I. Introduction

We provide information about collecting personal data when using it in the following.

„personal data“ means any information relating to an identified or identifiable natural person

1. Contact details

The controller within the meaning of Art. 4 (7) General Data Protection Regulation (GDPR) is Smciolon Friedrichshafener Str 31, München. Mohammed Hussein legally represent us.

You may reach our data protection team via the above address and datenschutz@smicolon.com.

2. Scope of data processing, objectives, and legal bases

We detail the scope of data processing, objectives, and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 (1) lit. a GDPR is our legal basis for processing operations for which we obtain consent.
  • Art. 6 (1) lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g., if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 (1) lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 (1) lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g., for cookies necessary for our website's technical operation.

3. Data processing outside the European Economic Area („EEA“)

Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission guarantee the security of the data during the transfer, insofar as they exist (e.g., for Great Britain, Canada, and Israel) (Art. 45 (3) GDPR).

If no adequacy decision exists (e.g., for the USA), the legal basis for the data transfer is usually, i.e., unless we indicate otherwise, standard contractual clauses. These are rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 (2) lit. b GDPR, they ensure the security of the data transfer. Many providers have given contractual guarantees beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

4. Storage Duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose. No legal obligations to retain data conflict with the deletion. Suppose the data are not deleted because they are necessary for other legally permissible purposes. In that case, their processing is restricted, i.e., the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

5. Rights of data subjects

Data subjects have the following rights against us about their data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.
  • the right to complain to a data protection supervisory authority about the processing of their personal data.

6. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process by Art. 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform you of this separately if this is required by law.

7. Contacting us

When contacting us, e.g., by e-mail or telephone, our data (e.g., names and e-mail addresses) will be stored to answer questions. The legal basis for the processing is our legitimate interest to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

II. Data processing on our website

1. Informative use of our website

During the informative use of the website, i.e., when site visitors do not separately transmit information to us, we collect the personal data that the browser sends to our server to ensure the stability and security of our website. This is our legitimate interest (Art. 6 (1) lit. f GDPR).

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software

This data is also stored in log files. They are deleted when their storage is no longer necessary.

2. Provision of the Website

Our website is hosted by [AWS] based on a data processing agreement (Art. 28 GDPR). The provider processes personal data transmitted via the website, e.g., content, usage, meta/communication, or contact. It is our legitimate interest to provide a website so that the legal basis for data processing is Art. 6 (1) lit. f GDPR.

We use a content delivery network to help provide our website. The provider is Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA (privacy policy: https://aws.amazon.com/de/privacy/?nc1=f_pr). The provider processes personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data. It is our legitimate interest to provide a website so that the legal basis for data processing is Art. 6 (1) lit. f GDPR.

3. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message.

The legal basis for the processing is our legitimate interest in answering inquiries directed to us. Therefore, the legal basis for the processing is Art. 6 (1) lit. f GDPR.We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

4. Booking of appointments

Site visitors can book appointments with us on our website. For this purpose, we process metadata or communication data, and the data is entered. We have a legitimate interest in offering interested parties a user-friendly option for making appointments. Therefore, the legal basis for data processing is Art. 6 (1) lit. f GDPR.

5. Technically necessary cookies

Our website sets cookies. Cookies are small text files stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective, and secure. Insofar as these cookies are necessary for the operation of our website or its functions (from now on, "technically necessary cookies"), the legal basis for the associated data processing is Art. 6 (1) lit. f GDPR. We have a legitimate interest in providing site visitors with a functional website.

6. Third parties

a. LinkedIn Insight Tag

We use LinkedIn Insight Tag for conversion tracking. LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 (1) lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies, and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.linkedin.com/legal/privacy-policy?.

b. Google Webfonts

We use Google Webfonts for fonts on the website. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. However, the processing only takes place on our servers. The provider processes meta/communication data (e.g., device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 (1) lit. f GDPR. We have a legitimate interest in using simple and inexpensive fonts on our website.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

c. Calendly

We use Calendly to schedule appointments. The provider is Calendly LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA. The provider processes usage data (e.g., web pages visited, interest in content, access times), contact data (e.g., e-mail addresses, telephone numbers), and master data (e.g., names, addresses) in the USA.

The legal basis for the processing is Art. 6 (1) lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for transferring a country outside the EEA are standard contractual clauses. The security of the data transmitted to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 (2) lit. c GDPR) adopted by the EU Commission by the examination procedure under Art. 93 (2) of the GDPR, which we have agreed to with the provider.

We deleted the data when the purpose for it was collected no longer applies. Further information is available in the provider's privacy policy at https://calendly.com/pages/privacy.

d. Google Tag Manager

We use Google Tag Manager for analytics and advertisement. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 (1) lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for transferring a country outside the EEA are standard contractual clauses. The security of the data transmitted to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 (2) lit. c GDPR) adopted by the EU Commission by the examination procedure under Art. 93 (2) of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

e. Twitter Conversion Tag

We use Twitter Conversion Tag for conversion tracking. The provider is Twitter International Company, 26 Fenian St, Dublin, D02 FX09, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 (1) lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

Standard contractual clauses are the legal basis for transferring a country outside the EEA. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 (2) lit. c GDPR) adopted by the EU Commission by the examination procedure under Art. 93 (2) of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies, and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://twitter.com/en/privacy.

f. Google Conversion Tag

We use Google Conversion Tag for conversion tracking. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g., web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 (1) lit. caGDPR. The processing is based on consent. Data subjects may revoke their consent by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for transferring a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 (2) lit. c GDPR) adopted by the EU Commission by the examination procedure under Art. 93 (2) GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies, and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en
https://support.google.com/tagmanager/answer/9323295?hl=en&ref_topic=3441532.

g. Google Analytics

We use Google Analytics for analytics. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Irland. The provider processes usage data (e.g., web pages visited, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 (1) lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for transferring a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 (2) lit. c GDPR) adopted by the EU Commission by the examination procedure under Art. 93 (2) GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies, and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

h. Hubspot Tag

We use Google Hubspot for analytics: HubSpot Inc. 25 First Street, Cambridge, MA 02141 USA. The provider processes usage data (e.g., web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 (1) lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for transferring a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 (2) lit. c GDPR) adopted by the EU Commission by the examination procedure under Art. 93 (2) GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies, and there is no obligation to retain it. Further information is available in the provider's privacy policy at: https://legal.hubspot.com/privacy-policy.

III. Data processing on social media platforms

We are represented in social media networks to present our company and services there. The operators of these networks regularly process their users' data for advertising purposes. They create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the users‘ interests. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries so that they process data there. This may result in risks for users, e.g., because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us to respond to inquiries. This is our legitimate interest, so the legal basis is Art. 6 (1) lit. f GDPR.

1. Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php

A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads. We are joint controllers for processing the data of visitors to our profile based on an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains precisely what data is processed at: https://www.facebook.com/legal/terms/information_about_page_insights_data

2. Twitter

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy

One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization.

3. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE

One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

4. Xing

We maintain a profile on Xing. The operator is New Work SE, Am Strandkai 1, 20457 Hamburg, Germany The privacy policy is available here: https://privacy.xing.com/en/privacy-policy.

One way to object to data processing is via the settings for advertisements: https://privacy.xing.com/en/privacy-policy/terms-used-in-our-privacy-policy.

IV. Updates of this Privacy Policy

This Privacy Policy was updated in February 2022. We reserve the right to change this Privacy Policy with effect for the future.