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Privacy Policy

We are pleased about your interest in XTRONIC GmbH as well as in our products and services. Protecting your privacy when using our online offering is an important concern for us. When processing personal data, we observe the applicable data protection regulations, in particular the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

Contents

1. General information on data processing
2. Provision of the website
3. Data processing for services
4. Your rights
5. Controller
6. Data Protection Officer

1. General information on data processing

1.1 Scope and purpose of processing personal data

We generally process personal data of our users only insofar as this is necessary to provide a functional website as well as our content and services.

The processing of personal data regularly takes place only with the consent of the data subject. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

1.2 Legal basis for data processing

The processing of your personal data is carried out on the basis of the General Data Protection Regulation (GDPR) as well as other applicable legal provisions, in particular the German Federal Data Protection Act (BDSG).

1.2.1 Consent Art. 6 para. 1 lit. a GDPR

If you have given us consent to process personal data for specific purposes, the processing is carried out on the basis of Art. 6 para. 1 lit. a GDPR.

Consent given can be revoked at any time with effect for the future. The lawfulness of the processing carried out up to the revocation remains unaffected.

1.2.2 Pre-contractual and contractual measures Art. 6 para. 1 lit. b GDPR

The processing of personal data is carried out on the basis of Art. 6 para. 1 lit. b GDPR insofar as this is necessary for the performance of a contract to which you are a party or for the implementation of pre-contractual measures that are carried out at your request.

The purposes of data processing arise in particular from the respective contractual documents and the underlying contractual relationship.

1.2.3 Legal obligation Art. 6 para. 1 lit. c GDPR

If the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, this processing is carried out on the basis of Art. 6 para. 1 lit. c GDPR.

1.2.4 Legitimate interests Art. 6 para. 1 lit. f GDPR

If the processing is necessary to safeguard a legitimate interest of XTRONIC GmbH or a third party and your interests, fundamental rights and freedoms as a data subject do not prevail, the processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR.

Legitimate interests may in particular be:

• the assertion of legal claims and defense in legal disputes
• ensuring IT security and IT operations
• the prevention of criminal offenses
• measures for business management as well as for the further development of services and products

1.3 Data deletion and storage duration

We process and store your personal data only as long as this is necessary to fulfill the respective processing purpose.

If the purpose of processing ceases to apply, the personal data will be deleted, provided that no statutory retention obligations prevent this.

Personal data processed in connection with a marketing consent will generally be deleted within two months after withdrawal of the consent. Irrespective of this, we delete the history of our marketing communication after five years at the latest.

1.4 Access to personal data within XTRONIC GmbH and by third parties

Within XTRONIC GmbH, only those departments receive access to your personal data that require it to fulfill their tasks. Access is granted according to the principle of minimal rights allocation (“least privilege”) as well as the “need-to-know” principle.

Personal data is only passed on to third parties if:

• this is necessary for the fulfillment of a contract,
• we are legally obliged to do so,
• you have given prior consent, or
• processors commissioned by us pursuant to Art. 28 GDPR have been contractually obligated to comply with data protection requirements.

Recipients of personal data may in particular be internal specialist departments as well as external service providers who support us in providing our services, for example providers of analysis or IT services.

1.5 IT security and links to third-party websites

XTRONIC GmbH uses appropriate technical and organizational measures to protect your personal data against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons. Our security measures are continuously improved in line with technological developments.

Our website may contain links to websites of other providers. The respective provider is solely responsible for the content of these external websites as well as their data protection provisions.

1.6 Obligation to provide personal data

Within the framework of concluding contracts, you must provide those personal data that are necessary for the establishment, execution and termination of the contractual relationship or that we are legally obliged to collect.

In addition, we provide services on our website that you can use voluntarily. Without providing the required personal data, individual services may not be usable.

1.7 Automated decision-making and profiling

As a matter of principle, we do not use automated decision-making within the meaning of Art. 22 GDPR. Profiling also does not take place.

Should we use such procedures in individual cases, we will inform you separately if this is required by law.

1.8 Sources of your personal data

We process personal data that we receive directly from you within the framework of our business relationship, for example through personal contact, via registration or contact forms on our website or via our social media channels.

2. Data processing operations in connection with the provision of the website and the creation of log files

When our website is accessed, information is automatically collected by the web servers of XTRONIC GmbH that your browser transmits to our server. This information is temporarily stored in so-called log files.

The following data may in particular be collected:

• IP address of the accessing end device
• date and time of access
• name and URL of the retrieved file
• website from which access is made (referrer URL)
• browser used and, if applicable, the operating system of your end device
• name of your internet service provider

The processing of this data takes place for the following purposes:

• provision of the website for the user’s end device
• ensuring the functionality of our information technology systems
• optimization of the website
• ensuring the security of our information technology systems (e.g. for investigating misuse or fraudulent acts)

The data is stored in log files of our system. This data is not merged with other personal data of the user.

Insofar as IP addresses are stored, this is done exclusively in shortened form (IP anonymization), so that direct assignment to a specific person is not possible. The legal basis for this processing is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the technically error-free presentation and the secure provision of our website.

The data is deleted as soon as it is no longer required to achieve the purpose of its collection. In the case of storage in log files, deletion usually takes place after seven days at the latest, unless security-relevant events make longer storage necessary.

The collection of data for the provision of the website as well as the storage of the data in log files is absolutely necessary for the operation of the website. Therefore, there is no possibility for the user to object.

3. Data processing for services offered on the website

Various services are offered on our website, for the use of which personal data is requested from you.

3.1 Use of our contact and inquiry forms

Contact and inquiry forms are available on our website via which you can contact us electronically.

To use the contact forms, the data marked as mandatory in the input mask (e.g. your email address) is required. All further information is voluntary.

The personal data you enter will be transmitted to the department responsible for processing within our company and stored in our systems. At the time the message is sent, the date and time of the inquiry are also stored.

The processing of the data you enter is carried out exclusively for the purpose of processing and answering your inquiry.

Insofar as your inquiry aims at the conclusion of a contract or is related to the implementation of pre-contractual measures, the processing is carried out on the basis of Art. 6 para. 1 lit. b GDPR.

In all other cases, processing is carried out on the basis of our legitimate interest in processing and answering your inquiry in accordance with Art. 6 para. 1 lit. f GDPR.

The data will be deleted as soon as your inquiry has been finally processed and no statutory retention obligations prevent deletion.

3.2 Data processing in connection with cookies and similar technologies

Our website uses cookies as well as comparable technologies (e.g. local storage) to ensure the functionality of our website, to store user preferences and – if you have consented – to analyze usage behavior on our website.

Cookies are small text files that are stored on your end device via your internet browser. They make it possible to recognize your browser when you visit our website again.

When you access our website for the first time, you will be informed about the use of cookies and can use our consent management tool to determine which categories of cookies you would like to consent to.

3.2.1 Technically necessary cookies and similar technologies

To manage the cookies used and your consents, we use the consent management tool “Borlabs Cookie”.

Borlabs Cookie stores your cookie settings in a technically necessary cookie in order to be able to track whether and to which data processing you have consented.

The legal basis for the use of Borlabs Cookie is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the legally compliant management and documentation of consents pursuant to Art. 7 GDPR.

Further information can be found at: https://de.borlabs.io/borlabs-cookie/

You can adjust your settings here:

3.2.2 Analysis, statistics and marketing cookies

Some cookies are necessary so that our website functions technically flawlessly and basic functions can be provided.

These cookies store, for example:

• your cookie settings
• security-relevant information
• technical session information

Processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the secure and functional operation of our website.

3.2.3 Management of cookies and consents

If you have given your consent, we use Google Analytics, a web analysis service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses cookies that enable an analysis of the use of our website. The information generated by the cookies about your use of this website is generally transmitted to a server of Google and stored there.

We use Google Analytics with activated IP anonymization. As a result, your IP address is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before further processing.

On our behalf, Google will use this information to evaluate your use of our website, to compile reports on website activities and to provide further services associated with website use.

Processing is carried out exclusively on the basis of your consent in accordance with Art. 6 para. 1 lit. a GDPR.

You can revoke your consent at any time via the cookie settings on our website.

Further information on data processing by Google can be found at: https://policies.google.com/privacy

3.2.4 Local Storage

We use the local storage of your browser to store certain information locally on your end device and thereby improve the functionality as well as the user-friendliness of our website.

Insofar as the use of local storage is necessary for technical operation or the provision of explicitly requested functions, processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR.

Insofar as local storage is used for analysis, statistical or marketing purposes, processing is carried out exclusively on the basis of your consent pursuant to Art. 6 para. 1 lit. a GDPR.

You can restrict the storage of data in local storage via the settings of your browser or delete stored content. Please note that in this case individual functions of our website may not or only to a limited extent be available.

3.2.5 Google Analytics

If you have consented, we use Google Analytics on our website, a web analysis service of Google. Google Analytics enables us to evaluate the use of our website and to create reports on user behavior on our website.

In particular, information about website usage, details about your end device, your browser, accessed pages, duration of stay, interactions as well as shortened IP addresses may be processed. Processing is carried out exclusively on the basis of your consent pursuant to Art. 6 para. 1 lit. a GDPR.

If Google Analytics is used on our website with IP anonymization, your IP address is shortened within the European Union or the European Economic Area before further processing. Only in exceptional cases may the full IP address be transmitted to servers of Google and shortened there.

We have concluded a contract processing agreement with the provider where required under data protection law.

You can revoke your consent at any time with effect for the future via our cookie settings.

Further information on data processing by Google can be found in the provider’s privacy notices.

3.2.6 Google advertising functions / remarketing

If you have consented, we use functions of Google for marketing and remarketing purposes. This may make it possible to address visitors to our website with interest-based advertising on other websites or within Google services.

In this context, information about your usage behavior, visited pages, interactions with advertising media and technical identifiers may be processed. Processing is carried out exclusively on the basis of your consent pursuant to Art. 6 para. 1 lit. a GDPR.

You can revoke your consent at any time with effect for the future via our cookie settings.

Further information on Google advertising functions and data processing by Google can be found in the provider’s privacy notices.

3.3 Data processing in connection with social media networks

The following information applies to the social media presences of XTRONIC GmbH on the platforms:

• LinkedIn
• Instagram
• YouTube
• Facebook

We operate these presences in order to inform about our company, our services as well as career opportunities and to communicate with users and interested parties.

Please note that the providers of the respective platforms process personal data independently. This applies both to registered users of the platforms as well as to visitors of the pages. We generally have no influence on this data processing.

Further information on data processing by the respective providers can be found in the privacy policies of the respective platform operators.

3.3.1 Processing of your personal data when contacting us

If you contact us via our social media presences, for example via direct messages, comments or posts, we process the personal data transmitted by you exclusively for processing and answering your inquiry.

The following data may in particular be processed:

• username
• publicly visible profile data
• content of your message or your comment
• if applicable, further information that you voluntarily provide to us

Processing is carried out either for the implementation of pre-contractual measures or for contract fulfillment pursuant to Art. 6 para. 1 lit. b GDPR or on the basis of our legitimate interest in effective communication with users pursuant to Art. 6 para. 1 lit. f GDPR.

3.3.2 Processing of personal data within social media networks

If you interact with our posts on social media platforms (e.g. by “liking”, commenting, sharing or other reactions), we can view these interactions.

We can also see when users follow or subscribe to our social media pages. On some platforms, additional publicly visible information about users may be displayed to us.

We process this data in order to operate our social media presences, to improve content and to communicate with users.

The legal basis for processing is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in public relations, informing about our company and communicating with users.

3.3.3 Processing of statistical data within social media networks

The providers of social networks sometimes provide us with anonymized statistical evaluations on the use of our social media pages (so-called “insights”).

These statistics may include information about:

• reach of our posts
• interactions with our posts
• demographic information in aggregated form
• use of our social media pages

This data does not allow us to draw conclusions about individual persons.

Processing is carried out on the basis of our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR in analyzing and optimizing our social media presence.

3.3.4 Processing of data for advertising purposes and creation of user profiles by social media providers

The providers of social networks process personal data of users under their own responsibility. In doing so, usage profiles may be created in order, for example, to display personalized advertising within or outside the respective platform.

We do not have full influence on the data processing by the respective platform providers.

Please also note that personal data may be processed by the providers of social networks outside the European Union. This may result in risks, particularly with regard to the enforcement of data subject rights.

Further information can be found in the privacy policies of the respective platform providers.

4. Your rights as a data subject

If personal data concerning you is processed, you are a data subject within the meaning of the GDPR. You have the following rights vis-à-vis us as the controller:

4.1 Right of access (Art. 15 GDPR)

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

If this is the case, you have the right to access this personal data as well as further information pursuant to Art. 15 GDPR, in particular regarding:

• the purposes of processing
• the categories of personal data
• the recipients or categories of recipients
• the planned storage duration
• the existence of further data subject rights
• the existence of a right to lodge a complaint with a supervisory authority

The restrictions pursuant to §§ 34 and 35 BDSG apply.

4.2 Right to rectification (Art. 16 GDPR)

You have the right to request that we immediately correct inaccurate personal data concerning you or complete your personal data stored by us.

4.3 Right to restriction of processing (Art. 18 GDPR)

Under the legal requirements, you can request the restriction of the processing of your personal data.

This is the case in particular if:

• you contest the accuracy of the data,
• the processing is unlawful,
• we no longer need the data but you require it for the assertion, exercise or defense of legal claims, or
• you have objected to the processing.

4.4 Right to erasure (Art. 17 GDPR)

You have the right to request that we delete personal data concerning you without delay, provided that one of the reasons listed in Art. 17 GDPR applies.

There is no right to erasure insofar as the processing is necessary, in particular for compliance with a legal obligation or for the assertion, exercise or defense of legal claims.

The restrictions pursuant to §§ 34 and 35 BDSG apply.

4.5 Right to notification

If you have exercised your right to rectification, erasure or restriction of processing vis-à-vis us, we are obliged to inform all recipients to whom your personal data has been disclosed of these changes, unless this proves impossible or involves disproportionate effort.

4.6 Right to data portability (Art. 20 GDPR)

You have the right to receive the personal data 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, provided that the legal requirements are met.

4.7 Right to object (Art. 21 GDPR)

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data if this is based on Art. 6 para. 1 lit. e or lit. f GDPR.

We will then no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing or the processing serves the assertion, exercise or defense of legal claims.

4.8 Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates data protection regulations.

The supervisory authority responsible for us is:

The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Lautenschlagerstraße 20
70173 Stuttgart
https://www.baden-wuerttemberg.datenschutz.de

5. Controller within the meaning of the GDPR

Controller responsible for the processing of personal data within the meaning of the GDPR is:

XTRONIC GmbH
Herrenberger Straße 56
71034 Böblingen
Phone: +49 7031 20947–0
Fax: +49 7031 20947–101
E-mail: info@xtronic.de

6. Address of the Data Protection Officer

You can contact our Data Protection Officer at:

XTRONIC GmbH
Data Protection Officer
Herrenberger Straße 56
71034 Böblingen
Phone: +49 7031 20947–0
Fax: +49 7031 20947–101
E-mail: datenschutz@xtronic.de

Status of the privacy policy: March 2026
Last update: Revision of the cookie and analytics sections