Privacy policy - Stemmann-Technik

1. Introduction

With the following information, we would like to give you, as the "data subject," an overview of how we process your personal data and your rights under data protection laws. It is generally possible to use our website without entering any personal data. However, if you wish to use specific services offered by our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain your consent.

The processing of personal data, such as your name, address, or email address, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to STEMMANN-Technik GmbH. With this privacy policy, we would like to inform you about the scope and purpose of the personal data we collect, use, and process.

As the controller responsible for processing, we have implemented numerous technical and organizational measures to ensure the most complete protection possible for the personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are free to transmit personal data to us by alternative means, for example by telephone or mail.

You too can take simple and easy-to-implement measures to protect yourself against unauthorized access to your data by third parties. We would therefore like to take this opportunity to give you some tips on how to handle your data securely:

Protect your account (login, user or customer account) and your IT system (computer, laptop, tablet, or mobile device) with secure passwords.
Only you should have access to the passwords.
Make sure you only use your passwords for one account (login, user or customer account).
Do not use the same password for different websites, applications, or online services.
Especially when using publicly accessible IT systems or those shared with other people, you should always log out after each session on a website, application, or online service.

Passwords should consist of at least 12 characters and be chosen so that they cannot be easily guessed. Therefore, they should not contain common words from everyday life, your own name or the names of relatives, but should include upper and lower case letters, numbers, and special characters.

2. Responsible party

The controller within the meaning of the GDPR is:

STEMMANN-Technik GmbH
Niedersachsenstraße 2, 48465 Schüttorf, Germany

Representative of the controller: The management

3. Data protection officer

You can contact the data protection officer as follows:

DataOrga® GmbH - Ingo Krause
Email: fsg-stemmann-datenschutz@wabtec.com

You can contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

4. Definitions

The privacy policy is based on the terminology used by the European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms in this privacy policy, among others:

4.1 Personal data

Personal data is any information relating to an identified or identifiable natural person. A natural person is considered identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier, or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural, or social identity of that natural person.

4.2 Data subject

A data subject is any identified or identifiable natural person whose personal data is processed by the controller (our company).

4.3 Processing

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, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

4.4 Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting its future processing.

4.5 Profiling

Profiling is any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

4.6 Pseudonymization

Pseudonymization is 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 organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

4.7 Processor

A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

4.8 Recipient

A recipient is a natural or legal person, public authority, agency, or other body to which personal data is disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

4.9 Third party

A third party is a natural or legal person, public authority, agency, or other body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

4.10 Consent

Consent is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

5. Legal basis for processing

Art. 6 (1) (a) GDPR (in conjunction with Section 25 (1) TDDDG (formerly TTDSG)) serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 (1) (b) GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.

If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) (c) GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were injured and his name, age, health insurance details, or other vital information had to be passed on to a doctor, hospital, or other third party. In this case, the processing would be based on Art. 6 (1) (d) GDPR.

Finally, processing operations could be based on Art. 6 (1) lit. f) GDPR. This legal basis applies to processing operations that are not covered by any of the above legal bases if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47, sentence 2 of the GDPR).

Our offer is generally aimed at adults. Persons under the age of 16 may not transmit any personal data to us without the consent of their parents or legal guardians. We do not request personal data from children and young people, do not collect it, and do not pass it on to third parties.

6. Transfer of data to third parties

Your personal data will not be transferred to third parties for purposes other than those listed below.

We only pass on your personal data to third parties if:

1. you have given us your express consent to do so in accordance with Art. 6 (1) (a) GDPR,

2. the transfer is permissible under Art. 6 (1) lit. f) GDPR to safeguard our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,

3. there is a legal obligation to disclose the data in accordance with Art. 6 (1) (c) GDPR, and

4. this is legally permissible and necessary for the performance of contractual relationships with you pursuant to Art. 6 (1) (b) GDPR.

In order to protect your data and, if necessary, enable us to transfer data to third countries (outside the EU/EEA), we have concluded agreements on order processing based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent pursuant to Art. 49 (1) (a) GDPR may serve as the legal basis for the transfer to third countries. This does not apply to data transfers to third countries for which the European Commission has issued an adequacy decision pursuant to Art. 45 GDPR.

Your personal data will not be transferred to third parties for purposes other than those listed below.

We will only disclose your personal data to third parties if:

1. you have given us your express consent in accordance with Art. 6 (1) (a) GDPR,

2. the transfer is permissible under Article 6(1)(f) GDPR to safeguard our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,

3. there is a legal obligation to disclose the data in accordance with Art. 6 (1) (c) GDPR, and

4. this is legally permissible and necessary for the performance of contractual relationships with you pursuant to Art. 6 (1) (b) GDPR.

Within the scope of the processing operations described in this privacy policy, personal data may be transferred to the USA. Companies in the USA only have an adequate level of data protection if they have certified themselves under the EU-US Data Privacy Framework and thus the adequacy decision of the EU Commission pursuant to Art. 45 GDPR applies. We have explicitly mentioned this in the privacy policy for the service providers concerned. In order to protect your data in all other cases, we have concluded agreements on order processing based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent pursuant to Art. 49 (1) (a) GDPR may serve as the legal basis for the transfer to third countries. This does not apply to data transfers to third countries for which the European Commission has issued an adequacy decision pursuant to Art. 45 GDPR.

7. Technology

7.1 SSL/TLS encryption

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data, or contact requests that you send to us as the operator. You can recognize an encrypted connection by the fact that the address line of the browser contains "https://" instead of "http://" and by the lock symbol in your browser line.

We use this technology to protect the data you transmit.

7.2 Data collection when visiting the website

When you use our website for informational purposes only, if you do not register or otherwise provide us with information or give your consent to processing that requires consent, we only collect data that is technically necessary to provide the service. This is usually data that your browser transmits to our server ("in so-called server log files"). Our website collects a range of general data and information each time you or an automated system accesses a page. This general data and information is stored in the server's log files. The following may be collected:

1. browser types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system reaches our website (so-called referrer),
4. the subpages accessed on our website via an accessing system,
5. the date and time of access to the website,
6. an abbreviated Internet Protocol address (anonymized IP address), and
7. the Internet service provider of the accessing system.

We do not draw any conclusions about your person when using this general data and information. Rather, this information is required in order to

1. deliver the content of our website correctly,

2. optimize the content of our website and the advertising for it,

3. ensure the long-term functionality of our IT systems and the technology of our website, and

4. to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack.

We therefore evaluate this collected data and information statistically on the one hand and with the aim of increasing data protection and data security in our company on the other, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

The legal basis for data processing is Art. 6 (1) lit. f) GDPR. Our legitimate interest follows from the purposes listed above for data collection.

8. Cookies

8.1 General information about cookies

Cookies are small files that your browser automatically creates and that are stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our site.

Information is stored in the cookie that results from the context of the specific end device used. However, this does not mean that we immediately become aware of your identity.

The use of cookies serves to make the use of our website more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.

In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your device for a specific period of time. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website and to evaluate our offer for you for the purpose of optimization. These cookies enable us to automatically recognize that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period of time. The respective storage period of the cookies can be found in the settings of the consent tool used.

8.2 Legal basis for the use of cookies

The data processed by the cookies, which is necessary for the proper functioning of the website, is therefore necessary to safeguard our legitimate interests and those of third parties in accordance with Art. 6 (1) lit. f) GDPR.

For all other cookies, you have given your consent in accordance with Art. 6 (1) (a) GDPR via our opt-in cookie banner.

8.3 Information on avoiding cookies in common browsers

You can delete cookies, allow only selected cookies, or completely deactivate cookies at any time via the settings of your browser. Further information is available on the support pages of the respective providers:

Chrome: https://support.google.com/chrome/answer/95647?tid=311178978.
Safari: https://support.apple.com/de-at/guide/safari/sfri11471/mac?tid=311178978.
Firefox: https://support.mozilla.org/de/kb/cookies-und-website-daten-in-firefox-loschen?tid=311178978.
Microsoft Edge: https://support.microsoft.com/de-de/microsoft-edge/cookies-in-microsoft-edge-l%C3%B6schen-63947406-40ac-c3b8-57b9-2a946a29ae09.

8.4 Usercentrics (consent management tool)

We use the consent management tool "Usercentrics" from Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich, Germany. This service enables us to obtain and manage the consent of website users for data processing.

Usercentrics collects data generated by end users who use our website. When an end user gives their consent, Usercentrics automatically logs the following data:

Browser information.
Date and time of access.
Device information.
The URL of the page visited.
Geographical location.
Page path of the website.
The consent status of the end user, which serves as proof of consent.

The consent status is also stored in the end user's browser so that the website can automatically read and comply with the end user's consent for all subsequent page requests and future end user sessions for up to 12 months. The consent data (consent and revocation of consent) is stored for three years. The retention period corresponds to the regular limitation period in accordance with § 195 BGB (German Civil Code). The data is then immediately deleted or, upon request, forwarded to the responsible person in the form of a data export.

The functionality of the website cannot be guaranteed without the processing described. The user has no right to object as long as there is a legal obligation to obtain the user's consent to certain data processing operations (Art. 7 (1), 6 (1) (c) GDPR).

Usercentrics is the recipient of your personal data and acts as a processor for us.

Detailed information on the use of Usercentrics can be found at: https://usercentrics.com/privacy-policy/.

9. Content of our website

9.1 Contacting us / contact form

When you contact us (e.g., via contact form or email), personal data is collected. The data collected when using a contact form can be seen in the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and the associated technical administration. The legal basis for the processing of the data is our legitimate interest in responding to your request in accordance with Art. 6 (1) lit. f) GDPR. If your contact request is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b) GDPR. Your data will be deleted after your request has been processed, which is the case when it can be inferred from the circumstances that the matter in question has been conclusively clarified and there are no legal retention obligations that prevent deletion.

9.2 Application management / job exchange

We collect and process the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits the relevant application documents to us electronically, for example by email or via a web form on the website. If we conclude an employment or service contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If we do not conclude a contract with the applicant, the application documents will be automatically deleted six months after notification of the rejection decision, provided that no other legitimate interests on our part prevent deletion. Another legitimate interest in this sense is, for example, the burden of proof in proceedings under the General Equal Treatment Act (AGG).

The legal basis for the processing of your data is Art. 6 (1) lit. b), 88 GDPR in conjunction with § 26 (1) BDSG.

10. Newsletter dispatch

10.1 Newsletter dispatch to existing customers

If you have provided us with your email address when purchasing goods or services, we reserve the right to regularly send you offers for similar goods or services from our range by email. In accordance with Section 7 (3) UWG (German Unfair Competition Act), we do not need to obtain your separate consent for this. Data processing in this regard is based solely on our legitimate interest in personalized direct advertising in accordance with Art. 6 (1) lit. f) GDPR. If you initially objected to the use of your email address for this purpose, we will not send you any emails. You are entitled to object to the use of your email address for the aforementioned advertising purpose at any time with effect for the future by notifying the controller named at the beginning. You will only incur transmission costs according to the basic rates for this. Upon receipt of your objection, the use of your email address for advertising purposes will be discontinued immediately.

11. Our activities on social networks

We have our own pages on social networks so that we can communicate with you there and inform you about our services. When you visit one of our social media pages, we are jointly responsible with the provider of the respective social media platform for the processing operations triggered by this, within the meaning of Art. 26 GDPR.

We are not the original provider of these pages, but merely use them within the scope of the options offered to us by the respective providers.
As a precaution, we would therefore like to point out that your data may also be processed outside the European Union or the European Economic Area. Use may therefore involve data protection risks for you, as it may be more difficult to protect your rights, e.g., to information, deletion, objection, etc., and processing on social networks is often carried out directly for advertising purposes or to analyze user behavior by the providers, without us being able to influence this. If usage profiles are created by the provider, cookies are often used or your usage behavior is assigned to your own member profile on social networks.

The processing of personal data described above is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest and the legitimate interest of the respective provider in communicating with you in a modern way and informing you about our services. If you have to give your consent to data processing as a user to the respective providers, the legal basis refers to Art. 6 (1) lit. a) GDPR in conjunction with Art. 7 GDPR.

As we do not have access to the providers' databases, we would like to point out that it is best to exercise your rights (e.g., to information, correction, deletion, etc.) directly with the respective provider. Further information on the processing of your data in social networks is listed below for each social network provider we use:

11.1 Facebook

(Joint) controller for data processing in Europe:
Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Unless you object, Meta (Facebook) may process content from adult users in the EU, e.g., photos, posts, or comments, for the purpose of training its own AI models. The basis for this is a legitimate interest pursuant to Art. 6 (1) (f) GDPR. As a company, we have no influence on this specific data processing by Meta. Users can object to this via an online form on the Meta platforms.

11.2 LinkedIn

(Joint) controller for data processing in Europe:
LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland

12. Web analytics

12.1 Matomo

We have integrated the Matomo component from the provider InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand, into this website. Matomo is a software tool for web analysis, i.e. for collecting, gathering, and evaluating data on the behavior of visitors to websites. Among other things, data is collected about which website a data subject came to a website from (so-called referrer), which subpages of the website were accessed, or how often and for how long a subpage was viewed. This is used to optimize the website and for cost-benefit analysis of internet advertising.

The software is operated on the server of the controller, and the log files, which are sensitive in terms of data protection, are stored exclusively on this server.

Matomo sets a cookie on your IT system. Setting the cookie enables us to analyze the use of our website. Each time one of the individual pages of this website is accessed, the Matomo component automatically prompts the Internet browser on your IT system to transmit data to our server for the purpose of online analysis. As part of this technical process, we receive personal data, such as the IP address of the data subject, which we use, among other things, to track the origin of visitors and clicks.

The cookie is used to store personal information, such as the access time, the location from which access originated, and the frequency of visits to our website. Each time you visit our website, this personal data, including the IP address of the Internet connection you are using, is transmitted to our server. This personal data is stored by us. We do not pass this personal data on to third parties.

These processing operations are carried out exclusively with your express consent in accordance with Art. 6 (1) (a) GDPR.

You can view Matomo's privacy policy at: https://matomo.org/privacy/.

13. Plugins and other services

13.1 Google reCAPTCHA

We use the reCAPTCHA function on this website. The operating company of Google reCAPTCHA is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The reCAPTCHA function is primarily used to distinguish whether an entry is made by a natural person or is abusive due to machine and automated processing. The service also includes sending the IP address and, if necessary, other data required by Google for the reCAPTCHA service to Google.

These processing operations are carried out exclusively with the express consent of the user in accordance with Art. 6 (1) (a) GDPR.

The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. This means that an adequacy decision pursuant to Art. 45 GDPR has been made, so that personal data may be transferred without further guarantees or additional measures.

Further information on Google reCAPTCHA and Google's privacy policy can be found at: https://www.google.com/intl/de/policies/privacy/.

13.2 Google WebFonts

Our website uses so-called web fonts for the uniform display of fonts. Google WebFonts are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

These processing operations are carried out exclusively with the express consent of the user in accordance with Art. 6 (1) (a) GDPR.

Further information on Google WebFonts and Google's privacy policy can be found at: https://developers.google.com/fonts/faq ; https://www.google.com/policies/privacy/.

14. Your rights as a data subject

14.1 Right to confirmation

You have the right to request confirmation from us as to whether personal data concerning you is being processed.

14.2 Right to information Art. 15 GDPR

You have the right to obtain from us, free of charge, information about the personal data stored about you and a copy of this data in accordance with the statutory provisions.

14.3 Right to rectification Art. 16 GDPR

You have the right to request the rectification of inaccurate personal data concerning you. Furthermore, you have the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

14.4 Erasure Art. 17 GDPR

You have the right to request that we delete your personal data immediately if one of the reasons provided for by law applies and if the processing or storage is not necessary.

14.5 Restriction of processing Art. 18 GDPR

You have the right to request that we restrict processing if one of the legal requirements is met.

14.6 Data portability Art. 20 GDPR

You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from us, to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out using automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Furthermore, when exercising your right to data portability pursuant to Art. 20 (1) GDPR, you have the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

14.7 Objection Art. 21 GDPR

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) (data processing in the public interest) or (f) (data processing based on a balancing of interests) of the GDPR.

This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 GDPR.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing serves to assert, exercise, or defend legal claims.

In individual cases, we process personal data for direct marketing purposes. You can object to the processing of personal data for such marketing purposes at any time. This also applies to profiling insofar as it is related to such direct marketing. If you object to us processing your data for direct marketing purposes, we will no longer process your personal data for these purposes.

In addition, you have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you that we carry out for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 (1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

You are free to exercise your right to object in relation to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.

14.8 Revocation of consent under data protection law

You have the right to withdraw your consent to the processing of personal data at any time with effect for the future.

14.9 Complaint to a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

15. Routine storage, deletion, and blocking of personal data

We process and store your personal data only for the period necessary to achieve the purpose of storage or as provided for by the legal provisions to which our company is subject.

If the storage purpose no longer applies or a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

16. Duration of storage of personal data

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment of a contract or for the initiation of a contract.

17. Up-to-dateness and changes to the privacy policy

This privacy policy is currently valid and was last updated in October 2025.

Due to the further development of our website and offers or due to changed legal or official requirements, it may be necessary to change this privacy policy. You can access and print out the current privacy policy at any time on the website at "[LINK]".

This privacy policy was created with the support of the data protection software: audatis MANAGER.