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Data Privacy

We appreciate your interest in our company. The management of SWS-Packaging GmbH attaches great importance to data protection. The use of the SWS-Packaging GmbH website is generally possible without providing personal data. However, if a data subject wishes to make use of special services of 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 generally obtain the consent of the data subject.
The processing of personal data, such as name, address, e-mail address or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to SWS-Packaging GmbH. With this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data that we collect, use and process. In addition, the data subject is informed of the rights to which he or she is entitled by virtue of this data protection declaration. As the data controller, SWS-Packaging GmbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed via this website. Nevertheless, the transmission of data over the Internet is generally subject to security gaps, so that absolute protection cannot be guaranteed. For this reason, each data subject is free to transmit personal data to us by other means, such as by telephone. 

1. Definitions

 The SWS-Packaging GmbH privacy policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology we use.

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

a) personal data

Personal Data shall mean any information relating to an identified or identifiable natural person (“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) data subject

A Data Subject is any identified or identifiable natural person whose personal data is processed by the Controller responsible for processing such data.

c) 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, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

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

e) Profiling

Profiling is any form of automated processing of personal data consisting of using 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.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be associated with a specific data subject without the use of additional information, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data is not associated with an identified or identifiable natural person

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

    h) Processor

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

    i) Recipient

    Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which 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.

    j) Third

    Third party is a natural or legal person, public authority, agency or 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.

    k) 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.

    2. The name and address of the controller

    The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union and other provisions relating to data protection is:

    SWS-Packaging GmbH

    Obere Losterbach 1/1

    75050 Gemmingen

    Germany

    Phone: +49 7131-88723-0

    E-Mail: info@sws-packaging.de

    Website: www.sws-packaging.de

    3. The Name and address of the data protection officer

    The data protection officer of the controller is:

    NABICON IT-Business Consulting GmbH

    Hanns-Martin-Schleyer-Straße 1

    74177 Bad Friedrichshall

    Deutschland

    Tel.: 07136 98490 40

    E-Mail: datenschutz@sws-packaging.de

    Website: www.nabicon.de

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

    4. Cookies

    The Internet pages of SWS-Packaging GmbH use cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.
    Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters that can be used to assign websites and servers to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.
    Through the use of cookies, the SWS-Packaging GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
    By means of a cookie, the information and offers on our website can be optimized for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie for a shopping basket in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.
    The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

    5. Collection of general data and information

    The website of the SWS-Packaging GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website can be recorded, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.When using these general data and information, the SWS-Packaging GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber-attack. Therefore, the SWS-Packaging GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

    6. Possibility of contact via the website

    The website of SWS-Packaging GmbH contains information that enables quick electronic contact with our company as well as direct communication with us, including a general electronic mail address (e-mail address). If a data subject contacts the data controller via e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data, voluntarily provided by the data subject to the data controller, will be stored for the purpose of processing or contacting the data subject. Such personal data will not be disclosed to third parties.

    7. Routine erasure and blocking of personal data

    The controller shall process and store the personal data of the data subject only for as long as is necessary to achieve the purpose of storage or as is permitted by the European legislator or other legislator in laws or regulations to which the controller is subject.
    If the purpose of storage no longer applies or if a retention period prescribed by the European legislator or other competent legislator has expired, the personal data will be routinely blocked or deleted in accordance with the legal provisions.

    8. Rights of the data subject
    a) Right of confirmation

    Any data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

    b) Right of access

    Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

    • the purposes of the processing,
    • the categories of personal data being processed,
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations,
    • where possible, the envisaged length of time for which the personal data will be stored or, if this is not possible the existence of a right to rectify or erase personal data concerning him or her or to restrict processing by the controller or a right to object to such processing
    • the existence of a right to lodge a complaint with a supervisory authority where the personal data are not obtained from the data subject:
    • All available information on the origin of the data the existence of automated decision making, including profiling, in accordance with Article 22 (1) and (4) GDPR, at least in these cases, meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.
    c) Right to rectification

    Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
    If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

    d) Right to erasure (right to be forgotten)

    Any person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the following grounds applies and insofar as the processing is not necessary:

    • The personal data have been collected or otherwise processed for purposes for which they are no longer necessary.
    • The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
    • The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.
    • The personal data has been processed unlawfully.
    • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
    • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
    e) Right to Restriction Processing

    Every data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing in any of the following cases:

    • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
    • The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
    • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
    • The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
    f) Right to data portability

    Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 

    Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.


    In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by the SWS-Packaging GmbH or another employee. 

    g) Right to object

    Every data subject shall have the right granted by the European legislator to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling on the basis of these provisions.

    The SWS-Packaging GmbH will no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.  If SWS-Packaging GmbH processes personal data for the purpose of direct marketing, the data subject shall have the right at any time to object to the processing of personal data concerning him or her for such marketing. This also applies to profiling, insofar as it is connected with such direct marketing. If the data subject objects to the processing for direct marketing purposes, SWS-Packaging GmbH shall no longer process the personal data for these purposes.

    In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the SWS-Packaging GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

    In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of the SWS-Packaging GmbH or another employee. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

    h) Automated individual decision-making, including profiling

    Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is permissible on the basis of Union or Member State legislation to which the controller is subject and that such legislation contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is taken with the express consent of the data subject.

    If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the SWS-Packaging GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

    If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of the controller or another employee of the controller.

    i) Right to withdraw consent under data protection law

    Any person affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

    If the data subject wishes to exercise their right to withdraw consent, they may contact our data protection officer or another employee of the controller at any time.

    9. data protection provisions about the application and use of Google Analytics (with anonymization function)
    1. On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analysis service. Web analysis is the collection, gathering and evaluation of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on the website from which a data subject came to a website (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. Web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.


    The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

    The data controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the Internet connection of the person concerned is shortened and anonymized by Google if access to our Internet pages is from a member state of the European Union or from another state party to the Agreement on the European Economic Area.


    The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us that show the activities on our website, and to provide other services related to the use of our website.

    Google Analytics places a cookie on the user’s computer. What cookies are has already been explained above. Setting the cookie enables Google to analyze the use of our website. Each time you access one of the individual pages of this website operated by the controller and on which a Google Analytics component has been integrated, the Internet browser on the IT system of the person concerned is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. In the course of this technical process, Google obtains knowledge of personal information, such as the IP address of the data subject, which helps Google, among other things, to understand the origin of visitors and clicks and subsequently to prepare commission settlements.

    The cookie is used to store personal information, such as the access time, the location from which access was made and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.


    The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a cookie on the data subject’s IT system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

    Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the link tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the data subject’s IT system is deleted, formatted or reinstalled at a later date, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person who is attributable to their sphere of control, it is possible to reinstall or reactivate the browser add-on

    Further information and the applicable data protection provisions of Google may be retrieved under www.google.de/intl/de/policies/privacy/ and under www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link www.google.com/intl/de_de/analytics/.

    9a) Use of Matomo

    Matomo

    This website uses the open source web analysis service Matomo. Matomo uses technologies that enable the cross-page recognition of the user to analyze user behavior (e.g. cookies or device fingerprinting). The information collected by Matomo about the use of this website is stored on our server. The IP address is anonymized before it is stored.

    With the help of Matomo, we are able to collect and analyze data about the use of our website by website visitors. This enables us to find out, among other things, when which pages were accessed and from which region. We also record various log files (e.g. IP address, referrer, browser and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.). 

    This analysis tool is used on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the anonymized analysis of user behavior in order to optimize both its website and its advertising. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time. 

    IP anonymization
    We use IP anonymization for the analysis with Matomo. Your IP address is shortened before the analysis so that it can no longer be clearly assigned to you.


    Hosting
    We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on. 

    10. data protection provisions about the application and use of Google AdWords

    The controller has integrated Google AdWords on this website. Google AdWords is an Internet advertising service that allows advertisers to place ads both in Google’s search engine results and in the Google advertising network. Google AdWords allows an advertiser to specify certain keywords in advance, which are used to display an ad in Google’s search engine results only when the user uses the search engine to retrieve a keyword-relevant search result. In the Google advertising network, the ads are distributed to relevant websites using an automatic algorithm and taking into account the previously defined keywords.

      The operating company of the Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

      The purpose of Google AdWords is to advertise our website by displaying interest-relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine and by displaying third-party advertising on our website.

      If a data subject reaches our website via a Google ad, a so-called conversion cookie is stored on the data subject’s IT system by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. If the cookie has not yet expired, the conversion cookie is used to track whether certain sub-pages, such as the shopping cart from an online store system, have been accessed on our website. The conversion cookie enables both us and Google to track whether a data subject who has reached our website via an AdWords ad has generated sales, i.e. completed or canceled a purchase.

      The data and information collected through the use of the conversion cookie is used by Google to compile visit statistics for our website. These visit statistics are in turn used by us to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could be used to identify the data subject.

      The conversion cookie is used to store personal information, such as the websites visited by the data subject. Each time our website is visited, personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

      The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the data subject’s IT system. In addition, a cookie already set by Google AdWords can be deleted at any time via the Internet browser or other software programs.

      The data subject may also opt out of interest-based advertising by Google. To do so, the data subject must access the link www.google.de/settings/ads from each of the Internet browsers he or she uses and make the desired settings there.


      Further information and Google’s applicable privacy policy can be found at www.google.de/intl/de/policies/privacy/.

      11. Legal basis of the processing

      Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations for 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 the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis 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, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

      12. Legitimate interests in the processing pursued by the controller or by a third party

      Where the processing of personal data is based on Article 6 I lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and our shareholders.

      13. Duration for which the personal data is stored

      The criterion for the duration of the storage of personal data is the respective statutory retention period. Once this period has expired, the corresponding data is routinely deleted, provided it is no longer required to fulfill or initiate a contract.

      14. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

      We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided. 

      15. Existence of automated decision making

      As a responsible company, we do not use automated decision making or profiling.