Privacy Policy

This Privacy Policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter briefly referred to as “data”) within our online offering and the associated websites, functions, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). With regard to the terminology used, such as “processing” or “controller,” we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

TropoTherm, S.L.
Address and Tax Identification Numbers.

Patents:
DE 10 2013 010 702
EP 147 33 093

Types of Data Processed

  1. Inventory data (e.g., names, addresses).
  2. Contact data (e.g., email, phone numbers).
  3. Content data (e.g., text entries, photographs, videos).
  4. Usage data (e.g., visited websites, interest in content, access times).
  5. Meta/Communication data (e.g., device information, IP addresses).

Categories of Data Subjects

Visitors and users of the online offering (hereinafter, we collectively refer to the data subjects as “users”).

Purpose of Processing

  • Provision of the online offering, its functions and content.
  • Responding to contact inquiries and communication with users.
  • Security measures.
  • Audience Measurement/Marketing

Terminology Used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural 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 online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of 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 concerning that natural person’s performance at work, economic situation, health, personal preferences, interests,
reliability, behaviour, location or movements.

The “controller” means the natural or legal person, public authority, agency or other body which, alone
or jointly with others, determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal
data on behalf of the controller.

Relevant Legal Bases

In accordance with Art. 13 GDPR, we inform you about the legal bases of our data processing. Unless the legal basis is stated in this Privacy Policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR; the legal basis for processing to fulfill our services and carry out contractual measures, as well as responding to inquiries, is Art. 6 para. 1 lit. b GDPR; the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR; and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

Security Measures

In accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, disclosure, ensuring availability, and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal

data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR). Cooperation with Processors and Third Parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, is necessary for the fulfillment of the contract in accordance with Art. 6 para. 1 lit. b GDPR), if you have consented, if a legal obligation
provides for this, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a “data processing agreement,” this is done on the basis of Art. 28 GDPR.

Transfers to Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing/transferring data to third parties, this is done only if it is necessary for the fulfillment of our (pre-)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process or have data processed in a third country only if the special conditions of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level equivalent to that of the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized specific contractual obligations
(so-called “Standard Contractual Clauses”).

Rights of Data Subjects

You have the right to request confirmation as to whether data concerning you is being processed, and to obtain information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR. In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you. In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted without undue delay, or alternatively, in accordance with Art. 18 GDPR, to request a restriction of the processing of the data. You have the right to request that the data concerning you, which you have provided to us, be received in accordance with Art. 20 GDPR and to demand its transmission to other controllers.

Furthermore, in accordance with Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.

Right to Revoke Consent

You have the right to revoke granted consents in accordance with Art. 7 para. 3 GDPR with effect for the future.

Right to Object

You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR.
The objection can be made in particular against processing for direct marketing purposes.

Cookies and Right to Object to Direct Marketing

“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can, for example, store the content of a shopping cart in an online shop or a login status. “Permanent” or “persistent” cookies are those that remain stored even after the browser is closed. For example, the login status can be saved if users visit it again after several days. Likewise, user interests can be stored in such a cookie, which are used for audience measurement or marketing purposes. “Third-party cookies” are cookies offered by providers other than the controller operating the online offering (otherwise, if they are only its own cookies, they are called “first-party cookies”). We may use temporary and permanent cookies and explain this in our Privacy Policy. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser’s system settings. Stored cookies can be deleted in the browser’s system settings. The exclusion of cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies employed for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site
http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by deactivating them in the browser settings. Please note that in this case, not all functions of this online offering may be available.

Deletion of Data

The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated otherwise in this Privacy Policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and no legal retention obligations prevent its deletion. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, retention periods are, in particular, 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, booking vouchers, commercial books, tax-relevant documents, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).

According to legal requirements in Austria, retention periods are, in particular, 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statement of income and expenses, etc.), 22 years in connection with real estate, and 10 years for documents related to electronically supplied services, telecommunications, broadcasting and television services provided to non-taxable persons in EU Member States and for which the Mini One Stop Shop (MOSS) is used.

Data Protection Information in the Application Process

We process applicant data only for the purpose and within the scope of the application process in accordance with legal requirements. The processing of applicant data takes place for the fulfillment of our (pre-)contractual obligations within the application process in the sense of Art. 6 para. 1 lit. b GDPR, Art. 6 para. 1 lit. f GDPR, provided that data processing becomes necessary for us, e.g., in the context of legal proceedings (in Germany, § 26 BDSG also applies).

The application process requires applicants to provide us with their applicant data. The necessary applicant data, if we offer an online form, are marked as such; otherwise, they result from the job descriptions and generally include personal details, postal and contact addresses, and the documents belonging to the application, such as cover letter, CV, and certificates. In addition, applicants may voluntarily provide us with additional
information. By submitting their application to us, applicants agree to the processing of their data for
the purposes of the application process in accordance with the type and scope outlined in this Privacy Policy.

Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated during the application process, their processing also takes place in accordance with Art. 9 para. 2 lit. b GDPR (e.g., health data, such as severe disability status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants during the application process, their processing also takes place in accordance with Art. 9 para. 2 lit. a GDPR (e.g., health data, if these are necessary for the exercise of the profession).

If available, applicants can submit their applications to us via an online form on our website. The data is transmitted to us encrypted in accordance with the state of the art.

Furthermore, applicants can submit their applications to us via email. However, please note that emails are generally not sent encrypted, and applicants must ensure encryption themselves. Therefore, we cannot assume responsibility for the transmission path of the application between the sender and the receipt on our server and therefore recommend using an online form or postal
delivery instead. Because instead of applying via the online form and email, applicants still have the option to send us their application by post.

The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. The applicant’s data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time
.

Deletion takes place, subject to a justified revocation by the applicants, after a period of six months, so that we can answer any follow-up questions regarding the application and fulfill our obligations to provide evidence under the General Equal Treatment Act. Invoices for any travel expense reimbursement will be archived in accordance with tax law requirements.

Contacting Us

When contacting us (e.g., via contact form, email, telephone, or social media), user information is processed for the purpose of handling the contact inquiry and its processing in accordance with Art. 6 para. 1 lit. b) GDPR. User information may be stored in a Customer Relationship Management system (“CRM system”)
or similar inquiry organization system.

We delete inquiries if they are no longer necessary. We review the necessity every two years; furthermore, legal archiving obligations apply.

Hosting and Email Dispatch

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services, and technical maintenance services that we use for the purpose of operating this online offering.

In this context, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties, and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

Google Analytics

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR), we use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transmitted to a Google server in the USA
and stored there.

Google is certified under the Privacy Shield Agreement, thereby offering a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on activities within this online offering, and to provide us with further services related to the use of this online offering and internet usage.
Pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with IP anonymization activated. This means that the IP address of users is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software settings; users can also prevent the collection of data generated by the cookie and related to their use
of the online offering by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on data usage by Google, settings, and objection options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google
(https://adssettings.google.com/authenticated).

Users’ personal data will be deleted or anonymized after 14 months.

Integration of Third-Party Services and Content

Within our online offering, based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR), we use content or service offerings from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “Content”).

This always requires that the third-party providers of this content perceive the users’ IP address, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the
display of this content. We endeavor to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called
pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Through the “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information can also be stored in cookies on the users’ device and may include, among other things, technical information about the browser and operating system, referring websites,
visit time, and other details about the use of our online offering, as well as be combined with such information
from other sources.

Google Fonts

We integrate the fonts (“Google Fonts”) from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Maps

We integrate the maps of the service “Google Maps” from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually obtained through the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.