Data protection statement

1. Controller as defined by data protection legislation

Klüber Lubrication München SE & Co. KG (hereinafter referred to as “Klüber Lubrication”) is a globally operating company and part of the Freudenberg Group. Personal data is processed by Klüber Lubrication employees, national sales companies and affiliated companies.

Who the controller is with respect to data protection legislation depends on the specific digital product being used. There is no joint responsibility between the companies unless this has been indicated separately:

The controller as defined by data protection legislation is:

For the MyKlüber app:
Klüber Lubrication München SE & Co. KG (hereinafter “Klüber”)
Geisenhausenerstraße 7
81379 München
Tel.: +49 89 78 76-0
Fax: +49 89 78 76-333
E-Mail: info@klueber.com

For the Chem-Trend Now app:
Chem-Trend L.P.
1445 W. McPherson Park Drive
Howell, Michigan 48843
U.S.A.
Tel: +1 517-545-7980
Fax: +1 517-546-1199

For the Efficiency Manager / Webshop / Homepage:
Klüber Lubrication München SE & Co. KG (im Folgenden „Klüber“)
Geisenhausenerstraße 7
81379 München
Tel.: +49 89 78 76-0
Fax: +49 89 78 76-333
E-Mail: info@klueber.com

  • Hereinafter also referred to as “Klüber”

You can contact our data protection officer as follows:

Data protection officer of Klüber Lubrication München SE & Co. KG
c/o activeMind AG
Potsdamer Str. 3
80802 München
Telefon: +49 (0)89 / 91 92 94 – 900
E-Mail: klueber@activemind.de

2. Your rights as the data subject

Every data subject has the right to information according to Art. 15 GDPR, the right to rectification according to Art. 16 GDPR, the right to erasure according to Art. 17 GDPR, the right to the restriction of processing according to Art. 18 GDPR, the right to object from Art. 21 GDPR and the right to data portability from Art. 20 GDPR.

The restrictions under Sections 34 and 35 BDSG apply to the right to information and the right to erasure.

You can revoke consent issued to us previously for the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued to us before the General Data Protection Regulation came into force, i.e. prior to 25 May 2018. Please note that such revocation only applies to the future. Processing that took place prior to consent being revoked is not affected by such.

Furthermore, relevant persons have a right of appeal to a responsible data protection supervisory authority (Art. 77 GDPR in connection with Section 19 BDSG). A list of supervisory authorities (for the non-public area) with address details is available at:

https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Information on your right to object according to Art. 21 GDPR is provided at the end of the document

3. Processing activities within FCS Customer Apps

The relevant controller has the option of transmitting your data to affiliated companies. For data processed in countries outside the EU, EU standard contractual clauses, including suitable technical and organisational measures, are used to ensure that your personal data is processed in accordance with the European level of data privacy.
Please contact our data protection officer if you would like to receive concrete information on the processing of your data in other countries.

Other special recipients are specified during the respective processing activities.

I. Processing activities within the digital products

The processing activities listed here apply to the digital product used by you. Refer to section 1 to find out which digital product belongs to which controller. It may be the case that not all processing activities take place in each digital product. If you would like to receive more detailed information on this topic, please contact our data protection officer.

(1) Registration in the digital products

Type and purpose of processing:
When you register for use of the personalised services of the app, some personal data is collected, such as your first name, surname, contact and communication details (e.g. phone number and e-mail address), country, employer, user ID. Once you are registered, you can access contents and services, which are only available to registered users, e.g. further information on the products. Accesses to such are recorded and stored by us. Registered users may also change or erase any of the data they specified when registering by request at any time (with the exception of the country). This registration also allows you to log in to web shops and websites of the controllers.

At the same time, joint responsibility exists between the companies, in whose app you register, amongst each other and with Klüber. The respective app provider is responsible for the obligations from the GDPR, in particular the fulfilment of data subject rights and the duties to inform.

Legal basis:
Data entered during registration is processed on the basis of the user’s consent (Art. 6 (1) (a) GDPR).

Recipients:
Data recipients include technical service providers who are responsible for the operation and maintenance of our application as processors.
• Microsoft Azure Cloud (Host)
• Klüber, unless Klüber is the Controller.

Third-country transfer:
A transfer to the following third countries can take place:
[...]
If an adequacy decision according to Art. 45 GDPR exists for these countries, the data transfer takes place on the basis of this decision. In all other cases, the standard contractual clauses according to Art. 46 (2) (c) GDPR serve as suitable guarantees.
Please contact our data protection officer for more details.

Storage period:
Data will only be processed in this context for as long as the corresponding consent applies or the purpose no longer applies. Data will be erased at the latest three years from the end of the year following the user's last login unless statutory retention obligations apply.

Prescribed or required provision:
You provide your personal data on a voluntary basis, based solely on your consent. We will not be able to provide you with access to the contents and services offered additionally without the provision of your personal data.

Use of Cookies:
Cookies are small files sent by a web server to your browser and stored on your devices. EU Directive 2009/136/EC stipulates that we may store cookies on your computer if they are essential for operation of this website without your consent.

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

For the domain fcsidentity.azurewebsites.net, we only use necessary cookies:

Name
.AspNetCore.Antiforgery.w5W7x28NAIs
Purpose
Communicate to linked applications if the user is logged in
Expiry
Session
Type
http Cookie

Name
.AspNetCore.Identity.Application
Purpose
Communicate to linked applications if the user is logged in
Expiry
Session
Type
http Cookie

Name
ai_session
Purpose
Documentation if error occured
Expiry
30 minutes
Type
http Cookie

Name
ai_user
Purpose
Documentation if error occured
Expiry
1 year
Type
http Cookie

Name
ARRAffinity
Purpose
Communicate to linked applications if the user is logged in
Expiry
Session
Type
http Cookie

Name
ARRAfinitySameSite
Purpose
Communicate to linked applications if the user is logged in
Expiry
Session
Type
http Cookie

Name
idsrv.session
Purpose
Communicate to linked applications if the user is logged in
Expiry
Session
Type
http Cookie

(2) Product scan

Type and purpose of processing:
If the user has registered in the application, data collected when scanning the product, such as first name, surname, contact and communication details (e.g. phone number and e-mail address), country, employer, will be stored and linked to the scan. This helps us assign the product scan to a user. If you have also agreed to location determination (see below), your position at the time of scanning will also be stored.

The data is collected in anonymised form before the personal reference is erased at the end of the storage period. A personal reference can no longer be created following this.

Legal basis and legitimate interest:
Data received via the product scan is processed on the basis of a legitimate interest (Art. 6 (1) (f) GDPR).
This processing takes place in order to trace the route of a product. This allows you to identify the source of counterfeiting according to the principle of exclusion. This results in increased product and workplace safety. This also allows the relevant documents (product data sheets, safety instructions etc.) to be provided in the correct language and according to the legal requirements.

Recipients:
Data recipients include technical service providers who are responsible for the operation and maintenance of our application as processors:
• Microsoft Azure Cloud (Host)
• SDX (technical service provider for operation and maintenance)
• Klüber, unless Klüber is the Controller.

Third-country transfer:
A transfer to the following third countries can take place:
[...]
If an adequacy decision according to Art. 45 GDPR exists for these countries, the data transfer takes place on the basis of this decision. In all other cases, the standard contractual clauses according to Art. 46 (2) (c) GDPR serve as suitable guarantees.
Please contact our data protection officer for more details.

Storage period:
Personal data is erased at the latest three years after collection.

Prescribed or required provision:
You provide your personal data on a voluntary basis. We cannot provide you with any further information on the scanned product if you do not enter your personal data.

(3) Location determination

Type and purpose of processing:
If location determination is agreed, the location of the scanning device will be processed upon collection of the product. This is used to determine the route our products will take. In addition, this helps us identify counterfeiting and incorrect labelling.
The exact GPS position and date/time are collected. The data is collected in anonymised form before the personal reference is erased at the end of the storage period. A personal reference can no longer be created following this.

Legal basis:
Data entered during localisation is processed on the basis of the user’s consent (Art. 6 (1) (a) GDPR).

Recipients:
Data recipients include technical service providers who are responsible for the operation and maintenance of our application as processors:
• Microsoft Azure Cloud (Host)
• SDX (technical service provider for operation and maintenance)
• Klüber, unless Klüber is the Controller.

Third-country transfer:
A transfer to the following third countries can take place:
[...]
If an adequacy decision according to Art. 45 GDPR exists for these countries, the data transfer takes place on the basis of this decision. In all other cases, the standard contractual clauses according to Art. 46 (2) (c) GDPR serve as suitable guarantees.
Please contact our data protection officer for more details.

Storage period:
Data will only be processed in this context for as long as the corresponding consent applies. It will then be erased or anonymised unless statutory retention obligations apply. To contact us on this issue, please use the contact details provided at the end of this data protection statement. Data will be deleted at the latest after three years from the end of the year following collection.

Prescribed or required provision:
You provide your personal data on a voluntary basis, based solely on your consent. If you do not provide your personal data, we cannot track the routes our products take, making it more difficult to tackle counterfeiting and incorrect labelling effectively.

(4) Feedback form

Type and purpose of processing:
The data you enter is processed for the purpose of individual communication with you.

Legal basis and legitimate interest:
We process the data entered in the contact form on the basis of a legitimate interest (Art. 6 (1) (f) GDPR).
The purpose of the contact form is to provide you with a simple way to make contact. The information you provide is stored in order to respond to your enquiry and any follow-up questions. If you contact us to request a quotation, the data entered in the contact form will be processed in order to implement pre-contractual measures (Art. 6 (1) (b) GDPR).

Recipients:
Data recipients include technical service providers who are responsible for the operation and maintenance of our application as processors:
• Microsoft Azure Cloud (Host)
• SDX (technical service provider for operation and maintenance)
• Klüber, unless Klüber is the Controller.

Storage period:
Data is erased at the latest six months after processing the enquiry.
If a contractual relationship is concluded, we will be subject to the statutory retention periods and will erase your data after six or ten years.

Prescribed or required provision:
You provide your personal data on a voluntary basis. However, we can only process your enquiry if you communicate your name, e-mail address and the reason for your enquiry.

(5) Transmission of error reports

Type and purpose of processing:
If a scanned barcode cannot be found in the system, you have the option of sending an error report containing additional information to the relevant Controller.

Legal basis and legitimate interest:
The data entered in the error report is processed on the basis of a legitimate interest (Art. 6 (1) (f) GDPR).
This report helps identify counterfeiting and helps effectively prevent such cases. In addition, errors can be identified in the system or app in this way.

Recipients:
Data recipients include technical service providers who are responsible for the operation and maintenance of our application as processors:
• Microsoft Azure Cloud (Host)
• SDX (technical service provider for operation and maintenance)
• Klüber, unless Klüber is the Controller.

Storage period:
Data is erased at the latest three years after processing.

Prescribed or required provision:
You provide your personal data on a voluntary basis. However, we can only process errors and try to eliminate them going forward if you provide us with relevant information.

(6) Transmission of app analytics data

Type and purpose of processing:
If consent has been given to the transmission of app analytics data, data on user behaviour will be processed in order to improve app functions, optimise the product verification process and provide new features. This also covers regional particularities in app usage. This data contains information on the device, product life, user behaviour on the whole and after updates or new features, user ID, location and other information if applicable.
The data is collected in anonymised form before the personal reference is erased at the end of the storage period. A personal reference can no longer be created following this.

Legal basis:
Data entered during registration is processed on the basis of the user’s consent (Art. 6 (1) (a) GDPR).

Recipients:
Data recipients include technical service providers who are responsible for the operation and maintenance of our application as processors:
• Microsoft Azure Cloud (Host)
• SDX (technical service provider for operation and maintenance)
• Klüber, unless Klüber is the Controller.

Third-country transfer:
A transfer to the following third countries can take place:
[...]
If an adequacy decision according to Art. 45 GDPR exists for these countries, the data transfer takes place on the basis of this decision. In all other cases, the standard contractual clauses according to Art. 46 (2) (c) GDPR serve as suitable guarantees.
Please contact our data protection officer for more details.

Storage period:
Data is anonymised as quickly as possible following collection and then deleted; this takes place at the latest six months after collection.

Prescribed or required provision:
You provide your personal data on a voluntary basis. However, we can only make effective improvements to the application going forward if you allow us to process the necessary information in this regard.

II. Changes to our data protection regulations

We reserve the right to adjust this data protection statement so that it is always compliant with the latest statutory requirements or in order to make changes to our services in the data protection statement e.g. when introducing new services. The new data protection statement will then apply the next time you use the application.

III. Questions to the data protection officer

If you have any questions about data protection, please get in touch using the contact details provided. You should also let us know which app you are using specifically:

Data protection officer of the FCS Group
c/o activeMind AG
Potsdamer Str. 3
80802 Munich
+49 89 919294-900
datenschutz@klueber.com

Information on your right to object according to Art. 21 GDPR is provided at the end of the document

4. Processing activities within Efficiency Manager

For data processed in countries outside the EU, Klüber uses EU standard agreements, including suitable technical and organisational measures, to ensure that your personal data is processed in accordance with the European level of data privacy. An overview of subsidiaries within the corporate group is available here:
www.klueber.com/de/kontakt/klueber-lubrication-subsidiaries.
Other special recipients are specified during the respective processing activities.

I. Processing activities within Efficiency Manager

Note: Such processing only takes place if you use the Efficiency Manger. If you only use the MyKlüber app, the processing activities specified here will not be carried out and do not therefore apply to you.

(1) Using the service platform

Type and purpose of processing:
We obtain the first name, surname, name of the organisation, as well as the e-mail address and user-defined password within the scope of registration. Provided that further users are registered in user management, we likewise obtain first name, surname and the e-mail address. You use your e-mail address and password to log in to the Efficiency Manager. Function/position, department and telephone number are provided voluntarily.
The Efficiency Manager user can save maintenance tasks with or without allocation of a user/user group. Personalised allocation to maintenance tasks will not be evaluated by Klüber Lubrication München SE & Co. KG, when applied.

Legal basis and legitimate interest:
Data entered during registration is processed on the basis of the user’s consent (Art. 6 (1) (a) GDPR).

Recipients:
This data is provided to the following departments within our company: IT and other departments that provide support for the application.
Data recipients may include technical service providers who are responsible for the operation and maintenance of our application as processors.

Storage period:
Data will only be processed in this context for as long as the corresponding consent applies. To contact us on this issue, please use the contact details provided at the end of this data protection statement. Data will be erased at the latest three years from the end of the year following the user's last login.

Prescribed or required provision:
You provide your personal data on a voluntary basis. We will not be able to provide you with access to the contents and services offered additionally without the provision of your personal data.

II. Questions to the data protection officer

If you have any questions about data protection, please send us an e-mail or contact the person responsible for data protection directly:

Data protection officer of Klüber Lubrication München SE & Co. KG
c/o activeMind AG
Potsdamer Str. 3
80802 Munich
+49 89 919294-900
datenschutz@klueber.com

Information on your right to object according to Art. 21 GDPR is provided at the end of the document

5. Webshop

For data processed in countries outside the EU, Klüber uses EU standard agreements, including suitable technical and organisational measures, to ensure that your personal data is processed in accordance with the European level of data privacy. An overview of subsidiaries within the corporate group is available here:
www.klueber.com/de/kontakt/klueber-lubrication-subsidiaries.

Other special recipients are specified during the respective processing activities.

(1) Data processing office

The controller is

Klüber Lubrication Deutschland SE & Co. KG
Geisenhausener Str. 7
81379 Munich

(2) Processors used

Transmission shall only take place to third parties, if necessary for the performance of the contract, with whom we have concluded commissioned data processing contracts in compliance with the statutory provisions.
The relevant processor here is:

https://www.electronic-minds.de/de/

(3) Accessing our web shop

Purpose, legal basis and legitimate interest
If you access our web shop – that is, if you do not register or otherwise provide us with information – information of a general nature will be collected automatically. This information (server log files) includes your web browser, the operating system used, the domain name of your internet service provider, your IP address etc.

It is processed for the following purposes in particular:

• To ensure a smooth connection to the website
• To ensure comfortable use of our website
• To evaluate system security and stability as well as for other administrative purposes

Furthermore, we reserve the right to check the server log files subsequently if there are concrete indications of illegal use.

We do not use your data to draw conclusions about you. Details of this kind may be statistically evaluated by us with a view to optimising our website and the underlying technology.

Data is processed in accordance with Art. 6 (1) (f) GDPR based on our legitimate interest in improving the stability and functionality of our website.

Recipients:

We use technical service providers to operate and maintain our website who act as our processors.

The relevant processor here is:

https://www.electronic-minds.de/de/

Storage period:
The data will be erased as soon as it is no longer required for the purpose of its collection. For data used for the provision of the website, this is generally the case when the respective session has ended.

Prescribed or required provision
The provision of the above-mentioned personal data is not prescribed by law or under contract. However, we cannot guarantee the service and functionality of our website without an IP address and cookie identification. In addition, individual functions and services may be restricted or unavailable.

Objection
Refer to the information in relation to your right to object under Art. 21 GDPR below.

(4) Newsletter and provision of information

Your data is used for the purpose of sending you the subscribed newsletter by e-mail and offering you related goods or services. Your name is specified in order to address you personally in the newsletter and potentially identify you if you want to make use of your rights as a data subject.

You just need to specify your e-mail address in order to receive the newsletter. When you subscribe to our newsletter, the data you provide for this purpose will be used entirely for the purpose of your subscription. Subscribers may also be sent information by e-mail where this is relevant to the provision of our service or registration (for example, changes to the newsletter subscription or technical matters).

To ensure effective registration, we require a valid e-mail address. In order to verify that it was really the owner of an e-mail address who subscribed to our newsletter, we use a “double opt-in” procedure. This involves logging the subscription of the newsletter.

Based on your express consent (Art. 6 (1) (a) GDPR), we will send our newsletter or similar information by e-mail to your specified e-mail address on a regular basis.

We present you with personal recommendations. These are based on your shopping history, i.e. products and product categories that you have viewed, searched for or purchased previously. This “information” is stored in pseudonymised form pursuant to Section 15 (3) p. 1 of the Telemedia Act [Telemediengesetz, TMG]. It cannot be used to identify you personally.

Recipients:
Recipients of the data are restricted to the controller and the processor Marketo https://de.marketo.com/, Inc., through which we send the newsletter.

Third-country transfer:
Processing does not take place outside the European Union (EU) or the European Economic Area (EEA).

Storage period:
The data will only be processed in this context for as long as the corresponding consent applies. It will be erased following this.

Prescribed or required provision
You provide your personal data on a voluntary basis, based solely on your consent. Unfortunately, we cannot send you our newsletter without your consent.

Withdrawal of consent
You may withdraw your consent to the storage of your personal data and to its use by Klüber for the newsletter subscription at any time. Each newsletter contains a link for this purpose. You can also withdraw your consent using the other contact options specified under section 1.

Profiling
Once you have given us your consent, we will evaluate your use of the sent newsletters and analyse any subsequent visits to Klüber's website in order to make continuous improvements to the newsletter and the web offering and to optimise both according to the actual interests of the visitors.

(5) Registration/user account

Type and purpose of processing:
When you register for use of the online shop, some personal data is collected, such as your first name, surname, title, customer number and e-mail address. Once registered, in your user account you can view and in some cases manage, among other things, your address and contact details,. your current and previous orders, as well as product descriptions, prices and scaled quantities.
If needed, registered users also have the option of modifying data they specified when registering (exception: customer number, e-mail address and country).

At the same time, there is joint responsibility between Klüber and the companies specified under section 1. Klüber is responsible for the obligations from the GDPR, in particular the fulfilment of data subject rights and the duties to inform.

Legal basis:
Data entered during registration is processed on the basis of the user’s consent (Art. 6 (1) (a) GDPR).

Recipients:
Data recipients include technical service providers who are responsible for the operation and maintenance of our application as processors.
• Syntax Systems GmbH
• Klüber, unless Klüber is the Controller.

Third-country transfer:
Processing does not take place outside the European Union (EU) or the European Economic Area (EEA).

Storage period:
Data will only be processed in this context for as long as the corresponding consent applies or the purpose no longer applies. Data will be erased at the latest three years from the end of the year following the user's last login unless statutory retention obligations apply.

Prescribed or required provision:
You provide your personal data on a voluntary basis, based solely on your consent. We will not be able to provide you with access to the contents and services offered additionally without the provision of your personal data.

(6) Contact form

Purpose, legal basis and legitimate interest
The data you enter is stored for the purpose of individual communication with you. We process the data entered in the contact form on the basis of a legitimate interest (Art. 6 (1) (f) GDPR). The purpose of the contact form is to provide you with a simple way to make contact. The information you provide is stored in order to respond to your enquiry and any follow-up questions.

If you get in touch with us in order to request a quotation, the data entered in the contact form will be processed in order to implement pre-contractual measures (Art. 6 (1) (b) GDPR).

Recipients:
Our website is maintained by a service provider who acts as our processor.

The relevant processor here is:

https://www.electronic-minds.de/de/

If you send us an enquiry for a quotation, processors appointed by us may receive data for this purpose, provided that these processors need the data to perform their respective service (e.g. IT services).

All service providers are contractually obligated to treat your data confidentially.

Storage period:

Data is deleted at the latest six months after processing the enquiry.

If a contractual relationship is concluded, we will be subject to the statutory retention periods and will erase your data after six or ten years.

Prescribed or required provision
You provide your personal data on a voluntary basis. However, we can only process your enquiry if you communicate your name, e-mail address and the reason for your enquiry.

(7) Use of cookies

7.1. What is a cookie?
Cookies are small files sent by a web server to your browser and stored on your devices. EU Directive 2009/136/EC stipulates that we may store cookies on your computer if they are essential for operation of this website but that we must obtain your consent for all other cookies that exceed this scope. Acceptance of cookies is not a requirement for use of our website. Nevertheless, cookies help us to design our website and our offers for you and make it easier to use the website, for example the use of the shopping basket function when shopping or particular information about you that is stored in such a way that you do not have to keep re-entering it.

No personal data is stored in the cookies used by us. Therefore, they cannot be assigned to you or to another specific person. When the cookie is activated, an identification number (unique identifier) is assigned to it. An assignment of your personal data to this identification number is not possible at any time and is not done. Your name, your IP address and similar data that would allow assignment of the cookie to you are never used. Through this cookie technology, we merely receive pseudonymised information.

7.2. Technically necessary cookies
We use cookies to make our website more user-friendly. Some of our website’s elements require the browser to also be identifiable after a page change.

Here, the following data in particular is saved and transmitted in the cookies:

• Shop language environment
• Shopping basket
• Device used (e.g. tablet)
• Cookie settings
• Session ID
• CSRF token ID

Technically necessary cookies are used to make websites more user-friendly for visitors. Some of our website functions cannot be provided without the use of cookies. To this end, the browser needs to be recognised even after you move to a new page.

We require cookies for the following applications:

• Adoption of language settings
• Adoption of shopping basket
• Responsive display of shop
• Obtaining cookie declaration of consent
• Logging in to shop
• Safeguarding sending of forms

Data is processed in accordance with Art. 6 (1) (f) GDPR based on our legitimate interest in providing a user-friendly website.

Data recipients
Data recipients may include technical service providers who are responsible for the operation and maintenance of our website as processors. We have concluded the relevant order processing contracts with the providers in this regard.

The relevant processor here is:

https://www.electronic-minds.de/de/

Length of storage and cookie details
Details on the storage period of cookies and functional scope can be found in the information presented when you first access our website via the “Cookiebot” tool under the category “Expiry” or “Purpose”, as well as in our cookie list below.

Prescribed or required provision
The provision of the above-mentioned personal data is not prescribed by law or under contract. However, we cannot guarantee the service and functionality of our website without this data. In addition, individual functions and services may be restricted or unavailable.

Objection
Refer to the information in relation to your right to object under Art. 21 GDPR below.

7.3. Cookies not technically necessary
Purpose and legal basis
“Cookies” are used on our web pages in part. Hidden beneath this standard technology are small text files that are stored on the device you are using and enable, among other things, a more comfortable and secure visit to a website. Cookies can also be used to better tailor the offering of a website to the interests of the visitor or to make general improvements based on statistical evaluations.

Refer to our “Cookiebot” tool, which you see when you first access our website, for more details on the cookies we use.

The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Data recipients
Data recipients may include technical service providers who are responsible for the operation and maintenance of our website as processors. We have concluded the relevant order processing contracts with the providers in this regard.

The relevant processor here is:

https://www.electronic-minds.de/de/

Our “Cookiebot” tool contains further recipients and details on the technical functionality of the tools used.

Length of storage and cookie details
Details on the storage period of cookies and functional scope can be found in the information presented when you first access our website via the “Cookiebot” tool under the category “Expiry” or “Purpose”, as well as in our cookie list below.

Withdrawal of consent
You may withdraw your consent to the storage of your personal data and to its use by Klüber without any form requirement and at any time. To this end, simply use the contact details specified on the website or in this data protection statement.

Profiling
The tracking tools can be used to evaluate the behaviour of website visitors and analyse their interests. This involves creating a pseudonymous user profile.

7.4. Prevention of cookies
However, you can always view our website without cookies. Internet browsers are regularly set up in such a way that they accept cookies. Generally speaking, you can disable the use of cookies at any time by making settings in your browser. To find out how to change such settings, please refer to the help function of your internet browser. See the list below for standard browsers. Please remember, however, that some functions on our website may not work if you disable the use of cookies.

To the extent that these cookies may (also) concern personal data, we will inform you of this in the following sections.

You can erase individual cookies or all cookies via your browser settings. Furthermore, you will be informed of and instructed on how you can erase these cookies or block their storage in advance. Depending on the provider of your browser, you can find the required information at the following links:

• Mozilla Firefox: https://support.mozilla.org/de/kb/cookies-loeschen-daten-von-websites-entfernen
• Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
• Google Chrome: https://support.google.com/accounts/answer/61416?hl=de
• Opera: http://www.opera.com/de/help
• Safari: https://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=de_DE

**(8) Use of Google Analytics **

This website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses so-called cookies, i.e. text files that are stored on your computer and facilitate an analysis of your use of the website. The information about your use of this website generated by the cookie is normally sent to a Google server in the USA and stored there.

However, if IP anonymisation is activated on this website, your IP address will first be truncated by Google within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. The full IP address will only be sent to a Google server in the USA and truncated there in exceptional cases. On behalf of the operator of this website, Google will use this information in order to analyse your use of the website, to compile reports about website activities and to render further services associated with website use and internet use for the website operator.

The IP address transferred from your browser within the framework of Google Analytics will not be kept together with other data of Google. You can prevent the storage of cookies by making the relevant setting in your browser software; however, we draw your attention to the fact that in this case you may not be able to make full use of all the functions of the website. You can also prevent the recording of the information generated by the cookie which relates to your use of the website (including your IP address) at Google as well as the processing of this data by Google by downloading and installing the browser plug-in available with the following link:
https://tools.google.com/dlpage/gaoptout?hl=en-GB

As an alternative to the browser add-on or within browsers on mobile devices, please click this link http://tools.google.com/dlpage/gaoptout?hl=en, to prevent any future collection of data by Google Analytics within this website (the opt-out only works in the browser and only for this domain). At the same time, an opt-out cookie will be stored on your device. If you erase your cookies in this browser, you will need to click this link again.

Further information about terms of use and data protection is available at
https://www.google.com/analytics/terms/us.html or at https://www.google.de/intl/en/policies/.

We would like to point out that on this website Google Analytics has been expanded with the code “anonymizeIp” in order to guarantee anonymous recording of IP addresses (known as IP masking).

(9) Cookie set-up

(10) Questions to the data protection officer

If you have any questions about data protection, please get in touch using the contact details provided. You should also let us know which app you are using specifically:

The controller as defined by data protection legislation is:

Klüber Lubrication Deutschland SE & Co. KG
Geisenhausenerstraße 7
81379 Munich
Tel.: +49 89 78 76-0
Fax.: +49 89 78 76-333
info@klueber.com

You can contact our data protection officer as follows:
Data protection officer of Klüber Lubrication Deutschland SE & Co. KG
c/o activeMind AG
Potsdamer Str. 3
80802 Munich, Germany
+49 89 919294-900
datenschutz@klueber.com

Information on your right to object according to Art. 21 GDPR is provided at the end of the document

6. Homepage

I. What processing activities are carried out on the website?

Basic information on recipients of data in the corporate group:

Klüber is a globally operating company, incorporated in the Freudenberg group. Personal data is processed by Klüber employees, national sales companies and affiliated companies.

For data processed in countries outside the EU, Klüber uses EU standard agreements, including suitable technical and organisational measures, to ensure that your personal data is processed in accordance with the European level of data privacy.

An overview of the companies within the corporate group is available here.

Other special recipients are specified during the respective processing activities.

a. Newsletter and sending information by e-mail

Purpose and legal basis
Your data is used for the purpose of sending you the subscribed newsletter by e-mail, analysing your interaction and assigning your actions to your user profile. Your name is specified in order to address you personally in the newsletter and potentially identify you if you want to make use of your rights as a data subject.

You just need to specify your e-mail address in order to receive the newsletter. When you subscribe to our newsletter, the data you provide for this purpose will be used entirely for the purpose of your subscription. Subscribers may also be sent information by e-mail where this is relevant to the provision of our service or registration (for example, changes to the newsletter subscription or technical matters).

To ensure effective registration, we require a valid e-mail address. In order to verify that it was really the owner of an e-mail address who subscribed to our newsletter, we use a “double opt-in” procedure. This involves logging the subscription of the newsletter. The data is not passed on to third parties.

Based on your express consent (Art. 6 (1) (a) GDPR), we will send our newsletter or similar information by e-mail to your specified e-mail address on a regular basis.

Recipients:
Recipients of the data are restricted to the controller and the processor Marketo, Inc., through which we send the newsletter.

https://de.marketo.com/

https://www.onemedia-consulting.com/

https://www.electronic-minds.de/de/

Third-country transfer:
Third-country transfers do not take place.

Storage period:
The data will only be processed in this context for as long as the corresponding consent applies. It will be erased following this.

Prescribed or required provision
You provide your personal data on a voluntary basis, based solely on your consent. Unfortunately, we cannot send you our newsletter without your consent.

Withdrawal of consent
You may withdraw your consent to the storage of your personal data and to its use by Klüber for the newsletter subscription at any time. Each newsletter contains a link for this purpose. You can also withdraw your consent using the other contact options available on the website.

Profiling:
Once you have given us your consent, we will evaluate your use of the sent newsletters and analyse any subsequent visits to Klüber's website in order to make continuous improvements to the newsletter and the web offering and to optimise both according to the actual interests of the visitors.

b. Gated Content

Purpose and legal basis

Your data will be used exclusively to provide you with information material free of charge. Documents, in particular our whitepapers, podcast, one pager, listicle, videos, tips & tricks, trainings, LinkedIn, global campaigns, will be sent to you by email. Your name will be provided in order to identify you in case you wish to exercise your rights as a data subject.

The legal basis for these processing operations is a contractual exchange relationship, (Art. 6(1)(b) GDPR).

Recipients of the data

Recipients of the data are only the controller and the following processors.

Third Country Transfer

A third country transfer does not take place.

Storage period

The data will only be stored as long as the purpose of use is given. As a rule, your data will be deleted if you have not logged in for more than three years.

Provision prescribed or required

The provision of your personal data is based on the existing exchange relationship.

Cancellation/objection

You can terminate the use of the gated content at any time without notice. To do so, simply follow the regulations under the item "Information about your right to object according to Art. 21 DSGVO", under which you will also receive further information. You will then no longer receive any emails from us regarding the Gated Content. At the same time, you will no longer have access to this.

c. Contact form

Purpose, legal basis and legitimate interest
The data you enter is stored for the purpose of individual communication with you. We process the data entered in the contact form on the basis of a legitimate interest (Art. 6 (1) (f) GDPR). The purpose of the contact form is to provide you with a simple way to make contact. The information you provide is stored in order to respond to your enquiry and any follow-up questions.

If you get in touch with us in order to request a quotation, the data entered in the contact form will be processed in order to implement pre-contractual measures (Art. 6 (1) (b) GDPR).

Recipients:
Our website is maintained by a service provider who acts as our processor.

https://www.electronic-minds.de/de/

If you send us an enquiry for a quotation, processors appointed by us may receive data for this purpose, provided that these processors need the data to perform their respective service (e.g. IT services).

All service providers are contractually obligated to treat your data confidentially.

Storage period:
Data is deleted at the latest six months after processing the enquiry.

If a contractual relationship is concluded, we will be subject to the statutory retention periods and will erase your data after six or ten years.

Prescribed or required provision
You provide your personal data on a voluntary basis. However, we can only process your enquiry if you communicate your name, e-mail address and the reason for your enquiry.

Objection
Refer to the information in relation to your right to object under Art. 21 GDPR below.

d. Visiting our website

Purpose, legal basis and legitimate interest
If you access our website – that is, if you do not register or otherwise provide us with information – information of a general nature will be collected automatically. This information (server log files) includes your web browser, the operating system used, the domain name of your internet service provider, your IP address etc.

It is processed for the following purposes in particular:

• To ensure a smooth connection to the website
• To ensure comfortable use of our website
• To evaluate system security and stability as well as for other administrative purposes

Furthermore, we reserve the right to check the server log files subsequently if there are concrete indications of illegal use.

We do not use your data to draw conclusions about you. Details of this kind may be statistically evaluated by us with a view to optimising our website and the underlying technology.

Data is processed in accordance with Art. 6 (1) (f) GDPR based on our legitimate interest in improving the stability and functionality of our website.

Recipients:
We use technical service providers to operate and maintain our website who act as our processors.

https://www.electronic-minds.de/de/

Storage period:
The data will be erased as soon as it is no longer required for the purpose of its collection. For data used for the provision of the website, this is generally the case when the respective session has ended.

Prescribed or required provision
The provision of the above-mentioned personal data is not prescribed by law or under contract. However, we cannot guarantee the service and functionality of our website without an IP address and cookie identification. In addition, individual functions and services may be restricted or unavailable.

Objection
Refer to the information in relation to your right to object under Art. 21 GDPR below.

e. Registration on our website

Purpose, legal basis and legitimate interest
When you register for the use of our personalised services, some personal data is collected, such as your name, address and contact details (e.g. phone number and e-mail address). Once you are registered with us, you can access our content and services which are only available to registered users. If needed, registered users may also at any time change or erase any of the data they specified when registering. Over and above this, you are welcome to request from us information on any of your personal data stored by us, and you may do so at any time.

Data entered during registration is processed on the basis of the user’s consent (Art. 6 (1) (a) GDPR).

Recipients:
We use technical service providers to operate and maintain our website who act as our processors.

https://www.electronic-minds.de/de/

Storage period:
Data will only be processed in this context for as long as the corresponding consent applies. It will then be deleted unless statutory retention obligations apply. To contact us on this issue, please use the contact details provided at the start of this data protection statement.

Prescribed or required provision
You provide your personal data on a voluntary basis, based solely on your consent. We will not be able to provide you with access to the contents and services offered without the provision of your personal data.

Withdrawal of consent
You may withdraw your consent to the storage of your personal data and to its use by Klüber without any form requirement and at any time. To this end, simply use the contact details specified on the website or in this data protection statement.

f. Technically necessary cookies

Purpose, legal basis and legitimate interest
We use cookies to make our website more user-friendly. Some of our website’s elements require the browser to also be identifiable after a page change.

Here, the following data in particular is saved and transmitted in the cookies:

Language settings
Technically necessary cookies are used to make websites more user-friendly for visitors. Some of our website functions cannot be provided without the use of cookies. To this end, the browser needs to be recognised even after you move to a new page.

We require cookies for the following applications:

• Adoption of language settings
• Remembering search words

Data is processed in accordance with Art. 6 (1) (f) GDPR based on our legitimate interest in providing a user-friendly website.

Data recipients
Data recipients may include technical service providers who are responsible for the operation and maintenance of our website as processors. We have concluded the relevant order processing contracts with the providers in this regard.

https://www.electronic-minds.de/de/

Length of storage and cookie details
Details on the storage period of cookies and functional scope can be found in the information presented when you first access our website via the “Cookiebot” tool under the category “Expiry” or “Purpose”.

Prescribed or required provision
The provision of the above-mentioned personal data is not prescribed by law or under contract. However, we cannot guarantee the service and functionality of our website without this data. In addition, individual functions and services may be restricted or unavailable.

Objection
Refer to the information in relation to your right to object under Art. 21 GDPR below.

Information on cookies
However, you can always view our website without cookies. Internet browsers are regularly set up in such a way that they accept cookies. Generally speaking, you can disable the use of cookies at any time by making settings in your browser. To find out how to change such settings, please refer to the help function of your internet browser. See the list below for standard browsers. Please remember, however, that some functions on our website may not work if you disable the use of cookies.

To the extent that these cookies may (also) concern personal data, we will inform you of this in the following sections.

You can erase individual cookies or all cookies via your browser settings. Furthermore, you will be informed of and instructed on how you can erase these cookies or block their storage in advance. Depending on the provider of your browser, you can find the required information at the following links:

• Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
• Google Chrome: https://support.google.com/accounts/answer/61416?hl=en
• Opera: https://www.opera.com/help • Safari: https://support.apple.com/kb/PH17191?locale=en_GB&viewlocale=en_GB

g. Cookies not technically necessary

Purpose and legal basis
“Cookies” are used on our web pages in part. Hidden beneath this standard technology are small text files that are stored on the device you are using and enable, among other things, a more comfortable and secure visit to a website. Cookies can also be used to better tailor the offering of a website to the interests of the visitor or to make general improvements based on statistical evaluations.

Refer to our “Cookiebot” tool, which you see when you first access our website, to find out more about the cookies we use. The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Data recipients
Data recipients may include technical service providers who are responsible for the operation and maintenance of our website as processors. We have concluded the relevant order processing contracts with the providers in this regard.

https://www.electronic-minds.de/de/

Our “Cookiebot” tool contains further recipients and details on the technical functionality of the tools used.

Length of storage and cookie details
Details on the storage period of cookies and functional scope can be found in the information presented when you first access our website via the “Cookiebot” tool under the category “Expiry” or “Purpose”.

Withdrawal of consent
You may withdraw your consent to the storage of your personal data and to its use by Klüber without any form requirement and at any time. To this end, simply use the contact details specified on the website or in this data protection statement.

Profiling:
The tracking tools can be used to evaluate the behaviour of website visitors and analyse their interests. This involves creating a pseudonymous user profile.

h. Use of Google Analytics

Purpose and legal basis
We use Google Analytics on our website as a tracking or web analysis tool. Web analysis helps us collect information about the behaviour of visitors on our website, e.g. details on their origin and time spent on the site. This information allows us to find the website’s flaws and improve its efficiency.

Google Analytics is an analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter: “Google”). Google Analytics uses so-called cookies, i.e. text files that are stored on your computer and facilitate an analysis of your use of the website. The information that is generated by the cookie about your use of this website is usually transmitted to a Google server in the USA where it is saved. However, if you have activated IP anonymisation for this website, your IP address will not be sent without first being truncated by Google within the member states of the European Union or other parties to the Agreement on the European Economic Area. The full IP address will only be sent to a Google server in the USA and truncated there in exceptional cases. On behalf of the operator of this website, Google will use this information to analyse your use of the website, to compile reports about website activities and to provide further services associated with website use and internet use for the website operator. The IP address transferred from your browser within the framework of Google Analytics will not be kept together with other data of Google.

The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Withdrawal of consent
You can prevent the storage of cookies by making the relevant setting in your browser software; however, we draw your attention to the fact that in this case you may not be able to make full use of all functions of the website. You can also prevent the collection of the data relating to your use of the website (including your IP address) created by the Google cookie and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: Google Analytics opt-out browser add-on [LINK: https://tools.google.com/dlpage/gaoptout?hl=en].

As an alternative to the browser add-on described above or within browsers on mobile devices, you can prevent tracking by Google Analytics on our web pages by clicking this link [ https://support.google.com/analytics/answer/181881?hl=en]. This has the effect of installing an opt-out cookie on your device. It prevents Google Analytics from any future collection of your data in relation to this website and this browser for as long as the cookie remains installed in your browser.

Recipients:
Data recipients are the controller and Google as the processor. We have concluded the relevant order processing contracts with Google in this regard.

https://www.electronic-minds.de/de/

Storage period:
Data transmitted by us to Google is erased after 14 months. Data whose retention period expires after 14 months is erased on a monthly basis.

Third-country transfer:
Google processes your data in the USA. We have concluded standard contractual clauses as suitable guarantees for legally-compliant data transmission.

Profiling:
The tracking tool Google Analytics can be used to evaluate the behaviour of website visitors and analyse their interests. This involves creating a pseudonymous user profile.

Prescribed or required provision:
The provision of your personal data is not prescribed by law or under contract. You may not be able to use all of the functions of the website if you prevent access.

i. Google Signals

We also use the technical extension "Google Signals", which enables cross-device tracking. This makes it possible to associate a single website visitor with different end devices. However, this only happens if you have logged into your Google service when visiting the website and at the same time have activated the "personalized advertising" option in your Google account settings. Personal data may flow to Google in the process. We do not receive any personal data or access to user profiles. If you do not wish to use "Google Signals", you can deactivate the "personalized advertising" option in your Google account settings.

j. Use of script libraries (Google Fonts)

Purpose and legal basis
To display our content correctly and in a graphically appealing way across all browsers, we use “Google Fonts” provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”) on our website to display fonts.

The privacy policy of the library operator Google is available here: https://www.google.com/policies/privacy/

The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Recipients:
Running script libraries or font libraries automatically triggers a connection to the library operator. It is theoretically possible for operators, in this case Google, to collect data, but it is currently unclear whether and, where applicable, for what purposes they might do so.

Storage period:
We do not collect personal data through the use of Google Fonts.

More information on Google Fonts is available at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.

Third-country transfer:
Google processes your data in the USA. We have concluded standard contractual clauses as suitable guarantees for legally-compliant data transmission.

Objection to processing:
The programming language JavaScript is often used to display contents. You can therefore prevent data processing by disabling JavaScript in your browser or installing a JavaScript blocker. Please note that you may not be able to use all of the functions of the website as a result.

Prescribed or required provision:
The provision of personal data is not prescribed by law or under contract. However, the correct presentation of standard-fonts content is not possible without this provision.

k. Use of Google Maps

Purpose and legal basis
We use the Google Maps function on this website. Google Maps is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”). This allows us to show you interactive maps directly on the website and allows you to use the maps function with ease.

Refer to Google’s privacy policy for more information on data processing by Google. Here you can also change your personal data protection settings in Google’s privacy centre.

Detailed instructions on managing your own data when using Google products are available here.

The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Recipients:
By visiting the website, Google receives information that you have accessed the corresponding subpage of our website. This occurs regardless of whether Google provides a user account that you are logged in to or whether there is no user account. If you are logged in to Google, your data will be assigned directly to your account.

https://www.electronic-minds.de/de/

Objection to processing:
If you do not wish to be assigned to Google on your profile, you must log out of Google before activating the button. Google stores your data as usage profiles and uses them for purposes of advertising, market research and/or tailor-made website design. Such an evaluation is carried out in particular (also for users not logged in) for the presentation of needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise it.

Storage period:
We do not collect personal data through the use of Google Maps.

Third-country transfer:
Google processes your data in the USA. We have concluded standard contractual clauses as suitable guarantees for legally-compliant data transmission.

Preventing processing:
You can deactivate JavaScript in your browser settings if you do not want Google to collect, process or use data about you on our website. In this case, however, you will not be able to use some or all of our website’s functions.

Prescribed or required provision:
The provision of your personal data is not prescribed by law or under contract. You may not be able to use all of the functions of the website if you prevent access.

l. Embedded YouTube videos

Purpose
We embed YouTube videos on some of our web pages. The operator of the relevant plug-in is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (hereinafter “YouTube”). If you visit a page featuring the YouTube plug-in, a connection to the YouTube servers will be established. YouTube will be informed of which pages you visit. If you are logged in to your YouTube account, YouTube can assign your surfing behaviour to you personally. You can prevent this by logging out of your YouTube account first.

When a YouTube video is started, the provider uses cookies that collect information on user behaviour.

More information on the purpose and scope of data collection and its processing by YouTube is available in the provider’s privacy policies; here you will also obtain further information on your rights in this regard and settings options to protect your privacy (https://policies.google.com/privacy). Google processes your data in the USA. We have concluded standard contractual clauses as suitable guarantees for legally-compliant data transmission.

Legal basis:
The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Recipients:
Calling up YouTube automatically triggers a connection to Google.

Storage period and objection to processing:
Anyone who has disabled the storage of cookies for the Google Ads program will not have to expect such cookies when watching YouTube videos. However, YouTube also stores non-personal usage information in other cookies. If you want to prevent this, you must block the storage of cookies in your browser.

More information on data protection at “YouTube” is available in the provider’s privacy policy at: https://policies.google.com/privacy?hl=en&gl=en

Third-country transfer:
Google processes your data in the USA. We have concluded standard contractual clauses as suitable guarantees for legally-compliant data transmission.

Prescribed or required provision:
The provision of your personal data is not prescribed by law or under contract. You may not be able to use all of the functions of the website if you prevent access.

Objection
Refer to the information in relation to your right to object under Art. 21 GDPR below.

m. Social plug-ins

Type and purpose of processing:
Our website gives you the option to use so-called “social media buttons”. We use the “Shariff” solution to protect your data when integrating these buttons. These buttons are integrated as graphics on the website, containing a link to the corresponding website of the button provider. Clicking the graphic takes you to the services of the respective providers. Only then will your data be sent to the respective providers. No exchange will take place between you and the providers of the social media buttons if you do not click the graphic. Information on the collection and usage of your data in the social networks can be found in the respective terms of use of the corresponding providers. More information on the Shariff solution is available at: http://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html

We have placed social media buttons from the following companies on our website:

Facebook Inc. (1601 S. California Ave - Palo Alto - CA 94304 - USA)
LinkedIn Corporation (2029 Stierlin Court - Mountain View - CA 94043 - USA)
Twitter, Inc. (1355 Market Street, Suite 900, San Francisco – CA 94103 – USA)
XING AG (Gänsemarkt 43 - 20354 Hamburg - Germany)
YouTube LLC (901 Cherry Ave., San Bruno - CA 94066 – USA)

n. Google AdWords

Purpose and legal basis
Our website uses Google conversion tracking. The company operating the services of Google AdWords is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you have reached our website via an advertisement placed by Google, Google AdWords puts a cookie on your computer. The cookie is used for the purpose of conversion tracking whenever a user clicks on an advertisement placed by Google.

If a user visits certain pages of our website and the cookie has not yet expired, we and Google know that the user has clicked the advert and has been directed to this page. Each Google AdWords customer is given a different cookie. This means that cookies cannot be traced via the websites of AdWords customers. Details obtained through conversion cookies serve the purpose of generating conversion statistics for AdWords customers who have opted for conversion tracking. Such customers are told the total number of users who have clicked their adverts and who have been redirected to a page carrying a conversion tracking tag. However, they do not receive information that might enable them to identify any users in person.

The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Recipients:
Personal data including your IP address is transmitted to Google in the USA every time you visit our website. This personal data is also stored by Google. Google may share personal data collected in this way with third parties under certain circumstances.

https://www.electronic-minds.de/de/

Our company does not receive information from Google that might be used to identify the data subject.

Storage period:
Cookies of this kind lose their validity after 30 days and cannot be used for personal identification.

Third-country transfer:
Google processes your data in the USA. We have concluded standard contractual clauses as suitable guarantees for legally-compliant data transmission.

Objection to processing:
If you wish to opt out of conversion tracking, you can refuse the setting of such a cookie via a browser setting that generally disables the automatic setting of cookies. Or you can set your browser so that it blocks any cookies coming from the domain “googleleadservices.com”.

However, please remember not to erase opt-out cookies for as long as you wish to be exempted from the recording of the relevant tracking data. If you have erased all the cookies in your browser, you need to set the relevant opt-out cookie again.

Prescribed or required provision:
The provision of your personal data is not prescribed by law or under contract. You may not be able to use all of the functions of the website if you prevent access.

o. Use of Google Remarketing

Purpose and legal basis
This website uses the Remarketing function of Google Inc. The company operating the services of Google Remarketing is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”).

This function makes it possible to present interest-related advertisements to website users within the Google advertising network. A so-called cookie is saved to the site user’s browser which makes it possible to identify this user the next time they access these web pages which are within the Google advertising network. Such websites may present visitors with advertisements that relate to content previously called up by them on websites which also use the Google Remarketing function.

The legal basis for this processing of data is your consent, Art. 6 (1) (a) GDPR.

Recipients:
Personal data including your IP address is transmitted to Google in the USA every time you visit our website. This personal data is also stored by Google. Google may share personal data collected in this way with third parties under certain circumstances.

Our company does not receive information from Google that might be used to identify the data subject.

Preventing processing:
According to information from Google, this procedure does not involve any personal data. If you would prefer not to use the Google Remarketing function, you can deactivate it by making the relevant settings at https://support.google.com/adwordspolicy/answer/143465 . Alternatively, you can disable the use of cookies for interest-related advertising through the advertising network initiative by following the instructions provided at http://www.networkadvertising.org/managing/opt_out.aspfolgen.

Prescribed or required provision:
The provision of your personal data is not prescribed by law or under contract. You may not be able to use all of the functions of the website if you prevent access.

p. Using Marketo

Purpose and legal basis
We use Marketo on our website as a tracking or web analysis tool. Web analysis helps us collect information about the behaviour of visitors on our website, e.g. details on their origin and time spent on the site. This information allows us to find the website’s flaws and improve its efficiency. This tool allows us to show you content that matches your interests. This also includes, among other things, interest data collected in relation to the newsletter subscription or your purchasing history.

Data is processed in accordance with Art. 6 (1) (a) GDPR on the basis of your consent.

Recipients:
Recipients of the data are restricted to the controller and the processor Marketo, Inc.

https://de.marketo.com/
https://www.onemedia-consulting.com/
https://www.electronic-minds.de/de/

Storage period:
In principle, your data will be processed until your consent is withdrawn. Furthermore, we will delete your data if there are clear indications to suggest that the purpose of data processing has been fulfilled or you no longer have an interest in our products and services.

Third-country transfer:
Third-country transfers do not take place.

Profiling:
Marketo can be used to evaluate the behaviour of website visitors and analyse their interests. This involves creating a pseudonymous user profile.

Prescribed or required provision:
The provision of your personal data is not prescribed by law or under contract. Your consent is voluntary. You may not be able to use all of the functions of the website if you prevent access.

Withdrawal of consent
You may withdraw your consent to the storage of your personal data and to its use by Klüber without any form requirement and at any time. To this end, simply use the contact details specified on the website or in this data protection statement.

II. Data security

We process personal data only insofar as this is permissible in accordance with the provisions of data protection law. In so doing, we employ all the necessary technical and organisational security measures to protect your personal data from unauthorised access and misuse at all times.

To protect the security of your data when transmitting it, we use encryption methods according to the HTTPS standard (e.g. SSL). Our servers are secured using firewalls and virus protection. It goes without saying that we use backup and recovery procedures as well as role and authorisation concepts.

Our employees are obligated to comply with the provisions of the GDPR and Federal Data Protection Act (BDSG).

III. What data protection rights do you have?

Every data subject has the right to information according to Art. 15 GDPR, the right to rectification according to Art. 16 GDPR, the right to erasure according to Art. 17 GDPR, the right to the restriction of processing according to Art. 18 GDPR, the right to object from Art. 21 GDPR and the right to data portability from Art. 20 GDPR.

The restrictions under Sections 34 and 35 BDSG apply to the right to information and the right to erasure.

You can revoke consent issued to us previously for the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued to us before the General Data Protection Regulation came into force, i.e. prior to 25 May 2018. Please note that such revocation only applies to the future. Processing that took place prior to consent being revoked is not affected by such.

Furthermore, relevant persons have a right of appeal to a responsible data protection supervisory authority (Art. 77 GDPR in connection with Section 19 BDSG). A list of supervisory authorities (for the non-public area) with address details is available at:

https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

IV. Changes to our data protection regulations

We reserve the right to adjust this data protection statement so that it is always compliant with the latest statutory requirements or in order to make changes to our services in the data protection statement e.g. when introducing new services. Any new visit to our website will then be subject to the new data protection statement.

V. Information on your right to object according to Art. 21 GDPR

Information on your right to object according to Art. 21 GDPR is provided at the end of the document

VI. Cookies

This website uses cookies. We use cookies at Klueber.com to store information about your visit. Cookies, also from third-party providers, help us improve our website and provide you with offers tailored to your interests. By clicking “I consent”, you give your consent to such processing activities. Your consent is voluntary and can be revoked at any time with future effect. More information can be found in our data protection statement, Site notice.

Cookies are small text files that are used by websites to make the user experience more efficient. We are legally permitted to store cookies on your device if these are deemed necessary for the operation of this site. We require your consent for all other types of cookies. This site uses various cookie types. Some cookies are placed by third parties that appear on our sites. You can change or revoke your consent from the cookie statement on our website at any time. Refer to our data protection policy to find out more about who we are, how to contact us and how we process personal data.

Your consent applies to the following domains: www.klueber.com

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Information on your right to object according to Art. 21 GDPR

Individual right to object:
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you, which is based on Art. 6 (1) (f) GDPR (data processing on the basis of a balancing of interests). If you file an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for its processing, which override your interests, rights and freedoms, or such processing is used for the establishment, exercise or defence of legal claims.

Recipients of an objection:
The objection can be filed without any form requirement using the subject “Objection” and specifying your name, your e-mail address and the app in question, and should be sent to:

Data protection officer of the FCS Group
c/o activeMind AG
Potsdamer Str. 3
80802 Munich
+49 89 919294-900
datenschutz@klueber.com