Data Policy

1. An overview of data protection
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General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in thisPrivacy Policy.

How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form. Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system,or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right todemand that the processing of your data be restricted under certain circumstances. Furthermore, you havethe right to log a complaint with the competent supervising agency. Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.
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Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs. For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting
We are hosting the content of our website at the following provider: Webflow
The provider is the Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter referred to as “Webflow”). When you visit our website, Webflow records various log files, including your IP 4 / 13address. Webflow is a tool for the creation and hosting of websites. Webflow stores cookies or other recognition technologies that are required for the depiction of the site, for the provision of certain website functions andto guarantee its security (necessary cookies). For details, please consult the data privacy policy of Webflow: https://webflow.com/legal/eu-privacy-policy.
We use Webflow on the basis of Art.6(1)(f) GDPR. We have a legitimate interest in ensuring that our website is depicted as reliable as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaningof the TTDSG. This consent can be revoked at any time.The transfer of data to the United States is based on the standard contract clauses of the EU Commission.For details, please go to:https://webflow.com/legal/eu-privacy-policy.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with Europeandata protection standards for data processing in the US. Every company certified under the DPF is obliged tocomply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt0000000TT9jAAG&status=Active

Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is acontract mandated by data privacy laws that guarantees that they process personal data of our websitevisitors only based on our instructions and in compliance with the GDPR.

3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
DREWSEN SPEZIALPAPIERE GmbH & Co. KG
Georg-Drewsen-Weg 2D-29331 Lachendorf
Phone: +49 5145 88-0
E-mail: info@drewsen.com
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The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR orArt. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art.49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG. Theconsent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR.Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art.6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Designation of a data protection officer
We have appointed a data protection officer.
Rainer Brammer
E-mail: Rainer.Brammer@drewsen.com
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Information on the data transfer to third-party countries that are not secure under data protection law and the transfer to US companies that are not DPF-certified
We use, among other technologies, tools from companies located in third-party countries that are not safe under data protection law, as well as US tools whose providers are not certified under the EU-US DataPrivacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and processed in these countries. We would like you to note that no level of data protection comparable to that in the EU can be guaranteed in third countries that are insecure in terms of data protection law.We would like to point out that the US, as a secure third-party country, generally has a level of data protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances.Information on transfers to third-party countries, including the data recipients, can be found in this Privacy Policy.

Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g.,disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f)GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can alsorevoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WEWILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA,THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FORTHE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES(OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at anytime.

Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving –may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

4. Recording of data on this website

Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session(session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your deviceuntil you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued 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 into websites (e.g.,cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis ofthe consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time.You have the option to set up your browser in such a manner that you will be notified any time cookies areplaced and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookieswhen the browser closes. If cookies are deactivated, the functions of this website may be limited.Which cookies and services are used on this website can be found in this privacy policy.

Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time. The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Typeform
We have integrated Typeform on this website. The provider is TYPEFORM S.L., Carrer Bac de Roda, 163,08018 Barcelona, Spain (hereinafter “Typeform”). Typeform enables us to create online forms and integrate them into our website. The data you enter in our Typeform forms is stored on Typeform’s servers until you ask us to delete it, revoke any consent you have given to store it, or the purpose for storing the data no longer applies (e.g., after we have finished processing your request). Mandatory legal provisions – in particular, retention periods – remain unaffected by this.The use of Typeform is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in functioning online forms. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies orthe access to information in the user’s end device (e.g., device fingerprinting) within the meaning of theTTDSG. This consent can be revoked at any time.

5. Social media
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LinkedIn
This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company,Wilton Plaza, Wilton Place, Dublin 2, Ireland.Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use byLinkedIn.If your approval (consent) has been obtained the use of the above mentioned service shall occur on the basis of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the EuropeanCommission. Details can be found here:https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-dem-ewr-und-derschweiz?lang=en. For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at:https://www.linkedin.com/legal/privacy-policy.

6. Analysis tools and advertising

Fathom Analytics
We have integrated Fathom Analytics into this website. The provider is Conva Ventures Inc., BOX 37058 Millstream PO Victoria, British Columbia, V9B 0E8, Canada.Fathom Analytics enables us to analyze the usage patterns of visitors to our website. For this purpose, the IP address and the user agent is promptly anonymized after this information is recorded as the result of the generation of an individual hash. The hash value is archived for 48 hours at Hetzner in Germany. It is impossible to decode this hash. Fathom Analytics does not use any cookies and does not store any data that can be used to track or log visitors. According to the information provided by Fathom Analytics, all data generated within the EU is retained on servers within the EU. Our company uses Fathom Analytics on the basis of Art. 6 (1)(f) GDPR. The website operator has a legitimate interest in the anonymized analysis of user patterns, along with an interest in optimizing the operator’s web offerings. If a pertinent declaration of consent has been requested, processing shall occur exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TTDSG if such consent includes the storage of cookies or the granting of consent for access to information on the user’s device (e.g., device fingerprinting) as defined in the TTDSG. Any such consent may be revoked at any time.

LinkedIn Insight Tag
This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland UnlimitedCompany, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Data processing by LinkedIn Insight tag
We use the LinkedIn Insight tag to obtain information about visitors to our website. Once a website visitor is 10 / 13registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience. We can also use LinkedIn Insight tags to measure whether visitors to our websites make a purchase or perform other actions (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of the advertising addressee takes place.LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days. The data collected by LinkedIn cannot be assigned by us as a website operator to specific individuals. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own promotional activities. For details, please see LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy#choices-oblig.

Legal basis
If your approval (consent) has been obtained the use of the above mentioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in effective advertising promotions that include the utilization of social media. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

Objection to the use of LinkedIn Insight Tag
You can object to LinkedIn’s analysis of user behavior and targeted advertising at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.In addition, LinkedIn members can control the use of their personal information for promotional purposes in the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.

7. Newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below.

MailerLite
This website uses MailerLite to send newsletters. The provider is MailerLite Limited , “MailerLite”, 38 MountStreet Upper, Dublin 2, D02PR89 Ireland (hereinafter „MailerLite“). MailerLite is a service that, among other things, can be used to organize and analyze the sending of newsletters. The data you enter to subscribe to the newsletter is stored on MailerLite’s servers. If you do not want MailerLite to analyze your data, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.
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Data analysis by MailerLite
MailerLite enables us to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened, and which links were clicked on, if any. In this way we can determine which links were clicked on particularly often. We can also see whether certain previously defined actions were carried out after opening/clicking(conversion rate). For example, we can see whether you have made a purchase after clicking on the newsletter. MailerLite also enables us to divide the newsletter recipients into different categories (“clustering”). The newsletter recipients can be divided according to age, gender, or place of residence, for example. In this way, the newsletters can be better adapted to the respective target groups. Detailed information on the functions of MailerLite can be found at the following link: https://www.mailerlite.com/features. The MailerLite privacy policy can be found at: https://www.mailerlite.com/legal/privacy-policy.

Legal basis
Data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time for the future.Storage periodThe data you provide us with 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 deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. Were serve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR. This does not affect data stored by us for other purposes.After you have been removed from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action 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 compliance with the legal requirements when sending newsletters(legitimate interest in the sense of Art. 6(1)(f) GDPR). There is no time limit on storage in the blacklist. You can object to the storage if your interests outweigh our legitimate interest.

Source: https://www.e-recht24.de