1. Scope

1.1

This privacy policy and general information on data protection apply to all data processing carried out by Richard Wolf GmbH, Pforzheimer Straße 32, 75438 Knittlingen, email: info@riwospine.com, as the data controller within the meaning of Article 4 of the EU General Data Protection Regulation (‘GDPR’). You can contact our Data Protection Officer at datenschutz@riwospine.com or via our postal address, adding the words ‘Data Protection Officer’.

1.2

The protection of your personal data is important to us, particularly with regard to safeguarding your right to privacy when processing and using this information. Below, we provide information on the collection of personal data when you use our website. Personal data is any data that can be linked to you personally, such as your name, address, email addresses and user behaviour.

2. Automated data collection and processing by the browser

2.1

As with any website, our server automatically and temporarily collects information in the server log files that is transmitted by your browser, unless you have disabled this function.

If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure its stability and security (legal basis: Article 6(1)(f) of the GDPR):

• IP address of the requesting computer
• File request from the client
• The HTTP response code
• The website from which you are visiting us (referrer URL)
• The time of the server request
• Browser type and version
• Operating system used by the requesting computer

No personal analysis of the server log files takes place. At no time can the provider associate this data with specific individuals. This data is not combined with other data sources.

2.2 Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (‘Google’), to analyse and regularly improve the use of our website. The statistics obtained enable us to improve our offering and make it more interesting for you as a user. Google Analytics uses so-called ‘cookies’, text files that are stored on your computer and enable an analysis of your use of the website. According to information from Google, these cookies have a lifespan of up to two years. After this period, they are automatically deactivated. The information generated by the cookie regarding your use of this website is usually transmitted to a Google server in the USA and stored there. We use Google Analytics with the ‘_anonymizeIp()’ extension. This ensures that IP addresses are processed in truncated form, thereby ruling out any possibility of personal identification. Where the data collected about you is personally identifiable, this is therefore immediately ruled out and the personal data is consequently deleted straight away. On our behalf, Google will use this information to analyse your use of the website, to compile reports on website activity and to provide other services relating to website and internet usage.

According to Google, the IP address transmitted by your browser as part of Google Analytics is not combined with any other data held by Google. In the exceptional cases where personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

The legal basis for the use of Google Analytics is your consent in accordance with Article 6(1)(a) of the GDPR. On your first visit to our website, you will be asked whether you wish to give your consent to the setting of cookies that collect data for various purposes. You may either give your consent for all categories of services (using the ‘Select All’ button) or make customised settings by ticking the relevant boxes. Google Analytics falls under the ‘Statistics’ category. This allows you to decide whether to give your consent to data processing or to refuse to give your consent. Consent is voluntary and you may withdraw it at any time with future effect via ‘Cookie Settings’ at the bottom of our website (the ‘footer’) by deselecting any tick you have previously set.

You can also prevent cookies from being stored by adjusting the settings in your browser software; however, we would like to point out that, in this case, you may not be able to make full use of all the functions of this website. Furthermore, you can prevent the collection of data generated by the cookie and relating to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available via the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

You can prevent data collection by Google Analytics by clicking on the following link. An opt-out cookie will be set, which prevents the future collection of your data when you visit this website:

Third-party provider information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of use: http://www.google.com/analytics/terms/de.html, Privacy policy overview: http://www.google.com/intl/de/analytics/learn/privacy.html, and the privacy policy: http://www.google.de/intl/de/policies/privacy. You can find information about cookies used by Google Analytics at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=de

2.3 Google Ads

This website also uses Google Ads to place adverts on the Google Display Network (e.g. in search results, in videos, on websites, etc.) so that they are shown to users who are likely to be interested in them. This enables us to display adverts for and within our online service in a more targeted manner, so that users are shown only those adverts that potentially match their interests. If, for example, a user is shown adverts for products they have previously shown an interest in on other websites, this is referred to as ‘remarketing’. For these purposes, when our website or other websites on which the Google advertising network is active are visited, a Google code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as ‘web beacons’) are embedded in the website.

User data is processed pseudonymously within the Google Advertising Network. This means that Google does not, for example, store or process users’ names or email addresses, but instead processes the relevant data on a cookie-by-cookie basis within pseudonymous user profiles. This means that, from Google’s perspective, the adverts are not managed and displayed for a specifically identified individual, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.

When you visit our website, Google receives the information that you have accessed our website. To this end, Google uses a web beacon to set a cookie on your computer. The data specified in section 2.1 of this policy is transmitted. We have no influence over the data collected, nor are we aware of the full scope of the data collection or the duration of storage. Your data is transferred to the USA and analysed there. If you are logged in to your Google account, your data may be directly associated with it. If you do not wish your data to be associated with your Google profile, you must log out. It is possible that this data may be passed on to Google’s contractual partners, third parties and public authorities. The legal basis for the processing of your data is Article 6(1)(f) of the GDPR.

You can prevent the installation of Google Ads cookies in various ways: a) by adjusting your browser settings accordingly; in particular, blocking third-party cookies means you will not receive adverts from third-party providers; b) by disabling interest-based adverts on Google via the link http://www.google.de/ads/preferences, although this setting will be reset if you clear your cookies; c) by disabling interest-based advertising from providers participating in the ‘About Ads’ self-regulatory campaign via the link http://www.aboutads.info/ choices, although this setting will be reset if you clear your cookies; d) by permanently disabling these features in your Firefox, Internet Explorer or Google Chrome browsers via the link http://www.google.com/settings/ads/plugin. Please note that, in this case, you may not be able to make full use of all the features of this website.

Further information on the purpose and scope of data collection and its processing, as well as further information on your rights in this regard and the options available to protect your privacy, can be obtained from: Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA; Advertising Privacy Policy: http://www.google.de/intl/de/policies/technologies/ads.

2.4 Facebook Remarketing

Furthermore, the website uses the ‘Custom Audiences’ remarketing feature provided by Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA (‘Facebook’). This enables interest-based adverts (‘Facebook Ads’) to be displayed to users of the website whilst they are visiting the Facebook social network or other websites that also use this feature. Our aim is to show you adverts that are relevant to your interests, in order to make our website more appealing to you.

Due to the marketing tools used (“Facebook Pixel”), your browser automatically establishes a direct connection to Facebook’s server. We have no influence over the scope and further use of the data collected by Facebook through the use of this tool and therefore provide you with the following information to the best of our knowledge: Through the integration of Facebook Custom Audiences, Facebook receives the information that you have visited the relevant page on our website or clicked on one of our adverts. If you are registered with a Facebook service, Facebook may associate your visit with your account. Even if you are not registered with Facebook or are not logged in, it is possible that the provider may obtain and store your IP address and other identifying characteristics.

The legal basis for the use of Custom Audiences is your consent in accordance with Article 6(1)(a) of the GDPR. On your first visit to our website, you will be asked whether you wish to give your consent to the setting of cookies that collect data for various purposes. You can either give your consent for all categories of services (using the ‘Select All’ button) or make customised settings by ticking the relevant boxes. Facebook Custom Audiences falls under the ‘Marketing’ category. This allows you to decide whether you wish to give your consent to data processing or to refuse to give your consent. Consent is voluntary and you can withdraw it at any time with future effect via ‘Cookie Settings’ at the bottom of our website (the footer) by deselecting any tick box you have previously ticked.

Logged-in users can disable the ‘Facebook Custom Audiences’ feature at https://www.facebook.com/settings/?tab=ads#_.

Further information on data processing by Facebook is available at https://www.facebook.com/about/privacy.

2.5 LinkedIn Insights

Furthermore, the website uses the ‘Insights’ marketing feature provided by LinkedIn Inc., 2029 Stierlin Court, Mountain View, California, 94043, USA (‘LinkedIn’). This enables interest-based adverts to be displayed to users of the website whilst they are visiting the LinkedIn social network or other websites that also use this service. Our aim in doing so is to display interest-based advertising to you in order to make our website more interesting for you.

LinkedIn uses cookies for the Insights service; these are text files that are stored on your computer and enable an analysis of your use of the website. According to information from LinkedIn, these cookies have a duration of between 30 days and three months. As a result of the cookies used, your browser automatically establishes a direct connection to LinkedIn’s server. We have no influence over the scope and further use of the data collected by LinkedIn through the use of this tool and therefore inform you in accordance with our current knowledge: Through the integration of LinkedIn Insights, LinkedIn receives the information that you have visited the relevant page on our website or clicked on one of our adverts. If you are registered with a LinkedIn service, LinkedIn may associate your visit with your account. Even if you are not registered with LinkedIn or have not logged in, it is possible that the provider may obtain and store your IP address and other identifying characteristics.

The legal basis for the use of LinkedIn Insights is your consent in accordance with Article 6(1)(a) of the GDPR. On your first visit to our website, you will be asked whether you wish to give your consent to the use of cookies that collect data for various purposes. You can either give your consent for all categories of services (using the ‘Select All’ button) or make customised settings by ticking the relevant boxes. LinkedIn Insights falls under the ‘Marketing’ category. This allows you to decide whether to give your consent to data processing or to refuse to give your consent. Consent is voluntary and you may withdraw it at any time with future effect via ‘Cookie Settings’ at the bottom of our website (the footer) by deselecting any tick box you have previously ticked.

Logged-in users can disable the ‘LinkedIn Insights’ feature at https://www.linkedin.com/psettings/enhanced-advertising. Further information on data processing by LinkedIn is available at https://www.linkedin.com/legal/privacy-policy. Information on the cookies used can be found at https://www.linkedin.com/legal/l/cookie-table.

3. Collection and processing of data provided voluntarily

3.1 General Enquiries

If you provide us with personal data via email or through our website (surname, first name, email address, postal address), this is generally done on a voluntary basis. This data is used to fulfil the contractual relationship, to process your enquiries or orders, and for our own market or opinion research and for our own advertising by post and email. No further use of the data, in particular its disclosure to third parties for the purposes of advertising, market research or opinion polling, takes place. We will delete the data collected in this context once storage is no longer necessary, or restrict its processing where statutory retention obligations apply. The legal basis is Article 6(1)(b) of the GDPR or Article 6(1)(f) of the GDPR.

3.2 Newsletter

With your consent, you can subscribe to our newsletter, through which we will inform you about our latest interesting offers. The goods and services advertised are specified in the declaration of consent.

We use the so-called double opt-in procedure for subscribing to our newsletter. This means that, following your registration, we will send an email to the email address you provided, asking you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your details will be blocked and automatically deleted after one month. In addition, we store the IP addresses you use and the times of registration and confirmation. The purpose of this procedure is to verify your registration and, if necessary, to investigate any potential misuse of your personal data.

The only mandatory information required to receive the newsletter is your email address. The provision of any further, separately marked data is voluntary and is used to address you personally. Following your confirmation, we will store the data you have provided for the purpose of sending you the newsletter (the legal basis for this is Article 6(1)(a) of the GDPR).

You may withdraw your consent to receiving the newsletter and unsubscribe at any time. You can withdraw your consent by clicking on the link provided in every newsletter email or by sending an email to presse(at)richard-wolf.com.

3.3 Data processing in the context of contract performance

Personal data relating to our customers, clients, prospective customers and other contractual partners (collectively referred to as ‘contractual partners’) is processed in accordance with Article 6(1)(b) of the GDPR. This takes place within the framework of our contractual or pre-contractual services provided to our contractual partners. The data processed in this context, as well as the nature, scope, purpose and necessity of its processing, are determined by the underlying contractual relationship.

The data processed includes the master data of our contractual partners (e.g. names and addresses), contact details (e.g. email addresses and telephone numbers), as well as contractual data (e.g. services used, contract details, contractual correspondence, names of contact persons) and payment data (e.g. bank details, payment history). We process special categories of personal data only where these form part of commissioned or contractual processing. As a general rule, this data is not disclosed to third parties, unless such disclosure is necessary for the pursuit of our claims in accordance with Article 6(1)(f) of the GDPR or there is a legal obligation to do so in accordance with Article 6(1)(c) of the GDPR.

The data will be deleted when it is no longer required to fulfil contractual or statutory duties of care, or to deal with any warranty obligations or similar obligations; the necessity of retaining the data is reviewed every three years; otherwise, the statutory retention obligations apply.

3.4 Electronic applications

Via our careers page, you can apply via email either as a speculative application or in response to specific job vacancies. Your data (name, email address, contact details, application documents) will only be processed in connection with the relevant job vacancy (Article 6(1)(b) of the GDPR, Section 26 of the BDSG) or, where you have given your consent, for use in connection with other job vacancies (Article 6(1)(a) of the GDPR). If you have given us your consent to process your application data, you may withdraw this consent at any time.

Note on sensitive data: We expressly draw your attention to the fact that applications, in particular CVs, references and other data you submit to us, may contain particularly sensitive information regarding mental and physical health, racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union or political party, or sexual life.

If you provide us with such information in your online application, you expressly agree that we may process this data for the purpose of handling your application. The processing of this data is carried out in accordance with this privacy policy and other relevant legal provisions.

If your application is rejected or you receive a negative decision, the data you have provided will be deleted no earlier than 3 months after the end of the application process. This does not apply if statutory provisions prevent deletion, if further storage is necessary for the purposes of providing evidence, or if you have consented to longer-term storage.

4. Disclosure to third parties

4.1

Insofar as you have provided us with personal data, this will not, as a general rule, be disclosed to third parties.

Disclosure will only take place within the following frameworks:
 

• Consent given by you (see section 3.2). The recipients or categories of recipients will be disclosed to you at the time the data is collected.
• The processing of your enquiries, your orders and the use of our services by appointed subcontractors, who receive the data necessary solely for the performance of this contract and use it for the specified purpose only.
• Data processing on our behalf in accordance with Article 28 of the GDPR by external service providers. These have been carefully selected and commissioned by us, are bound by our instructions and the provisions of the GDPR, and are subject to regular monitoring.
• To fulfil legal obligations to authorities entitled to receive such information.

4.2

Social plugins are used on this website. Social plugins are web applications that connect this website to selected social networks. However, the social plugins are not directly integrated; they must first be activated by a separate click. Only upon activation is a connection established with the social network, regardless of whether you actually click on the social plugins. Through this connection, your IP address and user data from the respective social network may be transmitted to that network. Please refer to Section 6 for details on the social plugins used.

5. Cookies

5.1

The website uses cookies. Cookies are small text files that are stored locally in your browser’s cache.

The following types of cookies, the scope and functionality of which are explained below, are used on this website:
 

• Transient cookies (see 5.2)
• Persistent cookies (see 5.3).

5.2

Transient cookies are automatically deleted when you close your browser. These include, in particular, session cookies. These store a so-called session ID, which allows various requests from your browser to be assigned to the same session. This enables your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close your browser.

5.3

Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete these cookies at any time via your browser’s security settings.

5.4

You can configure your browser settings as you wish and, for example, refuse to accept third-party cookies or all cookies. Please note that you may not be able to use all the functions of this website.

6. Social media

On our website, you will find links to the social media platform YouTube. The following privacy notice applies in this regard:

To display our videos, we use the video service provided by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (‘YouTube’). The legal basis for this is Article 6(1)(f) of the GDPR.

Where YouTube videos are directly embedded on our website, the content of the embedded video is transmitted directly from YouTube to your browser. At the same time, certain data is transmitted from your browser to YouTube. This occurs regardless of whether you click on the video or not. We have no influence over the scope of the data that YouTube collects in this way.

To the best of our current knowledge, this involves the following data, in particular for the display of the embedded YouTube videos:
 

1. The page on our website containing the video that you have visited,
2. The data generally transmitted by your browser (IP address, browser type and version, operating system, time),
3. For registered and logged-in YouTube or Google users, their Google user ID.
    

Embedded YouTube videos can also be hidden using browser add-ons, thereby preventing any data collection by YouTube. If you are logged in to Google, your data will be directly associated with your account. If you do not wish for this data to be associated with your YouTube profile, you must log out before clicking the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or tailoring its website to users’ needs. Such analysis is carried out in particular (even for users who are not logged in) to deliver personalised 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; to exercise this right, you must contact YouTube.

Further information on the purpose and scope of data collection and its processing by YouTube can be found in the privacy policy. There you will also find further information on your rights and settings options for protecting your privacy: www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has opted into the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.

7. Duration of storage

Your data will only be used for as long as is necessary for the existing customer relationship, unless you have given us your consent or we have a legitimate interest in further processing. In such cases, we will process your data until you withdraw your consent or object to our legitimate interests. Notwithstanding this, we are obliged under commercial and tax law to retain your address, payment and order details for a period of ten years.

8. Your rights

8.1

You have the following rights in relation to your personal data:
 

• Right of access,
• Right to rectification or erasure,
• Right to restriction of processing,
• The right to object to processing,
• The right to data portability.
   

Please address your written enquiry to Richard Wolf GmbH, Pforzheimer Straße 32, 75438 Knittlingen, email: info@riwospine.com.

8.2

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