1. Processing of Your Personal Data within the SCHMOLZ + BICKENBACH Group
1.1. The protection of your privacy during the processing of your personal data and the security of business data are very important to us. Controller regarding the processing of your personal data is
Deutsche Edelstahlwerke Specialty Steel GmbH & Co. KG
58452 Witten, Deutschland
(in the following "Controller").
1.2. The Controller is member of the SCHMOLZ + BICKENBACH Group (in the following „SCHMOLZ + BICKENBACH“), which includes group companies in 40 countries worldwide.
2. Type and Origin of Data Processed by the Controller
2.1. We process your personal data. "Processing" for example means that we collect, store (see 6.), delete (see 6.) or transmit (see 4.) your personal data.
2.2. The data processed by us include:
- Your name and professional contact data.
- The products and services in which you expressed your interest to us or (if your company is an existing customer) which you have already ordered.
- Your preferred communication channels.
- Your statements during visits (discussed business units, your customer satisfaction, comments).
We receive these personal data directly from you, e.g. via the consent form used by us, by post, by e-mail or personally, for example at a trade fair, during a visit or a telephone call. You are not obliged to provide your personal data to us. Without providing your contact information and your interests, however, we cannot contact you with regard to your interests.
2.3. In addition, we process your following personal data:
Data about the business relationship with you, such as
- Your status (active/inactive).
- Activities in which you were involved (e.g. communication by e-mail, telephone or visits).
- Attachments which were uploaded to you (e.g. your consent).
- Target group to which you belong (e.g. for trade fair invitations).
- Your relationship with our business partners (assignment of your individual contact person).
We do not receive these personal data directly from you, but it is entered into our systems by our employees. Our employees receive such information from personal communications with you from the sources listed under 2.2.
2.4. We also receive your personal data mentioned under 2.2. and 2.3. for the purposes mentioned under 3 from those SCHMOLZ + BICKENBACH companies,
- To whom you have provided your consent to the transmission, or
- Whose customer your company is, as soon as your company has also become our customer.
This transfer to us will only take place under the conditions mentioned in 4.2.
2.5. If you receive an e-mail from us for direct marketing purposes, we will, in addition to your professional e-mail address, process the following personal data from you to remind you of this e-Mail if you do not open it:
- Delivery time, and
- Retrieval time.
These personal data are collected by our system on which the e-mail is stored for retrieval.
3. Purpose and Legal Basis of the Processing by SCHMOLZ + BICKENBACH
3.1. We process your personal data only for permissible purposes and in accordance with the applicable statutory provisions of the General Data Protection Regulation ("GDPR") and the applicable national data protection laws.
3.2. If you have given us your consent, we process your personal data in accordance with Article 6 Paragraph 1 Sentence 1 a) GDPR for direct marketing purposes. You may withdraw your consent at any time. Please note, however, that the data processing remains permissible until the moment of your withdrawal.
3.3. We also process your personal data without your consent on the basis of Article 6 Paragraph 1 Sentence 1 f) GDPR, insofar as this is permissible after balancing your interests to pursue the legitimate interests of SCHMOLZ + BICKENBACH and its group companies. You may object this data processing at any time with effect for the future. This includes the necessary data processing for the purpose of exercising, asserting or defending legal claims, as well as internal administrative purposes (e.g. intra-group analysis and agreements on corporate management). This also includes data processing for direct marketing purposes (including customer surveys)
- By post, unless you indicate that you do not wish to receive such advertising.
- By telephone, if special circumstances indicate your presumed consent.
- By e-mail if your e-mail address has been collected in connection with the sale of a product or service, which concerns advertising for similar goods or services and if you have not objected this processing. You may object this processing at any time with effect for the future without incurring any costs other than the transmission costs according to the basic tariffs.
3.4. We are obliged to process certain data in order to comply with our legal obligations. Such obligations may arise from certain provisions of national commercial, tax and social law as well as European legislation, e.g. in connection with regulations to avoid the financing of terrorism. This may result in individual obligations for SCHMOLZ + BICKENBACH to secure, store, report and collect data, which are generally used for control purposes by the respective authorities. This data processing is carried out on the basis of Art. 6 Paragraph 1 c) GDPR.
3.5. If we should process your personal data in the future for a reason other than that for which we originally collected it, we will inform you of this new purpose in advance, insofar as this is legally permissible.
4. Recipients of Your Personal Data
4.1. Within the Controller, which is defined in 1.1, only those persons receive your personal data, who are in charge of you or who control or execute the marketing activities relevant to you (need-to-know principle).
4.2. Under certain circumstances, we transfer your personal data within the Group to the other companies of SCHMOLZ + BICKENBACH. An up-to-date list of these companies can be found at https://www.schmolz-bickenbach.com/en/locations. Your personal data will only be made available to these companies if
- You have provided your consent,
- It is permitted on the basis of a balance of interests which takes your interests into account (e.g. in order to make intra-group administrative decisions), or
- We are legally obliged to do so.
4.3. As regards marketing, we work together with service providers within and/or outside of SCHMOLZ + BICKENBACH. For example, in connection with the operation of the IT infrastructure or service providers who support us, for example, in the distribution of advertising or customer satisfaction surveys. Insofar as we involve service providers, this is always done within the framework of the applicable data protection regulations.
4.4. Moreover, we only transfer personal data to other recipients outside of the SCHMOLZ + BICKENBACH Group if we are legally obliged to do so or if this serves to exercise, assert or distribute legal claims. In such cases, recipients of your data are e.g. authorities, lawyers or courts. In all other cases, we will only transfer your data to other third parties if you have provided your corresponding consent.
5. Date Transfer to Third Countries
We do not transfer your personal data to recipients in countries outside of the EU or the EEA.
6. Storage- and Retention Periods
6.1 We will stop processing your personal data for marketing purposes as soon as,
- You withdraw your consent, or (if we do not process your data on the basis of your consent)
- You object the data processing for the purpose of marketing or
- The further processing is no longer necessary, because According to our knowledge you are no longer employed by the company in whose context we store your data, or Five full calendar years have passed upon the last request or order from your company to a SCHMOLZ + BICKENBACH company, or Five full calendar years have passed upon the collection of your contact data, if there was no request or order from your company to a SCHMOLZ + BICKENBACH company during this period.
6.2 Furthermore, we will process your personal data only to the extent necessary for the purpose of asserting, exercising or defending legal claims, fulfilling our statutory obligations or for internal group administration purposes. For example, your data may be processed for the duration of legal proceedings or for the legally required retention period of commercial letters (six years) or accounting records (ten years). We will no longer process your personal data for group-internal administration purposes as soon as one of the cases mentioned under 6.1 occurs according to which the processing would no longer be necessary for marketing purposes.
7. Automated Decision-Making Including Profiling
We do not use automated decision-making for processes that have legal effects or similarly significant effects for you. No decision is made without further human consideration.
8. Your Rights Concerning Data Protection
8.1. In connection with the processing of personal data by SCHMOLZ + BICKENBACH, all data subjects have the following rights according to Articles 15 to 21 GDPR:
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to restrict processing;
- Right to data portability;
- Right to object.
8.2. In addition, you have the right to withdraw your consent to the processing of your personal data at any time with effect for the future. Such withdrawal has no effect on the past, i.e. it has no influence on the lawfulness of the data processing carried out until the withdrawal. Your withdrawal does not require any special form and can be sent e.g. by e-mail to marketing(at)schmolz-bickenbach.com. Alternatively, you can select the opt-out option in any marketing e-mail you receive from us.
8.3. If you are of the opinion that the processing of personal data by SCHMOLZ + BICKENBACH does not comply with data protection regulations or that you are not satisfied with the information provided by us, you have the right to lodge a complaint with a supervisory authority (see Article 77 GDPR).
9. Information Regarding Your Right to Object
9.1. At any time, you have the right to object certain types of processing of your personal data for reasons arising from your individual situation. This right applies to data processing in the public interest and to data processing to pursuit legitimate interests. This right also applies to profiling insofar as it is based on one of these provisions.
9.2. In case of an objection, we will cease the processing of your personal data. However, this does not apply if we can prove compelling legitimate grounds, which outweigh your interests, rights and freedoms, or if the processing serves the assertion, exercise or defense of legal claims. If you object the processing of your data for purposes of direct marketing, we will nevertheless cease the processing of your personal data for these purposes without further preconditions.
9.3. Your objection does not require any special form and can be sent to us e.g. by e-mail to marketing(at)schmolz-bickenbach.com. Alternatively, you can select the opt-out option in any marketing email you receive from us.