Privacy policy

Controller according to the General Data Protection Regulation: 

tubus carrier systems GmbH 

represented by its Managing Director Christian Junker

Virnkamp 24
48157 Münster 
Phone: +49 | 251 | 143223-0
Fax: +49 | 251 | 143223-97
E-Mail: contact[at]hebie-group.com

Data Protection Officer 

CRO Datenschutz GmbH
Nora Loof
Adenauer-Platz 4
33602 Bielefeld, Germany  

In this privacy policy, we provide information to you (the ‘user’ or ‘data subject’) on how we process your data in connection with the use of digital systems that prepare and display data and establish a connection to a cloud. We will also inform you of your rights with regard to the processing of your data. Data processing always refers to the processing of personal data. We attach great importance to the protection of your privacy and the integrity of your personal data. Please read this agreement carefully to understand how we handle your data.   

1. General information on data processing 

Our systems may collect personal information from you when you use them, register, contact us or otherwise interact with them. 

1.1 Categories of personal data 

We process the following categories of personal data:
• Inventory data (names, addresses, functions, organisational affiliation, etc.);
• Contact details (email address, phone/fax numbers, etc.);
• Content data (text input, image files, videos, etc.);
• Usage data (login credentials);
• Meta/communication data (IP addresses). 

1.2 Recipients and categories of recipients of your personal data 

If we disclose data from other persons and companies such as processors or third parties in the course of our processing, transfer data to them or otherwise grant them access to data, this takes place on the basis of legal authorisation (e.g. if a transfer of the data to third parties is necessary for the fulfillment of the contract in accordance with Art. 6 (1) lit. b GDPR), if the data subjects have provided their consent or a legal obligation permit the corresponding disclosure.  . 

1.3 Retention periods for personal data 

Your personal data is stored for the retention period prescribed by law. Once the retention period comes to an end, the relevant data are erased if they are no longer required for the purpose for which they were collected.   

1.4 Transfers to third countries 

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA) or if this takes place in relation to the use of third-party services or the disclosure or transfer of data to third parties, this will only take place where required to fulfill our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permission, we process or have data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. For instance, the processing is carried out on the basis of special guarantees, such as the officially recognized determination of a data protection level that corresponds to the level in place in the EU or compliance with officially recognized standard contractual clauses. 

2. Data processing

We process and use your personal data to provide you with the functions and services of the systems, to handle your queries, to improve the performance of the systems and to provide you with relevant information. This includes transferring and storing your data in the cloud.   

2.1 Strictly necessary cookies

The systems may use cookies and similar technologies to analyze your use of the systems, store user preferences and provide you with a personalized experience. By using the systems, you agree to the use of the above forms of technology. You can also control the use of cookies in your browser settings. We use strictly necessary cookies on the legal basis of Art. 6 (1) lit. f GDPR.   

2.2 Integration of other third-party services 

We also share content on social networks and other virtual platforms, where we can communicate with customers, potential customers and users and present our services to them. When these networks and virtual platforms are accessed, their terms and conditions and, above all, their data protection principles apply. This must be taken into account in particular if you access our pages on social networks and other platforms by clicking on the corresponding links on our website.
Unless otherwise stipulated in our privacy policy, we process the personal data that you disclose to us on social networks and virtual platforms when you communicate with us, e.g. by sending us messages, to handle your queries. The disclosed data is processed on the legal basis of Art. 6 (1)(1) lit. b GDPR. We also use third-party services on our website to optimize and analyze our online presence in order to embed content and services such as videos or fonts on our website (hereinafter uniformly referred to as ‘services’). This requires the providers of these services to process your IP address. Since this cannot be technically prevented, the processing of your IP address is therefore necessary for the use and realization of the services. We endeavor to use only services whereby the providers only process IP addresses for the immediate provision of the service. Third parties may also use pixel tags (transparent images, also known as web beacons) for statistical or marketing purposes. Web beacons permit various information, including on your visit to our website, to be examined and analysed.
Information may also be stored in cookies on your device in pseudonymised form, which may involve the processing of technical information concerning your browser and operating system, linked websites, the duration of your visit and other information about your use of our website. The disclosed data is processed on the legal basis of Art. 6 (1)(1) lit. b GDPR. The services that may be used are as follows:: Google Analytics, YouTube, Google Maps

2.3 Hosting 

We use certain hosting services to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating our website. In these scenarios, we or our processor process inventory data, contact data, content data, contract data, usage data, meta and communication data on the basis of our legitimate interests in the efficient and secure provision of our services pursuant to Art. 6 (1) lit. f GDPR in conjunction with Art. 28 GDPR.   

3. Data processing for contact purposes 

3.1 Contact by email, phone or fax

You can contact us using the email address, phone number or fax number published on our website. If you use one of these contact methods, the data you disclose (e.g. surname, first name, address, phone number), together with any personal data you disclose will be stored for the purpose of getting in touch with you and handling your query. In addition, the following data will be collected by our system when you contact us by email:   

• IP address of the querying computer; 
• The date and time of the email.

We process personal data received in emails sent to us or phone calls we receive on the legal basis of Art. 6 (1) lit. b and lit. f GDPR. 3.2 Contacting us by post If you send us a letter, the data you disclose (e.g. surname, first name, address) and the information contained in the letter together with any personal data you disclose will be stored for the purpose of getting in touch with you and handling your query. We process personal data received in letters or faxes sent to us on the legal basis of Art. 6 (1) lit. b and lit. f GDPR.   

4. Your rights

As a data subject, you are entitled to the following rights in relation to the processing of your personal data: 

4.1 Right of access 

(1) As a data subject, you reserve the right to request confirmation from us as to whether personal data concerning you are being processed; if this is the case, you have the right to access this personal data and the following information:   

a) the purposes of processing;
b) the categories of personal data processed; 
c) the recipients or categories of recipients to which your personal data have been or will be disclosed, in particular with regard to recipients in third countries or to international organisations;
d) where possible, the planned duration for which your personal data will be stored or, where this is not possible, the criteria for determining the duration of the retention period;
e) the existence of your right to rectify or erase personal data relating to you or to restrict the processing thereof by the controller or a right to object to any corresponding processing;
f) the existence of a right to lodge a complaint with a supervisory authority;
g) if personal data are not collected from the data subject, all available information on the source of the data;
h) the use of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) GDPR and – at least in these cases – conclusive information about the logic involved and the scope and intended effects of the corresponding processing for the data subject.   

(2) If personal data are transferred to a third country or to an international organisation, you have the right to receive information on the appropriate safeguards in accordance with Article 46 GDPR in relation to the transfer.

4.2 Right to rectification

You have the right to request from us the rectification of any inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, as a data subject, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

4.3 Right to erasure

4.3.1 You have the right to require us to erase personal data concerning you without undue delay and we are required to erase personal data without undue delay if any of the following apply:   

a) Your personal data are no longer required for the purposes for which they were collected or otherwise processed. 
b) You withdraw your consent on which the processing was based pursuant to Art. 6 (1) lit. a) or Art. 9 (2) lit. a) GDPR, and there is no other legal basis for the processing. 
c) You file an objection against the processing in accordance with Art. 21 (1) GDPR and there are no overriding legitimate reasons for the processing or you file an objection against the processing in accordance with Art. 21 (2) GDPR.
d) Your personal data has been processed unlawfully.
e) The erasure of your personal data is required for the fulfillment of a legal obligation under EU law or the law of the Member States to which we are subject.
f) Your personal data has been collected in relation to information society services offered in accordance with Art. 8 (1) GDPR.

4.3.2 If we have made your personal data public and we are obliged to delete them in accordance with 4.3.1, we shall take appropriate measures, including technical measures, taking into account available technology and the costs of implementation, to notify data controllers who process the personal data that a data subject has requested them to delete all links to this personal data or to copy or replicate this personal data. 

4.3.3 Sections 4.3.1 and 4.3.2 do not apply to the extent that processing is necessary  

a) to exercise the right to freedom of expression and information;
b) to fulfil a legal obligation which requires processing under EU or Member State law to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority conferred on the controller;
c) for reasons of public interest in the field of public health pursuant to Art. 9 (2) lit. h) and i) as well as Art. 9 (3) GDPR;
d) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1), in so far as the right referred to in para. 1 is likely to render impossible or seriously impair the attainment of the objectives of the corresponding processing; or
e) to assert, exercise or defend against legal claims. 

4.4 Right to restrict processing 

4.4.1 You have the right to demand that we restrict processing if one of the following conditions is met: 

a) the accuracy of the personal data is disputed by you for a period that allows us to verify the accuracy of the personal data;
b) the processing is unlawful and you refuse the deletion of the personal data and instead request that use thereof is restricted;
c) we no longer require the personal data for the purposes of the processing, but you need them to assert, exercise or defend against legal claims; or
d) you have filed an objection against the processing pursuant to Art. 21 (1) GDPR, as long as it is not yet clear whether our legitimate grounds outweigh yours.. 

4.4.2 In cases where processing has been restricted in accordance with Section 4.4.1, your personal data may be processed only with your consent or for the purpose of asserting, exercising or defending against legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest in the EU or a Member State, with the exception of storage.   

4.5 Right to data portability  

4.5.1 You have the right to receive the personal data relating to you that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transfer this data to another controller without hindrance from us to whom the personal data have been provided, subject to the proviso that   

a) the data is processed on the basis of a consent pursuant to Art. 6 (1) lit. a) or Art. 9 (2) lit. a) GDPR or on the basis of an agreement pursuant to Art. 6 (1) lit. b) GDPR; and
b) the processing takes place with an automated process.  

4.5.2 When exercising your right to data portability pursuant to para. 1, you have the right to demand that we transfer your personal data directly to another controller to the extent that this is technically feasible. The right granted to you as a data subject according to Section 4.5.1 must not affect the rights and freedoms of others. This right does not apply to processing required for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to us.

4.6 Right to object

You have the right to lodge an objection at any time against the processing of personal data concerning you, which is carried out on the basis of Art. 6 (1) lit. e) or f) GDPR for reasons arising from your particular situation; the same applies to profiling based on these provisions. We no longer process your personal data unless we can prove compelling legitimate reasons for processing that outweigh your interests, rights and freedoms, or the processing is required to assert, exercise or defend against legal claims.  
In relation to the use of information society services and notwithstanding Directive 2002/58/EC, you may exercise your right to object to the use of automated procedures that employ technical specifications.

4.7 Right to withdraw consent 

You have the right to withdraw your declaration of consent under data protection law at any time. Withdrawing your consent does not affect the lawfulness of the processing that takes place on the basis of your consent prior to the withdrawal.

4.8 Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial redress, you reserve the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you have reason to believe that the processing of your personal data infringes this regulation. The competent authority to contact with regard to data processing by us is:

State Commissioner for Data Protection and Freedom of Information (LDI) NRW,
Kavalleriestr. 2-4 in 40213 Düsseldorf, Germany