1. Homepage
  2. Privacy Statement

Data Privacy Policy

We, GAPI Technische Produkte GmbH (hereinafter: “the company”, “we” or “us”) take the protection of your personal data seriously and would like to inform you here about data protection in our company.

As part of our responsibility under data protection laws, we have additional imposed obligations by enforcement of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) and additional obligations have been imposed to ensure and protect the personal data of persons affected by processing such data (hereinafter refered to as: “customers”, “users”, “you”, “them” or “data subject” in the following).

Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this primarily includes the obligation to transparently inform you about the nature, scope, purpose, duration and legal basis of the data processing (cf. Articles 13 and 14 GDPR). With this statement (hereinafter: “Privacy Notice”), we will inform you about the manner in which your personal data is processed by us.

A. General

(1) Definitions
Following the example of Article 4 GDPR, these data protection notices are based on the following definitions:

  • “Personal data” (Article. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person ("data subject"). A person is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as: a name, an identification number, an online identifier, location data, or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. Identifiability may also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is not important (photos, video or sound recordings can also contain personal data).
  • “Processing” (Article. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by automated (i.e. technology-based) means. This includes, in particular, the collection (i.e. acquisition), recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the modification of purpose or intended purpose on which the data processing was originally based.
  • “Controller” (Article. 4 No. 7 GDPR) 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.
  • “Third party” (Article. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or processor, are authorized to process the personal data.
  • “Processor” (Article. 4 No. 8 GDPR) means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service provider). In particular, a processor is not a third-party in the sense of data protection laws.
  • “Consent” (Article. 4 No. 11 GDPR) of the data subject means any freely given indication of his or her wishes in an informed and unambiguous manner, in the form of a statement or any other unambiguous affirmative act, by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

(2) Name and Address of the Controller
The controller of your personal data within the meaning of Article 4 No. 7 GDPR, is us:

GAPI Technische Produkte GmbH
legally represented by the managing directors Roberto Galizzi and Dr. Sandro J. Silverio
Hans-Böckler-Strasse 14
D - 51503 Rösrath
Phone.: +49 2205 90494 -10
Fax: +49 2205 90494 33 / 66
E-Mail: s.silverio@gapi.de

For further information about our company, please refer to the imprint information on our website.

(3) Contact Details of the Data Protection Officer
Our company’s data protection officer is available at all times to answer any questions you may have, and to act as your contact person at our company on the subject of data protection. His contact details are:

Company: Stefan Stroessenreuther (SMCT MANAGEMENT)
Data Protection Officer: Stefan Stroessenreuther
Wunsiedlerstraße 23D
D - 95100 Selb
Phone.: +49 151 - 1659 3132
E-Mail: info@smct-management.de
Website: https://smct-management.de

(4) Legal Basis for Data Processing
By law, any processing of personal data is in principle, prohibited and only permitted if the data processing falls under one of the following justifications:

  • Article 6 Para. 1 S. 1 Item a, GDPR (“Consent”): If the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous confirmatory act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;
  • Article 6 Para. 1 S.1 Item b, GDPR: If the processing of data is necessary for the performance of a contract to which the data subject is a party, or for the performance of pre-contractual measures taken at the data subject’s request;
  • Article 6 Para. 1 S.1 Item c, GDPR: If the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., a legal obligation to keep records);
  • Article 6 Para. 1 S. 1 Item d, GDPR: If the processing is necessary to protect vital interests of the data subject or another natural person;
  • Article 6 Para 1 S. 1 Item E, GDPR: If the processing is necessary for the performance of a task carried out in the public interest, or in the exercise of official authorities vested in the controller; or
  • Article 6 Para. 1 S. 1 Item. f, GDPR (“Legitimate Interests”): If the processing of data is necessary to protect legitimate (in particular legal or economic) interests of the controller or a third party, unless conflicting interests or rights of the data subject override third party interests (in particular if the data subject is a minor).

For processing operations carried out by us, we indicate below the applicable legal basis in each case. Processing may also be based on several legal bases.

(5) Data Deletion and Storage Period
For processing operations carried out by us, we indicate below in each case, how long the data will be stored by us and when it will be deleted or blocked. If no explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. Your data will only be stored on our servers in Germany, subject to any disclosure that may take place in accordance with the regulations in A.(7) and A.(8).

However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings, or if storage is required by legal regulations to which we are subject as the responsible party (e.g. § 257 HGB, § 147 AO). If the storage period prescribed by the statutory provisions expires, the personal data will be blocked or deleted, unless further storage by us is necessary and there is a legal basis for this.

(6) Data Security
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TSL encryption for our website), taking into account state of the art technology, implementation costs and the nature, scope, context and purpose of processing data, as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

We will be happy to provide you with more detailed information on request. Please contact our data protection officer (see under A.(3)).

(7) Cooperation with Processors
As with any larger company, we also use external domestic and foreign service providers to process our business transactions (e.g. for the areas of IT, logistics, telecommunications, sales and marketing). These service providers only act on our instructions and are contractually obligated to comply with the data protection provisions of Article. 28 in the GDPR.

If your personal data is passed on by us to our subsidiaries or is passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing processing relationships.

(8) Requirements for the Transfer of Personal Data to Third-party Countries.
In the course of our business relationships, your personal data may be transferred or disclosed to third-party companies. These may be located outside the European Economic Area (EEA), i.e. in third-party countries. Such processing is carried out exclusively for the fulfillment of contractual and business obligations and to maintain your business relationship with us. We will inform you about the respective details of the transfer below at the relevant points.

Some third-party countries are certified by the European Commission through so-called adequacy decisions, to have data protection comparable to the EEA standard (a list of these countries as well as a copy of the adequacy decisions can be found here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html). However, in other third-party countries to which personal data may be transferred, there may not be a consistent high-level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding company regulations, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognized codes of conduct. Please contact our data protection officer (see under A.(3)) if you would like more information on this.

(9) Non-automated Decision Making (including Profiling)
We do not intend to use any personal data collected from you for any automated decision making process (including profiling).

(10) Non-obligation to Provide Personal Data
We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. For you as a customer, there is also no legal or contractual obligation to provide us with your personal data; however, it may be that we can only provide certain offers to a limited extent or not at all if you do not provide the data required for this. If this exception should be the case in the context of the products we offer presented below, you will be informed of this separately.

(11) Legal Obligation to Transfer Certain Data
We may, under certain circumstances, be subject to a specific legal or statutory obligation to provide lawfully processed personal data to third parties, in particular public bodies (Article 6 Para. 1 S 1. item c, GDPR).

(12) Customer Rights
You may assert your rights as a data subject regarding your processed personal data at any time by contacting us, using the contact details provided at the beginning of A.(2). As a data subject, you have the following rights:

  • to request information about your data processed by us in accordance with Article. 15 of the GDPR. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details;
  • to demand the correction of incorrect data or the completion of your data stored by us without delay; in accordance with Article. 16 of the GDPR;
  • to request the deletion of your data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims, pursuant to Article. 17 of the GDPR;
  • to request the restriction of the processing of your data, insofar as the accuracy of the data is disputed by you or the processing is unlawful, pursuant to Article. 18 of the GDPR;
  • to receive your data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller (“data portability”), pursuant to Article. 20 of the GDPR;
  • object to the processing your data, provided that the processing is based on Article. 6 Para. 1 S.1 item. e or item. f of the GDPR, and pursuant to Article. 21 of the GDPR. This is the case if the processing is not necessary for the performance of a contract with you. Unless there is an objection to direct marketing, when exercising such objection, we ask you to explain the reasons why we should not process your data as normal. In the event of your justified objection, we will review the merits of the case and either discontinue or adjust the data processing, or show you our compelling legitimate grounds on the basis of which we will continue the processing;
  • to revoke your consent once given (also before the GDPR came into force, i.e. before 25.5.2018), your voluntary consent, in an informed and unambiguous manner, by means of a declaration or other confirming act, that you agree to the processing of the personal data in question for one or more specific purposes – at any time – vis-à-vis us, if you have given such consent, in accordance with Article 7 Para. 3 of the GDPR. As a result of the previous section, we may no longer allow to continue the data processing based on your consent in the future.
  • to complain to a data protection supervisory authority about the processing of your personal data in our company in accordance with Article. 77 of the GDPR, for example at the data protection supervisory authority responsible for us: State Commissioner for Data Protection and Freedom of Information (LDI) NRW, Kavalleriestr. 2-4 40213 Düsseldorf, Phone 0211 / 38424-0 Fax 0211 / 38424-10, E-Mail: poststelle@ldi.nrw.de, Internet: www.ldi.nrw.de

(13) Changes to the Data Protection Notice
In the context of further development of data protection laws and technological or organizational changes, our data protection notices are regularly reviewed to determine whether they need to be adapted or supplemented. You will be informed of any particular changes on our German website at www.gapi.de. This data protection notice is current as of August 2021.

B. Visiting Websites

(1) Explanation of Function
You can obtain information about our company and the services we offer in particular, at www.gapi.de along with the associated sub-pages (hereinafter collectively: “websites”). When you visit our Web pages, personal data may be processed.

(2) Processed Personal Data
During the informational use of our Websites, the following categories of personal data are collected, stored and processed by us:

“Log data”: When you visit our websites, a protocol data record (server log files) is stored temporarily and anonymously on our web server. This consists of:

  • the page from which the page was requested (referrer URL)
  • the name and URL of the requested page
  • the date and time of the request
  • the description of the type, language and version of the web browser used
  • the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
  • the amount of data transferred
  • the operating system
  • the message whether the call was successful (access status/http status code)
  • the GMT time zone difference

“Contact Form Data”: When contact forms are used, the resulting data transmitted is processed (e.g. gender, surname and first name, address, company, e-mail address and the time of transmission).

(3) Purpose and Legal Basis of Data Processing
We process the personal data described above in more detail, in accordance with the provisions of the GDPR, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Article 6 Para. 1 S.1 item. f of the GDPR, the aforementioned purposes also represent our legitimate interests.

The processing of log data serves statistical purposes and is used to improve the quality of our website, in particular the stability and security of the connection (according to Article. 6 Para. 1 S. 1 item. f GDPR).

Contact form data is processed to handle customer inquiries (according to Article. 6 Para. 1 S.1 item. b and/or item. f GDPR).

(4) Duration of Data Processing
Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal bases stated in the context of the processing purposes apply accordingly. With regard to the use and storage duration of cookies, please refer to point A.(5).

Third parties used by us will store your data on their system for as long as is necessary, in connection with the provision of services for us, in accordance with the respective request.

(5) Transfer of Personal Data to Third-Parties; Basis for Justification
The following categories of recipients, which are usually order processors (see A.(7)), may receive access to your personal data:

  • Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer is Article. 6 Para. 1 S.1 item. b and/or item. f of the GDPR, as long as they are not a contract processor;
  • Government agencies/authorities, insofar as this is necessary for the fulfillment of a legal obligation. The legal basis for the transfer is Article. 6 Para. 1 S. 1 item. c of the GDPR;
  • Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for disclosure is Article. 6 Para. 1 S. 1 item. b and/or item. f of the GDPR.

For guarantees of an adequate level of data protection in the event of a transfer of data to third-party countries, see A.(8).

In addition, we will only share your personal data with third-parties if you have given your express consent to do so in accordance with Article. 6 Para. 1 S. 1 item. a of the GDPR.

(6) Use of Cookies, Plugins and other Services on our Website

a) Cookies
We only use session cookies on our websites. Cookies are small text files that are assigned to the browser you are using, and stored on your hard drive by a unique string of characters, and through which certain information flows to the body that sets the cookie. Cookies cannot execute programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the internet more user-friendly and effective, i.e. more pleasant for users.

Cookies can contain data that makes it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that cannot be related to a specific person. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. In terms of their function, cookies are again distinguished between:

  • Technical Cookies: These are mandatory in order to navigate the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which web pages you have visited;
  • Performance cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you – all information collected is anonymous and is used only to improve our website and find out what interests our users;
  • Advertising Cookies, Targeting Cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you - all information collected is anonymous and is only used to improve our website and find out what interests our users;
  • Sharing Cookies: These are used to provide the website user with tailored advertising on the website or offers from third-parties, and to measure the effectiveness of these offers; Advertising and Targeting Cookies are stored for a maximum of 13 months;

Any use of cookies that is not absolutely necessary technically, constitutes data processing that is only permitted with your explicit and active consent, pursuant to Article. 6 Para. 1 S. 1 item. a of the GDPR. This applies in particular to the use of advertising, targeting or sharing cookies. In addition, we will only share your personal data processed through cookies with third-parties if you have given your explicit consent to do so, pursuant to Article. 6 Para. 1 S. 1 item. a of the GDPR.

We only use cookies necessary for technical reasons, or so-called session cookies. These serve to be able to assign several inquiries of a page visit as belonging together. In order to use the full functionality of our website, it is necessary for technical reasons to allow the session cookies. Session cookies are deleted as soon as you end your browser session.

Used session cookies are as follows: ASP.NET_SessionId.

b) Web Analysis with e-tracker
We use the services of the e-tracker GmbH from Hamburg, Germany (https://www.etracker.com) to analyze usage data. We do not use cookies for web analysis by default. As we use analysis and optimization cookies, we need to obtain your explicit consent separately in advance. If this is the case and you consent, cookies are used to enable statistical coverage analysis of this website, measure the success of our online marketing measures, and test procedures, for example, to test and optimize different versions of our online offers or its components. e-tracker cookies do not contain any information that enables identification of a user.

The data generated by e-tracker is processed and stored by e-tracker on behalf of the provider of this website exclusively in Germany, and is thus subject to strict German and European data protection laws and standards. e-tracker has been independently audited and certified in this regard and awarded the e-Privacyseal data protection certification.

Data processing is carried out on the basis of the legal provisions in Article. 6 Para. 1 item. f (legitimate interests) of the German Data Protection Regulations (DSGVO). Our concern in terms of the DSGVO (legitimate interests) is the optimization of our online offers and our web presence. Since the privacy of our visitors is important to us, the data that may allow reference to an individual person, such as their IP address, login or device identifiers, are anonymized or pseudonymized as soon as possible. No other use, combination with other data, or transfer to third-parties will take place.

Objection to the aforementioned data processing can be made at any time. Any objection has no negative consequences.

Further information on data protection at e-tracker can be found at https://www.etracker.com/datenschutz/.

c) Social Media Plugins
We do not use social media plugins on our websites. Our websites contain icons from social media providers, we only use these for passive links to the pages of the respective providers.