Data Protection

Privacy Policy

0. Preamble

We appreciate your interest in our company. Data protection is of particular importance to Hellmann Process Management GmbH & Co. KG (hpm) as well as to the management.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the EU General Data Protection Regulation (IGDPR) and in accordance with the applicable country-specific data protection regulations. By means of this privacy policy, our company would like to inform the public and its customers about the type, scope and purpose of the personal data collected, used and processed by us. In addition, this privacy policy will inform individuals about their rights as users of the website and as customers.

hpm has implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website and the mobile applications (also referred to as apps) offered by us. Nevertheless, internet-based data transmissions can have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

hpm's privacy policy is based on the terms used by the European legislator in the adoption of the GDPR. Our privacy policy should be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy, we use, among others, the following terms:

  • a) Personal data

Personal data is all information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"). Identifiable refers to a person who can be identified directly or indirectly, in particular through the assignment of an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of said person.

  • b) Data subject

The data subject is any identified or identifiable person, whose personal data is processed by us.

  • c) Processing

Processing is 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

  • e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

  • f) Pseudonymization

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

  • g) Controller or controller responsible for the processing

Responsible person or the person responsible for processing means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the data controller or the specific criteria for their appointment may be laid down in accordance with Union law or the law of the Member States.

  • h) Processor

Contract processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the responsible person.

  • i) Recipient

The recipient is a person, public authority, agency or other body to which personal data is disclosed, whether or not it is a third party. However, authorities which may be entitled to receive personal data under Union law or the law of the Member States within the framework of a particular investigation mandate shall not be regarded as recipients.

  • j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

  • k) Consent

Consent by the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the data controller

The data controller within the meaning of the General Data Protection Regulation, other data protection laws in the Member States of the European Union and other provisions of a data protection character is:

Hellmann Process Management GmbH & Co. KG
Albert-Einstein-Straße 2

49076 Osnabrueck
Telephone: +49 541 40898 0

3. Contact person for data protection

Any person concerned can contact our management directly at any time with any questions or suggestions regarding data protection:

André Pohl
E-mail: andre.pohl@umweltmanager.net
Telephone: +49 541 40898 100

4. Cookies

Our Internet pages use cookies. Cookies are text files that are filed and stored on a computer system via an Internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows websites and servers that have been visited to distinguish the individual's browser from other Internet browsers that contain other cookies. A particular web browser can be recognised and identified by the unique cookie ID.

The use of cookies enables it to provide users of this website with more user-friendly services that would not be possible without cookies.

By means of a cookie, the information and offers on our website can be optimised for the user. Cookies enable us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because the website and the cookie stored on the user's computer system remembers the information. Another example is the cookie of a shopping basket in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket using a cookie.

The person concerned can prevent the setting of cookies by our website at any time by means of an appropriate setting using the Internet browser used and thus permanently prevent cookies from being used. Furthermore, cookies that have already been set can be deleted at any time using an Internet browser or other software programs. This is possible in all common internet browsers. If the person concerned deactivates the setting of cookies on the Internet browser used, not all functions of our Internet site may be fully usable.

5. Collection of general data and information

The hpm website and the mobile applications we offer, collect a range of general data and information each time they are called up by a person concerned or an automated system. This general data and information are stored in the log files of the server. We may record (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-pages which are accessed via an accessing system on our website, (5) the date and time the website was accessed, (6) an Internet Protocol address (IP address), (7) the Internet service providers of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our IT systems.

When using this general data and information, it does not draw any conclusions about the person concerned. Rather, this information is required to (1) correctly deliver the contents of our website, (2) optimise the contents of our website and the advertising for it, (3) ensure the permanent functionality of our IT systems and the technology on our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. This anonymously collected data and information is therefore evaluated by it statistically with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.

6. Contact possibility via the website

Our website contains information that enables quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a person concerned contacts us by email, the personal data transmitted by the person concerned will be automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. We will not disclose your information to third parties.

7. Routine erasure and blocking of personal data

hpm processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which hpm is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with legal requirements.

8. Rights of the data subject

You have the following rights towards us regarding your personal data:

  • The right to be informed,
  • The right to correction or deletion,
  • The right to limitation of processing,
  • The right to objection to processing,
  • The right to data portability.

If you would like to assert one of the aforementioned rights, you can contact our data protection officer at any time.

You also have the right to file a complaint with a data protection supervisory authority concerning our processing of your personal data.

9 Privacy Policy for the application and use of Google AdWords

The data controller has integrated Google AdWords into this website. Google AdWords is an Internet advertising service that allows advertisers to run adverts in both Google and Google advertising network search engine results. Google AdWords allows an advertiser to pre-define certain keywords to display an ad in Google's search engine results only when the user uses the search engine to retrieve a keyword-relevant search result. On the Google Network, ads are distributed to thematically relevant websites using an automatic algorithm and using the previously defined keywords.

The operating company for the services of Google AdWords is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to advertise our website by displaying interest-relevant advertising on the websites of third parties and in the search engine results of the Google search engine and by displaying third-party advertising on our website. We do not display third-party advertising on our website.

If a person concerned reaches our website via a Google advertisement and uses a form provided there to contact hpm, a so-called conversion cookie is stored on the information technology system of the person concerned by Google. Cookies have already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the person concerned. If the cookie has not yet expired, the conversion cookie is used to check whether certain forms have been called up on our website. The conversion cookie enables both we and Google to track whether an individual who came to our site through an AdWords ad has made contact with the company.

The data and information collected through the use of the conversion cookie is used by Google to generate visit statistics for our website. We use these visit statistics to determine the total number of users who have been referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the person concerned.

The conversion cookie stores personally identifiable information, such as the web pages visited by the person in question. Whenever you visit our website, this personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose personal data collected through the technical process to third parties.

The data subject can prevent cookies being set by our website at any time, as already described above, by using an appropriate setting of the Internet browser used and therefore permanently object to cookies being set. Setting the Internet browser used in this way would also prevent Google from placing a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programmes.

Furthermore, the person concerned has the possibility to object to interest-based advertising by Google. To do this, the person concerned must access the www.google.com/settings/ads link from each of the Internet browsers they use and make the required settings there.

Additional information and Google's privacy policy can be found at  https://policies.google.com/privacy?hl=en.

10. Legal basis of processing

Art 6 I letter. a, GDPR serves our company as a legal basis for processing operations through which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case for example with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I letter b GDPR. The same applies to such processing processes that are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, for example to fulfil tax obligations, the processing is based on Art. 6 I letter c GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured at our company and their name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. The processing would then be based on Art. 6 I letter d GDPR. Ultimately, processing operations could be based on Art. 6 I letter f GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not take priority. We are allowed to carry out such processing procedures because they have been specifically mentioned by the European legislator. In this respect, a legitimate interest could be assumed if the person concerned is a customer of hpm (recital 47, sentence 2, GDPR).

11. The legitimate interests pursued by hpm or by a third party

Where the processing of personal data is based on Article 6 I letter f GDPR, our legitimate interest is to carry out our business for the well-being of all our employees and the shareholders.

12. Period for which the personal data will be stored

The criterion for the duration of the storage of personal data is the statutory retention period in question. After the deadline, the corresponding data will be routinely deleted if it is no longer required for fulfilling the contract or for initiating a contract.

13. Legal or contractual need to provide personal data

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). In some cases, it may be necessary for a contract to be concluded if a data subject provides us with personal data which must subsequently be processed by us. For example, the person concerned is obliged to provide us with personal data if our company enters into a contract with him/her. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact our data protection team. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or required for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the failure to provide the personal data would have.

14. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

15. Google Analytics

This website uses the "Google Analytics" service provided by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) offered to analyze users' website usage. The service uses "Cookies" – text files which are stored on your device. The information collected by the cookies is usually sent to a Google server in the US and stored there.

IP anonymization is used on this website. The IP address of users within the Member States of the EU and the European Economic Area will be reduced. This reduction eliminates the personal reference to your IP address. As part of the contract data agreement concluded between the website operators and Google Inc., Google uses the information collected to evaluate the use of the website and website activity and to provide services related to Internet use.

You have the option of preventing the storage of cookies on your device by making the appropriate settings in your browser. There is no guarantee that you will be able to access all functions of this website without restrictions if your browser does not allow cookies.

Furthermore, you can use a browser plug-in to prevent the information collected by cookies (including your IP address) from being sent to Google Inc. and used by Google Inc. The following link takes you to the appropriate plugin: https://tools.google.com/dlpage/gaoptout?hl=de
Find more information on Google Inc.'s data usage here: support.google.com/analytics/answer/6004245

Last updated: 23.05.2018     

Hellmann Process Management GmbH & Co. KG                       


André Pohl
Management