Imprint & Privacy Policy

The controller within the meaning of the data protection laws is:

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ABS Safety GmbH

Gewerbering 3

47623 Kevelaer

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Tel.: +49 2832 97281-240

info@absturzsicherung.de

www.absturzsicherung.de

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1. Collection of general information

When you access our website (www.lock-book.de) or use our app (Lock Book), information of a general nature is automatically collected. We also collect information to improve our products and services and to provide you with information accordingly.

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a) Automatic data collection/information

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(1) Server log files

Through using our services and/or accessing our website, specific information is automatically collected, recorded and processed. This information (server log files) includes, for example, the type of web browser and operating system used, the domain name of your Internet service provider and similar. This only relates to information that does not enable identification of you personally. This information is required for technical reasons in order to be able to correctly deliver the content of the webpages that you have requested and is unavoidable when using the Internet. This type of anonymous information is statistically evaluated on our part in order to optimise our Internet presence and the technology behind it. The following data is stored: (1) The browser types and versions used, (2) the operating system used by the accessing system, (3) the webpage from which an accessing system accesses our website (so-called referrer), (4) the sub-webpages of our Internet site which are accessed by an accessing system, (5) the date and time when the Internet page was accessed, (6) the Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information which serves to avert danger in the event of an attack on our information technology systems.

The data referred to above (1-8) is used to improve our Lock Book service, for purposes of statistical analysis and to improve data security. The data is not used for the purposes of identifying the user concerned. The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR.

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(2) Cookies

Like many other websites, we also use so-called “cookies”. Cookies are small text files that are transferred over to your hard drive from a website server. This automatically provides us with specific data, such as your IP address, the browser used, the operating system of your computer and your Internet connection.

Cookies cannot be used to launch programmes or transfer viruses to another computer. We can use the information contained in these cookies to make navigation easier for you and to ensure that our webpages are displayed correctly.

On no account will the data collected by us be passed on to third parties or linked to personal data without your consent.

The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR.

It is, of course, generally possible for you to view our website without using cookies. Normally, Internet browsers are configured to accept cookies. You can deactivate the use of cookies at any time via your browser settings. Please use the help function of your Internet browser to find out how to change these settings. Please note that individual functions of our website may not work, if you have deactivated the use of cookies.

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(3) Google reCaptcha

We use the Google reCaptcha service in order to establish whether a particular entry in our contact or newsletter form has been made by a person or a computer. Google uses the following data to check whether you are a real live person or a computer: The IP address of the terminal device used, which of our website pages containing an embedded Captcha you are visiting, the date and duration of your visit, the identification data of the browser type and operating system used, your Google account, if you are logged into Google, mouse movements in the reCaptcha field as well as tasks where you have to identify certain pictures. The legal basis for the data processing described above is provided in Art. 6, para. 1 (f) of the General Data Protection Regulation. Our legitimate interest in processing this data is to ensure the security of our website and to protect ourselves from automated input (attacks).

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(4) Use of Google Analytics

Our platform uses Google Analytics, a web analysis service provided by Google Inc. (hereinafter referred to as “Google”). Google Analytics uses so-called “cookies”, i.e. text files which are stored on your computer and which enable an analysis of your use of a website to be carried out. Information generated by such cookies on your use of this website is generally transferred to a Google service in the USA where it is then stored. However, due to the activation of IP anonymisation on our platform, your IP address will be shortened by Google within the Member States of the European Union and other signatories to the Agreement on the European Economic Area prior to dispatch. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide further services to the website operator in connection with website and Internet usage. The IP address transmitted by your browser during the Google Analytics process will not, resp. cannot, be merged with any other Google data (anonymised IP). The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR

You can prevent the storage of these cookies through a corresponding setting in your browser software; however, we would like to point out that in this case you may then not be able to use the full range of functions offered by this website. Furthermore, you can prevent the collection of data generated by these cookies and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plugin available through the following link: Browser add-on for deactivating Google Analytics.

In addition, or as an alternative to using this browser add-on, you can prevent tracking by Google Analytics on our webpages by clicking on this link. This will install an opt-out cookie on your device. This will prevent Google Analytics from recording data from this website and this browser in the future and for as long as this cookie remains installed in your browser.

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(5) Embedded YouTube videos

YouTube videos are embedded on some of our webpages. The operator of the respective plugins is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit a page which incorporates a YouTube plugin, a connection to the YouTube servers is established and YouTube is informed of which pages you visit. If you are logged into your YouTube account, YouTube will be able to relate your surfing behaviour to you personally. You can avoid this by first logging out of your YouTube account.

If a YouTube video is launched, the provider uses cookies to collect information on user behaviour.

If you have deactivated cookie storage for the Google Ad programme, however, no such cookies need to be reckoned with when watching YouTube videos. YouTube also stores non-personal usage information in other cookies. If you wish to prevent this, you must block the storage of cookies in your browser.

Further information on data protection at YouTube can be found in the provider’s Privacy Statement at: https://www.google.de/intl/us/policies/privacy/

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(6) Google AdWords

Our website uses Google Conversion Tracking. If you visit our website via an advertisement placed by Google, a cookie will be set on your computer by Google AdWords. A Conversion Tracking cookie is set when a user clicks on an advertisement placed by Google. These cookies expire after 30 days and do not serve to identify individuals. If a user visits certain pages on our platform and the cookie has not yet expired, both we and Google can see that the user has clicked on the respective advertisement and has been transferred to this page. Every Google AdWords customer is assigned a different cookie. This means that it is impossible to track these cookies via the websites of AdWords customers. The information collected via these conversion cookies serves to compile conversion statistics for those AdWords customers who have decided to use Conversion Tracking. The customers receive details of the total number of users who have clicked on their advertisements and were then transferred to a page containing a Conversion Tracking tag. However, they do not receive any information which allows users to be personally identified.

If you do not wish to participate in this tracking process, you can refuse to let the required cookies be set - for example, by means of a browser setting that generally deactivates the automatic setting of cookies or by setting your browser in such a way that cookies from the "googleleadservices.com" domain are blocked.

Please note that as long as you do not wish performance data to be recorded, you must not delete the opt-out cookies. If you have deleted all the cookies in your browser, you will have to set the respective opt-out cookie again. The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR.

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(7) Use of Google Remarketing and Google Web Fonts

This website uses the remarketing feature provided by Google Inc. This function serves to present interest-based advertisements to website visitors within the Google advertising network. A so-called "cookie" is stored in the website visitor’s browser which allows the visitor to be recognised when revisiting websites that belong to the Google advertising network. On these pages, the visitor may be presented with advertisements that relate to content that the visitor has previously viewed on websites using Google's remarketing feature. The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR.

According to Google, no personal data is collected during this process. However, if you do not wish to be exposed to Google's remarketing feature, you can generally deactivate it by making the appropriate settings at http://www.google.com/settings/ads. Alternatively, you can disable the use of cookies for interest-based advertising via the Network Advertising Initiative by following the instructions at http://optout.networkadvertising.org.

In order to display our content correctly across all browsers and in a graphically appealing manner, we use script and font libraries, such as Google Web Fonts (https://www.google.com/webfonts/), on this website. Google Web Fonts are saved to your browser's cache in order to avoid multiple downloads. If your browser does not support Google Web Fonts or prevents their being accessed, the content will instead be displayed in a standard font.

If a script or font library is called up, this automatically opens up a connection to the operator of the respective library. This means that in theory the operators of such libraries may also collect data - although it is currently unclear as to whether this is actually done and to what purpose.

Google is a library operator. Their Privacy Policy can be found here: www.google.com/policies/privacy/.

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(8) Use of Hotjar

We use Hotjar in order to better understand your needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our your experience (e.g. how much time you spend on which pages, which links you choose to click, what you do and don’t like, etc.) and this enables us to build and maintain our service with your feedback. Hotjar uses cookies and other technologies to collect data on your behavior and your devices. This includes

- a device's IP address (processed during your session and stored in a de-identified form),

- device screen size,

- device type (unique device identifiers),

- browser information,

- geographic location (country only),

- and the preferred language used to display our website.

Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

You can prevent the collection of data generated by these cookies and related to your use of the website (including your IP address) and the processing of this data by downloading and installing the browser plugin available through the following link https://www.hotjar.com/legal/policies/do-not-track/

The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR.

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(9) Use of UserFlow

We use Userflow in order to better understand your needs and to optimize this service and experience as well as being able to offer you assistance and help. Userflow is a technology service that helps us better understand our your experience (e.g. how much time you spend on which pages, which links you choose to click or what problems exist) and this enables us to build and maintain our service with your feedback. Furthermore, with this information we can offer you additional information and recommend products in a better way. Userflow uses cookies and other technologies to collect data on your behavior and your devices. This includes

- IP address,

- your Lock Book ID,

- Lock Book company ID,

- User language

- date of registration,

- first name

- last Log-in.

UserFlow stores this information on our behalf. Userflow is contractually forbidden to sell or unauthorized transfer any of the data collected on our behalf.

The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR.

b) Information that you provide to us

We collect, process and store all the information that you transmit to us whilst using our website/app and other services. As far as this data is not essential for performing the contract, you can decide yourself whether or not you want to make this data available. However, not making this data available may result in your not being able to use our services to the full.

Any image data that you have transmitted to use will be stored for the purpose of creating installation and maintenance documentation or for plans that form part of the corresponding documents.

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2. Security / encryption

In order to safeguard the security of your data during transmission, we deploy state-of-the-art encryption procedures (e.g. SSL) via HTTPS when you use our services.

All our employees as well as external service providers working for us (order processors as provided for in Art. 4 (8) GDPR) are under obligation to observe the applicable data protection laws.

Our security precautions are subject to an ongoing improvement and optimisation process. Please always use the latest version of the Google Chrome web browser to ensure that your personal data is protected in the best possible way.

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3. For what purposes is your data processed?

In order to use our Lock Book platform and all the services and functions implemented on this platform, you are required to register. During the registration process and the subsequent usage of the services and functions described below, personal data is collected, processed and used as portrayed in the following:

(a) Registration and creation of a user account

When creating a user account through the registration process, you must provide the following information:

First name

Last name

Company name

Email address

Password

In addition to the aforementioned data, any data that you have voluntarily entered may also be stored.

The data provided will be collected, processed and used for the purpose of creating a user account and for using Lock Book. Among other things, this information will be used for addressing you and for authenticating and personalising your profile. You can also enter further voluntary information in your user profile, such as your telephone number, company details etc. This voluntary information is partially visible to other users who are logged into Lock Book. You can delete or modify it at any time via the settings in your account.

We process the data collected based on Article 6, para. 1 (b) and (f) GDPR in order to add you and create your account, to identify you each time you log in and to fulfil the user contract concluded with you. Depending on for which service or function the registration is being completed, further data may be collected and subsequently linked to your profile data.

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(b) Use of the services and functions offered on the platform.

The functions and services offered and available for usage within the scope of the Lock Book service, which is subject to registration, as well as the personal data, purposes and legal bases processed in each case, are described below.

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(1) Core functions of the platform

After having created a user profile, you can create projects, manage products, create users and record information on the platform - thus capturing data and making it available in a structured manner to facilitate the documentation, planning and maintenance of your safety systems. This data can be stored and exported via the platform. This data may also incorporate the personal data of third parties as well as image files. Art. 6, para. 1 (b) and (f) GDPR provide the respective legal basis.

If, in your case, we are talking about commissioned data processing, we can offer you an appropriate commissioned data processing contract. Should you require an appropriate contract, please contact:

datenschutz@absturzsicherung.de

When you create a new employee in your account, we collect information on this person, such as his/her name, company, role, function, and contact details, and make this information available as part of our services. We use the data collected exclusively for the purpose of fulfilling our contractual obligations based on Art. 6, para. 1 (b), resp. Art. 6, para. 1 (f) GDPR.

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(2) Contacting us by email or our contact form

You can contact us electronically by email or via our contact form. If you make use of the option of contacting us via our contact form, the following data will be transmitted to us:

- Email address (to be able to contact you)

- First and last names (optional)

- Telephone number (optional)

Through submitting an email or contact form, you automatically agree to our processing your data. The respective legal basis for the processing of this data for the purpose of establishing contact is provided in Art. 6, para. 1 (a) GDPR. This data will be stored until it is no longer required to achieve the purpose of conversing with you and the reason for contacting us has been completely resolved. If contacting us was aimed at concluding a contract with us, Art. 6, para. 1 (b) GDPR provides an additional legal basis for the processing of this personal data. This data is stored for as long as is necessary in order to fulfil the contract. Beyond that, we only store your data in order to comply with contractual or legal obligations (e.g. retention obligations as a result of the tax laws), in which case this is done on the basis of Art. 6, para. 1 (c) GDPR. In addition to the data that you voluntarily provide to us, we also store the date and time of the data transmission as well as your IP address. The processing of this data is done according to our legitimate interest in line with Art. 6, para. 1 (f) GDPR in order to ensure the security of our Lock Book systems and to counteract misuse. This data will be deleted as soon as it is no longer required for the above-mentioned purpose.

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(3) Newsletter

If you register to receive our newsletter, the data you provide will be used solely to this purpose. Subscribers may also be informed by email of circumstances that are relevant to this service or their registration (for example, changes to our newsletter offer or technical conditions).

For the registration to take effect, we require a valid email address. To verify that a registration has actually been completed by the owner of the email address in question, we implement the “double opt-in” procedure. To this end, we log the ordering of the newsletter, the sending of a confirmation email and the receipt of the answer requested in this email. No further data is collected. This data is used exclusively for distributing our newsletters and is not passed on to third parties.

You can withdraw your consent to the storage of your personal data and its usage for distributing newsletters at any time. Every newsletter contains an appropriate link to this purpose. You can also unsubscribe at any time either directly via this webpage or by informing us accordingly of your request via the contact option at the end of this Privacy Policy.

Your data will be deleted within one week of terminating your request to receive our newsletters provided that the deletion does not conflict with any legal retention periods. Through submitting the data you have entered to us, you automatically agree to the processing of your data and the terms of our Privacy Policy.

c) Personalised information

We use information, such as your data usage and interaction with our Lock Book platform, to provide you with interest-based information on functions, products and services that may be of interest to you and to be able, for example, to determine your preferences and personalise your experience with Lock Book.

Should you not wish to receive such information in the future, please let us know accordingly.

The data collected will not under any circumstance be passed on to third parties.

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4. Forwarding of data

We do not pass on any personal data to third parties unless this is necessary in order to fulfil a contract, or permitted by respective legal requirements, or where you have provided us with your consent to do so.

In order to fulfil our contractual obligations with respect to the use of our Lock Book platform, certain information needs to be passed on to (a) other users involved in the usage of the platform (e.g. Safety Check) as well as (b) other involved companies (administrator) for processing purposes. This information is passed on to these individuals solely in connection with using our Lock Book services and on no account for marketing purposes. The legal basis in this case is provided by the need to perform our contractual obligations (Art. 6, para. 1 (b) GDPR) as well as by our legitimate interest (Art. 6, para. 1 (f) GDPR) which consists of making Lock Bock services available to you in accordance with our Terms of Usage.

Furthermore, we are entitled to outsource the processing of personal data in its entirety or in part to external service providers who act as processors on our behalf (Art. 4 (8) GDPR) within the framework of the data protection regulations. If these service providers reside outside the European Union (EU) or the Agreement on the European Economic Area (EEA), we will take appropriate security measures in accordance with the legal and regulatory requirements to ensure the security of your personal data.

A transfer of data to State institutions and authorities which are entitled to receive information is only carried out in order to comply with the statutory duties to provide information, or if we are under commitment to provide information by a court or official decision. In this case, the transfer of your data is required in order to comply with a legal obligation to which we are subject in accordance with Art. 6, para. 1 (c) GDPR.

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5. Storage periods, deletion

Some of the storage periods for personal data have already been explicitly described in the respective points above. Additionally, resp. in as far as this is not otherwise stated in the respective offer or service description, the following generally applies: We store your personal data only as long as is necessary to fulfil the purpose of the contract or - in the case that we have received your consent - until this consent is revoked. Should you object, we will delete your personal data unless further processing is permitted by the respective legal provisions. We will also delete your personal data, if we are obliged to do so for legal reasons. If - and as long as - legal obligations to retain this data exist, we will not delete this data until the relevant periods have lapsed.

If you delete your user account, all the data we have collected on your person will be accordingly deleted. This, however, shall not apply to any data that needs to be retained in order to fulfil a contract or due to the legal regulations.

You can delete or change certain data in your profile yourself whenever you wish to do so.

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6. Legal basis for processing

In addition to the legal bases already discussed, the following also applies:

For transactions for which consent has been obtained, Art. 6, para. 1 (a) GDPR provides the legal basis for the respective activities.

Insofar as personal data is required for compliance with our contractual obligations or to prepare for the conclusion of a contract, Art. 6, para. 1 (b) GDPR provides the respective legal basis. The same applies to such processing operations which are necessary to complete steps prior to concluding a contract, for example, in the case of an enquiry concerning our products or services. The legal basis may also be provided by Art. 6, para. 1 (c) GDPR in as far as there is a legal obligation to process personal data. This includes, in particular, obligations resulting from tax and commercial law.

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7. Your right to information, rectification, blocking, erasure and objection

You have the right to receive information on the personal data we have stored on your person at any time. You also have the right to have your personal data rectified, blocked or erased - except where data storage is required for completing business transactions. Please contact our data protection officer in this regard. You will find the respective contact details at the end of this document.

In order to be able to ensure that data can be blocked at any time, this data must be kept in a blacklist for monitoring purposes. You can also demand the deletion of this data as long as no statutory archiving obligations exist. Should any such obligation exist, we will accordingly block your data upon request.

You can make changes to or withdraw your consent with future effect by notifying us accordingly

If you want to have data rectified, blocked or erased, revoke your consent or exercise your right to information, please contact:

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ABS Safety GmbH

Gewerbering 3, 47623 Kevelaer

Germany

Tel.: +49 2832 97281-240

datenschutz@absturzsicherung.de

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8. Changes to our data protection regulations

We reserve the right to amend this Privacy Policy from time to time to ensure that it remains compliant with the current legal requirements and/or to incorporate changes to our services into this Privacy Policy, e.g. when new services are introduced. Our new Privacy Policy then applies when you revisit our website.

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9. Questions for our data protection officer

If you have any questions regarding data protection, please send us an email or contact our data protection officer directly:

Maurice Pastuska

Gewerbering 3, 47623 Kevelaer

m.pastuska@absturzsicherung.de

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