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Data privacy Privacy Statement Pursuant to GDPR

We are delighted to welcome you during your visit to our website and want to thank you for your interest in our company. The protection of your private sphere during your use of our website is a matter of major importance to us. Accordingly, we will orient our use of your personal data strictly in line with the currently applicable data protection regulations. In the following, we will describe to you what personal data we collect and how we use the collected data during your use of our website.

What are personal data? The term “personal data” is defined in the German Federal Data Protection Act (BDSG/BDSG (revised)) and the European General Data Protection Regulation (GDPR). According to this definition, “personal data” means any information relating to an identified or identifiable natural person (the data subject). Such information encompasses (for example) your name, your address, your phone number, your email address, or your date of birth.

You can visit our website without providing any information about your person. We do not store any personal data whatsoever during such visits. We analyze solely statistical data that cannot be used to draw any conclusions about you personally so that we can improve our services. If and when personal data (such as your name, address, or email address) are collected on our site, it is done strictly on a voluntary basis. These data are not transferred to third parties without your express consent.

On the following pages, we would like to tell you about the way we process your personal data and the claims and rights to which you are entitled pursuant to data protection regulations.

I.  Name and Address of the Controller

The controller within the sense of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as any other legal data protection regulations is:

Albrecht Bäumer GmbH & Co. KG
Asdorfer Strasse 96–106
57258 Freudenberg
Germany

Phone: +49 (2734) 289–0
Email: contactnoSpam@baeumer.com
Website: www.baeumer.com 

II.  Name and Address of the Data Protection Officer

The controller’s data protection officer is: 

Sven Giesler
desegna Business IT Solutions
Eickhoffstr. 6
57234 Wilnsdorf
Germany

Phone: +49 (2737) 9409-866
Email: datenschutznoSpam@desegna.de
Website: www.desegna.de

III.  General Information About Data Processing

1.  Scope of Processing of Personal Data

As a general principle, we collect and use the personal data of our users solely to the extent this is necessary to provide a functional website and our content and services. The collection and use of our users’ personal data are fundamentally subject to the consent of the users. One exception is found in cases in which obtaining the prior consent is not possible because of factual circumstances and the processing of the data is permitted by legal statutes.

2.  Legal Basis for the Processing of Personal Data

If we have obtained the data subject’s consent to process personal data, point (a) of Art. 6 (1) of the EU General Data Protection Regulation (GDPR) is the legal basis for the processing of personal data.

During the processing of personal data required for the performance of a contract when the data subject is a party to the contract, point (b) of Art. 6 (1) GDPR is the legal basis. It is also the basis for the necessary steps taken prior to entering a contract.

If the processing of personal data is required for compliance with a legal obligation to which our company is subject, point (c) of Art. 6 (1) GDPR is the legal basis.

In the event that processing is necessary to protect the vital interests of the data subject or of another natural person, point (d) of Art. 6 (1) GDPR is the legal basis.

If processing is necessary for the purposes of the legitimate interests pursued by our company or a third party and such interests are not overridden by the interests or fundamental rights and freedoms of the data subject, point (f) of Art. 6 (1) GDPR is the legal basis for the processing.

3.  Data Erasure and Duration of Storage

The personal data of a data subject are erased or blocked as soon as the purpose of the storage ceases to exist. Storage of data may continue beyond this time if provision has been made by European or national legislatures in EU regulations, laws, or other statutes to which the controller is subject. Blocking or erasure of the data also occurs whenever the storage period required by the specified norm expires unless the continued storage of the data is required for the conclusion or performance of a contract.

IV.  Provision of the Website and Creation of Log Files

1.  Description and Scope of Data Processing

Whenever users access our internet site, our system automatically collects data and information from the computer system of the accessing device.

The following data are collected at this time:

  • Information about the type of browser and the release in use
  • The user’s operating system
  • Host name of the accessing computer
  • Date and time of the access
  • Websites that referred the user’s system to our internet site
  • Country code
  • Type of device

The data are also stored in the log files of our system. The user’s IP addresses or other data that would make it possible to correlate the data to a specific user are not part of this collection. These data are not stored in conjunction with other personal data of the user.

2.  Legal Basis for Data Processing

The legal basis for the temporary storage of the data is point (f) of Art. 6 (1) GDPR.

3.  Purpose of the Data Processing

The temporary storage of the IP address by the system is necessary so that a website can be transmitted to the user’s computer. The storage of the user’s IP address for the duration of the session is required for this purpose.

These purposes also represent our legitimate interests in the data processing pursuant to point (f) of Art. 6 (1) GDPR.

4.  Duration of the Storage

The data are erased as soon as they are no longer required to achieve the purpose of their collection. In the case of collection of data for the provision of the website, this is the case when the current session is terminated.

5.  Right to Object and Erasure

The collection of the data for the provision of the website and the storage of the data in log files is essential for the operation of the website. As a consequence, users do not have any rights to object.

V.  Use of Cookies

1.  Description and Scope of Data Processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. Whenever a user accesses a website, a cookie can be stored in the user’s operating system. This cookie contains a characteristic series of characters that make the unique identification of the browser possible when the website is accessed again.

The following data are stored and transmitted in the cookies:

  • Language settings
  • Login information

We also use cookies that enable us to analyze users’ surfing behavior on our website.

In this respect, the following data may be transmitted:

  • IP address (is collected and stored in anonymized format)
  • Resolution of the monitor/display
  • Device type (specific device identification characteristics)
  • Operating system and browser type
  • Geographic location (country only)
  • Mouse events (movements, position, and clicks)
  • Keyboard entries
  • Preferred language
  • Referring domain
  • Sites visited
  • Date and time
  • Search terms entered
  • Frequency of access to sites
  • Use of website functions

The user data collected in this way are pseudonymized by technical means, so a correlation of the data with the accessing user is no longer possible. The data are not stored together with any other personal data of the users.

When users access our website, an information banner alerting the users to the use of cookies for analysis purposes and referring to this privacy statement appears. The settings of the cookies can be changed here.

2.  Legal Basis for Data Processing

The legal basis for the processing of personal data using technically required cookies is point (f) of Art. 6 (1) GDPR.

The legal basis for the processing of personal data using cookies for analysis purposes, provided that the user has given his or her consent for the processing, is point (a) of Art. 6 (1) GDPR.

3.  Purpose of the Data Processing

The purpose of the use of technically required cookies is the simplification of the use of the websites for users. Some of the functions available on our internet site cannot be offered without the use of cookies. Their use requires the recognition of the browser after there has been a change of pages.

We require cookies for the following applications:

  • Transfer of language settings
  • Retention of login data

The user data collected by technically required cookies are not used for user profiling.

The analysis cookies are used for the purpose of improving the quality of our website and its content. Such cookies make it possible for us to learn how our website is used, allowing us in turn to improve our service continuously. For this purpose, we use analysis cookies from Google Analytics and Hotjar. We have a contract for commissioned processing with the providers of the analysis cookies.

Google Analytics Cookies

Google Analytics is a web analysis service of Google, Inc. (“Google”). Google Analytics uses cookies that enable its analysis of the use of our website. As a rule, the information about your use of the website generated by the cookie is transferred to a Google server in the USA and stored there. However, Google uses the IP anonymization on our website to truncate beforehand your IP address within the member states of the European Union or in other countries of the European Economic Area. The full IP address is transmitted to a Google server in the USA and truncated there only in exceptional cases. Acting on behalf of the operator of this website, Google uses this information to analyze your use of the website, to compile reports about website activities, and to perform additional services related to website use and internet use for the website operator. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other Google data. You can prevent the storage of cookies by making the relevant settings in your browser software; however, we point out that you may not be able to use all of the functions on this website in their full scope if you do so.

In addition, you can prevent the transmission of the data related to your use of the website generated by the cookie (including your IP address) to Google and the processing of these data by Google by downloading and installing the browser plugin available at the link tools.google.com/dlpage/gaoptout.

You can prevent collection by Google Analytics by clicking on the following link. It will set an opt-out cookie that prevents the future collection of your data during your visits to this website: Google Analytics ist deaktiviert Jetzt aktivieren

Additional information about the terms and conditions of use and privacy can be found at http://www.google.com/analytics/terms/de.html and https://www.google.de/intl/de/policies/. We want to point out that Google Analytics has been supplemented on this website by the code “anonymizelp”, which guarantees the anonymized collection of IP addresses (so-called IP masking).

4.  Duration of the Storage, Right to Object and Erasure

Cookies are stored on the user’s computer and transmitted from it to our site. This gives you, the user, full control over the use of cookies. By making the appropriate settings in your internet browser, you can block or restrict the transmission of cookies. Cookies that have been stored on the computer can be deleted at any time. You can set your browser to do this automatically. If cookies for our website are blocked, however, you may possibly no longer be able to use all the functions of our website in their full scope.

VI.  Google Tag Manager

1.  Description and scope of data processing

We use Google Tag Manager on our website. Google Tag Manager is a service provided by Google Inc. ("Google"). Google Tag Manager enables us to incorporate various codes and services in an orderly and simplified manner on our website. To do this, Google Tag Manager implements tags or “triggers” embedded tags. When a tag is triggered, Google also processes personally identifiable information. There can be no guarantee that Google will not forward this information to a server in a different country. For more details of Google Tag Manager, please refer to https://www.google.com/analytics/tag-manager/use-policy/ and https://policies.google.com/privacy.

The following data may be transferred as a result:

  • IP address

The data is not stored together with other personally identifiable information about users.

2. Legal basis for data processing

Art. 6 (1) (f) GDPR establishes the legal basis for processing the data.

3. Purpose of data processing

By incorporating Google Tag Manager, we are striving to enable the simplified and clearly organized incorporation of various services. In addition, integrating Google Tag Manager reduces the time it takes the various services to load. These purposes also constitute our legitimate interest in processing the personally identifiable information under Art. 6 (1) (f) GDPR. A Contract Data Processing Agreement has been entered into with Google to govern the use of Google Tag Manager.

4. Duration of storage; Right to object; Right to erasure

The processed data is only stored as long as is necessary to fulfill the intended purpose. You can prevent Google from processing your data by downloading and installing the browser plugin from the following link: Deactivate data collection by Google Tag Manager. Please bear in mind, however, that deactivation may result in your not being able to use all the features on our website.

VII. Google ReCaptcha

1. Description and scope of the data processing

This website uses the Google ReCaptcha service, operated by Google Ireland Limited, Gordon House, 4 Barrow St., Dublin, D04 E5W5, Ireland (“Google”). This service is used to recognize if an entry in our web forms is made by a human or if it is a case of misuse by means of automated processing. In order to use the functionalities of Google ReCaptcha, it is necessary for data to be transmitted to and stored on a Google server in the United States.

At the time of sending the Google ReCaptcha solution, the following data is stored:

  • IP address
  • Mouse movements
  • Time spent on the website

Your consent will be obtained in advance for the processing of the data and reference will be made to this privacy statement. In Google’s privacy statement (https://policies.google.com/privacy?hl=en) you will find information about what data is collected and for what purpose.

2. Legal base of the data processing

If user consent has been obtained, the legal base of the data processing is Article 6(1)(a) GDPR.

3. Purpose of the data processing

The integration of this service into our website serves to avoid misuse and spam by recognizing if an entry in our web forms is made by a human or by means of automated processing. These purposes also constitute our legitimate interest in the processing of personal data pursuant to Article 6(1)(f) GDPR.

4. Retention period

The data is deleted as soon as it is no longer needed for the purposes for which it was collected.

VIII.  Newsletter

1.  Description and Scope of Data Processing

Our internet site offers to you the opportunity to subscribe to a free newsletter. When you register for the newsletter, the following data are transmitted to us from the entry mask:

  • Form of address (optional)
  • First name (optional)
  • Last name (optional)
  • Email address
  • Name of company (optional)
  • Position (optional)
  • Phone number (optional)
  • Street (optional)
  • ZIP code (optional)
  • City (optional)
  • Industry (optional)
  • Major interests (optional)

In addition, the following data are collected during registration:

  • IP address
  • Date and time of registration

The following data are collected by the newsletter:

  • Campaign name
  • Campaign code
  • Downloads
  • Clicks
  • IP address
  • Date and time of the registration (if user registers)

During the registration process, you will be asked to give your consent to the processing of the data and reference will be made to this privacy statement.

Data are transferred to SC-Networks GmbH as part of the data processing involved in sending the newsletter. A contract for commissioned data processing has been concluded with SC-Networks GmbH.

2.  Legal Basis for Data Processing

Legal basis for the processing of personal data when users subscribe to a newsletter, provided that the user has given his or her consent for the processing, is point (a) of Art. 6 (1) GDPR.

Legal basis for sending the newsletter subsequent to the sale of goods or services is Section 7 (3) UWG [Act for the Prevention of Unfair Competition].

3.  Purpose of the Data Processing

The email address is collected so that the newsletter can be delivered.

We collect and process as well any voluntary information you provide during the registration process so that the information we send to you can be tailored to your interests and needs. In addition, the newsletter itself includes a personal tracking function.

The collection of other personal data during the registration process serves to prevent the misuse of the services or of the email address that is used.

4.  Duration of the Storage

The data are erased as soon as they are no longer required to achieve the purpose of their collection. The email address, the information that has been provided voluntarily, and the user’s other personal data are stored as long as the newsletter subscription remains active.

5.  Right to Object and Erasure

The registered user may unsubscribe to the newsletter at any time. Every newsletter includes a link for this purpose.

The consent for the storage of the personal data collected during the registration process can also be withdrawn in this way.

IX.  Contact Forms and Email Contact

1.  Description and Scope of Data Processing

There are contact forms that can be used for establishing electronic contact to us on our internet site. If a user takes advantage of this service, the data entered in the entry mask are transmitted to us and stored.

These data are:

  • Country
  • Company name (optional)
  • Form of address
  • First name
  • Last name
  • Phone number (optional)
  • Street
  • Zip code
  • City
  • Email address
  • Message
  • Purpose of the request (new machine, cutting tools, software, support, other)
  • Industry
  • Details of the requested product and the associated machine (e.g. name of the machine, manufacturer, order/production number, details of the associated spare parts, etc.).

At the moment the message is sent, the following data are also stored:

  • User’s IP address
  • Date and time of registration

During the transmission process, you will be asked to give your consent to the processing of the data and reference will be made to this privacy statement.

Alternatively, you can use the email address shown on the site to contact us. In this case, the user’s personal data sent with the email will be stored.

None of the data provided by this means will be transferred to third parties. The data are used solely and exclusively for processing the conversation.

In addition, there is a contact form for online job applications that can be used to submit applications to us electronically on our internet site. If a user takes advantage of this service, the data entered in the entry mask and the attached documents are transmitted to us and stored.

These data are:

  • Form of address
  • First name
  • Last name
  • Email address
  • Attached file(s)
  • Message
  • How did you hear from us

At the moment the message is sent, the following data are also stored:

  • User’s IP address
  • Date and time of registration

During the transmission process, you will be asked to give your consent to the processing of the data and reference will be made to this privacy statement.

None of the data provided by this means will be transferred to third parties. The data are used solely and exclusively for the job application process. 

2.  Legal Basis for Data Processing

Legal basis for the processing of personal data, provided that the user has given his or her consent for the processing, is point (a) of Art. 6 (1) GDPR.

Legal basis for the processing of personal data transferred during the sending of an email is point (f) of Art. 6 (1) GDPR. If the purpose of the email contact is the conclusion of a contract, an additional legal basis for the processing is point (b) of Art. 6 (1) GDPR.

3.  Purpose of the Data Processing

We process the personal data from the entry mask solely and exclusively for the processing of the contact request or the application. When contact is requested by email, this also includes the required legitimate interests in the processing of the data.

The other personal data processed during the transmission process serve to prevent the misuse of the contract form and to ensure the security of our IT systems.

4.  Duration of the Storage

The data are erased as soon as they are no longer required to achieve the purpose of their collection. This is the case for personal data from the entry mask of the contract form and the data transmitted for email when the pertinent conversation with the user is finished. The conversation is finished when it is evident from the circumstances that the pertinent matter has been finally clarified. The additional personal data collected during the transmission process are erased at the latest after seven days.

5.  Right to Object and Erasure

The user has the opportunity to withdraw his/her consent to the processing of the personal data at any time. If the user contacts us by email, he/she can object to the storage of his/her personal data at any time. In this case, the conversation cannot be continued. Any further conversation in this case is possible only by mail. All personal data that were stored for the establishment of the contact are erased in this case.

X.  Privacy policy for social plugins

Our website uses plugins from social networks (Facebook, LinkedIn etc.) to share content.
Every time you call up a website on our website that is provided with such a plugin, the plugin causes the browser you are using to load and display the visual representation of the plugin from the server on the social network. The Social Network Server is informed of which specific website of our Internet presence you are currently visiting and other data such as your IP address is transmitted.

In order to ensure an appropriate data protection standard of our Internet presence, we have therefore deactivated the plug-ins by means of corresponding buttons and placed a short data protection notice in front of them.

We have no influence on the amount of data the social network collects using this plugin. Please refer to the data protection information of the respective social Network.

Facebook
YouTube
LinkedIn

XI.  Rights of the Data Subject

If any of your personal data are processed, you are a data subject within the sense of the GDPR and you have the following rights with respect to the controller:

1.  Right of Access

You can request a confirmation from the controller as to whether or not we process personal data concerning you.

If data are being processed, you may obtain access to the following information from the controller:

(1) The purposes of the processing of the personal data;

(2) The categories of personal data concerned;

(3) The recipients or categories of recipient to whom the personal data concerning you have been or will be disclosed;

(4) The envisaged period for which the personal data concerning you will be stored, or, if not possible, the criteria used to determine that period;

(5) The existence of the right to request rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller, or to object to such processing;

(6) The right to lodge a complaint with a supervisory authority;

(7) Where the personal data are not collected from the data subject, any available information as to their source;

(8) The existence of automated decision-making, including profiling, referred to in Art. 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.

You have the right to be informed whether personal data concerning you are transferred to a third country or to an international organization. Where this is the case, you have the right to be informed about the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

2.  Right to Rectification

You have the right to obtain from the controller without undue delay the rectification and/or completion of inaccurate or incomplete personal data concerning you.

3.  Right to Restriction of Processing

You have the right to obtain from the controller restriction of processing of the personal data concerning you under the following circumstances:

(1) You contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

(2) The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;

(3) The controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims; or

(4) You have objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override your grounds.

Where processing of personal data concerning you has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a member state.

If restriction of processing pursuant to the above circumstances has been obtained, you will be informed by the controller before the restriction of processing is lifted.

4.  Right to Erasure

a) Obligation to Erase

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller has the obligation to erase these data without undue delay where one of the following grounds applies:

(1) The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(2) You withdraw your consent on which the processing is based according to point (a) of Art. 6 (1) or point (a) of Art. 9 (2) GDPR and where there is no other legal ground for the processing;

(3) Your object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR;

(4) The personal data concerning you have been unlawfully processed;

(5) The personal data concerning you have to be erased for compliance with a legal obligation pursuant to European Union or member state law to which the controller is subject;

(6) The personal data concerning you have been collected in relation to the offer of information society services referred to in Art. 8 (1) GDPR.

(7) Information to third parties

Where the controller has made the personal data concerning you public and is obliged pursuant to Art. 17 (1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

b) Exceptions

The right to erasure does not apply to the extent that processing is necessary:

(1) For exercising the right of freedom of expression and information;

(2) For compliance with a legal obligation which requires processing pursuant to European Union or member state law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(3) For reasons of public interest in the area of public health in accordance with points (h) and (i) of Art. 9 (2) as well as Art. 9 (3) GDPR;

(4) For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89 (1) GDPR in so far as the right referred to in point (a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(5) For the establishment, exercise, or defense of legal claims.

5.  Right to Notification

If you have exercised the right to rectification, erasure, or restriction of processing with respect to the controller, the latter is obligated to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort.

You have the right to request information about those recipients from the controller.

6.  Right to Data Portability

You have the right to receive the personal data concerning you which you have provided to a controller in a structured, commonly used, and machine-readable format. Moreover, you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

(1) The processing is based on consent pursuant to point (a) of Art. 6 (1) GDPR or point (a) of Art. 9 (2) GDPR or on a contract pursuant to point (b) of Art. 6 (1) GDPR; and

(2) The processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data transmitted directly from one controller to another, where technically feasible. The exercise of this right must not adversely affect the rights and freedoms of others.

The right to data portability not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7.  Right to Object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Art. 6 (1) GDPR, including profiling based on those provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

8. Right to Withdraw Consent

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. Automated individual Decision-making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. The above provision does not apply if the decision:

(1) Is necessary for entering into, or performance of, a contract between you and the data controller;

(2) Is authorized by European Union or member state law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or

(3) Is based on your explicit consent.

These decisions, however, must not be based on special categories of personal data referred to in Art. 9 (1) GDPR, unless point (a) or (g) of Art. 9 (2) applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in (1) and (3), the data controller implements suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view, and to contest the decision.

10. Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged will inform the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

We reserve the right to modify or amend this privacy statement at any time in compliance with applicable data protection provisions. Most recently revised in April 2018.

 

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