We, TORQEEDO GMBH (hereinafter also "Torqeedo"), take the protection of your personal data very seriously and adhere strictly to the rules of the applicable data protection regulations. Personal data is only collected on this website to the extent technically necessary. However, it is possible to use the TORQEEDO GMBH website without disclosing personal data. Under no circumstances will the data collected be sold or passed on to third parties for any other reason.
The following declaration gives you an overview of how we ensure this protection and what kind of data is collected for what purpose. You will also be informed about the rights you are entitled to.
(a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter "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, psychological, economic, cultural or social identity of that natural person.
(b) Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
Processing is any operation or set of operations that are performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, 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 limiting their future processing.
e) Controller or person responsible for processing
The controller or person responsible for processing is the natural or legal person, public authority, agency or other body who 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 designation may be provided for under Union or Member State law.
Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Recipient means a natural or legal person, public authority, agency or other body to whom personal data is disclosed, whether or not a third party. However, authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law shall not be considered as recipients.
h) Third party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
Profiling is any form of automated processing of personal data that consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.
Consent shall mean any freely given specific and informed indication of the data subject's wishes in the form of a statement or 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. The name and address of parties responsible (controller) for processing
The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
Tel: +49 (0) 8153 9215 100
3. Contact details of the data protection officer
Data protection officer
Mr Robert Schöttl
Föhrenweg 22, 85757 Karlsfeld
The internet pages of TORQEEDO GMBH use text files (so-called cookies), which are filed and stored on a computer system via an internet browser.
Cookies are used by numerous websites and servers, with many cookies containing a so-called cookie ID. A cookie ID is a unique identifier of the cookie and consists of a string of characters by which internet pages and servers can be assigned 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 thus be recognised and identified via the cookie ID.
Basically, there are two types of cookies. On the one hand, so-called session cookies. These cookies are deleted again after the end of a browser session. On the other hand, so-called permanent cookies. These cookies can remain stored on your computer for a defined longer period of time.
Furthermore, cookies are differentiated according to whether they are set by the operator of a website (first party cookie) or by third parties (third-party cookie).
If cookies are not absolutely necessary to offer the website, we ask for your consent before the cookies are used by means of a so-called consent menu when you first visit the website. In this menu, website visitors have the option to give or refuse their consent to various optional options/functionalities. In the menu item "Details", visitors can view the individual cookies/functionalities and how long they are stored.
For cookies that are absolutely necessary for the operation of the website, we assume the legal basis of Art. 6(1) GDPR (legitimate interest).
For cookies for which we obtain the consent of the visitor, Art. 6(1)(a) GDPR (consent) is the legal basis.
The data subject can prevent the setting of cookies by our website at any time by means of an appropriate 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 programmes. 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.
You can find your cookie settings here: https://www.torqeedo.com/en/cookie-settings.html
5. Collection of general data and information
The website of the TORQEEDO GMBH (hereinafter also referred to as "Torqeedo") collects a series of general data and information whenever a data subject or automated system calls up the website. This general data and information is stored in the server's log files. The following can be recorded
- browser types and versions used,
- the operating system used by the accessing system,
- the website from which an accessing system arrives at our website (so-called referrer),
- the sub-websites that are accessed via an accessing system on our website,
- the date and time of access to the website,
- an internet protocol address (IP address),
- the internet service provider of the accessing system and
- other similar data and information that serve to avert danger in the event of attacks on our information technology systems.
- When using these general data and information, TORQEEDO GMBH does not draw any conclusions about the data subject. Rather, this information is needed to
- to deliver the contents of our website correctly,
- optimise the content of our website and the advertising for it,
- to ensure the permanent functionality of our information technology systems and the technology of our website, and
- to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.
TORQEEDO GMBH therefore analyses anonymously collected data and information, on the one hand for statistical purposes, and, on the other, for the purpose of increasing the data protection and data security of our enterprise, in order 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 any personal data provided by a data subject and deleted after thirty (30) days.
Legal basis of this collection:
Art. 6(1)(f) GDPR (legitimate interest of the controller).
6. Registration on our website
It is possible to register on the website of the controller by providing personal data. Which personal data is transmitted to the controller in the process is determined by the respective input form used for registration. The personal data entered will be collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be transferred to one or more processors, such as web hosts, who will also use the personal data exclusively for an internal use attributable to the controller.
In these cases, we only use carefully and pre-screened processors with whom we have concluded a contract for commissioned processing pursuant to Art. 28 GDPR.
The registration of the data subject by voluntarily providing personal data serves the purpose of the controller to offer the data subject content or services which, by their nature, can only be offered to registered users. Registered persons are free to modify the data provided during registration at any time or to have them completely deleted from the controller's database.
Legal basis of this collection:
Art. 6(1)(a) GDPR (consent by the data subject)
Possibility of objection:
Those affected can revoke their user registrations by sending an informal email to email@example.com and have their data deleted.
Upon request, TORQEEDO GMBH will provide any data subject at any time with information about which personal data is stored about the data subject. Furthermore, the controller shall correct or delete personal data at the request or indication of the data subject, provided that this does not conflict with any legal obligation to retain the data. The entire staff of the controller responsible for processing shall be available to the data subject as contact persons in this context.
7. Use of apps
Please also pay particular attention to the separate data protection information in the following paragraphs regarding the app developed by TORQEEDO and the data protection information of the respective third-party providers.
8. TorqTrac app
Data storage takes place exclusively on the end device when using the TorqTrac app. No personal data, device data (e.g. location data) will be transmitted to Torqeedo or to third parties.
9. Data protection information on the use of the remote service
Data transmitted to Torqeedo within the scope of remote service:
- Your last name, first name, address, email addresses
- Contract number, serial numbers
- Parameters of the system components, in particular current, power, runtime and temperature
- Location information
Purposes of the processing:
- Torqeedo uses the transmitted data exclusively for the following purposes
- Carrying out advanced fault diagnostics and their early detection
- Detecting anomalies on individual components
- Recording system and component services
- Improving system stability
- Improving the control and regulation algorithms
- Informing about due maintenance work
- Use of the data in anonymised form for the creation of internal company user profiles
- Use of the data in anonymised form to determine the requirements regarding component selection and design
Legal basis of this collection:
Art. 6(1)(a) GDPR (consent by the data subject).
The consent and data protection information for the use of the remote service can be found here:
The data collected within the scope of the remote service will be processed exclusively by Torqeedo. A transfer to third parties does not take place.
A transfer to third countries does not take place and is not planned.
Duration of storage and possibility to object:
As long as you do not object to the collection/processing, the collected data will be stored for the duration of the remote service contract.
If you withdraw your consent, your data will be deleted after receipt of the objection.
Please send your objection to the further processing of your data during remote service to:
Legal Department / Management
10. Subscription to our newsletter and investor relations news
On the website of TORQEEDO GMBH, users are given the opportunity to subscribe to our company newsletter and our investor relations news. The personal data transmitted to the data controller in this regard can be seen from the input form used for this purpose.
The newsletters of our company and the investor relations news can generally only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the respective mailing. For legal reasons, a confirmation email is sent to the email address entered by a data subject for the first time for dispatch using the double opt-in procedure. This confirmation email is used to verify that the owner of the email address, as the data subject, has authorised the receipt of the information.
During the respective registration, we also store the IP address of the computer system used by the data subject at the time of registration, as assigned by the internet service provider (ISP), as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject's email address at a later date and therefore serves as a legal safeguard for the controller.
The personal data collected in the course of registration will be used exclusively for sending newsletters/investor relations news. Furthermore, subscribers could be informed by email if this is necessary for the operation of the service or a related registration, as could be the case in the event of changes to the offer or changes in the technical circumstances. The personal data collected will not be passed on to third parties. The information subscription can be terminated by the data subject at any time.
Legal basis of this collection:
Art. 6(1)(a) GDPR (consent by the data subject).
Possibility of objection:
The corresponding link for the purpose of revoking consent can be found in each newsletter/investors relation news. Furthermore, it is possible to notify the controller of the revocation at any time by post or by email to firstname.lastname@example.org.
11. Data protection information on the use of your business card data
If you give us your business card as part of events / trade fairs, we will store your data in our CMS system in order to inform you about Torqeedo products or services in the future.
Legal basis of this collection:
Art. 6(1)(a) GDPR (consent by the data subject) and Art. 6(1)(f) GDPR (legitimate interest of the controller).
Please see the document: click here
Please send your objection to the further processing of your data to:
Legal Department / Management
Possibility of objection: Send an informal email to email@example.com to have your data deleted.
12. Newsletter/press release/investor relations news tracking
The newsletters, press releases and investor relations news of TORQEEDO GMBH contain so-called tracking pixels. A tracking pixel is a thumbnail graphic that is embedded in such emails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the TORQEEDO GMBH may see if and when an email was opened by a data subject, and which links in the email were called up by the data subject.
Such personal data collected via the included tracking pixels are stored and analysed by the controller in order to optimise the dispatch of information and to better adapt the content to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure.
After a revocation, these personal data will be deleted by the controller. TORQEEDO GMBH automatically interprets a cancellation of the receipt of the newsletter, press releases/investor relations news as a revocation.
13. How to contact us via the website
The website of TORQEEDO GMBH contains, on the basis of statutory provisions, details that enable rapid electronic contact to our company and direct communication with us. If a data subject contacts the controller, for example by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data voluntarily provided to the data controller will only be stored for the purposes of processing or contacting the data subject. This personal data will not be passed on to third parties.
Legal basis of this collection:
Art. 6(1)(a) (consent by the data subject)
Possibility of objection:
Those affected can revoke their user registrations by sending an informal email to firstname.lastname@example.org and have their data deleted.
14. Routine deletion and blocking of personal data
The controller shall process and store the personal data of the data subject only for the time necessary to achieve the purpose of storage or where provided for by the European legislator of directives and regulations or other legislators of laws or regulations to which the controller is subject.
If the purpose of storage no longer applies or if a storage period prescribed by the European legislator of directives and regulations or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
15. Data protection in applications and in the application procedure
The controller collects and processes the personal data of applicants for the purpose of managing the application procedure. Processing may also be carried out electronically. This applies in particular if an applicant submits the relevant application documents to the controller electronically (for example, by email or via a web form on the website). If the data controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the data controller does not conclude an employment contract with the applicant, the application documents shall be automatically deleted three months after notification of the rejection decision, unless the applicant has given his or her separate consent for the data to be stored for a longer period of time or the deletion is not contrary to any other legitimate interests of the data controller.
Legal basis of the collection:
Art. 88 GDPR in conjunction with § 26 BDSG-neu (new German federal data protection act). Please also note the data protection information within our career portal at ttps://career.torqeedo.com/datenschutz.html.
16. Rights of the data subject
a) Right to confirmation
Every data subject shall have the right to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right to information
Any data subject affected by the processing of personal data shall have the right to obtain from the controller, at any time and free of charge, information about the personal data stored concerning him or her, as well as a copy of such information. Furthermore, the European legislator of directives and regulations has granted the data subject access to the following information:
- the processing purposes
- the categories of personal data that are processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
- the existence of a right to obtain the rectification or erasure of personal data concerning them or to obtain the restriction of processing by the controller or a right to object to such processing
- the existence of a right of appeal to a supervisory authority
if the personal data is not collected from the data subject: all available information on the origin of the data
the existence of automated decision-making, including profiling, pursuant to Art. 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject
Furthermore, the data subject has the right to be informed whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.
If a data subject wishes to exercise this right of access, he or she may, at any time, contact any employee of the controller.
c) Right of rectification
Any data subject affected by the processing of personal data has the right to obtain the immediate rectification of personal data relating to him or her that are inaccurate. Furthermore, the data subject shall have the right, taking into account the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary declaration. If a data subject wishes to exercise this right of rectification, he or she may, at any time, contact any employee of the controller.
d) Right to restriction of processing
Any data subject affected by the processing of personal data has the right to obtain from the controller the restriction of processing where one of the following conditions is met:
- 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, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
- The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the establishment, exercise or defence of legal claims.
- The data subject has objected to the processing pursuant to Art. 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by the TORQEEDO GMBH, he or she may, at any time, contact any employee of the controller. The employee of the TORQEEDO GMBH will arrange the restriction of the processing.
e) Right to object
Any data subject affected by the processing of personal data has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her that is carried out on the basis of Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
The TORQEEDO GMBH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defence of legal claims. If TORQEEDO GMBH processes personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to processing of personal data processed for such marketing. This also applies to profiling, insofar as it is connected with such direct advertising. If the data subject objects to TORQEEDO GMBH to the processing for direct marketing purposes, TORQEEDO GMBH will 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 that is carried out by TORQEEDO GMBH for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) of the General Data Protection Act (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 any employee of the TORQEEDO GMBH or another employee. The data subject shall also be free to exercise his or her right to object by means of automated procedures using technical specifications in the context of the use of information society services, notwithstanding Directive 2002/58/EC.
f) Right to erasure (right to be forgotten)
Any data subject affected by the processing of personal data has the right to obtain from the controller the erasure without delay of personal data relating to him or her, where one of the following grounds applies and insofar as the processing is not necessary:
- The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
- The data subject revokes the consent on which the processing was based pursuant to Art. 6(1)(a) of the GDPR or Art. 9(2)(a) of the GDPR and there is no other legal basis for the processing.
- The data subject objects to the processing pursuant to Art. 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) of the GDPR.
- The personal data have been processed unlawfully.
- The deletion of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data was collected in relation to information society services offered pursuant to Art. 8(1) GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to arrange for the deletion of personal data stored by the TORQEEDO GMBH, he or she may, at any time, contact any employee of the controller. The employee of TORQEEDO GMBH will ensure that the request for deletion is complied with immediately.
If the personal data has been made public by the TORQEEDO GMBH and our company as the controller is obliged to erase the personal data pursuant to Art. 17(1) GDPR, TORQEEDO GMBH shall implement reasonable measures, including technical measures, to compensate other data controllers for processing the personal data published, taking into account the available technology and the cost of implementation, in order to inform the data subject that he or she has requested from those other data controllers the erasure of all links to the personal data or to copies or replications of the personal data, insofar as the processing is not necessary. The employee of TORQEEDO GMBH will arrange for the necessary action to be taken in individual cases.
g) Right to data portability
Any data subject affected by the processing of personal data shall have the right to obtain the personal data relating to him or her which have been provided by the data subject to a controller in a structured, commonly used and machine-readable format. He or she shall also have the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) of the GDPR or Art. 9(2)(a) of the GDPR or on a contract pursuant to Art. 6(1)(b) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, when exercising his or her right to data portability pursuant to Art. 20(1) of the GDPR, the data subject shall have the right to have the personal data transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.
In order to assert the right to data portability, the data subject may at any time contact any employee of TORQEEDO GMBH.
h) Automated decisions in individual cases including profiling
Any data subject affected by the processing of personal data has the right 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, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is permitted by Union or Member State law to which the controller is subject and that law contains suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is made with the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2) it is made with the data subject's explicit consent, TORQEEDO GMBH shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, which includes at least the right to obtain the intervention of a person 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 decisions, he or she may, at any time, contact any employee of the controller.
i) Right to revoke consent under data protection law
Any data subject affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of the controller.
17. Data protection provisions on the use and application of Google Analytics (with anonymisation function)
The controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, collation and evaluation of data on the behaviour of visitors to websites. A web analysis service collects, among other things, data about the website from which a data subject has accessed a website (so-called referrer), which sub-pages of the website have been accessed or how often and for how long a sub-page has been viewed. A web analysis is mainly used to optimise a website and to analyse the cost-benefit of internet advertising. The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The 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 data subject is shortened and anonymised by Google if access to our internet pages is made 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 analyse the flow of visitors to our website. Google will use the data and information collected for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity.
Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. Setting the cookie enables Google to analyse the use of our website. Each time a data subject accesses one of the individual pages of this website operated by the data controller on which a Google Analytics component has been integrated, the internet browser on the data subject's information technology system is automatically triggered by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission calculations.
Personal information is stored by means of the cookie. For example the access time, the place from which an access originated and the frequency of visits to our website by the data subject. Each time you visit our website, 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.
You can also prevent the collection and transmission of the data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: tools.google.com.
You can prevent the collection by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent future collection of your data when visiting this website:
The controller has integrated YouTube components on this website.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
Each time a data subject accesses one of the individual pages of this website operated by the data controller on which a YouTube component (YouTube video) has been integrated, the internet browser on the data subject's information technology system is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information on YouTube can be found at https://www.youtube.com/yt/about/de/. As part of this technical procedure, YouTube and Google receive information about which specific sub-page of our website is visited by the data subject.
If the data subject is logged into YouTube at the same time, YouTube recognises which specific sub-page of our website the data subject is visiting when a sub-page containing a YouTube video is called up. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is logged into YouTube at the same time as calling up our website; this takes place regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not want this information to be transmitted to YouTube and Google, he or she can prevent the transmission by logging out of his or her YouTube account before accessing our website.
The display of YouTube videos is only possible if website visitors have given their consent to this via the Consent menu. In the event of consent, Art. 6(1)(a) GDPR is used as the legal basis.
19. Data protection provisions for the use of social media buttons
Our website uses buttons from the following companies:
Twitter, Twitter Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA
Facebook, Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA
YouTube, LLC, 901 Cherry Ave, San Bruno CA 94066, USA
Google+, Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA
LinkedIn, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland
These social media buttons only provide links to the respective providers. As long as these buttons are not clicked, no transmission to these providers takes place.
If you click on these buttons, you will be redirected to the website of the respective provider. Depending on whether you were logged in to the respective provider at the time of clicking, your data will be processed according to the data usage guidelines of these providers and may be used for profiling, which is not within our area of responsibility.
You can find more information on the data usage policies of the individual providers under the following links:
If you do not want these companies to collect data about you, you should not click on these buttons.
20. Google Maps
21. Google remarketing
On this website, we use the "remarketing" and "similar target groups" functions from Google to target visitors to our websites with suitable advertising messages, even after they have left. For this purpose, a "cookie" is placed on your computer or mobile device, which enables Google to recognise your device even after you have left our web pages and send advertising messages to you about our offers.
Legal basis of collection and use:
Art. 6(1)(a) GDPR (consent by the data subject via cookie banner), alternatively Art. 6(1)(f) GDPR (legitimate interest of the data subject).
Possibility of objection:
If you do not want it, you can deactivate this functionality at any time by logging into your Google Ads preferences at the following link: www.google.com/settings/ads. Or go to the following Network Advertising Initiative deactivation page: www.networkadvertising.org/managing/opt out.asp
22. Google reCAPTCHA
To protect our website, we use Google reCAPTCHA from Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. reCAPTCHA enables us to recognise whether a visitor to our website is a human being or automated software that is misusing our website and the functions implemented in it, which is prevented by the use of reCAPTCHA. When Google reCAPTCHA is used, the IP address of the website visitor and possibly other data required by Google for the operation of reCAPTCHA are transmitted to Google. The data protection provisions of Google inc. apply here, which you can view at http://www.google.de/intl/de/privacy or https://www.google.com/intl/de/policies/privacy/.
Legal basis: Art. 6(1)(f) GDPR, as it is a legitimate interest of the website operator to protect the functions offered against improper use.
TORQEEDO uses the Pinterest tracking pixel if you have consented to this collection within our consent management system. Pinterest is a social network for the reproduction of photographs or graphics of its members. By means of the Pinterest tracking pixel of the service Europe Ltd. Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland, we can track your user behavior and evaluate it so that advertising measures can be better tailored to your wishes and interests. Furthermore, Pinterest Inc. uses the collected data for analysis purposes and its own advertisements.
Pinterest users can adjust their own settings for advertisements at https://www.pinterest.de/settings/privacy. Pinterest Europe Ltd. and Torqeedo GmbH are to be regarded as so-called "joint controllers" under data protection law within the meaning of Art 26 DSGVO, as they use advertising data functions for which the collection and transmission of personal data is carried out. Further data protection information from Pinterest and options for exercising data subject rights against Pinterest Europe Ltd. can be found at https://policy.pinterest.com/de/privacy-policy.
24. Customer surveys with SurveyMonkey
To conduct customer surveys, we use the tool from SurveyMonkey, Europe UC, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland. SurveyMonkey collects information about the device (PC, notebook, smartphone, tablet, etc.) that you use to participate in the survey. This includes the IP address, operating system version, device type, system and performance information and browser type. For mobile devices, the UUID of the device is also recorded. SurveyMonkey also uses so-called third-party tracking services, which in turn set cookies and page tags to collect usage time and user statistics.
We have no control over the amount of data collected by SurveyMonkey. For more information on SurveyMonkey, please visit: https://www.surveymonkey.de/mp/legal/privacy-policy/#pp-section-10
SurveyMonkey Europe UC is a subsidiary of SurveyMonkey Inc. based in the USA. It cannot be ruled out that your data collected by SurveyMonkey may also be transferred to the USA. SurveyMonkey Inc. has, however, submitted to the Privacy Shield Agreement concluded between the European Union and the USA and has been certified accordingly. SurveyMonkey is therefore committed to complying with the standards and regulations of European data protection law.
As a result of the ECJ ruling C-311/18 "Schrems II", SurveyMonkey has undertaken to perform data transfers on the basis of the EU standard contractual clauses.
You can find more information on this at: https://www.surveymonkey.de/mp/legal/eu-data-transfer-statement/
The legal basis is Art. 6(1)(f) GDPR. It is our legitimate interest to conduct customer surveys using SurveyMonkey, whereby we assume that the protectable interests of the survey participants do not outweigh this.
25. Legal basis of the processing
Art. 6(1)(a) GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6(1)(b) GDPR.
The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. (6)(1)(c) GDPR.
In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance details or other vital information needed to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1)(d) GDPR.
Ultimately, processing operations are also based on Art. 6(1)(f) GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator considered that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, sentence 2, GDPR).
26. Duration for which personal data is stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the deadline, the corresponding data is routinely deleted if it is no longer required for the fulfilment or initiation of the contract.
27. Legal or contractual requirements to provide the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of not providing the personal data
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, in order to conclude a contract, it may be necessary 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 TORQEEDO GMBH concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data by the data subject, the data subject must contact one of our employees. Our employee 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 of not providing the personal data would be.
28. Existence of automated decision making
As a responsible company, we do not use automatic decision-making or profiling.
We take all necessary technical and organisational security measures to protect your personal data from loss and misuse. This way, your data is stored in a secure operating environment that is not accessible to the public. Payment data is transmitted encrypted (128-bit SSL).
Should you wish to contact us by email, we would like to point out that the confidentiality of the information transmitted is not guaranteed. The content of emails can be viewed by third parties. We therefore recommend that you only send us confidential information by post.
30. Further information
Your trust is important to us. Therefore, we would like to be available at any time to answer your questions regarding the processing of your data. If you have any questions that are not answered by this data protection declaration or if you would like more detailed information on any point, please contact the TORQEEDO GMBH data protection officer at any time.
32. Data protection officer contact details
Mr Robert Schöttl
Tel. +49 (0) 8131 3333 220
Fax +49 (0) 8131 3385 388