google Maps is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use Google Maps, you will need to transmit your IP address to Google in the USA, where it will be stored.
6. Rights of the data subject
You have the right:
- pursuant to Art. 15 GDPR, to request information, free of charge, as to what personal information we process in your specific case. In particular, you have the right to obtain access to information concerning the purposes of the processing; the categories of personal data concerned; the categories of recipient to whom the personal data have been or will be disclosed and the envisaged period for which the personal data will be stored. You also have the right to request the rectification or erasure of personal data or the restriction of processing of personal data concerning you or to object to such processing; the right to lodge a complaint; where the personal data are not collected by us, the right to obtain information as to the source of the data and whether automated decision-making is employed, including profiling, and, where applicable, to meaningful information about the details concerned;
- pursuant to Art. 16 GDPR, to require, without delay, that incorrect personal data stored by us be rectified or incomplete personal data stored by us be completed;
- pursuant to Art. 17 GDPR, to obtain the erasure of personal data saved by us concerning you provided that the processing is not required for exercising the right of freedom of expression and information; for compliance with a legal obligation; for reasons of public interest; or for the establishment, exercise or defence of legal claims.
- pursuant to Art. 18 GDPR, to obtain from us the restriction of processing of your personal data if and to the extent that the accuracy of the personal data is contested by you, the processing is unlawful but you oppose the erasure of the personal data, and we no longer need data but you require them for the establishment, exercise or defence of legal claims; or you have objected to the processing pursuant to Art. 21 GDPR;
- pursuant to Art. 20 GDPR, to require that we make your personal data available to you in a structured, commonly used and machine-readable format or transmit such data to another controller;
- pursuant to Art. 7, Para. 3 GDPR, to withdraw, at any time, any consent that you may have initially granted. This will result in our ceasing, in the future, the data processing for which you gave us your consent.
- pursuant to Art. 77 GDPR, to lodge a complaint with the supervisory authority. As a rule, you may contact the supervisory authority responsible for your habitual residence or place of work, or for our registered office.
5. Analytics tracking tools
The tracking methods listed below and used by us are performed on the basis of Art. 6, Para. 1, Sent. 1, Point (f) GDPR. By using these tracking methods, we strive to ensure that our website is tailored to the needs of our users and is continuously optimised.
We also deploy tracking methods to create statistical records on how our website is being used and to evaluate the recorded data in order to optimise what we offer there. These interests are deemed justified within the meaning of the aforementioned specifications.
The individual data processing purposes and data categories are as specified in the corresponding tracking tools.
6. Google Analytics
To tailor our website to the needs of our users and continuously optimise it, we use Google Analytics, a web analytics service provided by Google Inc. (https://about.google/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter referred to as “Google”). In this process, pseudonymised user profiles are created and cookies (see Item 4) used. The information generated by the cookie concerning how you use this website, such as
- browser type/version;
- operating system;
- referrer URL (the website visited prior to this one);
- hostname of the computer accessing this website (IP address);
- time of server request;
is transmitted to a Google server in the USA and saved there. The information is used to analyse how the website is being used, to compile reports on website activity, and to provide additional services related to website and Internet use for market research purposes and in order to tailor the design of the website to specific needs.
The information may also be transmitted to third parties if this is required by law or third parties process such data on our behalf. Under no circumstances will your IP address be merged with other Google data. IP addresses are anonymised to eliminate any form of association (IP masking).
You can prevent cookies from being installed by changing the corresponding settings in your browser software, though we wish to point out that such changes may result in you not being able to enjoy all of the features of our website.
You can also prevent Google from collecting and processing the data generated by the cookie and relating to your use of the website (including your IP address) by downloading and installing an opt-out browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).
Further information on safeguarding your data in connection with Google Analytics can be found in the Google Analytics Help Center, for example, at: (https://support.google.com/analytics/answer/6004245?hl=en).
7. Right to object
You have the right, pursuant to Art. 21 GDPR, to object to your personal data being processed, when these are processed on the basis of our legitimate interests pursuant to Art. 6, Para. 1, Sent. 1, Point (f) GDPR, if there are grounds supporting your particular case.
Your right to object to direct advertising always applies.
To make use of this right, all you need to do is send us an e-mail.
8. Data security
We have implemented technical and organisational security measures in order to protect your data, especially against unauthorised third-party access. We also continuously strive to improve our security measures.
Data exchanges between the visitor/user via our website are encrypted using the SSL (Secure Socket Layer) system, which is set to the highest level of encryption supported by your browser. This is typically 256-bit or, alternatively, 128-bit encryption.
9. Privacy notice status
Last revised: June 2019.
Stefan Jönsson (lawyer), www.joensson.de