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Privacy Policy

Data protection is important to us, and we attach great importance to protecting your data and your privacy. In the following, we would like to show you which data we process, at what time, for what purpose, and on what legal basis.

In accordance with our information obligations under the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG), and the Telemedia Act (TMG), this should enable you to understand as clearly as possible the function of the services we offer and how the protection of your personal data is ensured.

1. Responsible Person

is the controller of personal data within the meaning of Article 4 No. 7 of the GDPR:

schwa-medico, Medizinische Apparate, Vertriebsgesellschaft mbH
Wetzlarer Strasse 41-43
35630 Ehringshausen
Allemagne

Managing Director: Jürgen Schaubel

Phone: +49 6443 8333 - 0
Fax: +49 6443 8333 - 155
Email: info@schwa-medico.de

2. Data Protection Contact Person

If you have questions regarding the processing of your personal data or your data protection rights, please contact:

schwa-medico, Medizinische Apparate, Vertriebsgesellschaft mbH
Legal and Data Protection Department
Wetzlarer Straße 41-43
35630 Ehringshausen
Germany

Data Protection Officer: Sibylle Wirth

Fax: +49 6443 8333 - 136
Email: datenschutz@schwa-medico.de

3. What Personal Data Is

According to Article 4 No. 1 of the GDPR, personal data includes all information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, in particular through association with an identifier such as a name, customer number, location data, online identification, or other characteristics. In the GDPR, these individuals are referred to as "data subjects." Further details can be found in Article 4 No. 1 of the GDPR.

4. Data Collected During Website Visits

4.1 Hosting and Log Files

When you visit our website, our web server automatically collects data and information about your device's system and stores it in server log files. This data is automatically transferred by your browser when accessing our website:

  • Timestamp of the page request on the web server
  • URL of the accessed webpage
  • Type and version of the browser you are using
  • Operating system transmitted by your browser
  • The IP address of your computer, masked (the last octet is set to zero).

The purpose of this processing is to make our website accessible from your device and to provide the best possible display by adapting it accordingly. Additionally, we use this data for website optimization and to ensure system security. These data are not analyzed for marketing purposes.

The legal basis for this processing is Article 6(1)(f) of the GDPR. We have a legitimate interest in presenting you with a website optimized for your browser and enabling communication between our server and your device. This communication specifically requires processing your IP address.

The data is stored for 10 days, after which old logs are automatically overwritten.

The recipient of this data is our hosting provider, which works for us under a data processing agreement:

Platform.sh GmbH
Marienstr. 90 
50825 Cologne
Germany

Further information about data protection at Platform.sh is available at https://platform.sh/privacy-policy/.

You have the right to object. You can exercise this right by contacting our company using the provided contact details.

4.2 Content Delivery Network (CDN)

To ensure the best possible delivery of this website, we use the Fastly CDN service. Fastly operates global servers for traffic distribution, enabling fast and secure delivery of this website (Content Delivery Network). This service is connected to our web host through DNS. Technically, the flow of information between your browser and our website is routed via the Fastly network. This facilitates fast website delivery and malicious traffic filtering through traffic analysis. Fastly uses cookies or other technologies to recognize internet users. No use beyond the described purpose is made.

The legal basis for this processing is Article 6(1)(f) of the GDPR. We have a legitimate interest in making our website available as quickly, reliably, and securely as possible.

The recipient of this data is the CDN operator, which works for us under a data processing agreement:

Fastly, Inc. 
475 Brannan St. #300
San Francisco, CA 94107
USA

Fastly, Inc. is Privacy Shield certified. For more information on security and privacy, visit https://www.fastly.com/privacy.

You have the right to object. You can exercise this right by contacting our company using the provided contact details.

4.3 Cookies

Our website uses cookies. These are small text files stored on your device to make website usage more convenient. Functions such as saving settings or recognizing a user's device are achieved through a cookie ID. Cookies help us create an online offering that is as user-friendly and personalized as possible for you as a website visitor. We use both our own cookies and third-party cookies.

You can configure the settings for these cookies at any time. This allows you to limit cookie usage in your browser settings, block them entirely, or set them to delete automatically when the browser window is closed. Additionally, you can manage cookie settings via the pop-up window at the bottom of the page. We distinguish the following categories of cookies:

  • Technically necessary cookies: These are essential for the proper functioning of the website. We use them in accordance with Article 6(1)(c) GDPR.
  • Cookies for analysis: These measure the reach of our offering and help optimize it in accordance with Article 6(1)(a) GDPR.
  • Cookies for marketing purposes (currently not implemented): These enable us to advertise our services through interest-based advertising. This option requires approval and is carried out in accordance with Article 6(1)(a) GDPR.

5. Our Services on This Page

5.1 Contact Form

Our website includes a contact form that you can use to reach us electronically. If you contact us using this form, the data entered into the input fields will be processed by us and will include the following information:

  • Salutation
  • First and last name
  • Company affiliation, if applicable
  • Contact details (phone, email)
  • Customer category
  • Information entered under "Message"

When you submit the form, your IP address (see "Log Files") and the time of submission will also be recorded.

Mandatory and optional fields are treated equally by us. Mandatory fields are required to contact you and process your request.

The processing of personal data provided in the mandatory and optional fields serves the purpose of responding to your contact request and enabling communication with you. The legal basis for processing the personal data you provide when contacting us is Article 6(1)(b) GDPR.

The collection of additional personal data at the time of submission is intended to prevent misuse of our contact form. The legal basis for this is our legitimate interest under Article 6(1)(f) GDPR in preventing misuse of the contact form or in being able to prove an incident.

The data will be deleted as soon as they are no longer required for the purpose for which they were collected.

The recipient of the data is our mail host, which processes the data for us under a data processing agreement.

5.2 How to Contact Us

You can reach us by mail, phone, fax, or email. Based on the information you provide when contacting us, we will respond via phone, fax, or email, call you back, or send you a written response.

  • If you contact us by mail, we may process data related to your address (e.g., name, first name, street, city, postal code), the date and time of receipt of the mail, as well as the data contained in your letter itself.
  • If you contact us by phone, we will process your phone number and, if necessary, your name, email address, the time of the call, and the details of your request.
  • If you contact us by fax, the fax number or sender identification and the data contained in the fax will be processed.
  • If you contact us by email, your email address, the time the email was sent, and the data contained in the message text (and any attachments, if applicable) will be processed.

The purpose of processing the aforementioned data is to handle the contact request and communicate with the inquirer to provide a response.

The legal basis for processing personal data described here is Article 6(1)(f) GDPR. It is in our legitimate interest to offer you the ability to contact us at any time and to respond to your inquiries.

Personal data will be processed only as long as necessary to address the contact request and may be accessed or handled by the following companies:

Mail Hoster (Microsoft Azure)

After you send the contact form or your email, it will be received and processed by our mail host. This host works for us under a data processing agreement.

Microsoft Ireland Operations Limited
South County Business Park, Leopardstown
Dublin 18
Ireland

For more information on privacy at Microsoft, please click the following link: https://privacy.microsoft.com/de-de/privacystatement

Customer Relationship Management ("CRM") HubSpot

We use HubSpot CRM as an interface between office staff and sales to address customer concerns in the most effective and targeted way possible. Inquiries sent to us via email or the contact form are processed through HubSpot and handled by our employees. HubSpot operates under a data processing agreement for us.

HubSpot Ireland Limited
Rez-de-chaussée, Two Dockland Central
Guild Street, Dublin 1
Ireland

For more information on HubSpot's privacy policy, please follow this link: https://legal.hubspot.com/privacy-policy&nbsp

Business Partner

Depending on the type and content of your inquiry, we reserve the right to forward your request to our business partners. This transfer of your data is based on "disclosure by transmission" in accordance with Article 6(1)(a) GDPR, of which you will be informed when submitting the website's contact form:

Johnson Health Tech. GmbH 
Europaallee 51 
D-50226 Frechen
Germany

Data protection information from "Johnson Health Tech. GmbH" can be viewed at the following link: https://www.johnsonhealthtech.com/de/deu/privacy-policy.

You have the right to object to any data processing and transmission. You can assert this right using the contact details provided for our company, as well as when your data is transmitted to our business partners under "disclosure by transmission."

6. Services Integrated on This Website

6.1 Services Google

This website uses various services provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

By integrating Google services, Google may collect and process information, including personal data. It cannot be ruled out that Google may also transfer this information to servers in third countries.

Google's Privacy Shield certification indicates that Google is committed to adhering to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. This applies to the collection, use, and storage of personal data from EU member states and Switzerland. Google, including Google LLC and its wholly-owned subsidiaries in the United States, has declared through certification that it complies with the Privacy Shield principles.

We have no control over the data Google collects, processes, and stores. Google states that it processes, among other things, the following information (including personal data):

  • Log data, including IP addresses
  • Location information
  • Unique request numbers
  • Cookies and similar technologies

If you are logged into your Google account, Google may associate the processed information with your account and treat it as personal information. This depends on your account settings. For details, see: https://www.google.de/policies/privacy/partners.

You can prevent this association by logging out of your Google account or changing your account settings. You can also modify your cookie settings (e.g., delete cookies, block cookies). For more information and instructions, refer to the "Cookies" section.

Google Ads (formerly AdWords)

This website uses Google Ads (formerly AdWords) and, as part of Google AdWords, Conversion Tracking, an online advertising service provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads and Google Conversion Tracking are analytics services provided by Google. When you click on an ad placed by Google, a "cookie" (a text file) is stored on your device. This enables analysis of the pages you visit on our website. This information (including your IP address) is transferred to and stored on a Google server. These servers may be located in the United States or other third countries. After 30 days, these cookies expire. During this period, Google and we can identify if you clicked on one of our ads and were redirected to our website. Since each website visitor receives an individual cookie, the cookies can be tracked by the pages visited by Adwords customers. However, you can limit this tracking by adjusting your cookie policy. Please refer to the "Cookies" section for more details.

The legal basis for processing the personal data described here is Article 6(1)(a) of the GDPR.

You have the right to object to this processing. You can exercise this right by using the contact information provided for our company.

Google Analytics

We use Google Analytics on our website, a web analysis service provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses cookies to enable the analysis of website usage. Google Analytics may also use "web beacons" (invisible graphics). These web beacons allow the evaluation of information such as visitor traffic on websites. Information generated by cookies and web beacons about the use of our website (including the user's IP address) is transmitted to a Google server and stored there. This server may be located in the United States or other third countries and may also transfer the data to other contractual partners of Google, according to Google's Service Level Agreement (SLA).

Google processes the following types of data:

  • Online identifiers (including cookie identifiers)
  • IP address
  • Device identifiers

Detailed information about the data processed can be found at the following address: https://www.google.com/intl/de/policies/privacy/#infocollect.

We only use Google Analytics with IP anonymization enabled ("anonymous IP"). Therefore, your IP address is truncated by Google in member states of the European Union or other states party to the Agreement on the European Economic Area. A transfer and shortening of the IP address only occur in exceptional cases on a Google server in the United States.

Additionally, we have entered into a data processing agreement with Google for the use of Google Analytics (Article 28 GDPR). Google processes the data on our behalf to evaluate the use of our website, compile reports on website activities, and provide related services. Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google.

Integrating Google Analytics allows us to analyze user behavior on our website, enabling us to improve our offerings in a targeted manner. The legal basis for processing personal data as described here is Article 6(1)(a) of the GDPR. Under the terms of the data processing agreement, Google is authorized to engage subcontractors. A list of these subcontractors can be found at https://privacy.google.com/businesses/subprocessors/. The processed information is retained as long as necessary for the described purpose or as required by law.

You have the right to object to this processing. You can exercise this right by contacting our company using the provided contact details.

Providing personal data is not required by law or contract and is not necessary for concluding a contract. You are not obligated to provide personal data. However, if you choose not to provide it, you may not be able to use our website or certain features of it in full.

Google Tag Manager

We use Google Tag Manager on our website. Google Tag Manager is a service provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager allows us to integrate various codes and services on our website in an organized and simplified manner. Google Tag Manager implements or separates tags. Google may process information (including personal data). It cannot be ruled out that this information is transferred to a server in the United States or other third countries. In particular, the following personal data is processed by Google Tag Manager:

  • Online identifiers (including cookie identifiers)
  • IP address

Detailed information about the integration of Google Tag Manager is available at: https://www.google.de/tagmanager/use-policy.html

If you have disabled individual tracking services, the deactivation will remain in effect for all tracking tags integrated via Google Tag Manager. This can be done through the opt-out option for cookies or third-party tools.

By integrating Google Tag Manager, we aim to achieve simplified and streamlined integration of various services. Additionally, the integration of Google Tag Manager optimizes the loading times of these services.

The legal basis for the processing of personal data described here is Article 6(1)(a) of the GDPR.

The processed information is retained as long as necessary to achieve the stated purpose or as required by law.

You have the right to object to this processing. You can exercise this right by using the contact information provided for our company.

The provision of personal data is not required by law or contract and is not necessary for the conclusion of a contract. You are also not obliged to provide personal data. However, if you do not provide it, you may not be able to use our website or its full functionality.

Use of YouTube

We use YouTube videos and plugins on our website. YouTube is a service provided by YouTube LLC ("YouTube"), 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube LLC is a subsidiary of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

YouTube is integrated into our website via embedded services using "iFrames." When loading this iFrame, YouTube or Google may collect and process information (including personal data). It cannot be ruled out that YouTube or Google also transfer this information to a server located in a third country.

By integrating YouTube, we aim to present various videos on our website so that you can watch them directly on our site.

The legal basis for the processing of personal data described here is Article 6(1)(f) of the GDPR. Our legitimate interest lies in the benefits YouTube provides through its platform. By embedding external videos via YouTube, we reduce the load on our servers and improve loading speed by automatically providing different playback quality options. Additionally, YouTube and Google have a legitimate interest in the (personal) data collected to improve their services.

The provision of personal data is not required by law or contract and is not necessary for the conclusion of a contract. You are also not obliged to provide personal data. However, if you do not provide it, you may not be able to use our website or its full functionality.

6.2 Facebook Services

We use various Facebook services on our website. "Facebook" is operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

Pixel Facebook

Through Google Tag Manager, Facebook pixels are integrated into our website. These pixels are retrieved from a Facebook server when you visit a page, recording the access to the specific page you have visited. This enables us to use "Facebook Custom Audience." According to Facebook, the following information (including personal data) may be collected:

  • Browser information
  • Websites visited
  • Hashed Facebook ID of the website user

For more information about Facebook Pixel, visit: https://www.facebook.com/business/help/651294705016616.

Custom Audiences

This marketing tool is a targeting option that uses the integrated Facebook Pixel to match data from our website visitors with individuals on Facebook. It allows us to target groups of visitors with advertisements on the Facebook platform. Additionally, this service helps reduce marketing inefficiencies.

For more information about Facebook Custom Audiences, visit:

Facebook Conversations

This service allows us to communicate more easily via Facebook Chat and is integrated into "Hubspot CRM." For more information, please refer to the "Contact Us" section.

For the services provided by Facebook, it cannot be excluded that Facebook may transfer the transmitted information to a server in the United States or another third country.

The Privacy Shield certification indicates that Facebook, Inc. commits to complying with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. This applies to the collection, use, and storage of personal data from EU and Swiss member states. Facebook, Inc. has certified its compliance with the Privacy Shield principles.

The legal basis for processing personal data described here is Article 6(1)(a) of the GDPR. Regarding the retention of information, Facebook states that data will be retained as long as necessary to provide you or others with products and services.

For more information and contact details, please visit: https://de-de.facebook.com/about/privacy/ and the following addresses:

If you live in the United States or Canada:

Facebook, Inc. 
1601 Willow Road
Menlo Park, CA 94025

If you live elsewhere in the world:

Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour, Dublin 2 
Ireland

Privacy Policy for Our Facebook Fan Page Insights

Facebook Ireland Ltd ("Facebook") provides us, as the operator of the Facebook Fan Page, with what are known as "Facebook Insights" ("Insights"). Insights are various statistics that give us information about the use of our Facebook Fan Page. Detailed information about this can be found at: https://www.facebook.com/business/a/page/page-insights.

To generate these statistics, Facebook processes various information provided by you (including personal data). Personal data is processed by Facebook and us as joint controllers under Article 26 of the GDPR. Below, we provide you with the key information from the agreement concluded between Facebook and us (https://www.facebook.com/legal/terms/page_controller_addendum) in accordance with Article 26 of the GDPR.

Information on the Agreement Between Facebook and Us

I. Identification of Joint Controllers

Joint Controllers:

Facebook Ireland Ltd
4 Grand Canal Square
Dublin 2
Ireland

and

schwa-medico, Medizinische Apparate, Vertriebsgesellschaft mbH
Wetzlarer Str. 41-43
35630 Ehringshausen
Germany

Phone: +49 6443 8333 - 0
Fax: +49 6443 8333 - 119
Email: info@schwa-medico.de

II. Insights Data

Facebook has assumed primary responsibility for the processing of data (fulfilling all obligations under the GDPR). Specifically:

  • Obligations of Information: Facebook fulfills the necessary obligations to provide information (e.g., Article 13 of the GDPR).
  • Rights of Data Subjects: Data subjects can assert their rights directly against Facebook (e.g., the right to information or deletion, objection to data processing, or revocation of any consent given; see also Section "V. Rights of Data Subjects").
  • Technical and Organizational Measures: Facebook ensures the technical and organizational measures for data processing.

Facebook provides comprehensive information about data processing at: www.facebook.com (Article 13 of the GDPR). For an overview of the key information, we also refer to the content provided by Facebook as part of this privacy notice.

While Facebook has primary responsibility as agreed, you may, of course, also assert your rights under the GDPR directly with us. We will promptly forward such requests to Facebook via a form provided for this purpose.

1. Legal Basis for Processing

The legal basis and purposes of Facebook's data processing can be found at https://www.facebook.com/about/privacy/legal_bases and https://de-de.facebook.com/policy.php. Our legal basis for processing Insights data is our legitimate interest under Article 6(1)(f) of the GDPR. We have a legitimate interest in monitoring user behavior on our Facebook Fan Page. This allows us to track the reach and effectiveness of our campaigns, posts, and other activities through prepared statistics. This, in turn, enables us to continuously optimize our website and services to better meet demand. This purpose also represents the goal of our data processing efforts.

2. Data Processing on a Facebook Fan Page

Facebook may process the following data:

  • User interactions (click behavior, impressions, preferences, video views, pages visited, etc.)
  • Cookies
  • Demographic characteristics (age, gender, region, etc.)
  • IP address
  • System and device information (e.g., browser type, operating system, etc.)

The exact processing of your data when visiting our Facebook fan page depends on whether you have a Facebook account or not:

  • If you have a Facebook account, Facebook may permanently associate the data with your account to learn more about you.
  • If you do not have a Facebook account, Facebook may still store your data through the use of cookies. Cookies are typically small text files stored on your device. Various pieces of information are written into this text file, which can be read again later. This allows Facebook to store and process information about you even if you don’t have a Facebook account. More detailed information about Facebook cookies can be found at: https://de-de.facebook.com/policies/cookies/.

When using Insights, we only receive anonymous statistics from Facebook about the usage of our fan page. We can see how many users performed certain interactions but cannot identify which user performed a specific action. The statistics provided by Insights do not allow us to draw conclusions about an individual.

3. Rights of Data Subjects

In principle, you have the following rights:

  • Right to Information (Art. 15 GDPR)
  • Right to Rectification (Art. 16 GDPR)
  • Right to Object (Art. 21 GDPR)
  • Right to Erasure (Art. 17 GDPR)
  • Right to Restrict Processing (Art. 18 f. GDPR)
  • Right to Data Portability (Art. 20 GDPR).

You have the right to revoke any consent you have given at any time with future effect, without affecting the legality of the processing carried out based on the consent up to the point of revocation.

You can exercise these rights directly with Facebook or with us (see the section "II. Responsibility for the Processing of Insights Data"). If you wish to assert your rights with us, please contact us at the email address datenschutz@schwa-medico.de and describe your specific concern as detailed as possible.

You also have the right to object to the processing of cookies. You can exercise this right, for example, in the following ways:

  • Browser Settings: In your browser settings, you can restrict or completely prevent the installation of cookies. You can also set cookies to be automatically deleted when you close the browser window. For more information or instructions on how to proceed, please refer to the section "Cookies."
  • Facebook Settings: You can also adjust your settings for the use of cookies at https://de-de.facebook.com/policies/cookies/. Under the sections "If you have a Facebook account" and "Public" (if you do not have a Facebook account), you will find information on how to object to processing with Facebook.

You can determine the storage duration of cookies via your browser by displaying the cookies (usually by clicking the "i" next to the address bar, for example, in Firefox or Google Chrome).

7. General Notes on Providing Data

The provision of personal data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obligated to provide personal data. However, if you do not provide this data, you may not be able to use our services or may only be able to use them in a restricted form.

8. Social Networks and External Links

In addition to this website, we are also present on various social media platforms, which you can access via the corresponding buttons on our website. If you visit such a presence, personal data may be transmitted to the social network provider.

We would like to point out that information (including personal data) may be transferred to a server in a third country, meaning the data may be processed outside the European Union. U.S. providers certified under the "Privacy Shield" have committed to adhering to EU data protection standards. More information about this is available at https://www.privacyshield.gov/Program-Overview.

Additionally, it is possible that beyond storing the data you have specifically entered on this social media platform, the social network provider may also process other information. This could include important data from your computer system used to access the platform (such as your IP address, type of processor, browser version, and installed plugins). If you are logged in with a user account on the respective network while visiting such a site, that network may assign your visit to your account.

For details about the purpose, scope, and further processing of your data, as well as your rights in this context, please refer to the respective terms of the responsible party.

We also want to highlight that our website contains additional links to external third-party websites, over which we have no influence regarding data processing.

9. Data Security

We secure our website and all related systems through technical and organizational measures to protect your data from loss, destruction, access, modification, or distribution by unauthorized individuals. However, despite regular checks, complete protection against all risks is not possible.

10. Revocation

You have the right to revoke any consent you have given at any time with future effect, without affecting the lawfulness of processing carried out based on the consent before its revocation.

11. Rights of Data Subjects

In general, you have the following rights:

  • Right to information (Art. 15 DSGVO)
  • Right to rectification (Art. 16 DSGVO)
  • Right to objection (Art. 21 DSGVO)
  • Right to erasure (Art. 17 DSGVO)
  • Right to restriction of processing (Art. 18f DSGVO)
  • Right to data portability (Art. 20 DSGVO).

For any such request, please contact datenschutz@schwa-medico.de. Please note that for such requests, we need to ensure that the person making the request is the actual data subject.

You have the right to appeal to a data protection supervisory authority, without prejudice to any other administrative or judicial remedy.

Automated decision-making ("profiling") does not take place on our website.

schwa-medico, medizinische Apparate, Vertriebsgesellschaft mit beschränkter Haftung
Status: November 2020 / The German version applies.