Privacy Policy

We are pleased that you are interested in our company and our products & services, and would like you to feel secure when visiting our website with regard to the protection of your personal data. We would like you to know when we store which data and how we use such data. We are subject to the provisions of the Swiss Federal Data Protection Act(Bundesgesetz über den Datenschutz, DSG)and/or – if we offer our goods and services in the EU/EEA area – the provisions of the European General Data Protection Regulation (GDPR). In order to ensure that the data protection provisions are being complied with by us and also by service providers engaged by us, we have taken appropriate technical and organisational measures.

The terms used in this Privacy Policy, such as Controller or personal data, are used in accordance with the definitions given in the DSG and the definitions given in the GDPR. For easier readability and therefore also for the purpose of a transparent provision of information, we have generally refrained from quoting individual articles, sections or similar.

Controller

The Controller in the context of data protection provisions is:

Neoperl Group AG
Pfeffingerstrasse 21
4153 Reinach - Basel
Sitzerland
Tel: +41 (0) 61 716 74 00
E-Mail: info@neoperl.com

Data Protection Officer and Representative in the Union

The Controller has appointed a Data Protection Officer and Representative in the Union. His contact details are:

Michael Kranzer
Bechtle GmbH IT-Systemhaus Freiburg
Leinenweberstraße 1
79108 Freiburg im Breisgau
Germany
E-Mail: datenschutz@neoperl.com

General information regarding data processing

Legal bases for the processing of personal data

Within the scope of data protection law, the processing of personal data is generally not permitted unless there is statutory permission. We are obliged to inform you about the legal bases for the processing of data.

If we obtain your consentfor the processing of personal data, such consent constitutes the legal basis.

If the processing of personal data is necessary for the performance of a contract, whose contracting party is you, the performance of the contract constitutes the legal basis. This also applies to any processing that is necessary in order to implement pre-contractual measures.

If the processing of personal data is necessary for compliance with a legal obligation to which we are subject, this constitutes the legal basis.

In the event that interests which are essential for the lifeof the data subject or that of another natural person make the processing of personal data necessary, this constitutes the legal basis.

If the processing of personal data is necessary for purposes of safeguarding a legitimate interestof our company or of a third party, and if your interests or fundamental rights and freedoms do not override this, this constitutes the legal basis for the processing.

Deletion of data and storage time

As soon as the purpose for processing data ceases to apply, we will delete or block your personal data. Data may, however, be stored beyond such time period if this is required due to statutory provisions to which we are subject. This applies above all to data that must be retained for legal archiving reasons (e.g. usually for 6 years for commercial law reasons or usually for 10 years for tax law reasons).

Data transfers to third countries

The GDPR ensures a consistently high level of data protection within the European Union (EU) and the European Economic Area (EEA). The DSG ensures a high level of data protection in Switzerland. Where possible, when selecting our service providers and cooperation partners, we therefore rely on partners in Switzerland, the EU and the EEA in the event that your personal data is to be processed.

If we have your data processed in a third country – i.e. outside the EU/EEA or Switzerland – this is always carried out in accordance with legal requirements.

In addition to your express consent or contractually or legally required transfer, we only allow your data to be processed in third countries with a recognised level of data protection, through a contractual obligation using the standard contractual clauses of the EU Commission and by taking sufficient additional measures, where certifications or binding internal data protection regulations are in place.

Storage locations

Your personal data is currently processed in the following data locations:

Germany
Ireland
Switzerland
United States of America

Recipients of the data / categories of recipients

Within our company, we ensure that your data is only received by those persons who need it to fulfil contractual and legal obligations.

On occasion, we use carefully selected external service providers in the processing of your data. Should data be passed on to service providers as part of order processing, this will be carried out in accordance with the provisions of the GDPR. Our commissioned data processors have been carefully selected, are bound by our instructions and are checked at regular intervals. We only commission such data processors who provide sufficient guarantees that suitable technical and organisational measures are taken to ensure that the processing takes place in accordance with data protection requirements and safeguards the protection of your rights.

Sharing personal data with third parties

As a general rule, we will not share any personal data with third parties without your express consent. In the event that we do share your data with third parties, transmit it to them or grant them access to it in any other way in the context of the processing, this also occurs only on the basis of one of the aforementioned legal bases.

We transfer data, for instance, to payment providers or suppliers if this is necessary in order to fulfil the contract. If we are obliged to do so by statute or by court order, we have to transfer your data to the respective bodies entitled to such data.

Enquiries sent to us

If you send us an enquiry via our website – for instance by using the contact form or by making email contact – your personal data will be processed in order to respond to your enquiry:

Where your enquiry is related to the performance of a contract or is necessary for the performance of pre-contractual measures, this purpose constitutes the legal basis for this processing.

In all other cases, the processing is based on our legitimate interest in the effective handling of the enquiries addressed to us or, where applicable, also on your consent, provided this is necessary and has been obtained in advance.

Automated decision-making

We refrain from using automated decision-making processes or profiling (in Switzerland also referred as the processing of personality profiles).

Use of our online offerings

You are generally able to use our online offerings without disclosing your identity. In this section we will explain when and in what connection we process data when you use our online offerings, what offers of service providers we have implemented, how these work and what happens to your data.

Children

Our offering is generally aimed at adults. People under the age of 16 must not transfer any personal data to us without the consent of their parents or legal guardians.

Transport encryption

In order to protect your transmitted data as best as possible, we use a process known as transport encryption. To ensure the security of your data during the transmission process, we use a state-of-the-art SSL/TLS encryption process.

Data collection upon visits to our websites

If you use our websites purely for purposes of obtaining information, i.e. if you do not register for an offer, enter into a contract with us or otherwise disclose information to us, we will only collect personal data that your browser transmits to our server.

When you access our websites, we will collect the following data which we require for technical reasons in order to display our websites and ensure that they are stable and secure:

IP address of the visitor
Date and time of the request
Requested content (specific page)
Access status / http status code
Data volume transmitted in each case
Website from which the request originates
Operating system of the visitor
Language and version of the browser software

This data is temporarily stored in our system log files for a period lasting no longer than seven days. Data may be stored for longer; in this case, however, the IP addresses will be truncated or distorted such that it is no longer possible to identify the accessing client. In this connection the log files will not be stored together with other personal data concerning you. The legal basis for these processing operations is our legitimate interest.

Given that the collection of the data is essential in order to display the websites, and the storage of the data in log files is essential for the operation of our websites and to ensure IT security, you have no right to object in this regard.

Use of cookies

General information on the use of cookies

When you use our websites, cookies will be stored on your device in addition to the aforementioned data. Cookies are small datasets that may be sent by a website to the browser, which stores and returns them. Cookies can be used to store various details, which are read by the entity that has placed the cookie.

Legal bases

We use cookies in accordance with legal provisions. We therefore obtain prior consent from you for the use of cookies, except where such consent is not required by law. Consent is not necessary if the storage and reading of the information stored in cookies is absolutely necessary in order to provide the telemedia service (i.e. our online offering) expressly requested by you. In all other cases, your consent is required. This consent can be given by you in advance, verifiably and revocably, with the help of our consent management tool.

You will find information on the legal basis for the respective cookie use under data protection law either in this Privacy Policy or in our cookie management tool.

Storage duration

With regard to storage duration, two different types of cookies can be used:

Session cookies:these cookies are deleted after you leave our online offering and close your browser.
Persistent cookiesremain stored even after the browser has been closed. This allows the login status or search terms entered to be saved, for example. These cookies can also be used to measure reach.

Information on the storage duration of the respective cookies can be found in ourcookie management solution.

Information regarding services used

Cookie management solution

We use a cookie management solution. This allows you to manage the cookies we use as well as the consents you have given, to find out more information about the respective data processing, and to view the purpose and storage duration for the cookies used.

The provider of this solution is Jaohawi AB, Håltegelvägen 1b, 72348 Västerås, Sweden, website: https://www.consentmanager.de (hereinafter Consent Manager Provider).

When you enter our website, a connection is established to the servers of the Consent Manager Provider in order to provide you with information about the data processing operations and to give you the opportunity to consent to data processing operations that require your consent. The Consent Manager Provider then stores a cookie in your browser to be able to allocate to you any consents granted or their revocation. The data collected in this way is stored until you request us to delete it, delete the Consent Manager Provider cookie yourself or the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.

We use this solution to comply with our legal obligations in the context of the use of cookies and similar technologies.

Water and energy saving calculator

The data you enter when using the water and energy saving calculator is processed exclusively for calculating values and, if you wish, for providing the results in the form of a PDF. The water and energy saving calculator is integrated from a website belonging to the Neoperl Group. Data processing during the use of the calculator also takes place within our group of companies.

Information regarding data processing by third parties

Google Analytics

Insofar as you have given your consent, Google Analytics 4 is used on this website. This is a web analysis service offered by Google LLC, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as Google). You can find further information on terms of use and privacy at Google here and here.

Scope of processing

Google Analytics uses cookies which enables an analysis of your use of the website. The information gathered by the cookie about your usage of this website will generally be transferred to a Google server in the USA and stored there.

In Google Analytics 4, anonymisation of IP addresses is activated by default. IP anonymisation means your IP address will be truncated by Google within Member States of the European Union or other parties to the Agreement on the European Economic Area. In exceptional cases only, the full IP address is transferred to a Google server in the U.S. and truncated there. The IP address transmitted by your browser within the scope of Google Analytics is, according to Google, not merged with other Google data.

However, we expressly point out here that Google generally processes data for its own purposes, in particular also for the purpose of providing its web analysis and tracking service. Within the scope of Google Analytics, further usage data is collected that is to be assessed as personal data, such as identification features of the individual users, which also allow a link to an existing Google account, for example.

During your visit to the website, your user behaviour is recorded in the form of events. Events can be:

Pages you visit
First visit to the website
Start of the session
Your "click path" – interaction with the website
Scrolls (whenever a user scrolls to the end of the page (90 %))
Clicks on external links
Internal searches
Interaction with videos
File downloads
Adverts seen/clicked on
Language setting

Also recorded:

Your approximate location (region)
Your IP address (in truncated form)
Technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
Your internet provider

Purposes of processing

On our behalf, Google will use this information to evaluate your use of the website and compile reports on website activity. The reports provided by Google Analytics are used to analyse the performance of our website and the success of our marketing campaigns.

Demographic characteristics

We use the "demographic characteristics" function of Google Analytics to be able to display suitable adverts to website visitors within the Google advertising network. This allows reports to be created that contain statements about the age, gender and interests of the site visitors. This data comes from interest-based advertising from Google and visitor data from third-party providers. This data cannot be assigned to a specific person.

E-commerce tracking

We use the "e-commerce tracking" function of Google Analytics. E-commerce tracking allows us to analyse the buying behaviour of website visitors to improve our online marketing campaigns. Here, information such as orders placed, average order values, shipping costs and the time from viewing to purchasing a product is recorded. This data can be collated by Google under a transaction ID, which is assigned to the respective user or their device.

Signals

We use Google Signals. This allows Google Analytics to capture additional information about users who have activated personalised adverts (interests and demographics), and adverts can be delivered to these users in cross-device remarketing campaigns.

Google Remarketing

Google Remarketing analyses your user behaviour on our website (e.g. clicks on certain products) in order to classify you into certain advertising target groups and subsequently play suitable advertising messages to you when you visit other online offerings (remarketing or retargeting).

Furthermore, the advertising target groups created with Google Remarketing can be linked with Google's cross-device functions. In this way, interest-based, personalised advertising messages that have been adapted to you on one end device (e.g. mobile phone) according to your previous usage and surfing behaviour can also be displayed on another of your end devices (e.g. tablet or PC).

Third country transfer

Insofar as data is processed outside the EU/EEA and Switzerland and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transmission of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to legal remedy against access by authorities.

Recipients/categories of recipient

Recipients of the data are/could be:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor according to Art. 28 GDPR)
Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

Duration of data storage

Please refer to our cookie management tool for information about the length of time cookies will be stored on your device.

The data sent to us and linked to cookies, user ID or similar or advertising ID will be automatically deleted after 6 months. The data whose retention time has expired will be deleted automatically once a month.

Legal basis

The legal basis for the use of Google Analytics is yourvoluntary consent.

Revocation

You can revoke your consent at any time with effect for the future by calling up the cookie settings and changing your selection there. This shall not affect the lawfulness of processing based on consent before revocation.

Google Universal Analytics

If you have given your consent, Google Universal Analytics will be used on this website. This is a web analysis service offered by Google LLC, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as Google). This allows us to match data, sessions and interactions across several devices to a pseudonymous user ID and, by doing so, to analyse the activities of a user across devices.

Universal Analytics uses cookies that enable an analysis of your use of the website. The information gathered by the cookie about your usage of this website will generally be transferred to a Google server in the USA and stored there. In the event that IP anonymisation is activated on this website, however, your IP address will first be truncated by Google within Member States of the European Union or other parties to the Agreement on the European Economic Area. We have extended Universal Analytics on this website to include IP anonymisation, in order to ensure the collection and transmission of truncated IP addresses only. The IP address transmitted by your browser in the context of Universal Analytics is not merged with other Google data. However, we expressly point out here that Google generally processes data for its own purposes, in particular also for the purpose of providing its web analysis and tracking service. Within the scope of Universal Analytics, further usage data is collected that is to be assessed as personal data, such as identification features of the individual users, which also allow a link to an existing Google account.

The following usage data is analysed on our site by Universal Analytics:

Number of page views
Number of users
Bounce rate (page is closed after viewing one page only)
Session duration (average duration across all users)
Country from which the website was accessed
Use of website features
How many times which page is visited
The website the user comes from
Booking conversion rate (how many users of the website book goods or services)
The region the user comes from
Device and device category used by the user to access our website

On our behalf, Google will use this information to analyse your use of the website, to compile reports on website activity and to provide us with additional services related to usage.

Recipients/categories of recipient

Please refer to our cookie management tool for information on recipients / categories of recipient of the data collected.

Duration of data storage

Please refer to our cookie management tool for information about the length of time cookies will be stored on your device.

Legal basis

The legal basis for the use of Universal Analytics is yourvoluntary consent.

Revocation

YouTube

We have integrated YouTube components in various places. YouTube is an online video portal that allows the posting of videos. YouTube is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as Google). You can find further information on terms of use and privacy at Google here.

We integrate the videos from YouTube using a two-click solution. This means that when you call up a page in which a video is embedded, the video is initially deactivated and therefore does not load. The video in question is only loaded after we have received your consent.

The integration of YouTube content takes place in extended data protection mode. This is provided by YouTube and thus ensures that initially no cookies are stored on your device. However, when the relevant pages are called up, the data mentioned above under "Data collection upon visits to our websites" is transferred. Nevertheless, this information cannot be attributed to you unless you have logged in to YouTube or another Google service before accessing the page or are permanently logged in. We would like to point out here that Google processes this data worldwide and therefore a third country transfer also takes place.

Third country transfer

The parent company of YouTube, Google LLC, is based in California, USA. A transmission of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to legal remedy against access by authorities.

Recipients/categories of recipient

Recipients of the data are/could be:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor according to Art. 28 GDPR)
Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

Duration of data storage

Please refer to our cookie management tool for information about the length of time cookies will be stored on your device.

Legal basis

The legal basis for the use of YouTube is your voluntary consent.

Revocation

Your rights as a data subject

As a data subject, you have various rights, which we would like to inform you about below. Depending on the reason and type of processing of your personal data, you have the rights described in the following sections.

Your right of access

As a data subject, you have the right to learn from us whether we are processing personal data about you and – if so – which personal data about you we are processing.

You also have the right to ask us for a copy of your personal data that is the subject of processing.

Your right to rectification

You have the right to ask us to immediately rectify any of your personal data if you consider it to be incorrect.

You also have the right to ask us to complete any personal data that you consider to be incomplete.

Your right to erasure

If the legal requirements are met, you can request the erasure of your personal data.

This is the case, for example, if we have been processing your data based on your consent and you revoke this consent.

However, we are not allowed to erase data if we have to store it due to legal retention periods, for example. We will also not be able to comply with your erasure request if it is necessary for us to process your personal data in order to assert, exercise or defend legal claims.

Your right to restriction of processing

Under certain conditions, you as the data subject have the right to demand that we restrict the processing of your personal data.

One of these conditions is, for example, that you dispute the accuracy of your personal data. Another example could be a case in which we no longer need your personal data, but you need this data to assert, exercise or defend legal claims.

Your right to object

If we process your personal data on the basis of a legitimate interest, you have the right to object to this processing on grounds relating to your particular personal situation. However, this right to object does not exist if there is a compelling public interest in the processing which outweighs your interest, if we are obliged by law to process the data or if the processing serves the assertion, exercise or defence of legal claims.

If we use your personal data for direct marketing, you have the right to object to processing for the purpose of such marketing at any time. If you object to processing for this purpose, your personal data will no longer be processed for this purpose.

If we process your data based on your consent, you have the right to revoke your consent at any time with effect for the future. Your revocation does not affect the lawfulness of any processing that has taken place before then.

Your right to data portability

You only have this right in respect of personal data which you have provided to us yourself. You have the right to request that we transfer this personal data directly to another controller.

Alternatively, you have the right to request that we provide you with your data in a machine-readable format. However, this only applies if we process your personal data on the basis of your consent or on the basis of a contract and the processing is carried out with the aid of automated procedures.

Complaint to the supervisory authority

You also have the right to lodge a complaint with a supervisory authority if you are of the opinion that the processing of personal data concerning you violates data protection law.

Amendments

This Privacy Policy will be amended from time to time. These amendments will be made, for instance, if there are changes due to technical developments, legal provisions or other influences.

Effective date: November 2022