Information obligations for customers and suppliers
1. Introduction
Ingenics AG takes the protection of your personal data very seriously. Your privacy is an important concern for us. We process your personal data in accordance with the applicable statutory data protection requirements for the purposes listed below. Personal data within the meaning of this data protection information is all information that relates to you personally.
Below you will find out how we handle this data. For a better overview, we have divided our data protection information into chapters.
Responsible body for data processing
The adress is:
Ingenics AG
Schillerstraße 1/15
89077 Ulm, Germany
Phone +49 731 93680 0
E-Mail: contact@ingenics.com
If you have any questions or comments about data protection, e.g., about accessing and updating your personal data, you can also contact our data protection officer:
DDSK GmbH, Dr.-Klein-Str. 29, 88069 Tettnang, Germany
E-mail: datenschutz@ingenics.com
2. Processing frame
2.1 Source and origin of data collection
We process personal data that we have collected directly from you.
Insofar as this is necessary for the provision of our services, we process personal data legitimately received from other companies or other third parties, e.g., credit agencies, address publishers. In addition, we process personal data that we have permissibly taken, received or acquired from publicly accessible sources (such as telephone directories, commercial and association registers, population registers, debtor directories, land registers, press, Internet and other media) and are permitted to process.
2.2 Data categories
Relevant personal data categories can be in particular
- Personal data (name, date of birth, profession/industry and comparable data)
- Contact details (address, e-mail address, telephone number and similar data)
- Data about your use of the digital services offered by us, e.g., time of accessing our websites, apps or newsletters, pages/links clicked on by us or entries and comparable data.
2.3 Purposes and legal bases of the processed data
We process personal data in accordance with the provisions of the General Data Protection Regulation (GDPR), the new version of the German Federal Data Protection Act (BDSG-neu) and other applicable data protection regulations (details below). Which data is processed in detail and how it is used depends largely on the services requested or agreed in each case. Further details or additions to the purposes of data processing can be found in the respective contract documents, forms, a declaration of consent and/or other information provided to you, e.g., as part of the use of our website or our terms and conditions.
Purposes for the fulfillment of a contract or pre-contractual measures (Art. 6 para. 1 b GDPR)
The processing of personal data takes place for the execution of our contracts with you and the execution of your orders as well as for the execution of measures and activities in the context of pre-contractual relationships, e.g., with interested parties. This essentially includes: contract-related communication with you, the corresponding billing and associated payment transactions, the verifiability of orders and other agreements as well as quality control through appropriate documentation, goodwill procedures, measures for the control and optimization of business processes as well as for the fulfillment of general duties of care, management and control by affiliated companies; statistical evaluations for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, billing and tax assessment of operational services, risk management, assertion of legal claims and defense in legal disputes; ensuring IT security, e.g., system and plausibility tests. IT security (including system and plausibility tests) and general security, safeguarding and exercising domiciliary rights, e.g., through access controls; ensuring the integrity, authenticity and availability of data, preventing and investigating criminal offenses and monitoring by supervisory bodies or control authorities, e.g., auditing.
Purposes within the scope of a legitimate interest of us or third parties (Art. 6 para. 1 f GDPR)
Beyond the actual fulfillment of the contract or preliminary contract, we may process your data if it is necessary to protect our legitimate interests or those of third parties, for the following purposes
- advertising or market and opinion research, provided you have not objected to the use of your data;
- the testing and optimization of procedures for needs analysis;
- the further development of services and products as well as existing systems and processes;
- the enrichment of our data, e.g., by using or researching publicly available data;
- statistical evaluations or market analysis; benchmarking;
- the assertion of legal claims and defense in legal disputes that are not
- are directly attributable to the contractual relationship;
- limited storage of the data if deletion is not possible or only possible with disproportionate effort due to the special type of storage;
- the development of scoring systems or automated decision-making processes;
- the prevention and investigation of criminal offenses, unless exclusively for the fulfillment of legal requirements;
- building and plant security, e.g., through access controls, insofar as this goes beyond the general duty of care;
- internal and external investigations and security checks;
- the receipt and maintenance of certifications of a private or official nature;
- securing and exercising domiciliary rights through appropriate measures (such as video surveillance) as well as securing evidence in the event of criminal offenses and preventing them.
- the effective and resource-saving implementation of web meetings through the use of internet-based communication tools.
Purposes within the scope of your consent (Art. 6 para. 1 a GDPR)
Your personal data may also be processed for certain purposes, e.g., use of your e-mail address for marketing purposes) on the basis of your consent. As a rule, you can withdraw this at any time. This also applies to the revocation of declarations of consent that were given to us before the GDPR came into force, i.e. before May 25, 2018. You will be informed separately about the purposes and consequences of revoking or not granting consent in the corresponding text of the consent. As a general rule, the withdrawal of consent only takes effect for the future. Processing that took place before consent was withdrawn is not affected and remains lawful.
Purposes for the fulfillment of legal requirements (Art. 6 para. 1 c GDPR) or in the public interest (Art. 6 para. 1 e GDPR)
Like everyone involved in business, we are also subject to a variety of legal obligations. These are primarily legal requirements, e.g., commercial and tax laws, but may also include regulatory or other official requirements. The purposes of processing may include the fulfillment of control and reporting obligations under tax law and the archiving of data for the purposes of data protection and data security as well as audits by tax and other authorities. In addition, the disclosure of personal data may become necessary in the context of official/judicial measures for the purposes of gathering evidence, criminal prosecution or the enforcement of civil law claims.
Existence of automated decision-making in individual cases (including profiling)
We do not use any purely automated decision-making processes in accordance with Art. 22 GDPR. If we do use such a procedure in individual cases in the future, we will inform you of this separately if this is required by law.
2.4 Consequences of not providing data
As part of the business relationship, you must provide the personal data that is necessary for the establishment, execution and termination of the legal transaction and the fulfillment of the associated contractual obligations or that we are legally obliged to collect. Without this data, we will not be able to carry out the legal transaction with you.
2.5 Recipients of the data within the EU
Within our company, those internal departments or organizational units receive your data that need it to fulfill our contractual and legal obligations or in the context of processing and implementing our legitimate interest.
Your data will only be passed on to external bodies
- in connection with the execution of the contract;
- for the purposes of fulfilling legal requirements according to which we are obliged to provide information, report or disclose data or the disclosure of data is in the public interest (see section 2.4);
- to the extent that external service providers process data on our behalf as processors or function providers, e.g., data centers, support/maintenance of EDP/IT applications, archiving, document processing, call center services, compliance services, controlling, data validation or plausibility checks, data destruction, purchasing/procurement, customer administration, letter shops, marketing, media technology, research, risk controlling, billing, telephony, website management, auditing services, credit institutions, printers or companies for data disposal, courier services, logistics);
- on the basis of our legitimate interest or the legitimate interest of the third party for the purposes mentioned, e.g., to authorities, credit agencies, debt collection agencies, lawyers, courts, experts, subsidiaries and committees and supervisory bodies;
- if you have given us your consent to transfer your data to third parties.
We will not pass on your data to third parties beyond this. If we commission service providers as part of order processing, your data will be subject to the same security standards as we do. In all other cases, the recipients may only use the data for the purposes for which it was transmitted to them.
2.6 Recipients of the data outside the EU
If we transfer personal data to service providers or group companies outside the European Economic Area (EEA), the transfer will only take place if the third country has been confirmed by the EU Commission to have an adequate level of data protection or if other appropriate data protection guarantees, e.g., binding internal data protection regulations or EU standard contractual clauses are in place.
2.7 Storage periods
We process and store your data for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.
In addition, we are subject to various retention and documentation obligations arising from the German Commercial Code (HGB) and the German Fiscal Code (AO), among others. The retention and documentation periods specified there are up to ten years to the end of the calendar year after the end of the business relationship or the pre-contractual legal relationship.
Furthermore, special statutory provisions may require a longer retention period, such as the preservation of evidence within the framework of statutory limitation periods. According to Sections 195 et seq. of the German Civil Code (BGB), the regular limitation period is three years; however, limitation periods of up to 30 years may also be applicable.
If the data is no longer required for the fulfillment of contractual or legal obligations and rights, it is regularly deleted, unless its - temporary - further processing is necessary to fulfill the purposes for an overriding legitimate interest. Such an overriding legitimate interest also exists, for example, if deletion is not possible or only possible with disproportionately high effort due to the special type of storage and processing for other purposes is excluded by suitable technical and organizational measures.
3. Your rights
Under certain circumstances, you can assert your data protection rights against us. If possible, your requests to exercise your rights should be addressed in writing or by e-mail to the address given above or directly in writing or by e-mail to our data protection officer.
- You have the right to receive information from us about your data stored by us in accordance with the rules of Art. 15 GDPR (possibly with restrictions according to § 34 BDSG-Neu).
- At your request, we will correct the data stored about you in accordance with Art. 16 GDPR if it is inaccurate or incorrect.
- If you wish, we will delete your data in accordance with the principles of Art. 17 GDPR, provided that other legal regulations, e.g., legal storage obligations or the restrictions according to § 35 BDSG-Neu) or an overriding interest on our part, e.g., to defend our rights and claims, do not conflict with this.
- Taking into account the requirements of Art. 18 GDPR, you can request us to restrict the processing of your data.
- If your personal data are processed on the basis of legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR or if they are necessary for the performance of a task carried out in the public interest or in the exercise of official authority, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation.
- You also have the right to receive your data in a structured, commonly used and machine-readable format or to transmit it to a third party in accordance with the requirements of Art. 20 GDPR.
- In addition, you have the right to withdraw your consent to the processing of personal data at any time with effect for the future.
- You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). However, we recommend that you always address a complaint to our data protection officer first.
You can contact the supervisory authority responsible for us at:
The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Represented by the State Commissioner for Data Protection and Freedom of Information Baden-Württemberg Prof. Dr. Tobias Keber.
Visitor address:
Lautenschlagerstrasse 20
70173 Stuttgart, Germany
Postal address:
P.O. Box 10 29 32
70025 Stuttgart, Germany
Phone: +49 711/615541-0
Fax: +49 711/615541-15
E-mail: poststelle@lfdi.bwl.de