Data Protection Guidelines

(Updated November 2020)

The protection of your personal data is important to us. Pursuant to EU General Data Protection Regulation (Art. 13 GDPR) we must inform you about the purpose for which we collect, save or forward data, and about your rights to data protection. The content and scope of the data processing corresponds essentially to the respective data that you provide or the data that are required for the business relationship or communication.

Who is responsible for data processing, and whom should I contact?

The Responsible Parties and the competent supervisory authority can be found in the Imprint of this website.

Which data are processed and what are the sources of this data?

We process personal data that we receive from you, from a partner commissioned by you or from one of our business partners in the context of our business relationship. In addition, we process data that we have legitimately received from publicly accessible sources (e.g., commercial register, address directory, media, trade fair participants). Personal data include your personal details (e.g., title, name, country, address, e-mail address and telephone number, delivery addresses, order and invoice data, information on creditworthiness, documentation data, log of trade fair talks, etc.).

What are the purposes and legal basis for our data processing?

We process personal data only in the context of our business activity. Beyond this, data processing takes places only based on legal requirements, based on a contractual relationship or a relationship of mutual trust preceding conclusion of a contract, based on your consent or if you contact us (e.g., at trade fairs, by e-mail, by post, by telephone or via this website).

Personal data are processed especially in the following business processes:

Visits to the website, Online-Shop
Initiation of contact
Visitor registration, WLAN guest access
Job applications
Trade fairs, events and product training
Advising by our employees or by trade partners
Order processing, delivery, invoicing
Based on legal obligations (customs and compliance screening, reporting of accidents)
Temporary work, training, vacation assistant programs
Quality inspections and quality certificates, claims
Service accounting of subcontractors

In the context of the business relationship, you must provide the personal data required to initiate and maintain the business relationship, and also those that we are legally obligated to collect. If you do not provide us with these data, then we will, as a rule, have to reject your requests or your contact query, conclusion of the contract, or explanation of the order, or have to end an existing contractual relationship.

If you have granted us your consent to processing your personal data, then the processing is carried out only according to the purposes set out in the declaration of consent and in the scope agreed therein. Once granted, your consent can be revoked at any time with future effect without stating reasons, as long as this is legally permissible. Please be aware that lawmakers classify job applications as a pre-contractual business relationship, and application documents are stored for 6 months after conclusion of the application process.

Moreover, we reserve the right to store your first and last names, your mailing address and - if we have received this additional information from you in the context of a contractual relationship - your title, academic degree and your professional, sectoral or business designation in compiled lists and use for own advertising purposes, e.g., for sending interesting offers and information on our products by mail. You can object to the storage and use of your data for these purposes at any time by giving notice at the address stated in the mailing.

If we provide services in advance, e.g., in the case of a purchase on account, we reserve the right to procure information on identity and creditworthiness from service companies specializing in this (credit agencies) to protect our justified interests.

Who is the recipient of my data?

We only transfer your data to third parties if this is permitted by law, if you have provided consent or the transfer is required for fulfilment of our business aims.

If possible the data are anonymised or pseudonymised for this purpose.

Within our corporate group, only the offices or employees that require your data to meet our contractual, legal or supervisory obligations or for protection of justified interests will receive them.

In addition to this, we transfer your data to processors commissioned by us:

IT and hosting service providers
Security services, visitor registration and registry
Credit institutions and payment providers to settle the payment transactions if orders have been placed
Back office service providers for handling advertising mailings
Suppliers for settlement of product and sample orders
Laboratories and institutes for testing of products
Transport businesses, logistics businesses
Marketing partners if they require your data to carry out your assignment
Agencies for surveys, marketing measures and organization of events.

Furthermore, data are transferred to public agencies and institutions (tax authorities, other authorities, customs offices), if there is a legal or supervisory obligation to do so.

All processors and marketing or trade partners are obligated by contract to process your data only in the context of the provision of services and pursuant to provisions of data protection law in force.

How long will my data be stored?

We store your data only as long as is required for processing of the business transaction or compliance with documentation obligations. Legal requirements stipulate that trade letters be stored at least 6 years, but at least 10 years if their content is relevant for tax purposes. Our IT systems are equipped, moreover, with comprehensive data backup concepts that do not permit premature deletion. In this case, access to data is restricted after expiry of the allowed storage period. Job application documents are saved or stored 6 months after the position has been filled, but if the application is made through an employment agency, then master data must be stored for a longer time.

What are my data protection rights?

You have a right to information free of charge regarding data that we have saved about you, as well as a right to correction, blocking or deletion of these data. If you have granted your consent for data processing, then you can revoke your consent for future processing.

To do so, please contact first the last office with which you have had contact. In addition, you can contact our Data Protection Officer.

If you believe that we breach European data protection law by processing your data, then we request that you contact us so that we are able to clarify your concerns. Furthermore, you have the right to lodge a complaint with the competent supervisory authority for data protection, if you believe that your personal data is being processed unlawfully.

How secure are my data?

We make use of state-of-the-art security measures to protect your data appropriately. Our employees, subcontractors and trade partners must observe our guidelines on information security.

Data protection for this website, for online services and for marketing

Saving of access data in server log files

You can visit our web pages without providing information about yourself. We store only access data in so-called server log files, such as the name of the requested file, data and time of its retrieval, amount of transferred data and the requesting provider. These data are assessed only for ensuring smooth operation of the page and for improving our offerings, and they do not allow us to infer your identity.

Newsletter data

If you would like to subscribe to the newsletter offered on our website, then we require your e-mail address and information that allows us to verify that you are the holder of the stated e-mail address and grant consent to receive the newsletter. Additional data are not collected or are only collected on a voluntary basis. We use these data only for sending the information requested, and we do not forward it to third parties. The processing of the data entered in the newsletter registration form is carried out based exclusively on your consent (Art. 6, para. 1, lit. a GDPR). The consent granted for storing data, e-mail address and for their use for sending the newsletter may be revoked at any time, for example, using the “de-register” link in the newsletter. The legitimacy of any data processing procedures that have already been carried out is not affected by the revocation. The data that you leave with us for the purpose of subscribing to the newsletter are stored by us. If you de-register from the newsletter distributor, then your profile is set to “de-registered,” and you will not receive any more newsletters. At your request, the data is deleted.

Personalized Tracking

Subscribers can opt-in to additional tracking to receive personalized emails based off their interests and interactions with each email. The personal data collection and evaluation as well as the use of various system functionalities is only permitted if the consent of the subscriber is granted during their time of subscription to the newsletter. The storage of the data serves the purpose of statistical evaluations and formation of interest profiles

You can revoke privilege for personalized tracking at any time using the tracking consent link in the footer of every email.

How long data is stored

Cookie type	Use/designation	Description	Holding period / Default values
Type 1	Tracking the recipient using the below mentioned objects and tracking data	ewafut	24 Months
Type 2	Tracking (anonymous history), see anonymous tracking history	ewafutano	<24 Months
Type 3	Transfer of conversion information, see tracking data	mid <id-group> _<id customer>	30 Days<
Type 4 (old)	Checkpoint (per object), no new creation currently possible	T <id object> L<id-Link><	60 Days
Type 5	System Cookie to identify the users in a session management	PHPSESSID	Quitting the browser session

Evalanche

Freudenberg Performance Materials uses Evalanche for sending newsletters. Provider is Evalanche (SC-Networks GmbH). Würmstraße 4, 82319 Starnberg, GERMANY. Evalanche is a service that enables organization and analysis of the newsletter mailing. The data that you enter to subscribe to the newsletter (e.g., e-mail address) are stored on Evalanche’s servers in Germany. As a provider based in Germany, Evalanche follows strict German and European data protection obligations in accordance with the EU GDPR. Our dealings with sensitive data reflect the high legal requirements and is proactive partly beyond current case law.

Our newsletters sent with Evalanche enable us to analyze the behavior of the newsletter recipients. This serves to analyze among other things, how many recipients have opened the newsletter message and how often recipients clicked on each link in the newsletter. Using so-called conversion tracking we can also analyze whether a pre-defined action takes place after clicking on the link in the newsletter. You can find further information on data analysis using Evalanche at: https://www.sc-networks.com/data-protection/

The data processing is carried out based on your consent (Art. 6, para. 1, lit. a GDPR). You can revoke this consent at any time by cancelling your subscription to the newsletter or opting out of personalized tracking consent. The legitimacy of any data processing procedures that have already been carried out is not affected by the revocation.

If you do not want analysis by Evalanche, then you must cancel your subscription to the newsletter. For this purpose, we provide you with a corresponding link in each Newsletter message

Conclusion of a contract for data processing:
We have established a contract for data processing with Evalanche, and we implement the strict requirements of the German data protection authorities completely in using Evalanche.

Accessing your data

To access your stored data please contact us at newsletters@freudenberg-pm.com

Data use for e-mail advertising without newsletter subscription and your right to object

If we receive your e-mail address in connection with the purchase of goods or services, and if you have not objected to this, then we reserve the right to send you regularly offers on our products similar to the one you have already purchased from our product line. You can object to this use of your e-mail address at any time using a link provided for that purpose in the e-mail.

Use of cookies

To make the design of our website attractive to visit and to enable the use of certain functions, we use so-called cookies on different pages. Cookies are small text files that are stored on your terminal. Some of the cookies used by us are deleted at the end of your browser session, i.e., when you shut down your browser (so-called session cookies). Other cookies remain on your terminal and enable us to recognise your browser again on your next visit (persistent cookies). You can configure your browser so as to be notified when cookies are saved and to decide individually whether to accept them or to exclude the acceptance of cookies in certain cases or in general. If you do not accept cookies, then the operation of our website may be restricted.

More about cookies on our website.

Use of Google (Universal) Analytics for web analysis

This website uses Google (Universal) Analytics, a web analysis service of Google Inc. (www.google.de). Google (Universal) Analytics uses methods that enable an analysis of your use of the website, e.g., so-called “cookies,” text files that are stored on your computer. The information generated by your use of this website is as a rule transferred to one of Google’s servers in the USA and stored there. If IP anonymisation is activated on this website, then the IP address is abbreviated before transfer within EU Member States or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the complete IP address transferred to one of Google’s servers in the USA and abbreviated there. The anonymised IP address transferred in the context of Google Analytics by your browser is not combined with other data by Google.

You can prevent the collection of data generated by the cookie referring to your use of the website (including your IP address) by Google and its processing by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de Instead of the browser plugin you can click on this link in order to prevent data collection by Google Analytics on this website in the future. If you do so, then an opt-out cookie is deposited on your terminal. If you delete your cookies, then you must click on the link again.

Use of Sitecore Tracking

For purposes of further development and to improve our approach to customers with contents customised for the customers, this web presence uses the web analysis service from Sitecore. You can prevent saving of cookies by setting your browser software appropriately. We advise you however that if you do so it is possible that all functions of this website will not be fully available to you.

Information on data processing by Sitecore and the corresponding data protection provisions can be found at: www.sitecore.net/legal/privacy-policy.aspx

Further information on cookies used can be found on our page www.freudenberg-pm.com/Footer/Cookies.

Use of a cookiebot

This website uses the cookiebot service provided by Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark. Information on data processing through Cybot and relevant privacy regulations can be found at: https://www.cookiebot.com/de/privacy-policy/

If an end user provides his or her approval on our websites, the following data are automatically recorded by Cybot:

· Anonymized IP number of the end user (the last three digits are set to “0”).

· Date and time of approval.

· Browser’s user agent of the end user.

· The URL from which approval was sent.

· An anonymous, random, encrypted key.

· The consent status of the end user serving as a verification of approval.

In the end user’s browser, the key and the approval status are also saved in the “CookieConsent” cookie so that the website can automatically read and comply with the end user’s approval and all subsequent website requests and future end-user sessions for up to 12 months. The key is used for verifying the consent and also for an option which checks whether the approval status saved in the end user’s browser remains unchanged from the original approval which was sent to Cybot.

Adjustment of the Data Protection Declaration

Please be aware that we can or could have to make adjustments when relevant in this information pursuant to Art. 13/14 GDPR on data processing. The respective current version of this information pursuant to Art. 13/14 GDPR can be found on our Homepage at all times.