A. Preface

We, Aliaxis Deutschland in conjunction with our subsidiaries (hereinafter jointly referred to as "the company", "we" or "us") is committed to  protecting the personal information and privacy of its customers and other users of the “WorkFlow” Module in the Customer Portal and of the “WorkFlow” App ("customer", "user", "you", "they" or "data subject").This  privacy notice will inform you about the manner in which your personal information is processed by our company. 
 

B. How we collect and use your information

When you use our app, then we will collect personal information about you. Personal information is personal information means information that can identify an individual, directly or indirectly. For example, your name, location data, IP address, device ID, SIM card number, postal address as well as email address are all personal information, your fingerprint, pictures, photographs, images, films, audio recordings, but also your user behaviour falls into this category.

In general, personal information does not include business contact information, such as your title or position, business address, business telephone or fax number.

1.      Personal information collected during a download

When downloading this app, certain personal information which is required for this purpose will be transmitted to the corresponding app store (e.g. Apple App Store or Google Play). In particular, the email address, the user name, the customer number of the downloading account, the individual device identification number, payment information as well as the time of the download will be transmitted to the App Store during the download.

We do not have any influence on the collection and processing of this data, which is executed exclusively by the App Store which you have selected for this purpose. Accordingly, we cannot therefore be held responsible for this collection and processing; the responsibility for this lies solely with the App Store, and we invite you to consult their respective privacy policies.

2.      Personal information collected during use

We can only permanently provide you with the benefits of our app when we collect certain personal information relating to you which is required for the operation of the app when you use it. We only collect this data when it is required for fulfilling the contract which has been concluded between you and us.

Furthermore, we will collect this data when it is required for the functionality of the app and your interest in the protection of your personal information does not outweigh this.

We will collect and process the following data from you:

·        Device information: Access data in this case includes the IP address, device ID, type of device, device-specific settings and app settings as well as app characteristics and their properties, the date and time of the retrieval, time zone, the amount of data transferred and the message whether the data exchange was complete, any app crash, browser type and operating system. This access data will be processed in order to enable the technical operation of the app.

·        Data which you make available to us: You need to create a user account in order to utilise the app. You must enter your login name as a minimum requirement for this purpose. Moreover, an essential part of the app is the transmission of photographs for the documentation of fusion procedure. You can always determine the content of the transmitted photographs; we never have any influence on them. In principle, these photographs can also contain personal information which relates to you. We will store and process the transmitted photographs within the framework of the user agreement on your behalf/on behalf of your company on the basis of an order data processing agreement.

·        Information with your consent: We will process miscellaneous information (e.g. GPS location data) when you permit us to do so. Note that the App may not work in whole or in part if some features are turned off.

·        Contact form data: If contact forms are used, then the data which is transmitted through them will be processed (e.g. gender, surname and first name, postal address, company, email address and the time of transmission).

We do not intend to utilise any personal information collected from you for any automated decision making process (including profiling).

 

C. How we disclose your personal information

It can occur that service providers are utilised for individual functions of our app. As with any other larger company, we also place orders with external domestic and foreign service providers to process our business transactions (e.g. for the areas of IT, logistics, telecommunications, sales, distribution and marketing). These service providers are only active according to our issued instructions and are always contractually obliged to comply with the provisions of applicable privacy legislation.

The following type of entities may receive access to your personal information when applicable:

·        Service providers for the operation of our app and for processing of data which is stored on and/or transmitted by the systems (e.g. for data centre services, payment processing, IT security);

·        Government agencies, bodies/local authorities, insofar as this is required for the fulfilment of a legal obligation, including to protect the rights, property or personal safety of the company, our users, employees, or others;

·        People who are assigned to execute our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties which are involved in company acquisitions or the establishment of joint ventures). Any third party to which assets of Aliaxis are sold will have the right to continue to use the information that you provided to us, provided that we comply with applicable federal, state and provincial privacy legislation governing such disclosures.

Furthermore, we will only pass on your personal information to other third parties when you have submitted your express consent or as permitted or required by applicable law.

Insofar as personal information from you is transferred on by us to our subsidiaries or is transferred to us by our subsidiaries (e.g. for advertising purposes), then this will be implemented on the basis of existing order processing relationships.

We may, without restriction, disclose aggregated and anonymous information concerning our users and information that does not identify any individual or disclose personal information.

 

D. Cookies and other tracking technologies

We use cookies when operating our app. Cookies are considered to be small text files which are stored on the device memory of your mobile end device and assigned from there to the mobile app which you are currently utilising and, through which, certain information can flow to the facility which has set the cookie. Cookies cannot execute programs or transfer viruses to your computer and therefore cannot cause any damage to it. They are only intended to make our app more user-friendly and effective overall, i.e. more pleasant for you.

Cookies can contain data which make it possible to recognise the device that is being used. In some cases, however, cookies only contain information on certain settings which are not personally identifiable. Cookies cannot directly identify a user. One makes a distinction between session cookies, which are deleted again as soon as you close your browser, and permanent cookies, which are stored beyond the time of the individual session. One makes a distinction between cookies with regard to their function.

·        Technical cookies: These are considered to be mandatory in order to move around within the app, to use basic functions and ensure the app's security; they do not collect information about you for marketing purposes nor do they store information about which websites you have visited;

·        Performance cookies: These collect information about how you use our app, which pages you visit and, for example, whether errors occur when using the app; they do not collect any information which could identify you - all the information collected is anonymous and is only utilised in order to improve our app and find out what interests our users;

·        Advertising cookies, targeting cookies: These are utilised to provide the app user with tailored advertising within the app or third party offers and to measure the effectiveness of these offers; advertising and targeting cookies will be stored for a maximum of 13 months;

·        Sharing cookies: These are intended to improve the interactivity of our app with other services (e.g. social networks); Sharing cookies will be stored for a maximum of 13 months.

Any utilisation of cookies, which is not absolutely technically required, constitutes data processing that is only permitted with your explicit and active consent. This applies in particular to the utilisation of advertising, targeting or sharing cookies. Furthermore, we will only pass on your personal information that is processed by cookies to other third parties when you have submitted your express consent to do so or as permitted or required by applicable law.

For additional information regarding which cookies we utilise, as well as how you can manage your cookie settings and disable certain types of tracking, please refer to our cookie guideline https://www.aliaxis.de/de/metanavigation/datenschutz.

Integration of Google Maps

Our app uses the services provided by Google Maps. We can thereby show you interactive map and localisation data directly in the app and also enable you to use the map and localisation function conveniently.

Google receives information about your location when you are using this function. The data additionally mentioned in section 2 of this declaration will be transmitted. This occurs irrespectively of whether Google provides a user account via which you are logged in, or whether no user account exists. Your data will be directly assigned to your account when you are logged in to Google.

When you wish that your data will not be associated with your Google profile, then you must always log out before using the app. Google stores your data as usage profiles and utilises it for the purposes of advertising, market research and/or the needs-based design of its website. Such an evaluation is particularly executed (even for users who are actually not logged in) to provide needs-based advertising and to inform other social network users about your activities on our website. You retain the right to object to the creation of these user profiles, whereby you must always contact Google in order to exercise this right.

For any additional information regarding the purpose and scope of data collection, as well as its processing by the plug-in provider, please refer to the provider's privacy policy. You will also find further information about your rights in this regard and setting possibilities for protecting your privacy there: https://policies.google.com/privacy. 

 

E. Retention period of personal information

We retain personal information only as long as necessary for the fulfillment of the purposes for which it was provided, or for legal or commercial purposes.

 

F. Transfer of personal information to other jurisdictions 

We will store personal information on our internal servers or with service providers. Personal information collected about you may be stored and/or processed outside the jurisdiction in which you reside, including Canada, the United States and the European Union.

When information is stored or processed outside your jurisdiction, it may be subject to the laws of, and accessible by, legal authorities in those other jurisdictions. Therefore your information might not benefit from the same confidentiality and security as the jurisdiction in which it was collected.

We endeavour to put in place appropriate contractual measures to ensure that your personal Information is treated by those third parties in a way that is consistent with and which respects applicable privacy legislation.

G. Children and minor

We do not knowingly collect personal information from children under the age of 14.  Children may not use the App or Customer Portal, and we request that children under the age of 14 not submit any personal information through the App or Customer Portal.

H. Information security

We utilise appropriate technical and organisational security measures in order to protect your data against accidental or intentional manipulation, partial or complete loss, data destruction or against unauthorised access by third parties, always taking into account the state of the art, implementation costs and the nature, scope, context and purpose of the processing, as well as considering the existing risks of a data breach (including its probability and impact) for the data subject involved. Our security measures will be continuously improved in line with technological developments.

However, there are no guarantees that information cannot or will not be accessed, disclosed, altered or destroyed by breach of any of our administrative, technical or physical controls.
 
I. Your rights

Subject to exceptions as provided by the applicable laws:

·        Right to access your information: You retain the right vis-à-vis our company to receive information about the personal information which concerns you. This right therefore requires that you submit a request, which must be sent either by email or by post to the addresses stated below.

·        Right to rectification: Insofar as personal information which concerns you is deemed to be incorrect, then you retain the right to demand that we rectify this without delay. To do so, please contact the contact point which has been included below.

·        Right to revoke the provided consent: You retain the right to revoke your consent - i.e. your voluntary will, made clear in an informed and unambiguous manner by a statement or other unambiguous affirmative act, that you agree to the processing of the personal information concerned for one or more specific purposes - which had been submitted once to us at any time. This will have the consequence that we may no longer continue the data processing based on this consent in the future. To do so, please contact the contact point which has been included below.

J. Changes to this privacy notice

We reserve the right to change this policy at any time. A revised notice will be posted on our website, in a timely manner. We encourage you to examine our website from time to time to ensure you are aware of any changes we made relation to the use, disclosure or retention of your personal information. By continuing to use of our website following any changes to this notice and providing your personal information, you consent to any such changes.

K. Contact us

Our Data Protection Officer is available at all times to answer any questions which you may have and to act as your contact person on the subject of the processing of personal information at our company. You can contact them at datenschutz@aliaxis.com or at our postal address:

Data Protection Officer
Aliaxis Deutschland GmbH
Steinzeugstraße 50, 68229
Mannheim, Germany