DATA PRIVACY STATEMENT

Preamble

STABILO International GmbH (in the following: STABILO) is firmly committed to data privacy. Therefore, as a matter of course, we strictly adhere to the legal regulations concerning the protection of data privacy (in particular those in GDPR (General Data Protection Regulation), BDSG [German Data Protection Act] and TMG [German Telemedia Act]) and will do everything possible to ensure the privacy of your data. In addition, it is important for us that you know at any given time which data we store and how we use them. Please take a moment to read the following text informing you about the way we deal with your data. We reserve the right to revise the content of this data privacy statement from time to time, in particular to adapt it to new legal stipulations and technical development so that we can also safeguard data protection in the future. It is therefore advisable to regularly take note of our information and remarks concerning data processing. This Data Privacy Statement is applicable to STABILO’s internet presence under the domain: www.stabilo.com/com, as well as other country STABILO websites (in the following: “Website”). 

1. Responsible person and scope 

 The responsible person is: STABILO International GmbH, Schwanweg 1 – 90562 Heroldsberg, Germany (hereinafter “STABILO”). 

2. Data Protection Officer 

Our Data Protection Officer is: Mr. Sebastian Meyer, Schwanweg 1 – 90562 Heroldsberg, Germany. Please refer to our Data Protection Officer if you have any questions regarding data protection issues at our company. You can reach him under the email-address: Datenschutz@schwan-stabilo.com . 

3. General Principles on data processing 

We collect and use personal data from our users basically only then, when this is necessary to provide a functional Website as well as to deliver our content and services. 

3.1. Personal data 

Personal data is all information relating to an identified or identifiable natural person. This includes, for example, information such as your name, email-address, address, date of birth or your phone number. Non-personal data is ex. data regarding the number of users at a website. 

3.2. Processing of personal data 

Processing of personal data is any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. We process personal data through our Website only if you provide us with this data, ex. when filling out our contact form or sending us an email. We process this data for the named purposes or for the purposes defined in your request. We do not disclose your personal data to third parties, unless otherwise provided by law or you have given us your consent thereto. Apart from that you may use the general information at www.stabilo.com/com without revealing your personal data. In particular we process your personal data as provided: 

3.2.1. Contact form 

On our Website, we offer you to contact us via a contact form provided by us. Basically, to answer your question or request, we will need you to provide us with the following data: your email-address, your country, as well as your first and last name. You may freely decide, whether you want to provide this information. Without this information we will however not be able to answer your question or reply to your request. The purpose of specifying this data is to assign your question or request and to be able to reply to you. As soon as your question or request has been answered or completed, your personal data will be deleted. Any further storage may however take place, if storage is required by law. The data processing described above is carried out in accordance with article 6 (1) lit. b and article 6 (1) lit. f GDPR. 

3.2.2. Job applications 

If you are interested in our job offer, you can use our application form or send us your application per email at: jobs.de@stabilo.com or per letter to our postal address. We assure you, that we will process your personal data only for the purposes of carrying out the job application process. Your personal data will be stored for 6 months after concluding the job application process. The legal basis for the data processing described above is carried out, in in case of a job application via our application form – article 6 sec. 1 (a) GDPR (consent of the data subject to processing personal data), and in case of a job application via email or letter - article 6 1 (b) GDPR (processing is necessary in order to take steps at the request of the data subject prior to entering into a contract). 

3.3. Legal basis 

Collecting and processing your personal data takes generally place upon your consent. Should the data processing be based on your consent, the legal basis for this data processing is Article 6 (1) lit. a GDPR. An exception may occur when obtaining a consent is not possible and/or this is permitted by law. If processing your data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, the legal basis for this data processing is Article 6 (1) lit. b GDPR. If processing your personal data is necessary for compliance with a legal obligation to which we as the controller are subject, the legal basis for this data processing is Article 6 (1) lit. c GDPR. If processing your personal data is necessary for the purposes of legitimate interests pursued by us, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, the legal basis for this data processing is Article 6 (1) lit. f GDPR. 

4. Cookies Below we describe the processing operations connected with usage of cookies, sessions and logfiles.

4.1. Usage of cookies, sessions and logfiles 

A cookie is a small text file stored in your browser cache and enables an analysis of your use of our Website and/or ensures the functionality of the Website. Further our partners use cookies in order to evaluate the user behavior for advertising purposes (social targeting). A session is a single session which will be saved on our server for a short period of time. Logfiles are created by the server and stored by us. They contain automatically generated logs of all or specific activities of processes on a computer system. 

4.2. Data collected by cookies 

Except for the IP address, no personal data will be stored in the cookies, sessions and logfiles. Furthermore, these files cannot transfer viruses, spy on your computer, or send emails undetected. In addition, each webserver can only read out those cookies it placed itself. The following data is automatically collected via cookies, sessions and logfiles when you call up our Website: 

• Your internet address (IP address) / host name 
• Agent/browser type and version 
• Website you were referred from (referrer URL) 
• Operating system used 
• Website that transfers you to other websites 
• Pages viewed on our Website 
• Date and time of access 
• Session
• Session ID 

This data is stored separately from any data you provided to us for registration as a user and is not linked with other personal data. The data processed according to 4.2. is processed for statistical purposes, in order to optimise our Website and our offer. For more information about cookies please read our Cookie-Policy. 

4.3. Prevention of cookies 

If you object to the use of cookies, sessions and logfiles, you can block or restrict their usage by settings in our Cookie-Policy or in your browser settings. However, it is very much possible, that in this case you might not be able to use individual functions on our webpages. The following third-party Cookies are used on our website: 

4.4. Google Analytics 

This Website uses Google Analytics, a web analysis service from Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google Analytics uses Cookies, small text files stored on your computer, to make it possible to analyze your use of our Website. Information about your use of our Website generated by cookies, ex. time, place and frequency of use of the Website, is usually transferred to a Google server in the USA and saved there. When using Google Analytics, it may not be excluded, that apart from the IP address Google processes further personal data. Please be informed that such information may be transferred by Google to third parties, if this is required by law or if Google contracts third parties to process such data. Google will use the information gathered by the cookies to evaluate your use of the Website in order to compile reports about Website activities for us and provide additional services associated with the Website and Internet usage. Only in exceptional cases, your IP-address will be transferred to a Google server in the USA and will be shortened there. IP-anonymization is activated on this website. By the website´s hosts order, Google will use this information, to evaluate the user’s usage of our Website, to report website-activities and to provide further services connected to the usage of the website and the internet for the website´s host. According to Google, Google will not associate your IP address with other personal data collected by Google. Data, connected with Cookies, User-ID or advertising-ID sent by us, will be automatically deleted after 14 months. The deletion of data that has reached this storage period will be done automatically once a month. More information about Google data usage for advertising reasons can be found on Google Website https://www.google.com/intl/de/policies/privacy/partners/; (“Data used visiting websites and Apps by Google”); https://www.google.com/policies/technologies/ads (Managing Information Google uses for fading in advertising) and https://www.google.com/ads/preferences/ (defining which advertise you are shown by Google. 

4.5. Google Remarketing 

This website uses Google Remarketing technologies, a google service. Advertisement can be presented within the google-advertising-network based on content, viewed by website visitors within this google-advertising-network. Particularly we use Google Remarketing, to show you advertisements based on former usage of this website, when visiting other websites, for example websites joining the Google-Content-network. You can deactivate this function by choosing the appropriate settings at https://www.google.com/settings/ads. Google-Account users may control their experienced advertisement by objecting personal advertisements in their account settings. Further information about data use for advertisement reasons by Google can be found on the Google Website: https://www.google.com/intl/de/policies/privacy/partners/ („data use by Google based on your usage of websites or apps of our partners”); https://www.google.com/policies/technologies/ads („managing information google uses to show advertisement “) und https://www.google.com/ads/preferences/ („decide which advertisement is shown by google”). 

4.6. Facebook Pixel 

This Website uses the Facebook Pixel from „Facebook“ (Facebook Inc., 1601 S. California Ave, Palo Alto, California 94304, USA). Facebook displays ads to users who have visited our websites and online services and are interested in a specific offer. Through the Facebook Pixel on our Website a direct connection to the servers of Facebook take place. Facebook uses cookies for this analysis. Facebook receives the information, that you have visited our website and assigns this information to your personal Facebook account. We have no influence on the scope and type of information including your personal data, which is transmitted to Facebook. For more information regarding your rights and possibilities to protect your data, please visit the Facebook Privacy policy at: https://www.facebook.com/about/privacy/. We alone do not transfer this data to Facebook. For more information about data protection rights and appropriate settings to protect your privacy please visit: https://www.facebook.com/policy.php, https://www.facebook.com/help/186325668085084 . 

4.7. Legal Basis 

In case of Cookies, technically needed for a functioning website, the legal basis for this data processing is Article 6 (1) lit. f GDPR (a company´s legitimate interest). In case of marketing, tracking and analyzing Cookies the legal basis for the data processing is Art. 6 (1) lit. a GDPR (consent). 

4.8. Facebook, Instagram, YouTube, LinkedIn, XING, TikTok and Twitter fan pages 

We host fan pages on social media platforms Facebook, YouTube, LinkedIn, XING and Twitter. Responsible persons as written in Art. 4 Nr. 7 GDPR are we as hosts of these fan pages and the network provider. When visiting our fan pages the persons in charge process your personal data. We as responsible person have made agreements with the providers to regulate amongst others the terms of use. These data privacy statements are uploaded on the concerned website, where you can find further information. Upon closing your browser, the session-cookies are deleted, other cookies after one year. Cookies from our Partners, e.g. Google (4.4.) are deleted maximally after 24 months. You can deactivate the usage of cookies by Google by means of visiting the deactivating site of Google. Alternatively, you may deactivate the usage of third party cookies by means of visiting the deactivating site of the network initiative. 

5. Data security and precautionary measures 

We are committed to protecting your privacy and treating your personal data confidential. In order to avoid any manipulation, loss or misuse of your data stored by us, we take extensive technical and organisational security measures that are regularly reviewed and adapted to technological progress. Intensive training of our employees and their obligation to data security ensure that your personal data is treated confidential. 

5.1. Responsibility of the User 

We urge you to also take all possible measures to protect your data while working on the internet. Due to the structure of the internet, it is not possible for us to ensure that third parties, which are not within the scope of our responsibility, adapt identical privacy and security measures. Possibly if personal data is not encrypted or is sent per email it may be seen or read by third parties. Hereto we have no impact. It is the responsibility of the user, to secure his/her data via encryption or by other means. 

5.2. Encryption 

We use the SSL (Secure Sockets Layer) to encrypt your data on all Websites which require providing personal data. SSL encryption masks your data before transmitting it to our server, in such a manner that it cannot be reconstructed by third parties. This safeguards the privacy of your personal data. 

5.3. Technical security measures at STABILO: 

• Encryption of sensitive data transfer with SSL certificates by PX-PRO Hosting GmbH, Erkrather Straße 310, 40231 Düsseldorf
• Server security: a firewall system protects our servers against attacks. 
• An internal security system and authorisation concept make sure that your sensitive data is not accessible to our employees unless they have a special authorisation. 

6. Service providers for processing personal data 

We employ service providers, who process personal data on our behalf and only on our instruction. The service providers are required to comply with all data protection regulations and to process data in accordance with our instructions. Our service providers have been carefully selected and receive access to your personal data only to the extent and for the time necessary to carry out their services. Service providers in third countries such as the USA and countries outside the European Economic Area are subject to data protection regulations, which do not protect personal data to the same extent as in the European Union. Should we process your personal data in countries, which do not provide such a high level of data privacy as in the European Union, then we will ensure by means of contractual regulations and other instruments that your personal data is safe and adequately protected. 

7. Storage period 

Your data will be stored only for the period of time required by law. Your data will be erased, when you have withdrawn your consent for processing your data or the purposes of processing your data have been obtained or when the processing is no longer legitimate for any legal reasons. Any retention periods required by law shall remain unaffected. During the statutory retention periods your data will not be processed for other purposes. 

8. Rights concerned 

From the GDPR, the following rights arise for you as an affected person for the processing of your personal data: 

8.1. Right of access 

According to art. 15 GDPR, you can request information about your personal data processed by us. In particular, you may request information on the source of the data, the recipients of this data or categories of recipients, as well as the processing purposes. 

8.2. Right of objection 

If the processing of personal data is based on your consent, you may object to this processing for the future, at any time and without any reason. To do so please send an email at: info@stabilo.com or a letter at: STABILO International GmbH, Schwanweg 1 – 90562 Heroldsberg, Germany. 

8.3. Right to rectification 

In accordance with art. 16 GDPR, you can immediately request the rectification of incorrect or the completion of your personal data stored by us. 

8.4. Right to erasure or restriction 

In accordance with art. 17 GDPR, you may request the deletion of your personal data stored by us. The personal data will be deleted within 7 working days from your request. Any retention periods required by law shall remain unaffected. If your data may not be deleted due to retention periods, only a restriction of processing may be applied. Upon deleting your data, no access right may be granted. 

8.5. Right to data portability 

According to art. 20 GDPR, you may request to receive your personal data that you have provided to us in a structured, common, and machine-read format, or you may request the transfer to another responsible person, insofar this is possible to due technical means. 

8.6. Right of revocation 

In accordance with art. 7 (3) GDPR, you can revoke your once given consent to us at any time. As a result, we are not allowed to continue the data processing based on this consent for the future. In such an event you may not access our company's online services to full extent. 

8.7. Exercising the rights concerned 

To exercise the aforementioned rights, please contact us at: info@stabilo.com or: STABILO International GmbH, Schwanweg 1 – 90562 Heroldsberg, Germany. Your personal data (possibly your email, name and telephone number) will be processed in order to answer your questions or respond to your concern. This data will be deleted if no longer necessary; in the event of statutory retention periods – the processing may only be limited. 9. Complaint to a supervisory authority According to art. 77 GDPR, you have the right to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of stay, your workplace or our company headquarters. 

Revised March 2022