Overaching Privacy Policy for the website of CTP Advanced Materials GmbH

General Information

We take the protection of your personal data very seriously. Your privacy is an important concern for us.

The following provisions serve to inform you about the processing of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
In particular, taking into account the duties to provide information in accordance with Art. 12 to 14 GDPR as well as to inform you about the rights of data subjects in accordance with Art. 15 to 22 and Art. 34 GDPR.

Information on the responsible authority

The following party is responsible for processing your personal data:

CTP Advanced Materials GmbH,
Stahlstrasse 60, 65428 Rüsselsheim
Telefon: +49 (0) 6142-9185-0
Fax: +49 (0) 6142-9185-55
E-Mail: am.de@adityabirla.com

Further information can be found in the imprint.

The processing of the data is carried out under joint responsibility in accordance with Art. 26 DSGVO with the following company:

Aditya Birla Group
Aditya Birla Centre
S K Ahire Marg, Worli

Mumbai 400030, India

We process your personal data in accordance with the applicable statutory data protection requirements for the purposes listed below for each group of data subjects:

Privacy Policy for Website Users

Scope

This data protection policy applies to all pages of our online network which are linked to this policy.
The overarching information can be found on our main data protection page.

Purpose of the data collection

The purpose of the data collection is to optimise our website(s), analyse errors, customise our website(s) to your needs, provide you the opportunity to get in touch with us and, if applicable, to sell goods and services.

General Data Processing

In principle, we collect and use personal data of our users only to the extent necessary to provide a functional website and our contents and services. The collection and use of personal data of our users is only carried out after the consent of the user. An exception is made in those cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

Legal basis for the processing of their data:

  • Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a) of the EU General Data Protection Regulation (EU-GDPR) serves as the legal basis.
  • In the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b) GDPR serves as the legal basis. This also applies to processing operations which are necessary to carry out pre-contractual measures.
  • Insofar as it is necessary to process personal data in order to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c) GDPR serves as the legal basis.
  • In the event that vital interests of the data subject or any other natural person require the processing of personal data, Art. 6 para. 1 lit. d) GDPR is used as the legal basis.
  • If the processing is necessary to safeguard the legitimate interests of our company or a third party and if the interest, fundamental rights and fundamental freedoms of the person concerned do not outweigh the former interest, Art. 6 para. 1 lit. f) GDPR applies as the legal basis for the processing.

Legitimate interests can be in particular:

  • the answering of inquiries;
  • the performance of direct marketing activities;
  • the provision of services and/or information intended for you;
  • the processing and transfer of personal data for internal or administrative purposes;
  • the operation and administration of our website;
  • the technical support of the users;
  • the prevention and detection of fraud and criminal offences;
  • the protection against non-payment when obtaining creditworthiness information in connection with the requests for goods and services; and/or
  • the protection of network and data security, insofar as these interests are in accordance with the applicable law and with the rights of the user

Categories of recipients:

  • Service providers for the optimization of websites, online marketing service providers and tools, service companies for information and communication technology, companies for software and equipment maintenance, some of them are described in detail below;
  • Social networks and communities;
  • Internal recipients according to the “need to know” principle.

User data / Server log files

Whenever you visit our website, our systems automatically collect data and information from the computer system of the calling computer. The following types of data are collected: Browser type, version used, operating system of the user, internet service provider, IP address of the user, date and time of retrieval, websites from which the user’s system has come to our website or to which the user of our website accesses. The legal basis for the temporary storage of data and logfiles is Art. 6 para. 1) lit. f) GDPR with the above mentioned legitimate interests. The temporary storage of the IP address by the system is necessary to enable the website to the computer of the user. For this purpose, the user’s IP address must remain stored for the duration of the session.

Storage in log files is done to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. These purposes also include our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f) GDPR. The data will be deleted as soon as they are no longer required for the purpose of their collection. In the case of the collection of data for the purpose of providing the website, this is the case when the respective session has ended. The collection of the data for the provision of the website and the storage of the data in log files is essential for the operation of the website. Furthermore, we reserve the right to check the files if, based on concrete evidence, there is a legitimate suspicion of illegal use or a concrete attack on the pages. In this case, our legitimate interest is the processing for the purpose of clarification and criminal prosecution of such attacks and illegal use.

Use of cookies

We use cookies. Cookies are text files that can be stored and retrieved on the user’s computer system when visiting a website in the Internet browser or by the Internet browser. Cookies can contain a characteristic string of characters that enables the browser to be uniquely identified when the website or a service integrated into it is accessed up again. We use cookies to enable the operation of our website (technically necessary cookies), to make our website more user-friendly (functional cookies) and for marketing and advertising purposes (advertising cookies).

Technical cookies: Some elements of our website require that the calling browser can be identified even after a page change. The purpose of this use is to enable the function of the website in the first place. Examples of technically necessary cookies are the provision of a shopping cart or the login as a registered user. The processing is therefore based on Art. 6 para. 1 lit. b) or f) GDPR.

Functional cookies: There may be functions which are not technically necessary for the operation of our website, but which considerably simplify its use, such as the adoption of language settings or font sizes, the memorization of search terms, etc. Processing is also carried out on the basis of Art. 6 para. 1 lit. b) or f) GDPR.

Advertising cookies: We also use cookies on some of our websites, which enable an analysis of the surfing behavior of the users. In this way, e.g.: search terms entered in search engines, frequency of page views, use of website functions, and information about the operating system and browser, etc. are transmitted. The user data collected in this way is pseudonymized by technical precautions. It is therefore no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the users. The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a) GDPR if the user has given his consent to this – e.g. by selecting in a cookie opt-in banner – otherwise Art. 6 para. 1 lit. f) GDPR in conjunction with If third-party services are integrated, the processing by them is governed by their respective data protection provisions, which are mentioned and/or linked below.

General statements about web beacons / tracking pixel

Web beacons are invisible graphics with the size of a pixel. They are used by partner companies, for the purpose of tracking a user via various web pages to create a profile for use in advertising tailored to the user (targeting). A pixel integrated into the web page is loaded from the partner’s server when the web page is accessed. In this way, the partner receives your IP address, as well as information about your browser and its version, browser plug-ins used (browser fingerprint), your operating system and your network operator. For the integration of external services through web beacons / tracking pixels or other scripts, the specifications for advertising cookies apply accordingly.

Content of external providers

On our website we use active JavaScript content and fonts, which may also come from external providers such as Google. By accessing our website, these providers may receive information about your visit to our website, for example by transmitting your IP address. You can prevent this transmission by installing a JavaScript blocker such as the browser plugin ‘NoScript’ or by deactivating JavaScript in your browser. However, this can lead to functional restrictions.

Some of our web pages integrate third party content within the offer, such as videos from YouTube, map material from Google Maps, images, texts and multi-media files, RSS feeds or other services from other websites. This always requires the transmission of your IP address to the providers of these contents. We cannot make any statement about the use of your data by these providers and have no influence on further processing. We do not know whether the data will be used for other purposes, such as profile building. Please refer to the corresponding data protection information of the respective third-party providers.

You can protect yourself against further persecution by tracking pixels from these providers by deactivating the acceptance of third-party cookies in your browser settings.

The legal basis for the transmission of personal data when integrating third party providers is Art. 6 para. 1 lit. a) GDPR if the user has given his consent to this – e.g. by selection in a cookie opt-in banner – otherwise Art. 6 para. 1 lit. f) GDPR in conjunction with recital 47.

Contact form and e-mail contact

On our website is a contact form available, which can be used for electronic contact. If a user takes advantage of this possibility, the data entered in the input mask is transmitted to us and stored. These data are: Name, address, e-mail address, telephone number, etc.. Not all of these data must be mandatory. At the time the message is sent, the following data is also stored: The IP address, date and time. The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.

Alternatively, it is possible to contact us via the provided e-mail address. In this case, the user’s personal data transmitted with the e-mail will be stored. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.

The legal basis for the processing is:

  • For the receipt of the data based on the sending of the contact form as consent in accordance with Art. 6 para. 1 lit. a) in connection with Art. 5 (expected processing) GDPR or alternatively on the basis of the legitimate interest of answering your contact request according to Art. 6 para. 1 lit. f) GDPR.
  • For the processing of data transmitted in the context of sending an e-mail, Art. 6 para. 1 letter f) GDPR with the above-mentioned legitimate interests.
  • If the e-mail contact aims at the conclusion of a contract, an additional legal basis for the processing is Art. 6 para. 1 lit. b) GDPR.

The data will be deleted as soon as they are no longer required for the purpose of their collection. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended and there is no reason for further storage. The conversation is finished when it can be concluded from the circumstances that the matter in question has been finally clarified. Retention periods under commercial and tax law may exist.

The user has the possibility to revoke his or her consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case the conversation cannot be continued.

Newsletter

On our website you have the possibility to subscribe to a free newsletter with promotional content. Our newsletters contain information about our service offers, promotions, events, competitions, job offers, contributions / articles. Newsletters, on the other hand, do not include news without advertising information that is sent within the framework of our contractual or other business relationship. This includes, for example, the sending of service e-mails with technical information and queries about orders, events, notifications of competitions or similar messages. When registering for the newsletter, the data from the input mask is transmitted to us. In addition, the IP address of the calling computer and the time of the call are collected. For the processing of the data, your consent is obtained during the registration process and reference is made to this data protection declaration. In case you purchase goods on our website via our online shop and enter your e-mail address, we reserve the right to send you newsletters with direct advertising for similar goods. In connection with the data processing for the dispatch of newsletters, the data will not be passed on to third parties. The data will be used exclusively for the dispatch of the newsletter. The legal basis for the processing of the data after registration for the newsletter by the user is, if the user has given his consent, Art. 6 para. 1 lit. a) GDPR and for the dispatch of the newsletter as a result of the sale of goods in accordance with § 7 para. 3 UCA or Art. 6 para. 1 lit. f) (dispatch based on our legitimate business interest).

The collection of the user’s e-mail address is used to send the newsletter. The collection of other personal data in the course of the registration process serves to prevent misuse of the services or the e-mail address used. The subscription to the newsletter can be revoked by the user at any time. For this purpose there is a corresponding link in every newsletter.

A statistical evaluation of the reading behavior only takes place to the extent that it can be determined whether the recipients have opened the newsletter and clicked on the links. This is a function that we use, however, only to check the user activities and to be able to make corresponding optimizations. For this purpose, the newsletter contains a so-called “web beacon”, a pixel-sized file that is retrieved from our server when the newsletter is opened. This web-beacon can be personalized, so that personal data is collected. Clicks are tracked via personalized links to the respective website. If personalized data are collected, the legal basis is Art. 6 para. 1 lit. a) GDPR.

Data collection during registration and registered use

Some of our websites require or offer registration. The data collected in the process is used for the purpose of using the respective websites and services, unless otherwise described and explicitly agreed upon during registration. The data collected is derived from the input mask in the context of registration, processing is based on Art. 6 para. 1 lit. b) GDPR. All other data that you can enter at a later date to complete your profile are optional and voluntary and are based on the legal basis of Art. 6 para. 1 lit. a) GDPR. After registration, we may inform you about relevant circumstances related to our offer for which you have registered by means of the deposited e-mail address.

Data in user-generated content

If you write comments or contributions, upload files to our servers, publish pictures or use other services, your IP address and – if you are logged in – your user data will be saved for our security. Due to the large number of illegal contents that are posted on the internet every day, we reserve the right to use this information for the defence in legal disputes or for criminal prosecution, i.e. also to pass it on to the opponents of claims, criminal prosecution authorities and courts. The legal basis for the content provided is Art. 6 para. 1 lit a) and/or b) GDPR, for all other data collected in the process Art. 6 para. 1 lit f) GDPR.

Commentary subscriptions

On some of our websites you can subscribe to follow-up comments. If you are not subscribed, you will receive a confirmation e-mail as part of a so-called double opt-in procedure to check whether you are the rightful owner of the specified mailbox. You can unsubscribe at any time. Instructions for this are included in each of the emails. Registered users do not have to go through the double opt-in procedure, as this takes place during registration. The legal basis for sending the newsletter applies.

Creditworthiness information

Furthermore, we reserve the right, in the case of orders or commissions, to pass on personal data to third parties for credit information purposes, insofar as this is necessary to protect our legitimate interests. In doing so, only the data required to calculate the creditworthiness using a mathematical-statistical procedure by the credit agency will be transmitted. We require creditworthiness information in order to be able to decide on the establishment and execution of a contractual relationship while safeguarding our legitimate interests.

Data transmission via the internet

Data transmission via the internet is generally associated with certain risks. A special encryption of the data is not carried out, especially messages from the contact form of our website and messages in the service chat are transmitted unencrypted.

Please bear this in mind when transmitting data. If you wish to communicate with us by means of encrypted e-mail, this is possible by using SMIME encryption. Please inform us of your wish to use encryption, as we regularly send unencrypted e-mails due to the current low market penetration of e-mail encryption methods.

Data transfer

If you provide us with personal data, this data will only be passed on to third parties if this is necessary for the processing of the contractual agreement or if another legal reason legitimises this passing on. However, we provide certain services with the cooperation of service providers. We have carefully selected these service providers and have taken appropriate measures to protect your personal data.

Storage periods

The personal data of the person concerned will be deleted or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the person responsible is subject. Data will also be blocked or deleted when a storage period prescribed by the above-mentioned standards expires, unless there is a need to continue storing the data for the purpose of concluding or fulfilling a contract.

Privacy Policy for Social Media Accounts

Facebook

We operate one or more corporate websites (“fan pages”) on the professional social media network Facebook, in particular for self-presentation, branding but also for the purpose of customer communication and recruiting.

According to the ruling of the European Court of Justice (ECJ) of 05.06.2018, Ref. C-210/16, the operator of social media sites is at least jointly responsible for data processing, at least in the case of Facebook fan pages, within the meaning of Art. 26 DSGVO.
Although Facebook offers such a declaration at Facebook we do not know whether it now meets the requirements of the GDPR.

We only process your data – apart from any further procedures below – if you contact us via the platform. In this case, Facebook collects your data and makes it available to us.
In the process, storage and further processing by us may also take place under certain circumstances. The processing of your personal data in the event of an inquiry or application is governed by our other data protection statements in this regard.

The legal basis for the processing of personal data is, depending on the case constellation, the processing for the initiation and execution of a contract with you pursuant to Art. 6 para. 1 lit. b) DSGVO or on the basis of our legitimate interest in communicating with users and our external presentation for the purpose of advertising pursuant to Art. 6 para. 1 lit. f) GDPR.
If you have given your consent to the social network provider for the aforementioned data processing with effect for us, the legal basis is Art. 6 (1) a) GDPR.

Furthermore, we may collect data from visitors to our company website, provided that the display as a visitor can be defined as processing. However, we do not store this data – subject to further procedures listed below – on our own systems, nor are they systematically processed beyond occasional notice.
Our information regarding the controller, the data protection officer and the declaration of your rights as a data subject apply to these processing steps.

Please note that for any processing beyond this on our Fanpages, the privacy policy of Meta Platforms, Inc. (1601 Willow Road Menlo Park, CA 94025 United States) or Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) is applicable.

The transfer of data to third countries is based on the use of standard contractual clauses in accordance with the European Commission: What are Standard Contractual Clauses? | Facebook Help Center .Further, detailed information on Facebook’s data processing and corresponding objection options can be found at Meta Privacy Policy – How Meta collects and uses user data and at Facebook . Facebook is the provider of this service and is alone competent to provide complete information on data processing on Facebook.
We would like to point out that the assertion of data subject rights and requests for information are best directed to Facebook. Only Facebook has access to your data and can take immediate action to delete, restrict, etc., the data or to provide information. Of course, we will support you in asserting your rights if necessary.
You can find options for opting out at: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com.

Facebook Insight

We use the analysis function “Facebook Insight” on our fan page. This function is used for advertising and market research purposes to provide you with more relevant content and to develop new features that may be of interest to you. Facebook uses cookies to help analyze your fan page visits. The information generated by the cookies about your use of the fan pages is usually transferred to Facebook servers in the USA and stored there.

Facebook relies on standard contractual clauses of the European Commission when transferring data to third countries and thus undertakes to comply with the European data protection rules: https://de-de.facebook.com/help/566994660333381.

The processing is based on a legitimate interest according to Art. 6 (1) f GDPR, whereby our legitimate interest consists in the display of targeted advertising and the targeted design of our fan page. If you have given the provider of the social network a consent to the aforementioned data processing with effect for us, the legal basis is Art. 6 (1) a GDPR.

Further information on terms of use and data protection can be found at https://www.facebook.com/about/privacy/. Detailed information on the respective processing operations and the possibilities for objection can be found at http://www.youronlinechoices.com/=ads or https://www.facebook.com/legal/terms/page_controller_addendum.

LinkedIn

Our company operates a social media channel on the platform LinkedIn. According to the judgment of the European Court of Justice (ECJ) of 05.06.2018, Az. C-210/16, is the operator of social media sites – at least on Facebook fan pages – partly responsible within the meaning of Art. 26 GDPR. So far, we do not know that LinkedIn offers an agreement that meets the requirements of Art. 26.

We only process your data when you contact our Human Resources department via the LinkedIn platform or when you contact us on LinkedIn for an advertised job. In that case, LinkedIn collects your information and makes it available to us.
The legal basis for the processing of the personal data is depending on the case: The processing for the initiation and execution of a contract with you in accordance with Art. 6 (1) b GDPR or based on our legitimate interest in communicating with users and our external presentation for the purposes of advertising in accordance with Art. 6 (1) f GDPR. If you have given consent to the above-mentioned data processing with effect for us to the provider of the social network, the legal basis Art. 6 (1) a GDPR.
Under certain circumstances, a storage and further processing by us can take place. The processing of your personal data in the case of an application is based on our application privacy policy.
We may also collect data from visitors to our corporate site if the ad as a visitor can be defined as processing. However, we do not store these data on our own systems, nor are they systematically processed through an occasional notice.
For these processing steps, our information regarding the responsible entity, the data protection officer and the declaration of your rights as the data subject apply.

For any processing beyond that, we point out that the LinkedIn Ireland Unlimited Company privacy policy, Wilton Place, Dublin 2, Ireland (LinkedIn), applies to our LinkedIn Company page.
For more information on LinkedIn’s processing of personal information, visit https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy.

Privacy Policy for Customers (incl. interested parties)

Information on data processing

As a customer and as an interested party or other affected party, we process your personal data primarily for the purpose of establishing and fulfilling a contractual relationship with you or on the basis of a legitimate interest. Your data will be collected, stored and, if necessary, passed on by us to the extent necessary to provide the contractually agreed service, to provide information, to carry out direct marketing activities or other activities of our business operations. Failure to provide such information may result in the contract not being concluded. In addition, we will only process your data if you have consented to the processing or another legal permission has been granted.

Purposes of data processing

FWe process your personal data to achieve the following purposes in relation to the initiation and implementation of a contractual relationship or other activities in the interest of the company:

  • the contractual processing (including shipping, after-sales, complaint management)
  • the communication with business partners about products, services and projects as well as for answering inquiries, customer service
  • Existing customer advertising, used as a selection criterion for direct marketing in order to offer you a service tailored to your needs
  • for credit checks
  • the management of our customer and supplier relation, dealer support
  • the quality management
  • the improvement and development of intelligent and innovative services
  • for customer analysis for market and opinion research
  • the handling of our logistics/materials management
  • the reporting on our company
  • the compliance with legal or contractual requirements
  • the settlement of legal disputes, enforcement of contracts and assertion of claims, defence and exercise of legal rights, detection and prosecution of fraudulent and other illegal activities.

Furthermore, we process your data only with your express declaration of consent.

Types of data processed by us

The following personal data are processed:

  • Contact details; name, address, telephone number
  • Identification/payment details; account number, VAT ID number
  • Ordering data: quantitiy, revenue, intervals
  • Geodata: Addresses, delivery conditions
  • Image data: Photos and video recordings in the context of corporate events and trade fair appearances
  • Ohter data: other necessary information relating to the business relationship or provided voluntarily and from publicly available sources

Categories of recipients

These service providers were carefully selected by us, commissioned in writing and are bound by our instructions. Our service providers are regularly checked by us. The service providers will not pass this data on to third parties, but will delete it after the contract has been fulfilled and statutory storage periods have been concluded, unless you have consented to storage beyond this.

This concerns e.g:

  • bank, payment service provider
  • Logistics companies
  • Specialist craft businesses
  • IT service provider
  • Marketing service provider
  • etc.

For orders on account, we reserve the right to carry out an assessment of the credit risk on the basis of mathematical-statistical procedures (scoring). For this purpose, your data, which are necessary for credit assessment, will be transferred to a credit agency (e.g. Schufa, Creditreform, Bürgel, Atradius, Coface). If the credit assessment is positive, an order on account is possible. If the credit assessment is negative, we cannot offer you payment on account. You can object to the transmission of this data to the credit agency at any time, but then it is no longer possible to order on account.

Legal basis for processing

Legal bases for the processing of your data are in particular

  • Art. 6 para. 1 lit. a) on the basis of your consent, whereby in principle none is required for the conclusion or continuation of an existing contract,
  • Article 6 para 1 lit. b) on the establishment, performance and termination of a contractual relationship,
  • Article 6 para. 1 lit. c) to fulfil a legal obligation,
  • Art. 6 para . 1 lit. f) to safeguard a legitimate interest

Legitimate interests

Our legitimate interests lie in the achievement of the above-mentioned purposes and, in addition, in, for example

  • safeguarding our business interests, including direct marketing and credit assessment,
  • the raising of efficiency and effectiveness potentials, also in cooperation with partners and possibly affiliated companies,
  • ensuring compliance with safety regulations, requirements, industry standards and contractual obligations,
  • the assertion, exercise or defence of legal claims,
  • the avoidance of damage and/or liability of the company through appropriate measures
  • the implementation of information and communication activities, including promotional activities
  • reporting on corporate information.

Data collected by third parties

If necessary, data may be made available to us by third parties, e.g. in the context of recommendations. In this case it is usually contact data in connection with data on specific product or service needs. If necessary, we collect data from credit agencies regarding creditworthiness and/or negative characteristics.

Storage period

Once the respective purpose has been achieved, your data will be deleted in compliance with the legal retention periods.

Privacy Policy for Applicants

When you apply for a position in our company, we process and store your personal data.
We take your privacy very seriously and would therefore like to inform you at this point how we handle your applicant data.

Purpose of data collection

Before joining our company or during the application process, we process your personal data exclusively for the purpose of establishing a contractual relationship to the required extent.

Types of data that are processed by us

The following types of personal data are regularly processed:

  • Candidate data; name, date of birth, CV, nationality/work permit, etc. for the selection, recruitment, entry and exit management,
  • Private contact details; address, telephone number, e-mail (for the purpose of contacting you),
  • Data within the framework of personnel screening (for example, police clearance certificate, reliability check (ZUP));
  • If applicable, data that is subject to professional secrecy; for example, data on health suitability and any restrictions
  • other data in personnel management; severe disability (if relevant), driving licence ownership

We do not require any information from you that is not usable according to the General Equal Treatment Act (AGG) (race, ethnic origin, gender, pregnancy, information on physical or mental illness, membership of a trade union, religion or belief, disability, age, sexual identity or sex life).

We kindly request that such data not be transmitted to us. The same applies to content that is likely to infringe the rights of third parties (e.g. copyrights, ancillary copyrights or other intellectual property rights, personal rights, press law or general rights of third parties).

Legal basis of the processing

  • For the establishment, implementation and termination of a contractual relationship pursuant to Art. 6 para. 1 lit. b) GDPR in conjunction with § 26 BDSG (German federal data protection act – version as of 25 May 2018),
  • to fulfil a legal obligation under Art. 6 para. 1 lit. c) GDPR
  • in the case of processing, to safeguard a legitimate interest under Art. 6 para. 1 lit. f) GDPR,
  • as well as on the basis of your consent through the voluntary provision of data that are not absolutely necessary for the purpose (such as hobbies in your curriculum vitae)
    (however, such a provision is generally not necessary for the conclusion or continuation of an existing contract) under Art. 6 para. 1 lit. a) GDPR.

Legitimate interests

  • the optimization of the application processes,
  • the achievement of efficiency gains by bundling services in individual Group companies (especially human resources, IT),
  • ensuring compliance with safety regulations, requirements, industry standards and contractual obligations,
  • the assertion, exercise or defence of legal claims,
  • the prevention of damage and/or liability of the company by taking appropriate measures.

Categories of recipients

  • Internal recipients according to the “need to know” principle,
  • Companies affiliated under company law (group companies) as joint responsible parties:
    The main contents of the regulation of the tasks with regard to the rights of data subjects can be obtained from the contact address given,
    pursuant to Art. 26 Para. 3 GDPR, however, these rights can be claimed by data subjects from all companies involved.

Deletion periods

After the respective purpose has been achieved, your data will be deleted. However, data will be kept for as long as necessary to defend legal claims. The storage period is usually 6 months. If your profile was sent to us by a personnel service provider and if commission claims of this service provider exist, the storage period can be until they are fulfilled or the limitation period expires. If processing relevant for accounting purposes has been carried out, such as the reimbursement of travel expenses, the data required for this purpose will be deleted in compliance with the statutory retention periods, usually 6 or 10 years. If the application was successful and we conclude a contract with you, we transfer the data collected during the application process to our personnel file.

Privacy Policy for Employees

Information on data processing

Hereby we would like to inform our employees about our processing of their personal data within the scope of their employment contract.

Purpose of data collection

During the period of your employment, your personal data will be processed mainly for the purpose of implementing and/or terminating the contractual relationship, including the tasks related to the respective activity. Other purposes may include processing for the purpose of complying with legal regulations (including third party claims for information) or for measures for corporate development or communication.

Types of data that are processed by us

Within the scope of your employment contract, we process the following personal data:

  • Candidate data; name Date of birth, CV, nationality/work permit, etc. for the selection, recruitment, entry and exit management;
  • private contact details; address, telephone number, e-mail;
  • business contact data; e.g. telephone numbers, e-mail, place of work, job title;
  • image data; photo for identification and photographs taken during company events;
  • identification/payment data; personal identity card data or work permit data for identification and determination of the legitimacy of employment, place of birth, marital status, parental status, tax identification number, health insurance membership, income tax class, allowances, religious affiliation for church tax, account number, any attachment of wages (for the purpose of payroll accounting and fulfilment of social security, tax and other legal obligations);
  • health data; e.g. within the scope of payroll accounting, for settlement with health insurance companies or professional associations or within the scope of legal obligations as an employer, such as company integration management or fulfilment of duties in the protection of severely disabled persons or within the scope of company self-control, such as occupational health and safety or company medical examinations;
  • time recording, access and usage data; vacation times, work time accounts, shift schedules, closing times or access protocols, time protocols relating to the activities performed, closing times or access protocols, also electronic protocols within the scope of the use of our IT infrastructure, etc;
  • data within the scope of personnel screening; (e.g. police clearance certificate, reliability test (ZUP));
  • data on suitability and for performance/behaviour monitoring; training and further training information, data for the purpose of measuring the achievement of objectives, e.g. for variable remuneration components, data on violations of road traffic regulations (“nodules”);
  • other data in personnel administration; secondary employment, data within the framework of company health care and company health management, occupational health and safety, any degree of severe disability, driving licence holders, any employee surveys, data within the framework of proposal management, employee inventions,

Categories of recipients

We send your personal data to the following recipients, e.g. to comply with legal obligations or obligations arising from the employment relationship:

  • Bank service providers, financial service providers, possibly service providers for the calculation of pension provisions,
  • service providers for payroll accounting (tax consultants), auditors, service providers for information and communication technology, companies for software and equipment maintenance, service providers only restructuring in the personnel sector,
  • health, social security, pension and accident insurance institutions and other insurance undertakings and institutions providing capital formation benefits,
  • authorities such as tax authorities, social security funds, employment agencies, safety, health, road traffic or related fine offices, customs authorities or monitoring bodies for undeclared work and minimum wages; other authorities,
  • company medical service,
  • companies affiliated under company law (group companies) as joint responsible parties: the main contents of the regulation of tasks with regard to the rights of data subjects can be enquired about at the contact address given, but under Art. 26 Para. 3 GDPR these rights can be claimed by data subjects from all companies involved,
  • third-party debtor in the case of wage garnishment, insolvency administrator in the case of private insolvency,
  • business partners and customers (official contact details), temporary employment agencies

Legal basis of the processing

When processing your personal data, we naturally comply with applicable law. Processing is therefore only carried out on a legal basis. The following legal bases come into consideration in particular in the employment relationship:

  • § 26 BDSG (German Federal Privacy Act – version from 25.05.2018) as far as necessary for the execution of the employment relationship or for the clarification of a concrete suspicion of criminal offences
  • Art. 6 para. 1 lit. a) GDPR on the basis of your consent, whereby in principle none is required for the conclusion or continuation of an existing contract,
  • Art. 6 para. 1 lit. b) GDPR on the establishment, performance and termination of a contractual relationship,
  • Art. 6 para. 1 lit. c) GDPR to fulfil a legal obligation,
  • Art. 6 para 1 lit. f) GDPR to safeguard a legitimate interest
  • Art. 88 GDPR on the basis of collective agreements (company agreements)

Legitimate interests

If we process your data within the scope of our legitimate interest, this is e.g. in:

  • the implementation of electronic access controls,
  • the optimization of personnel planning,
  • achieving efficiency gains by bundling services in individual Group companies (especially human resources, IT, procurement)
  • ensuring compliance with safety regulations, requirements, industry standards and contractual obligations,
  • the assertion, exercise or defence of legal claims, including data for the documentation of power flows
  • the prevention of damage and/or liability of the company by taking appropriate measures
  • the implementation of internal information and communication measures
  • reporting on company information.

You have the right to object to the processing of personal data within the scope of a legitimate interest for reasons arising from your particular situation. We will then no longer process your data unless we can prove that there are compelling reasons for us to protect your rights and freedoms, or unless the processing serves to assert, exercise or defend legal claims.

We do not use the personal data provided by you to make automated decisions concerning you.

Data collected by third parties

Using the ELSTAM procedure, we collect data for payroll accounting, which the tax authorities provide us with for correct accounting.
This applies in particular to the payroll data mentioned below.

Note: The general information can be found on our main data protection page.

Storage period

After the respective purpose has been achieved, your data will be deleted in compliance with the legal retention periods, usually 6 or 10 years, for various data categories such as occupational pension schemes 30 years and longer.

Use of service providers

Some of the aforementioned processes or services are carried out by carefully selected and commissioned service providers. We transmit or receive personal data from these service providers solely on the basis of a processing contract. If the registered office of a service provider is outside the European Union or the European Economic Area, a transfer to a third country takes place. We will contractually establish data protection agreements with these service providers in accordance with the legal requirements in order to establish an appropriate level of data protection and agree on appropriate guarantees.

Information on your rights

You have the right

  • to request confirmation from us as to whether your personal information is being processed;
    if this is the case, you are entitled to obtain details about this personal data; you may also receive the information specified in Art. 15 of the GDPR.
  • to request that we correct your data if it is deemed to be incorrect, inapplicable and/or incomplete. Such rectification of data also covers duties of completion through explanation or notification.
  • to request that we delete personal data relevant to you without delay
    if one of the reasons specified in Art. 17 of the GDPR applies.
    Unfortunately, we may not delete data that is subject to a legal retention period.
    If you would prefer that we never collect data from you or never contact you again in the future, we shall store such relevant contact details in a blacklist.
  • to revoke any consent given by you with future effect and without any negative consequences for you.
  • to request from us that processing be restricted if one of the prerequisites listed in Art. 18 of the GDPR is provided.
  • to object at any time to the processing of personal data relevant to you on grounds relating to your particular situation.
    We shall no longer process personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds to do so, which override your interests, rights and freedoms,
    or such processing is required for the establishment, exercise or defense of legal claims (Art. 21 of the GDPR).
  • to request that the data relevant to you be issued in a commonly used electronic and machine-readable format. This also covers the issuance (if possible) to another responsible party specified by you directly. (Art. 20 of the GDPR)
  • without prejudice to another administrative or judicial remedy and if you believe that
    the processing of your personal data is in breach of the GDPR, to file a complaint with
    • our data protection officer: datenschutz@ctpgmbh.de or by post (see imprint)
    • to assert claims vis-à-vis the supervisory authority in the member state of your place of stay, your place of work or the location where the alleged violation took place.

Deletion of your data

Unless otherwise regulated in the more detailed data protection declarations, we will delete your personal data once the contractual relationship with you has ended, you have exercised your right to deletion, all mutual claims have been met and there are no other legal storage obligations or legal justifications for storage. As a rule, storage periods under commercial law for financially relevant data are up to 10 years. We may also store data for as long as is necessary to protect ourselves from claims that may be asserted against us. These periods can be up to 30 years.

 

Regulations on joint responsibility under Art. 26 GDPR

CTP Advanced Materials GmbH processes in particular personnel data including applicant data, customer data and supplier data centrally and provides IT administration services within the scope of shared services by the above mentioned responsible party.

There is an agreement in accordance with Art. 26 GDPR, which essentially regulates the following with regard to the fulfilment of data subject rights: each co-responsible person is responsible and competent with regard to the exercise of data subject rights.

Definition

For the purposes of this general information concerning employees, the following definitions apply:

  1. personal data – any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an on-line identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person Examples are contact data, communication data, billing data.
  2. Controller – 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 determined by Union or national law, provision may be made for the controller or for the specific criteria for his or her identification in accordance with Union or national law.
  3. Processor – a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  4. Recipient – a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not that person is a third party.
  5. Employees – employees, including temporary workers in relation to the hirer, persons employed in relation to their vocational training, participants in benefits for participation in working life as well as in clarifications of occupational aptitude or work trials (rehabilitation candidates), persons employed in recognised workshops for disabled persons, volunteers performing a service in accordance with the Youth Voluntary Service Act or the Federal Voluntary Service Act, persons who are to be regarded as persons similar to employees on account of their economic dependence. These also include homeworkers and their equals, federal civil servants, federal judges, soldiers and persons performing community service. As well as applicants for employment and persons whose employment is terminated.
  6. Third party – a natural or legal person, public authority, agency or other body, other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.
  7. Profiling – any 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 relating to the job performance, economic situation, health, personal preferences, interests, reliability, behaviour, whereabouts or change of location of that natural person. Restriction of processing – marking of stored personal data with the aim of restricting your future processing.

Changes to the Privacy Policy

We reserve the right to change our privacy policy if necessary and to publish it here. Please check this page regularly. Subject to the applicable legal provisions, the updated declaration will enter into force upon publication. If we have already collected information about you that is affected by the change and/or is subject to a statutory duty to provide information, we will also inform you of any material changes to our privacy policy.