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Privacy policy

Privacy Policy

for the use of the digital operating logbook "eThemis" (Web Portal & Mobile App) Herborner Pumpentechnik GmbH & Co KG

Scope of this Privacy Policy: This Privacy Policy applies exclusively to processing for which Herborner is the controller in its own right within the meaning of Art. 4 No. 7 GDPR (in particular website and web portal access, registration and contract data, billing, support, and the security of the service). Insofar as Herborner processes personal data on behalf of the Customer — in particular the content entered by the Customer into the operations logbook — this is carried out exclusively on the basis of the Order Processing Agreement (OPA). Such order data is not used for the further development or improvement of the Services.

1. Controller

The controller for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:

Data Protection Officer Herborner Pumpentechnik GmbH & Co. KG Littau 3-5 35745 Herborn Phone: +49 (0) 2772 / 933-0 Email: dsb@herborner-pumpen.com

2. General Information on Data Processing

(1) We process personal data exclusively in accordance with the provisions of the GDPR and the German Federal Data Protection Act (BDSG).

(2) Data is processed only to the extent necessary for the provision of our app, our web portal, and the fulfillment of contractual obligations.

3. Collection and Processing of Personal Data

a) When Visiting the Website / Web Portal

  • IP address of the end device
  • Date and time of access
  • Browser type and version

This data is technically necessary to display the content of our website and serves system security purposes.

b) When Using the App

  • Device information (model, operating system version)
  • Log and usage data (timestamps, actions performed)

c) Upon Registration and Use of the User Account

  • First and last name
  • Email address, username, password
  • Organizational affiliation (e.g., facility/company)
  • Role and permission information

d) Support and Communication

  • Content of inquiries via email or support form
  • Contact details (e.g., phone number, email address)

4. Purposes of Processing

We process personal data for the following purposes:

  • Provision and operation of the digital operating logbook "eThemis" and other digital services of Herborner Pumpentechnik GmbH & Co KG
  • Fulfillment of contractual obligations toward our customers
  • Ensuring security, stability, and error-free operation
  • Support and responding to user inquiries
  • Further development and improvement of our Services, exclusively on the basis of data for which Herborner is itself the controller, or on the basis of permanently anonymized data. Personal data processed by Herborner on behalf of the Customer (order data) is not used for this purpose.

5. Legal Bases

Processing is based on:

  • Art. 6(1)(b) GDPR (performance of a contract),
  • Art. 6(1)(c) GDPR (legal obligation),
  • Art. 6(1)(f) GDPR (legitimate interest, e.g., IT security, prevention of misuse),
  • Art. 6(1)(a) GDPR (consent, e.g., for location data).

6. Disclosure of Data

(1) Personal data is disclosed to third parties exclusively within the framework of statutory requirements.

(2) Sub-processors (e.g., hosting providers, cloud services) are engaged only where they meet the requirements of Art. 28 GDPR.

(3) Personal data is not transferred to third countries outside the EU/EEA. Processing takes place exclusively on servers within the EU or the EEA.

7. Retention Period and Deletion

(1) Personal data is stored only for as long as necessary for the respective purposes.

(2) After termination of the Contract or upon the Customer's instruction, personal data is deleted after a transition period of three (3) months, unless statutory retention obligations preclude this.

8. Rights of Data Subjects

Users have the following rights under the GDPR:

  • Right of access to the processed data (Art. 15 GDPR)
  • Right to rectification of inaccurate data (Art. 16 GDPR)
  • Right to erasure ("right to be forgotten," Art. 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object to certain processing (Art. 21 GDPR)
  • Right to withdraw consent with effect for the future (Art. 7(3) GDPR)

Data subjects may exercise these rights at any time by contacting dsb@herborner-pumpen.com.

9. Security of Processing

We implement technical and organizational measures (TOMs) pursuant to Art. 32 GDPR to protect personal data against loss, misuse, unauthorized access, or disclosure. These include, in particular:

  • SSL/TLS encryption,
  • role- and permission-based access concepts,
  • access controls,
  • regular security updates and backups.

10. Cookies and Tracking

(1) Our website may use cookies that are necessary for its operation.

Use of Cookiebot

We use the Cookiebot service on our website, a tool for obtaining and managing cookie consent. The provider is:

Cybot A/S Havnegade 39 1058 Copenhagen Denmark

Purpose of Processing

Cookiebot enables us to display a banner on the first visit to our website, through which active consent to the use of certain cookies and tracking technologies can be given.

The tool also documents the decision in order to comply with the statutory record-keeping obligations under the GDPR.

Data Processed

The following data may, among other things, be transmitted to Cybot:

  • anonymized IP address
  • date and time of consent
  • URL of our website
  • technical browser and device data
  • an encrypted, anonymized key (ID) that stores your consent status

Legal Basis

Processing is based on Art. 6(1)(c) GDPR, as we are legally obliged to obtain and document consent for certain data processing activities.

Retention Period

The collected data is stored for as long as necessary to document your consent (generally 12 months), or until consent is withdrawn or the relevant cookie is deleted in the browser.

Objection and Withdrawal

Cookie settings can be changed at any time via the corresponding link in the footer of our website or by deleting browser cookies.

Further information on data processing by Cybot can be found here: https://www.cookiebot.com/en/privacy-policy/

(2) Insofar as analysis or tracking tools are used (e.g., to improve the app), this is done exclusively on the basis of consent pursuant to Art. 6(1)(a) GDPR.

11. App Stores (Apple/Google)

(1) When the app is downloaded, personal data is processed by the respective app store (Apple App Store / Google Play Store).

(2) The Provider has no influence over this processing. The data protection provisions of the respective store operators apply.

12. Amendments to this Privacy Policy

We reserve the right to amend this Privacy Policy in order to adapt it to changes in the law or technical developments. The then-current version is available at any time on our website.

13. Right to Lodge a Complaint with a Supervisory Authority

Users have the right to lodge a complaint with the Hessian Commissioner for Data Protection and Freedom of Information if they consider that the processing of their personal data violates the GDPR.