Data Policy

Protecting your privacy when processing personal data is a matter of great importance to us. When you visit our website, our web servers automatically record your Internet Service Provider’s IP address, the website from which you are visiting us, the pages you view on our site, and the date and duration of your visit. This information is essential for the technical delivery of the website and the secure operation of our servers. This data is not subject to personalised analysis.If you send us data via the contact form, this data will be stored on our servers as part of our data backup procedures. We will use your data exclusively to process your enquiry. Your data will be treated as strictly confidential. It will not be passed on to third parties.

Responsible party:

smicro GmbH
Lauterenstr. 37
55116 Mainz

info@smicro.de

Personal data

Personal data is data relating to you personally. This includes your name, your address and your email address. You are not required to disclose any personal data in order to visit our website. In some cases, we require your name and address, as well as further information, in order to provide you with the service you have requested.

The same applies if we supply you with information material at your request or when we respond to your enquiries. In such cases, we will always inform you accordingly. Furthermore, we only store the data that you have provided to us automatically or voluntarily.

When you use one of our services, we generally only collect the data necessary to provide you with our service. We may ask you for further information, but this is voluntary. Whenever we process personal data, we do so in order to provide you with our service or to pursue our commercial objectives.

Contacting us

When you contact us (e.g. via the contact form, email, telephone or social media), the details of the enquirer are processed to the extent necessary to respond to the contact enquiries and any requested actions.

Responding to contact enquiries within the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre-)contractual enquiries and, in other respects, on the basis of legitimate interests in responding to the enquiries.

• Types of data processed: Master data (e.g. names, addresses), contact details (e.g. email, telephone numbers), content data (e.g. entries in online forms).
• Data subjects: Communication partners.
• Purposes of processing: Contact enquiries and communication.
• Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Automatically stored data

Server log files

The website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Date and time of the request
• Name of the requested file
• Page from which the file was requestedAccess status (file transferred, file not found, etc.)
• web browser and operating system used
• full IP address of the requesting computer
• amount of data transferred

This data is not combined with other data sources. Processing is carried out in accordance with Article 6(1)(f) of the GDPR on the basis of our legitimate interest in improving the stability and functionality of our website.

For reasons of technical security, in particular to defend against attempted attacks on our web server, we store this data temporarily. It is not possible for us to identify individual persons on the basis of this data. After seven days at the latest, the data is anonymised by truncating the IP address to the domain level, so that it is no longer possible to establish a link to the individual user. In anonymised form, the data is also processed for statistical purposes; no comparison with other data sets or disclosure to third parties, even in part, takes place.

We use the provider RAIDBOXES GmbH, based at Friedrich-Ebert-Straße 7, 48153 Münster, Germany, to host our website.

Cookies

When you visit our website, we may store information on your computer in the form of cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that allows websites and servers to be associated with the specific web browser in which the cookie was stored. This enables the websites and servers visited to distinguish the data subject’s individual browser from other web browsers containing different cookies. A specific web browser can be recognised and identified via the unique cookie ID.

By using session cookies, the controller can provide users of this website with a user-friendly service that would not be possible without the use of cookies. Without consent, we use only technically necessary cookies on the legal basis of legitimate interest pursuant to Article 6(1)(f) of the GDPR.

We use personal data cookies to improve our website or for marketing/advertising purposes only with your consent. On your first visit, you may voluntarily consent to tracking or analysis via the cookie banner that appears. Where applicable, your data may be passed on to partners or third-party providers. These cookies will only be stored if you explicitly consent to this; the legal basis is then your consent in accordance with Article 6(1)(a) of the GDPR.

To obtain your valid consent to the use and storage of cookies in the browser you use to access our website, and to document this properly, we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH Amsterdam, Netherlands. Website: https://cookiefirst.com, hereinafter referred to as CookieFirst.

When you access our website, a connection is established with the CookieFirst server to enable us to obtain your valid consent to the use of certain cookies. CookieFirst then stores a cookie in your browser to activate only those cookies to which you have consented and to properly document this consent.

The processed data is stored for a period of 12 months, unless you withdraw your consent or request deletion beforehand. After that, your data will be automatically deleted. Notwithstanding this, statutory retention periods may apply.

You can withdraw or change your consent at any time by clicking on the cookie icon at the bottom of the website and adjusting your settings.

Data Processing Agreement

We have entered into a Data Processing Agreement with CookieFirst. This is a contract required under data protection law, which ensures that the data of visitors to our website is processed only in accordance with our instructions and in compliance with the GDPR.

Server log files

Our website and CookieFirst automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:

• Your consent status or the withdrawal of consent
• Your anonymised IP address
• Information about your browserInformation about your device
• Date and time of your website visit
• The URL of the webpage on which you saved or updated your consent preferences
• The approximate location of the user who saved their consent
• A universally unique identifier (UUID) of the website visitor who clicked on the cookie banner

Google Analytics (4)

This website uses features of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, time spent on the site, operating systems used and the user’s origin. This data is aggregated into a user ID and assigned to the website visitor’s respective device.

Furthermore, Google Analytics allows us, amongst other things, to record your mouse and scroll movements and clicks. Google Analytics also uses various modelling approaches to supplement the collected data sets and employs machine learning technologies in data analysis.

Google Analytics uses technologies that enable user recognition for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google regarding the use of this website is generally transmitted to a Google server in the USA and stored there. The use of this service is based on your consent in accordance with Article 6(1)(a) of the GDPR and Section 25(1) of the TTDSG. Consent may be withdrawn at any time.

Data transfer to the USA is based on the EU Commission’s Standard Contractual Clauses. You can find details here: https://privacy.google.com/businesses/controllerterms/mccs/

Browser plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available via the following link: https://tools.google.com/dlpage/gaoptout?hl=de

Further information on how Google Analytics handles user data can be found in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de

Google Signals

We use Google Signals. When you visit our website, Google Analytics collects, among other things, your location, search history and YouTube history, as well as demographic data (visitor data). This data may be used for personalised advertising via Google Signals. If you have a Google account, the visitor data from Google Signals will be linked to your Google account and used for personalised advertising. The data is also used to compile anonymised statistics on our users’ behaviour.

Google Analytics E-commerce Tracking

This website uses the ‘E-commerce Tracking’ feature of Google Analytics. With the help of E-commerce Tracking, the website operator can analyse the purchasing behaviour of website visitors to improve their online marketing campaigns. Information such as orders placed, average order values, delivery costs and the time taken from viewing to purchasing a product is recorded. This data may be aggregated by Google under a transaction ID assigned to the respective user or their device.

Security

We have implemented technical and administrative security measures to protect your personal data against loss, destruction, manipulation and unauthorised access. All our employees and service providers working on our behalf are bound by the applicable data protection laws.

Whenever we collect and process personal data, it is encrypted before being transmitted. This means that your data cannot be misused by third parties. Our security measures are subject to a continuous improvement process and our privacy policies are constantly revised. Please ensure that you have the latest version.

Information for customers, employees, applicants and business partnerships

What data is processed and from which sources does this data originate?

We process the data we have received from you in the context of contract initiation or fulfilment, on the basis of consent, or in connection with your application to us or your employment with us.

Personal data includes:

Your master/contact data; for customers, this includes, for example, first name and surname, address, contact details (email address, telephone number, fax), and bank details.

For applicants and employees, this includes, for example, first name and surname, address, contact details (email address, telephone number, fax), date of birth, data from CVs and references, bank details, religious affiliation, and photographs.

For business partners, this includes, for example, the names of their legal representatives, company name, commercial register number, VAT registration number, business number, address, contact details of the contact person (email address, telephone number, fax), and bank details.

In addition, we also process the following other personal data:

• Information regarding the nature and content of contract data, order data, sales and document data, customer and supplier history, as well as consultancy documents,
• marketing and sales data,
• other data that we have received from you in the course of our business relationship (e.g. during customer meetings),
• data that we generate ourselves from master/contact data and other data, such as through customer needs and customer potential analyses

For what purposes and on what legal basis is the data processed?

We process your data in accordance with the provisions of the General Data Protection Regulation (GDPR) and the Federal Data Protection Act 2018, as amended:

• to fulfil (pre-)contractual obligations (Art. 6(1)(b) GDPR): Your data is processed for the purpose of contract execution online or in one of our branches, and for the contract administration of your staff within our company. In particular, the data is processed during the initiation of business relations and during the performance of contracts with you.
• To fulfil legal obligations (Art. 6(1)(c) GDPR): Processing of your data is necessary for the purpose of fulfilling various legal obligations, e.g. under the German Commercial Code or the German Fiscal Code.
• To safeguard legitimate interests (Art. 6(1)(f) GDPR): Following a balancing of interests, data processing may take place beyond the actual fulfilment of the contract to safeguard the legitimate interests of us or third parties. Data processing to safeguard legitimate interests takes place, for example, in the following cases:
• Advertising or marketing
• Measures for business management and the further development of services and products;
• In the context of legal proceedings
• Sending of non-promotional information and press releases.
• Within the scope of your consent (Article 6(1)(a) GDPR): If you have given us your consent to process your data, e.g. for the publication of photos

Processing of personal data for advertising purposes

You may object to the use of your personal data for advertising purposes at any time, either in full or in relation to specific measures, without incurring any costs other than the transmission costs in accordance with standard rates.

We are entitled, subject to the legal requirements of Section 7(3) of the German Unfair Competition Act (UWG), to use the email address you provided when concluding the contract for direct marketing of our own similar goods or services. You will receive these product recommendations from us regardless of whether you have subscribed to a newsletter.

If you do not wish to receive such recommendations from us by email, you may object to the use of your address for this purpose at any time, without incurring any costs other than the transmission costs in accordance with standard rates. A notification in writing is sufficient for this purpose. Naturally, every email also contains an unsubscribe link.

Who receives my data?

If we engage a service provider for the purposes of data processing, we remain responsible for the protection of your data. All data processors are contractually obliged to treat your data confidentially and to process it only within the scope of providing the service. The data processors commissioned by us receive your data insofar as they require it to fulfil their respective services. These include, for example, IT service providers required for the operation and security of our IT system, as well as advertising and address publishers for our own promotional campaigns.

Where there is a legal obligation, and in the context of legal proceedings, public authorities, courts and external auditors may be recipients of your data.

Furthermore, for the purpose of initiating and fulfilling contracts, insurance companies, banks, credit reference agencies and service providers may be recipients of your data.

How long will my data be stored?

We process your data until the business relationship ends or until the applicable statutory retention periods expire (e.g. under the German Commercial Code, the German Fiscal Code or the Working Hours Act); furthermore, until the conclusion of any legal disputes in which the data is required as evidence.

Is personal data transferred to a third country?

As a general rule, we do not transfer any data to a third country. In individual cases, a transfer will only take place on the basis of an adequacy decision by the European Commission, standard contractual clauses, appropriate safeguards or your explicit consent.

What data protection rights do I have?

You have the right at any time to access, rectify, erase or restrict the processing of your stored data, the right to object to processing, as well as the right to data portability and the right to lodge a complaint in accordance with the provisions of data protection law.

1. Right of access: You may request information from us as to whether and to what extent we process your data.
2. Right to rectification: If we process your data that is incomplete or inaccurate, you may request that we rectify or complete it at any time.
3. Right to erasure: You may request that we erase your data if we are processing it unlawfully or if the processing disproportionately interferes with your legitimate interests. Please note that there may be reasons preventing immediate erasure, e.g. in the case of statutory retention obligations.

Irrespective of whether you exercise your right to erasure, we will erase your data immediately and in full, provided that no contractual or statutory retention obligation prevents this.

Right to restriction of processing: You may request that we restrict the processing of your data if

• you contest the accuracy of the data, for a period enabling us to verify the accuracy of the data.
• the processing of the data is unlawful, but you object to erasure and instead request a restriction on the use of the data,
• we no longer require the data for the intended purpose, but you still need this data to assert or defend legal claims, or
• you have objected to the processing of the data.

Right to data portability: You may request that we provide you with the data you have supplied to us in a structured, commonly used and machine-readable format, and that you may transmit this data to another controller without hindrance from us, provided that

• we process this data on the basis of consent given by you (which is revocable) or to fulfil a contract between us, and
• this processing is carried out using automated means.

Where technically feasible, you may request that we transfer your data directly to another controller.

1. Right to object: If we process your data on the basis of a legitimate interest, you may object to this data processing at any time; this would also apply to profiling based on these provisions. We will then no longer process your data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims. You may object to the processing of your data for the purpose of direct marketing at any time without giving reasons.
2. Right to lodge a complaint: If you believe that we are processing your data in breach of German or European data protection law, please contact us so that we can clarify any issues. You also, of course, have the right to contact the supervisory authority responsible for you, namely the relevant State Office for Data Protection Supervision.

If you wish to exercise any of the aforementioned rights against us, please contact our Data Protection Officer. In case of doubt, we may request additional information to verify your identity.

Am I obliged to provide data?

The processing of your data is necessary for the conclusion or performance of the contract you have entered into with us. If you do not provide us with this data, we will generally have to refuse to conclude the contract or will no longer be able to perform an existing contract and will consequently have to terminate it. However, you are not obliged to give your consent to the processing of data that is not relevant to the performance of the contract or not required by law.

Changes to this privacy policy

We reserve the right to amend our privacy policy should this be necessary due to new technologies. Please ensure that you have the latest version. Should fundamental changes be made to this privacy policy, we will announce these on our website.

All interested parties and visitors to our website can contact us regarding data protection matters at:

Mr. Christian Volkmer
Projekt 29 GmbH & Co. KG
Ostengasse 14
93047 Regensburg
Tel.: 0941 2986930
Fax: 0941 29869316
Email: anfragen@projekt29.de
Website: www.projekt29.de