Privacy notice

The following information provides an overview of what happens to your personal data when you visit our website. Personal data is any information that can be used to identify you personally.

Who is responsible for data processing on this website (the controller)?

The controller within the meaning of the General Data Protection Regulation (GDPR) is

Reflex Winkelmann GmbH
Gersteinstraße 19
59227 Ahlen

E-mail: datenschutz@aviatics.de
Website: https://www.reflex-winkelmann.com

You will find additional information about our corporate group and the persons authorised to represent us as well as additional contact opportunities in the legal disclosures on this website. https://reflex-winkelmann.com/en/site-notice.

How do we collect your data?

One way in which we collect your data is by you disclosing it to us. This can include the data that you enter in a contact form. Alternatively, you can use the email address shown on the site to contact us. If you contact us via one of these channels, the personal data you give us will automatically be stored. Your details may be saved in a Customer Relationship Management System (‘CRM System’) or comparable inquiry organisation system. Initially, storage is solely for the purposes of processing on contacting you. The data entered can continue to be used for a quote request or in an order procedure appropriately for the purpose in question.

Other data is automatically collected by our IT systems when our website is visited. This is mainly technical data (e.g., internet browser, operating system or time the page was accessed). This data is collected automatically as soon as you enter our website.

You can register on some of our web pages to be able to use additional functions on the pages. We use the data entered for this only for the purposes of using the offer or service for which you have registered. The mandatory information asked for during registration must be entered in full. Otherwise we will refuse registration.

If important changes (for example, in the scope of the offer or in the case of technically necessary changes) occur, we use the email address provided during registration to notify you.

What data do we collect?

• Information about the type of browser and the release in use

• The user’s operating system

• The user’s internet service provider

• The user’s IP address

• Date and time of the access

• Websites that referred the user’s system to our internet site (referrer)

• Websites that are accessed by the user’s system from our website

• Your data via the contact form or your registration to receive the newsletter or to use our range of services, such as title, surname, first name, email address, sector, company, telephone number (optional)

• Cookies

For what purpose and on what lawful basis do we process your data?

Data entered when you register to receive the newsletter or use the contact form is processed on the basis of your consent in accordance with Article 6 para. 1 letter a GDPR (General Data Protection Regulation).

Furthermore, we process your data on the basis of your consent in accordance with Article 6 para. 1 letter a GDPR (General Data Protection Regulation) for certain purposes, in particular:

• For sending newsletters with regular offers

• For receipt of special information and offers

• For market research and customer surveys

• For personalised use of the website and personalised offers

• For analytical purposes for the optimisation of our service for you

• For processing of cookies subject to consent

• For the personalised use of our configurators on the website

You can withdraw any consent you have given at any time by sending us an informal message by email. The lawfulness of data processing already carried out will not be affected by the withdrawal of consent.

The lawful basis of the processing of personal data required for performing a contract to which you are a party is set out in Article 6 para. 1 letter b GDPR. This also applies to processing operations which are required to conduct pre-contractual measures. This are listed below:

• Registration and use of some configurators on our website

• Registration of or request for offers on certain products (contract initiation)

Insofar as processing of personal data is required for compliance with a legal obligation to which our company is subject, the lawful basis is set out in Article 6 para. 1 letter c GDPR.

If processing is necessary for the purposes of the legitimate interests pursued by our company or a third party and such interests are not overridden by the interests or fundamental rights and freedoms of the data subject, Article 6 para. 1 letter f GDPR provides the lawful basis for the processing. The legitimate interest of our company is the conduct of our business activities.

Is data transferred to third parties?

We transfer personal data to third parties solely if and when this is necessary during contract processing, for example to the bank which has been instructed to process payments.

The lawful basis of this processing is Article 6 para. 1 letter b GDPR, which permits the processing of data for the performance of a contract or for pre-contractual measures.

When cookies and tools are used for marketing purposes, personal data is transferred to the relevant service companies. This transfer is based on your consent in accordance with Article 6 para. 1 letter a GDPR. We have concluded an order processing contract in accordance with the GDPR with service providers commissioned for this purpose.

Is data transmitted to third recipients?

Your personal data will be transferred to third recipient solely if and when this is necessary for the performance of the contract with you, the transfer is permitted pursuant to a weighing of interests within the meaning of article 6 para. 1 letter f GDPR, we are legally obliged to transfer the data, or you have given your consent to the transfer. For example, third recipients can be the following:

• Companies that are part of the Winkelmann Group

• Sub-processors (e.g., service providers, subcontractors) of the Winkelmann companies in question

Transfers to third countries

Insofar as we process data in a third country (i.e. outside of the European Union (EU) or the European Economic Area (EEA)) or this occurs as part of the use of third-party services or the disclosure or transfer of data to third parties, we do so solely to the extent necessary for the fulfilment of our (pre-)contractual obligations, on the basis of your consent, in compliance with a legal obligation or in the pursuit of our legitimate interests. To the extent allowed by law or contract, we process data, or cause data to be processed, in a third country solely if and when the specific conditions set out in Art. 44 et seq. of the GDPR are applied. i.e. the processing is carried out (for example) on the basis of special guarantees or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses“).

How long do we process your data for?

We only process your personal data for as long as this is necessary to achieve the purpose of the storage. Storage of data may continue beyond this time insofar as required by provisions adopted by European or national legislatures in EU regulations, laws or other legal statutes to which we are subject.

As soon as the purpose of storage has lapsed or a storage period prescribed by the aforementioned regulations expires, the personal data are routinely blocked or erased.

The data collected during registration will be stored by us for as long as you are registered on our website and will then be deleted. This statement is without prejudice to statutory retention periods.

What rights do you have regarding your data?

Withdrawal of your consent to data processing

Many data processing operations are possible solely with your express consent. You may withdraw any previously given consent at any time by sending us an informal message by email. The lawfulness of data processing carried out prior to the withdrawal of consent will not be affected by the withdrawal.

Your right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Article 6 para. 1 letters e or f GDPR, including profiling based on those provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.Informationer, berigtigelse,

Access, rectification, restriction and erasure

You have the right under the applicable statutory provisions to obtain at any time and free of charge information about your personal data that are stored, their origin and recipients, the purpose of the data processing and if applicable, a right to rectification, restriction or erasure of these data. You may contact us at any time by using the provided address to exercise these rights and to submit additional questions on the subject of personal data.

Right to data portability

You have the right to request the provision of any data that we process by automated means on the basis of your consent or in performance of a contract to you or to third parties in a commonly used, machine-readable format. Insofar as you request the direct transfer of the data to another controller, the data will be transferred solely insofar as technically feasible.

You have the right of appeal to a supervisory authority of your choice in Germany or another European country.

A list of the supervisory authorities in Germany and their contact details can be found in the link below:
https://www.bfdi.bund.de/DE/Service/Anschriften/anschriften_node.html

The following supervisory authority has jurisdiction over the controller:

State Officer for Data Protection and Freedom of Information of North Rhine-Westphalia

P.O. Box 20 04 44
40102 Düsseldorf
Germany

Kavalleriestraße 2-4
40213 Düsseldorf
Germany

Telefon: +49-(0)2 11/384 24-0
Fax: +49-(0)2 11/384 24-10
Email: poststelle@ldi.nrw.de

Our data protection officer

We have appointed a data protection officer in our corporation, i.e. the Winkelmann Group, all affiliated companies and the sales and production locations. You can contact this officer at the following address:

AVIATICS Cost & Safety Management GmbH & Co. KG
Kieshecker Weg 148
40468 Düsseldorf
Germany

E-mail: datenschutz@aviatics.de

Newsletter

Please find below information about the content of our newsletter and the registration, dispatch and statistic evaluation procedures and your rights to object. By subscribing to our newsletter, you are agreeing to receive it and to the procedures described.

Content of the Newsletter: We send newsletters, emails and other electronic notifications containing advertising material (hereinafter referred to as “Newsletters”) only with the consent of the recipient or legal permission. If the contents of a newsletter are paraphrased as part of the registration process, they are decisive for the user’s consent. Otherwise, our newsletters contain information on us and our services.

Registration data: To register for the newsletter, all you need to do is enter your email address. You can enter your name as an option so that you can be addressed personally in the newsletter.

We have commissioned a specialist service provider to send the newsletter and carry out the associated measurement of success. We have concluded an order processing agreement with this service provider. It cannot be ruled out that the external service provider commissions subcontractors and affiliated companies in a third country to process the data. If you would like information on this, please contact us.

The newsletter is sent and its success measured on the basis of the recipient’s consent in accordance with Article 6 para. 1 letter a, Article 7 GDPR in conjunction with Article 7 para. 2 No. 3 German Act on Unfair Competition (UWG) or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Article 6 para. 1 letter f GDPR in conjunction with Article 7 para. 3 UWG.

The registration process is logged on the basis of our legitimate interests in accordance with Article 6 para. 1 letter f GDPR. Our interest is directed to the use of a user-friendly and secure newsletter system that serves both our commercial interests and our users’ expectations and also allows us to prove consent.

Termination/revocation - you can terminate your subscription to our newsletter at any time, i.e., revoke your consent. You will find a link to unsubscribe from the newsletter at the end of every newsletter. We can store the revoked email addresses for up to three years on the basis of our legitimate interests before we erase them so that we can prove consent was given at the time. The processing of this data is limited to the purposes of a defence against claims. An individual application for erasure is possible at any time provided that the former existence of consent is confirmed.

Cookies and Integration of External Online Services

Some of the website pages use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. Cookies help us to make our sites more user friendly, more effective and more secure. Cookies are small text files which are placed on your computer and saved by your browser.

Among the cookies that we use are so-called session cookies. They are erased automatically at the end of your browser session. Other cookies remain on your device until you erase them. These cookies enable us to recognise your browser whenever you return to our site.

You can set your browser to notify you whenever cookies are set and allow cookies solely in specific cases; preclude the acceptance of cookies for certain cases or in general; and activate the automatic erasure of cookies when the browser is closed. The disabling of certain cookies may restrict the available functions on our website.

Cookies that are required to carry out the electronic communication process or to provide certain functions you request are stored in compliance with Article 6 para. 1 letter f GDPR. We have a legitimate interest in the placement of cookies to ensure optimised provision of our services free of any technical errors. Insofar as other cookies (e.g. cookies for the analysis of your surfing behaviour) are stored, they are processed solely on the basis of your consent in accordance with Article 6 para. 1 letter a of the GDPR.

Session and persistent cookies are fully preserved during any type of navigation on the internet (including the use of links) and can therefore be read by any website that you subsequently visit. Session cookies are not erased until the browser is closed; persistent cookies are not erased until their lifetime has expired.

If you have given your consent and wish to withdraw it, you can do so at any time in the browser settings.

IP Anonymisation

We have activated the IP anonymisation function on this website. As a result, within member states of the European Union or in other contracting parties to the Agreement on the European Economic Area your IP address is abbreviated prior to transmission to the USA. The full IP address is transmitted to a Google server in the USA and abbreviated there only in exceptional cases.

On behalf of the operator of this website, Google will use this information to analyse your use of the website, compile reports on website activities and provide further services to the website operator associated with the website use and internet use. The IP address transmitted by your browser in association with Google Analytics is not merged with other Google data.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called cookies, text files that are stored on your computer and enable an analysis of your use of the website. As a rule, the information regarding your use of this website generated by the cookie is transferred to a Google server in the USA and stored there.

Google Analytics cookies are stored on the basis of your consent pursuant to Article 6 para. 1 letter a GDPR.

Additional information about the terms and conditions of use and privacy can be round at http://www.google.com/analytics/terms/de.html and https://www.google.de/intl/de/policies/.

Browser plugin

Moreover, you can prevent the capture of the data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by deactivating Google Analytics. Do so by downloading and installing the plugin for your web browser. It will set an optout cookie that prevents the collection of your data during future visits to this website: https://tools.google.com/dlpage/gaoptout?hl=de.

Order processing

We have concluded an order processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic characteristics

This website uses the “demographic characteristics” function of Google Analytics. It creates reports containing statements about the age, gender and interests of the site visitors. This data is obtained from interest-based marketing from Google and visitor data from third-party providers. Such data cannot be attributed to a specific individual. You can deactivate this function at any time via the marketing settings in your Google account or generally prohibit the collection of your data by Google Analytics as described under “Objection to data collection”.

Google Maps

This site uses the Google Maps service via an API. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use the functions of Google Maps it is necessary to store your IP address. As a rule, this information is transferred to a Google server in the USA and stored there.

The provider of this site does not have any influence over this data transfer.

The use of Google Maps is in the interest of an attractive display of our online services and makes it easy to find the places we mention on our website. It is a legitimate interest within the meaning of Article 6 para. 1 letter f GDPR.

You can find more information about the handling of user data in Google’s privacy policy:
https://www.google.de/intl/de/policies/privacy/.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

The reCAPTCHA function is used to determine whether the data entered on our websites (e.g. in a contact form) comes from a human being or an automated program. reCAPTCHA analyses the behaviour of the website visitor according to various characteristics. The analysis begins automatically as soon as the website visitor accesses the website. reCAPTCHA evaluates various information (e.g. IP address, time the website visitor remains on the website or the user’s mouse movements) for the analysis. The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyses run completely in the background. Website visitors are not notified that an analysis is taking place.

This data processing is based on Article 6 para. 1 letter f GDPR. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and from spam.

For more information on Google reCAPTCHA and Google’s privacy policy, please click on the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/about/.

YouTube

Our website uses plugins of the YouTube site, which is operated by Google. The operator of the site is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one our pages with a YouTube plugin, a connection will be established to the YouTube servers. In the process, the YouTube server will be notified which of our pages you have visited.

If you are logged into your YouTube account, you are enabling YouTube to assign your browsing patterns directly to your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used in the interests of an attractive presentation of our online offerings. It is a legitimate interest within the meaning of Article 6 para. 1 letter f GDPR.

You can find more information about the handling of user data in YouTube’s privacy policy:
https://www.google.de/intl/de/policies/privacy/ and https://www.youtube.com/intl/ALL_de/howyoutubeworks/user-settings/privacy/#your-data-in-youtube

Adobe Web Fonts

On the basis of our legitimate interests (i.e., interests in the analysis, optimisation and economic operation of our online offerings within the meaning of Article 6 para. 1 letter 1 GDPR), we use external fonts from the provider Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business campus, Dublin 24, Republic of Ireland, for the uniform presentation of fonts. Adobe Fonts is a service that enables access to a font library on servers in the USA for use in desktop applications and websites. In the process, Adobe collects information on the fonts provided, the account ID, the application that requests the fonts, the server that provides the fonts and the host name of the website onto which the fonts are loaded. It is unclear whether Adobe also has access to the IP address and other personal data. However, it is clear that there is no appropriate data protection level for data transfer to the USA, with the result that this data processing is carried out on the basis of your consent Article 6 para. 1 letter a GDPR. You can find more information about the handling of user data in Adobe’s privacy policy: https://www.adobe.com/de/privacy/policy.html

Xing
Functions and content of the Xing service can be integrated into our online offering by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. For example, content such as images, videos or texts and buttons by means of which users can share contents of this online offering within Xing. If the users are members of the Xing platform, Xing can assign the above-mentioned content and functions to the profiles of users there. 
Information about the handling of the provider’s personal data can be found here: https://www.xing.com/app/share?op=data_protection.

LinkedIn
Functions and content of the LinkedIn service can be integrated into out online offering by LinkedIn Ireland Unlimited Company, Attn: Legal Dept. (Privacy Policy and User Agreement), Wilton Plaza, Wilton Place, Dublin 2, Ireland. For example, content such as images, videos or texts and buttons by means of which users can share contents of this online offering within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the above-mentioned content and functions to the profiles of users there.
Information about the handling of the provider’s personal data can be found here:
https://de.linkedin.com/legal/privacy-policy?trk=d_org_guest_company_overview_footer-privacy-policy

Use of Our (Online) Tools and (Online) Services (e.g. Configurators)

Via our website, you can use our tools and services in various application levels. These are available as a download or web application. Load or use our tools and services, conclude an appropriate usage agreement with us, even through it is possible to use them free of charge.

To be able to make full use of our tools and services, please enter your personal data in the registration form in advance. In particular, this data is master data, i.e., name, address and email address that we need to identify you as a contractual partner and to be able to contact you as such if necessary (Article 6 para. 1 letter b GDPR).

In addition, a job title is requested in some of our tools and services, which is decisive for us to be able to assign the relevant products of various professional fields to the user and align the products to the professional fields that use our products most intensively. This data processing is also in our legitimate interest (Article 6 para. 1 letter f GDPR).

Moreover, the data processing is also carried out in line with Article 6 para. 1 letter a GDPR on the basis of your consent because it is completely up to you to use the products offered free of charge and, in this context, to disclose your data for internal analysis purposes.

In addition to the opportunity to download software, with some tools and services we offer you the opportunity to register for use of the software and to create a password for subsequent log-ins. During registration, the same data is queried as on the download form described above, so that it is referred to first of all.

Your email address is also collected so that the registration process can be completed. To activate the account, you will receive an email from us that you then have to confirm. Furthermore, your email address is needed to be able to save and assign your configurators for you. You can log in as a user with your email address and the password and view all of your projects and configurators.

As soon as you have an account, you can create any number of projects. The only mandatory fields are the project name and the order date. The date is preset to the current date, whereas the project name has the default name “New Project”, which can be changed. As a result, you can directly create a project without entering any further details about the project. But you have the option of changing the project name and updating further project-related information (such as project abbreviation, project number, customer number, customer name, customer address). The data created by you in these processes is stored on our servers and can be accessed by the relevant user (i.e., you) only when the password you have created is used.

This data is processed according to the consent granted in your registration process in accordance with Article 6 para. 1 letter a GDPR, and, for fulfilling the contract, in accordance with Article 6 para. 1 letter b GDPR. Furthermore, we have a legitimate interest within the meaning of Article 6 para. 1 letter f GDPR in making practical software tailored to your needs and that constantly needs to be updated available to our (potential and/or former) customers as well as to our employees and contractual partners. For this purpose, use of the software must be analysed so that constant optimisations can be carried out.

The software use for web applications is analysed by using Google Analytics (in this connection and for the appeal options, see the chapter Cookies and Integration of External Online Services.

In this process, there is no access to your personal data created in the project.

It is also necessary to fulfil the contract (Article 6 para. 1 letter b GDPR), but also within our own legitimate interest (Article 6 para. 1 letter f GDPR) for us to your your stored contact data to be able to ask you for feedback on the software used an/or contact you to receive suggestions for improvement or to draw your attention to new features of the application you have already used or practical supplements/other applications.

We will not pass on your personal data to third parties not associated with processing the contract without your explicit consent or a legal basis other than the software developers or service providers commissioned by us.

We pass this data on to the commissioned software developers or service providers so that they can make the necessary technical information or updates to the software you are using available to you. We point out that this is order processing in accordance with Article 28 GDPR. The software developers or service providers concerned have contractually agreed to use to maintain the data protection provisions in line with the statutory requirements.

After the contract has been fully processed, your data will be blocked for further use. After expiry of the tax and commercial law provisions, this data will be erased unless you have explicitly consented to its further use. Data being processed on the basis of Article 6 para. 1 letter f GDPR will be processed until expiry of the legitimate interest and then erased, at the latest upon declaration of an objection to data processing by you. Statutory storage obligations will be maintained with respect to this data.

If the software is provided via an app store, the app store provider's information concerning the handling of your data must also be taken into account. Only the providers of the app stores are responsible for this data use.

Last revised: 14/08/2024