Data privacy is very important to HSP Hochspannungsgeräte GmbH. Our efforts to comply with the requirements of the EU General Data Protection Regulation (GDPR) and the new version of the German Federal Data Protection Act in particular focus primarily on respecting your privacy.
Nowadays, modern companies like HSP Hochspannungsgeräte GmbH cannot avoid using electronic data processing systems (EDP). When using them, we of course do our utmost to observe legal regulations.
As a rule, it is possible to use the HSP Hochspannungsgeräte GmbH website without providing any personal data. However, if a data subject wants to make use of specific services that our company offers via our website, we may need to process personal data. If we do need to process personal data and there is no legal basis for processing it, we always obtain the consent of the data subject.
We never sell or lease your personal information to third parties for marketing or other purposes. If you do not agree to the data privacy provisions, please do not send us any personal data.
1. General information and definitions
This Data Privacy Notice is based on terms used in the GDPR and is intended to be easy for everyone to read and understand. That is why we would like to explain a few terms in advance:
a) Personal data
Personal data 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.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data is processed by the controller for the processing.
c) Processing
Processing means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting its processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
f) Pseudonymization
Pseudonymization means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller
Controller means the natural or legal person, public authority, agency or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
i) Recipient
Recipient means a natural or legal person, public authority, agency or another body to which the personal data is disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent
Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.
2. Information on the collection of personal data
(1) This section contains information on the personal data collected when using our website. Personal data means any data that can be linked to you personally, such as your name, address, email addresses, user behavior, etc.
(2) The controller under Article 4 (7) of the EU General Data Protection Regulation (GDPR) is
HSP Hochspannungsgeräte GmbH
Camp-Spich-Straße 18
53842 Troisdorf, Germany
(3) Our data privacy officer is:
Sascha Weller, Attorney-at-Law, IDR – Institut für Datenschutzrecht
Ziegelbräustraße 7
85049 Ingolstadt, Germany
Phone: +49 (0)841 – 885 167 15
Email: ra-weller@idr-datenschutz.de
Website: https://idr-datenschutz.de (external data privacy officer)
(4) When you contact us by email or via a contact form, we automatically store the data you share (your email address, and possibly your name and telephone number) so that we can answer your questions. This personal data that a data subject voluntarily sends to the controller for the processing is only stored for the purposes of processing or contacting the data subject. We erase the data received in this situation once we no longer need to store it or restrict processing in accordance with relevant legal retention obligations.
(5) If we make use of commissioned service providers for individual functions of our offering or want to use your data for advertising purposes, we will provide detailed information about the relevant operations below. This information will include the criteria that determine the retention period.
(6) As the controller for the processing, we have implemented numerous technical and organizational measures to ensure protection of the personal data processed via this website that is as complete as possible. However, transferring data via the internet is, as a general rule, susceptible to vulnerabilities, meaning that absolute protection cannot be guaranteed. That is why every data subject also has the option of sending personal data to us using alternative methods, such as by telephone.
(7) As a responsible company, we do not use automated decision-making or profiling.
3. Your rights
(1) You have the following rights in relation to the personal data we hold about you:
Right of access:
Every data subject of personal data processing has the right under the GDPR to receive access to the personal data stored about them from the controller for the processing free of charge, and to receive a copy of this data. The EU issuer of directives and regulations has also granted the data subject access to the following information:
- the purposes of the processing
- the categories of personal data concerned
- the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
- the right to lodge a complaint with a supervisory authority
- where the personal data is not collected from the data subject: any available information as to its source
- the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
The data subject also has a right of access to information on whether personal data has been transferred to a third country or to an international organization. If it has, the data subject will additionally have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wants to assert this right of access, they can contact an employee of the controller for the processing at any time.
Right to withdraw consent given under data protection law:
Every data subject of personal data processing has the right to withdraw their consent to the processing of personal data at any time.
If a data subject wants to assert this right to withdraw consent, they can contact an employee of the controller for the processing at any time using any means of communication.
Right to rectification:
The data subject has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wants to assert this right to rectification, they can contact an employee of the controller for the processing at any time.
Right to erasure/right to be forgotten:
The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed
- the data subject withdraws consent on which the processing is based according to point (a) of Article 6 (1), or point (a) of Article 9 (2), and where there is no other legal ground for the processing
- the data subject objects to the processing pursuant to Article 21 (1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2)
- the personal data has been unlawfully processed
- the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject
- the personal data has been collected in relation to the offer of information society services referred to in Article 8 (1)
If a data subject wants to assert this right to erasure/right to be forgotten, they can contact an employee of the controller for the processing at any time.
Where we have made the personal data public and are obligated pursuant to Article 17 (1) GDPR to erase the personal data, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform controllers that are processing the personal data that a data subject has requested the erasure by such controllers of any links to, or copy or replication of, that personal data. Our employees will initiate the necessary steps.
Right to restriction of processing:
The data subject has the right to obtain from the controller restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead
- the controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defense of legal claims
- the data subject has objected to processing pursuant to Article 21 (1) pending the verification of whether the legitimate grounds of the controller override those of the data subject
If a data subject wants to assert this right to restriction of processing, they can contact an employee of the controller for the processing at any time.
Right to object to processing:
Every data subject of personal data processing has the right under the GDPR to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them that is based on point (e) or (f) of Article 6 (1) GDPR. This includes profiling based on those provisions.
In the event of an objection, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Where we process personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data for such marketing. This includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, we will no longer process the personal data for such purposes.
Where we process personal data for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1) GDPR, the data subject, on grounds relating to their particular situation, will also have the right to object to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The data subject can contact any employee directly at any time to exercise their right to object. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.
Right to data portability:
The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and has the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided, where
- the processing is based on consent pursuant to point (a) of Article 6 (1) or point (a) of Article 9 (2) or on a contract pursuant to point (b) of Article 6 (1) and
- the processing is carried out by automated means.
In exercising their right to data portability pursuant to Article 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where the rights and freedoms of others are not adversely affected.
If a data subject wants to assert this right to data portability, they can contact an employee of the controller for the processing at any time.
Automated individual decision-making, including profiling
Every data subject of personal data processing has the right under the GDPR not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, where the decision
- is not necessary for entering into, or performance of, a contract between the data subject and the data controller,
- is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests or
- is based on the data subject’s explicit consent.
Where the decision is necessary for entering into, or performance of, a contract between the data subject and the data controller or where it is based on the data subject’s explicit consent, we will implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
If the data subject wants to assert rights relating to automated decision-making, they can contact an employee of the controller for the processing at any time.
(2) They also have the right to lodge a complaint with a data protection supervisory authority about our processing of their personal data. The supervisory authority responsible for our company is:
Commissioner for Data Protection and Freedom of Information for the State of North Rhine-Westphalia
Kavalleriestr. 2-4
40213 Düsseldorf, Germany
Phone: +49 (0)211/38424-0
Fax: +49 (0)211/38424-999
4. Personal data collected when visiting our website/cookies
(1) If you use our website purely to find information and do not register or send us information in any other way, we only collect the personal data that your browser sends to our server. If you want to view our website, we collect the following data that we need for technical reasons to display our website for you and ensure its stability and security (the legal basis is Article 6 (1) (1) point (f) GDPR):
- IP address
- date and time of request
- time zone difference from Greenwich Mean Time (GMT)
- internet service provider of the accessing system
- content of the request (specific page)
- access status/HTTP status code
- quantity of data transferred
- website the request comes from (referrer)
- browser
- operating system and interface
- language and version of the browser software
(2) In addition to the data specified above, cookies are stored on your computer when you use our website. Cookies are small text files stored on your hard drive that are attributed to the browser you are using and send certain information to the party storing the cookie (us in this case). Cookies cannot execute any programs or transfer viruses to your computer. They are used to make the website more effective and easier for users to navigate overall.
(3) Use of cookies:
1. In general, the following different cookie types/functions exist:
a) Transient cookies are deleted automatically when you close your browser. This type particularly includes session cookies. Session cookies store a session ID that is used to attribute various requests from your browser to a single session. This enables your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close your browser.
b) Persistent cookies are deleted automatically after a set period of time, which may differ depending on the cookie. You can delete these cookies in your browser’s security settings at any time.
c) Necessary cookies are absolutely essential for a website to be able to operate.
d) Statistics, marketing or personalization cookies are used for measuring reach, among other purposes, and also if a user’s interests or behavior are to be stored in a user profile, for example. This process is also known as “tracking.” Where we use cookies or tracking services, we will inform you separately in our Data Privacy Notice or as part of the process of obtaining consent.
e) You can configure your browser settings to suit your needs and refuse to allow third-party cookies or all cookies, for example. Please note that you may not be able to use all the functions of this website.
f) We use cookies to identify you on subsequent visits if you have an account with us. Otherwise, you would have to log in again on each visit.
2. As a rule, the data processed using cookies is processed based on our legitimate interests (Article 6 (1) point (f)) or, where the use of cookies is necessary, to comply with our contractual obligations (Article 6 (1) point (b)). If we ask you for your consent, the legal basis for processing the data is the consent you gave us (Article 6 (1) point (a)).
3. You can, of course, withdraw any consent you have given at any time or object to the processing of your data using cookie technologies (“opt out”). As a first step, you can object using your browser settings. You can also object to the use of cookies for online marketing purposes, particularly tracking, using a wide variety of services, via the U.S. site http://www.aboutads.info/choices/, the EU site http://www.youronlinechoices.com/ or the general site http://optout.aboutads.info.
(4) You can change your cookie settings at any time via this link:
5. Other functions and offers on our website
(1) As well as visiting our website purely to find information, you may be interested in using some of our range of services. To do this, you generally need to give us more personal data that we use to provide the relevant service and to which the data processing principles specified above apply.
(2) In some cases, we use external service providers to process your data. These service providers have been chosen and commissioned by us with care, are obligated to follow our instructions and are inspected regularly.
(3) We use hosting services to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purposes of operating this website.
When providing these services, we or our hosting provider process personal data, contact data, content data, contract data, usage data, metadata and communication data of customers, interested parties and visitors to this website based on our legitimate interests in efficient and secure provision of this website in accordance with Article 6 (1) point (f) GDPR in conjunction with Article 28 GDPR.
(4) We may also share your personal data with third parties if we offer opportunities to participate in promotional activities, enter competitions, enter into contracts or similar services together with partners. You will receive more information about this when you provide your personal data, or you can find it in the description of the offer below.
(5) Where our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you about the consequences of this situation in the description of the offer.
Trans-Atlantic Data Privacy Framework (TADPF): In the context of the Trans-Atlantic Data Privacy Framework (TADPF), the European Commission has also recognized the data protection level of certain companies from the U.S. You can find the list of certified companies and further information on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/. Information in German and other languages is available on the website of the European Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_de. We will also inform you about the companies we use that are certified under the Trans-Atlantic Data Privacy Framework.
6. Data privacy in relation to job applications
The controller for the processing collects and processes the personal data of applicants for the purposes of handling the application process. Applications may also be processed electronically. This is particularly the case if an applicant sends relevant application documents to the controller for the processing electronically, such as by email, or via a contact form on the website. Where the controller for the processing enters into an employment contract with an applicant, the data sent for the purposes of managing the employment contract is stored in compliance with legal provisions. If the controller for the processing does not enter into an employment contract with the applicant, the application documents will be deleted automatically, unless deleting them would conflict with any other legitimate interests of the controller for the processing. Any other legitimate interests in this context may include an obligation to provide evidence in proceedings under the German General Act on Equal Treatment (AGG).
Applicant data is processed to comply with our (pre-)contractual obligations as part of the application process under Article 6 (1) point (b) GDPR, and under Article 6 (1) point (f) GDPR where data processing becomes necessary for us as part of legal proceedings, for example (Section 26 of the German Federal Data Protection Act (BDSG) also applies in Germany).
7. Objecting to or withdrawing consent for the processing of your data
(1) If you have given your consent for the processing of your data, you can withdraw it at any time using any means of communication. Once you have informed us of the withdrawal, the reliability of the processing of your personal data will be affected.
(2) If we are processing your personal data based on the consideration of interests, you can object to processing. This is particularly the case if processing is not necessary to perform a contract with you, which we make clear each time in the subsequent description of the functions. If you exercise this right to object, please set out the reasons why we should not process your personal data as we have been. When we receive your objection together with the reasons, we will examine the situation and either stop or modify data processing, or demonstrate our compelling legitimate grounds on which we will continue the processing.
(3) You can, of course, object to the processing of your personal data for the purposes of advertising and data analysis at any time. You can contact us about your objection to advertising using the address given under Section 2 (2).
8. Legal or contractual provisions on making personal data available/necessity for concluding a contract/consequences in the event of failure to make data available/erasure
(1) We want to make you aware that making personal data available is required by law in certain situations. However, it may also be the case that a data subject must make personal data available to us for a contract to be performed. Failure to make this data available would mean that the contract could not be concluded. Our employees are happy to answer any specific questions you may have about your situation.
(2) The data we process is erased or its processing is restricted in accordance with Article 17 and 18 GDPR. Unless specified explicitly in this Data Privacy Notice, we erase the data we store as soon as it is no longer required for its intended purpose and its erasure does not conflict with any legal retention periods. If the data is not erased because it is necessary for other purposes authorized by law, its processing is restricted. This means that the data is blocked and is not processed for other purposes. For example, this applies to data that must be retained under commercial or tax law.
In accordance with legal provisions, this data is, in particular, stored for 10 years under Section 147 (1) of the German Fiscal Code (AO) and Section 257 (1) no. 1 and 4 of the German Commercial Code (HGB) (books, records, management reports, accounting vouchers, commercial records, documents relevant to taxation, etc.), and 6 years under Section 257 (1) no. 2 and 3 and (4) HGB (commercial letters).
9. Web analytics
1. Use of Matomo
(1) This website uses the web analytics service Matomo, provided by InnoCraft Ltd., 150 Willis St., 6011 Wellington, New Zealand, to analyze use of our website and regularly improve it. The statistics we obtain enable us to improve our website and make it more interesting for you to use. The legal basis for using Matomo is your consent under Article 6 (1) (1) point (a) GDPR.
Cookies (see Section 4) are stored on your computer for the purposes of this analysis. The controller exclusively stores the information collected in this manner on its server in Germany. You can stop this analysis by deleting existing cookies and preventing cookie storage. If you prevent cookie storage, please note that you may not be able to use all the functions of this website. You can use your browser settings to prevent cookie storage. You can prevent the use of Matomo by removing the check mark below to activate the opt-out plugin:
(3) This website uses Matomo with the “AnonymizeIP” extension. This means that IP addresses are processed further in a shortened form, which eliminates the possibility of directly linking them to a person. The IP address sent by your browser using Matomo is not combined with other data we collect.
(4) The Matomo program is an open source project. Information from the third-party provider on data privacy can be found at https://Matomo.org/privacy/policy.
10. YouTube
1. Embedding of YouTube videos
(1) We have embedded YouTube videos into our website, which are stored at https://www.YouTube.com and can be played directly from our website. These are all embedded in “extended data protection mode,” meaning that no data about you as a user can be transferred to YouTube if you do not play the videos. The data specified in Section 2 is only transferred when you play the videos. We do not have any control over this transfer of data.
(2) By visiting the website, YouTube is informed that you have accessed the relevant subpage of our website. The data specified under Section 4 of this Notice is also sent. This happens whether YouTube provides you with a user account and you are logged in or you do not have a user account. If you are logged into Google, your data will be directly attributed to your account. If you do not want it to be attributed to your YouTube profile, you need to log out before clicking the button. YouTube stores your data as a user profile and uses it for the purposes of advertising, market research and/or tailoring its website to users’ needs. This kind of analysis is particularly performed (even for users who are not logged in) to provide personalized advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles; you will need to contact YouTube to exercise it.
(3) The legal basis is Article 6 (1) (1) point (f) GDPR (legitimate interests) and Article 6 (1) (1) point (a) GDPR (consent).
(4) You can find more information on the purpose and scope of data collection and processing by YouTube in the Privacy Policy. There you will also find more information about your rights and control options to protect your privacy: https://policies.google.com/privacy.