- Privacy Notice
- Information for Clients, Business Partners and Prospective Clients on the data processing of personal data
Privacy Notice of Suedwolle Group Italia S.p.A.
As the operator of this website (https://www.suedwollegroup.com/swgi), Suedwolle Group Italia S.p.A., Via del Mosso 10, 13894 Gaglianico, Italia, is the controller in the sense of the EU General Data Protection Regulation (GDPR) who individually or jointly makes decisions on the purposes and means of the processing of personal data, hereafter referred to as “data.”
2. Processing of Personal Data
According to the General Data Protection Regulation, personal data is any information concerning an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier (such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Use of our website does not require you to provide data. However, in certain cases, we will need your name, address and additional information to perform your requested services.
The same applies to, e.g., the sending of information material and ordered goods and to responses to individual inquiries. We will notify you when required. Furthermore, we only process data you provide to us voluntarily and data that is collected automatically when our website is visited (e.g., your IP address and the names of the pages you opened, your browser and operating system, time and date of access, search engines used or names of downloaded files).
If you request our services, usually only the data required for us to perform the service will be collected. Any additional data we may request may be provided voluntarily.
Data will only be processed to perform requested services and to safeguard our legitimate business interests.
3. Protection of Your Personal Data
Thank you for your interest in our company and our products and services. We want you to feel safe about your data when visiting our website. We take the protection of your data very seriously and strictly adhere to the General Data Protection Regulation and the German Federal Data Protection Act [Bundesdatenschutzgesetz, BDSG] in its respectively valid form.
We implemented technical and organizational measures to ensure compliance with data protection regulations by both us and our commissioned external service providers. We require our employees and commissioned service providers to maintain confidentiality and adhere to the General Data Protection Regulation and the German Federal Data Protection Act in its respectively valid form.
4. Purposes for Processing Personal Data
We will process the data you provide in accordance with the principles of data economy and purpose limitation. The principle of purpose limitation states that data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes is not considered to be incompatible with the initial purposes.
We only process your data to answer inquiries, handle your orders and provide access to certain information or offers to you. Maintaining customer relationships may also require us or a commissioned service provider to use this data to inform you about product offers or to conduct online surveys to fulfill the tasks and requirements set by our customers.
We will only process the data you provide online for the stated purposes. Your data will not be transferred to third parties without your express consent.
Data will only be collected or transmitted to authorized state institutions and officials in accordance with applicable laws or if we are required to do so due to a court order.
We respect that you may not wish to provide your data to support our customer relationship (especially not for direct marketing or market research purposes). We will not sell your data to third parties or otherwise market your data without your consent.
5. Data Collected Automatically When Visiting Our Website
When using our website, the following data may be processed for technical and organizational reasons: The names of the pages you opened, your browser and operating system, time and date of access, search engines used or names of downloaded files and your IP address.
When you visit our website, we may save information on your computer in form of a (session) cookie. Cookies are small text files transmitted by a web server to your browser and saved on your computer’s hard disk.
Except for your IP address, no personal user data will be saved. This information allows you to be automatically recognized during your next visit to our website and makes navigation easier. Cookies enable us to, e.g., adjust our website to your interests and to save your password so that you won’t have to re-enter it every time you visit our website.
You may also view our website without cookies. If you do not want us to recognize your computer, you may prevent cookies from being saved on your hard disk by setting your browser to “Disable cookies.” For detailed instructions, please see your browser’s help function. However, please note that disabling cookies may prevent you from fully using every function of our offers.
7. Use of Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
The information generated by the cookie about your use of this website will generally be transmitted to and stored by Google on servers in the United States. If IP anonymisation is activated on this website, however, Google will shorten your IP address beforehand within member states of the European Union or in other signatory states to the Agreement on the European Economic Area (so-called IP masking).
Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. IP anonymization is active on this website. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services to website operators relating to website activity and internet usage.
As an alternative to the browser plug-in or on browsers of mobile devices, you can click this link to prevent Google Analytics from collecting data on this website in the future. An opt-out cookie is placed on your device. If you delete your cookies, you must click the link again.
8. Use of Instagram
If you do not want Instagram to assign your visit to our website to your Instagram account, please log out of your Instagram account before visiting our website.
9. Use of WeChat
Our website uses “WeChat“ which is operated by Tencent Holdings Ltd., Tencent Building, Kejizhongyi Avenue, Hi-tech Park, Nanshan District, Shenzhen, P. R. China. WeChat App offers many possibilities of communication, such as transferring texts, photos, videos, voice mail etc. to other users.
If you use WeChat, your data and information that you opened a certain page of our website offer will be transmitted to the servers of WeChat and processed in China. This means that usage data will be assigned to your personal account. Even if you do not have a WeChat social media account, WeChat may obtain and save your IP address.
10. Children and Young People
Our website is aimed exclusively at potential applicants/customers, business partners and media representatives.
Persons under 16 years of age should not transmit data to us without the permission of a parent or guardian. We do not request data from children or youths who have not yet completed their sixteenth year of life. We do not collect such data or provide such data to third parties.
We implemented technical and operational protective measures in accordance with the applicable legal regulations to protect your data from, loss, destruction, manipulation and unauthorized access. Our security measures are reviewed regularly and adjusted to technological advances. All our employees and all persons participating in data processing are required to adhere to the General Data Protection Regulation, the German Federal Data Processing Act in its respectively valid form and other laws relevant for data protection and must treat data confidentially.
Furthermore, we conclude according agreements with any external service providers we commission.
Our security measures are regularly reviewed and adjusted in accordance with technological advances.
Should the processing of your data require your consent, we will obtain it from you and use your data for the stated purposes for which we requested your consent. Your consent will be documented digitally.
You may revoke your consent at any time with future effect. To do so, please write us at email@example.com.
14. Application Process
By transmitting your applicant data, you consent to the processing of your data for the respective application process. You may revoke your consent at any time with future effect.
15. Data Subject Rights
If we process your data, you are entitled the following extensive rights as a data subject:
a) Right to Information
Under Art. 15 of the General Data Protection Regulation, you have the right to information about the data processed by us.
You may especially obtain information about the purposes of the processing, the categories of personal data concerned, the categories of possible recipients and the envisaged period for which the personal data will be stored.
Please submit information requests to firstname.lastname@example.org
b) Right to Rectification
Under Art. 16 of the General Data Protection Regulation, you have the right to obtain rectification or completion of your data from us.
You may exercise this right by contacting the above-stated addresses.
c) Right to Erasure
Under Art. 17 of the General Data Protection Regulation, you have the right to obtain erasure of personal data concerning you if storage of the data is no longer required and if there is no other legal ground for its processing. You may also obtain erasure if you object to the processing and there are no overriding legitimate grounds for the processing and if your data was processed unlawfully or if the personal data must be erased for compliance with a legal obligation under EU or national law.
You may exercise this right by contacting the above-stated addresses.
d) Right to Restriction of Processing
Under Art. 18 of the General Data Protection Regulation, you have the right to obtain the restriction of processing if you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of your personal data; if the processing is unlawful, but you oppose the erasure of your personal data; the purposes for the processing cease to apply, but the data is required for the establishment, exercise or defense of legal claims or if you objected in accordance with Art. 21 of the General Data Protection Regulation and if whether the legitimate grounds of the controller outweigh your interests has not yet been determined.
You may exercise this right by contacting the above-stated addresses.
e) Right to Data Portability
Under Art. 20 of the General Data Protection Regulation, you have the right receive your personal data in a structured, commonly used and machine-readable format (data portability). In addition, under certain circumstances, you may also receive your data directly from a controller if technically possible.
You may exercise this right by contacting the above-stated addresses.
16. Right to Object
You have the right to object to use of your data for the above-stated purposes at any time (Art. 21 of the General Data Protection Regulation). This is possible for objections to direct marketing or on grounds relating to your particular personal situation. If you object to direct marketing, we will implement your general objection right without information about your particular personal situation.
To exercise your right to object, please write us at email@example.com.
17. Questions, Suggestions, Complaints to the Internal / External Data Protection Officer
Suedwolle Group Italia SpA
Via del Mosso 10
Information requests, suggestions and complaints may also be submitted to the data protection officer.
18. Right to Submit a Complaint to a Supervisory Authority
Please also note that, irrespective of other administrative or legal remedies, you have the right to submit complaints to supervisory authorities, especially in the Member state of your habitual residence, place of work or place of the alleged infringement if you believe that the processing of your personal data infringes on the General Data Protection Regulation.
A list of (non-public sector) supervisory authorities and their addresses is provided (in German) at:
Information for Clients, Business Partners and Prospective Clients on the data processing of personal data under Art. 13 and 14 of the General Data Protection Regulation
Dear clients, business partners and prospective clients,
As the controller, we hereby inform you as a client, business partner or prospective client that we, the
Suedwolle GmbH & Co. KG
90571 Schwaig, Germany
will process your personal data (hereafter referred to as “data”) in accordance with the EU General Data Protection Regulation (GDPR) and the new version of the German Federal Data Protection Act [Bundesdatenschutzgesetz, BDSG] in its currently version. You or your employees are data subjects in the sense of Art. 4 Number 1 of the General Data Protection Regulation.
The controller is subject to the following obligations to provide information to clients, business partners or prospective clients:
1. At the time of the data collection, under Art. 13(1) and Art. 14(1) of the General Data Protection Regulation, the controller must inform the data subject about the following if the data subject does not already possess this information:
a) Name and contact details of the controller and, if applicable, of his deputy
Responsible for adherence to data protection regulations is the controller and, therefore, the management. At our firm, this are:
Manfred Heinrich (managing director)
Johannes Rauch (managing director)
Stéphane Thouvay (managing director)
Hans-Georg von Schuh (managing director)
b) Contact details of the data protection officer
Our internal data protection officer is:
90571 Schwaig, Germany
Telefon: +49 (0) 911 / 50 480 – 184
Our internal data protection coordinators are:
Elena Haft (HR)
Manuel Grad (IT)
Judith Mantel (Marketing)
Wolfgang Seifert (Distribution)
c) Data processing purpose and legal basis
Data processing (especially the collection, use, storage or transmission) is performed for the purpose of contract fulfillment (contract performance, payment, client and invoice management, reporting), for the purpose of the implementation of pre-contractual measures (especially those made on request by a data subject, i.e., offers), for the purpose of the fulfillment of legal obligations or to safeguard legitimate interests (acquisition).
The legal basis for the processing of the client, business partner or prospective client data is especially Art. 6(1) Letter b of the General Data Protection Regulation (data processing for the performance of a contract), Art. 6(1) Letter f of the General Data Protection Regulation (data processing for the purposes of legitimate interests), Art. 6(1) Letter c of the General Data Protection Regulation (compliance with a legal obligation).
Another legal basis may be the consent of the client, business partner or of the prospective client in the sense of Art. 6(1) Letter a of the General Data Protection Regulation.
d) Legitimate interests of the controller or of a third party
If processing is performed on the basis of Art. 6(1) Letter f of the General Data Protection Regulation for the purposes of the legitimate interests pursued by the controller or by a third party, the client, business partner or prospective client must be informed about this. Legitimate interests may include legal, economic or intellectual interests whose legitimation must be determined by a weighing of the employee’s interests in each case.
In this case, processing may also be performed on the basis of economic interests that consist of establishing or maintaining a business relationship.
e) Recipients or categories of recipients
Under Art. 4 Number 9 of the General Data Protection Regulation, recipients of your data may include natural or legal persons, public officials or institutions.
Your data may be transferred to our competent internal offices.
In addition, your data may be transferred to external services providers (e.g., data destruction or accounting service providers). The service providers commissioned by us (commissioned processors) were carefully selected and reviewed by us. In addition, we conclude processing agreements with every commissioned processor in accordance with Art. 28 of the General Data Protection Regulation.
f) Data transmissions to third countries or international organizations
Your data will be processed exclusively within the EU and saved on secured servers in Germany under adherence to the General Data Protection Regulation. Data is not currently transmitted to third countries or international organizations.
If, during processing, your data is transmitted to countries outside of the EU or the EEA or to service providers in countries outside of the EU or the EEA (so-called third countries), we will check whether an adequacy decision by the European Commission is present or will conclude according data protection agreements, especially on commissioned processing and EU standard contract clauses.
g) Categories of personal data
For the cooperation, we will process in particular the following data concerning you:
• Identification data (e.g., name, first name, picture, gender, date of birth);
• Contact data (e.g., address, telephone numbers and email address)
• Position-related data (e.g., title/position, status, supervisors)
• Professional qualifications (e.g., report cards, driver’s license)
• Payment/financial information (e.g., account information, tax information)
• Other data disclosed voluntarily
2. Furthermore, at the time of data collection, the controller must inform the data subject about the following under Art. 13(2) and Art. 14(2) of the General Data Protection Regulation unless the data subject already possess this information:
a) Sources of personal data
Usually, your data will have been provided to us by you voluntarily. It is important for this data to be accurate and for you to assist us in keeping this data up to date.
Other sources include among other things:
• You contacting us
• Financial situation (via credit agencies)
• Business partners/suppliers
• Marketing measures (e.g., advertising)
• Certain publicly accessible information from public sources (including from the Internet)
b) Storage duration
We will only save your data until the pre-contractual or contractual purpose is fulfilled and no other legal storage obligations apply (e.g., commercial law or tax law storage requirements).
If you granted your consent, we will save your data until you withdraw your consent if there is no other legal basis for the processing of your data. You granted your consent to us by contacting us / subscribing to our newsletter.
c) Your data subject rights
Under Art. 15 of the General Data Protection Regulation, you may obtain information about the data we process concerning you at any time. You may especially obtain information about the purposes of the processing, the categories of processed data, the categories of possible recipients and the scheduled storage duration.
In addition, under Art. 16 of the General Data Protection Regulation, you may obtain rectification of any inaccurate data.
Additionally, under Art. 17 of the General Data Protection Regulation, you may obtain the erasure of data concerning you if its storage is no longer required, you withdraw your consent to the data processing and if there is no other legal basis for the processing, you object to the processing and there are no overriding reasons for further processing your data, your data is processed unlawfully or in case of a legal erasure obligation under EU or national law.
Furthermore, under Art. 18 of the General Data Protection Regulation, you have a right to restricted processing if you contest the accuracy of the data concerning you for a duration that allows the controller to review the accuracy, if the processing is unlawful, but you reject the erasure of the data, the purpose for the processing no longer applies, but the data is still needed for the exercise of legal claims or if you object in accordance with Art. 21 of the General Data Protection Regulation and whether the legitimate reasons of the controller override your interests has not yet been determined.
Furthermore, under Art. 20 of the General Data Protection Regulation, you have the right to receive the data concerning you in a commonly-used, structured and machine-readable format (data portability). In addition, under certain conditions, you may have your data transmitted directly by a controller if technically feasible.
You have the right to object to the use of your data for the above-stated purposes at any time (Art. 21 of the General Data Protection Regulation).
If you consent to our processing of your data, you may withdraw this consent at any time for the future.
If you would like to withdraw your consent or exercise the above-stated data subject rights, please write us at Suedwolle GmbH & Co.KG, Wieseneckstr. 26, 90571 Schwaig, Germany, or send us an email at firstname.lastname@example.org.
d) Right to lodge a complaint to a supervisory authority
You may lodge a complaint to a data protection supervisory authority at any time (Art. 77 of the General Data Protection Regulation). A list of supervisory authorities in Germany (for the non-public sector) and their addresses can be found at:
e) Providing data
If the providing of data is legally or contractually required or necessary for contract conclusion, the client, business partner or prospective client must be informed about this.
Data (e.g., one’s name, address or email address) is especially required for the establishment of contractual relationships. Invoicing and payment processing require additional data (e.g., the invoice recipient, account data and invoice address).
If you do not provide your data to us, we will be unable to establish or maintain a business relationship with you and cannot ensure the orderly fulfillment of contractual or legal obligations.
f) Automated decision-making, including profiling
No automated decision-making, including profiling, is performed (Art. 22 of the General Data Protection Regulation).
3. Information concerning intended changes to data processing purposes
We will only process your data for the above-stated purposes. Should the purposes for data processing change, we will inform you about the new purpose in time before any further processing.
President ERWO Holding AG