of the company VPF Veredelungsgesellschaft für Papiere & Folien GmbH & Co. KG pursuant to GDPR and BDSG
I. Name and address of the controller
The controller as defined by the GDPR and other national data protection regulations of the member states as well as other data protection provisions is:
VPF-Veredelungsgesellschaft für Papiere
und Folien GmbH & Co. KG
Tel: +49 2339 12050
Name and address of the Data Protection Officer
The Data Protection Officer of the controller is:
Dr. Hartmut Frenzel
Tel: +49 2022 541472
II. General information about data processing
1. Scope of the processing of personal data
We only process personal data of our users as required to provide a functional website as well as content and services. Personal data is only processed with the consent of the user. An exception shall apply when prior consent was not possible for legitimate grounds and the processing of the data is permitted by law.
2. Legal basis for processing personal data
Art. 6 Para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as legal basis for obtaining consent of the data subject for processing personal data.
When processing personal data required for the fulfilment of a contract with the data subject being the contractual party, Art. 6 Para. 1 lit. b GDPR serves as legal basis. That also applies for processing required for executing pre-contractual measures.
If processing personal data is required to comply with statutory obligations to which our company is subjected, Art. 6 Para. 1 lit. c GDPR serves as legal basis.
In case the processing of personal data is required due to the vital interests of the data subject or of any other natural person, Art. 6 Para. 1 lit. d GDPR serves as legal basis.
In case the processing of personal data is required due to legitimate interest of our company or a third party and if the interests, basic rights and freedoms of the data subject do not outweigh the interests mentioned above, Art. 6 Para. 1 lit. f GDPR serves as legal basis.
3. Data erasure and storage duration
Personal data of the data subject is deleted or blocked as soon as the purpose for storage is void. Storage may continue for a longer period of time if specified by the European or national authorities in union law directive, laws or other provisions applicable to the controller. The data is blocked or deleted if the storage duration specified by the mentioned standards expires, unless the data must be continued to be stored for the purposes of concluding or fulfilling a contract.
III. Provision of the website and creation of log files
1. Description and scope of data processing
Every time our website is accessed, our system collects automated data and information from the system of the accessing computer:
The following data is collected:
- Information about browser type and version used
- Operating system of the user
- Internet service provider of the user
- The IP address of the user
- Date and time of access
- Websites from which the user’s system was directed to our website
- Websites access by the user’s system via our website
Along with the log files, our system also stores data. That does not include the IP address of the user or other data which would enable matching the data with the user. This data is not stored along with any other personal data of the user.
2. Legal basis for data processing
Art. 6 Para. 1 lit. f GDPR serves as legal basis for temporary storage of data and log files.
3. Purpose of data processing
It is necessary for the system to temporarily store the IP address to enable delivery of the website to the computer of the user. To this end, the IP address of the user must be stored for the duration of the session.
The log files are stored to ensure the functionality of the website. In addition, the data serves to optimize the website and ensure the security of our IT systems. The data is not analyzed for marketing purposes in this context.
These purposes represent our legitimate interest in data processing as per Art. 6 Para. 1 lit. f GDPR.
4. Duration of storage
The data is deleted as soon as it is no longer required to fulfil its purpose. In case data is collected to provide proper functionality of the website, it will be deleted when the session is finished.
If data in log files is stored, it will be deleted after seven days at the latest. It is possible that the data is stored beyond that period. In this case, the IP address of the users are deleted or are distorted in such a way that it is no longer possible to match it with the accessing client.
5. Right to object and right to removal
It is essential for the operation of the website to collect the data required for the provision of the website and store the data in the log files. There is no option to object for the user.
V. E-mail contact
1. Description and scope of data processing
Users can contact us via the e-mail address provided on our website. In this case, the personal data of the user transmitted along with the e-mail will be stored.
No data is transferred to third parties in this context. The data is only used to process the conversation with the user.
2. Legal basis for data processing
Art. 6 Para. 1 lit. a GDPR serves as legal basis for processing data after having obtained consent.
Art. 6 Para. 1 lit. f GDPR serves as legal basis for processing data transmitted as part of sending an e-mail. Art. 6 Para. 1 lit. b GDPR serves as additional legal basis if the e-mail contact is intended to lead towards the conclusion of a contract.
3. Purpose of data processing
In case of e-mail contact, it is of legitimate interest to process the provided data.
4. Duration of storage
The data is deleted as soon as it is no longer required to fulfil its purpose. Personal data sent via e-mail is deleted when the respective conversation with the user has ended. The conversation is considered to have ended if the circumstances indicate that the respective subject matter has been settled.
5. Right to object and right to removal
The user has the option of withdrawing consent for the processing of personal data at any time. If a user contacts us by e-mail, the user may object to personal data being stored at any time. In this case, the conversation cannot continue.
If you would like to exercise your right of withdrawal or cancelation, please send an e-mail to email@example.com.
All personal data stored as part of the contact will be deleted.
VI. Rights of the data subjects
If your personal data is being processed, you are considered a data subject as defined by the GDPR and you have the following rights towards the controller:
1. Right of access
You may request a confirmation from the controller whether we process your personal data. If the data is indeed being processed, you may request the following information from the controller:
- purposes for which the personal data is being processed
- categories of personal data being processed;
- recipients or categories of recipients to whom the relevant personal data was disclosed or is to be disclosed;
- planned duration of storage of the personal data or, if it is not possible to provide specific information, criteria for determining the storage duration;
- existence of the right to rectification or deletion of your personal data, the right to restrict processing of the data by the controller or the right to object against such processing;
- existence of the right to lodge a complaint with a supervisory authority;
- all available information about the origin of the data if the personal data was not collected from the data subject directly;
- automated decision-finding including profiling as per Art. 22 Para. 1 and 4 GDPR and – in most cases – significant information about the logic involved as well as the importance and the anticipated consequences of such processing for the data subject
You have the right to request information about the fact whether your personal data is being transferred to a third country or to an international organization. In the context of transferring data, you may request to be informed about appropriate safeguards as per Art. 46 GDPR.
2. Right to rectification
You have the right to rectification and/or completion towards the controller if the personal data being processed is incorrect or incomplete. The controller must undertake the rectification immediately.
3. Right to restriction of processing
You may request a restriction of processing of your personal data under the following conditions:
- if you contest the accuracy of the personal data for a period enabling the controller to verify the accuracy of the personal data
- the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead
- the controller no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defense of legal claims, or
- if you have objected to processing pursuant to Article 21 Para. 1 GDPR pending the verification whether the legitimate grounds of the controller override your grounds.
Where processing of your personal data has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
If the processing has been restricted as specified by the above requirements, you shall be informed by the controller before the restriction of processing is lifted.
4. Right to erasure
You have the right to obtain from the controller the erasure of your personal data without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
- you withdraw consent on which the processing is based according to Art. 6 Para. 1 lit. a or Art. 9 Para. 2 lit. a GDPR, and where there is no other legal ground for the processing.
- you object to the processing pursuant to Art. 21 Para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 Para. 2 GDPR.
- the personal data has been unlawfully processed.
- the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data has been collected in relation to the offer of information society services referred to in Art. 8 Para. 1 GDPR.
b) Information to third parties
Where the controller has made the personal data public and is obliged pursuant to Art. 17 Para. 1 GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, the personal data.
The right to erasure shall not apply to the extent that processing is necessary
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- for reasons of public interest in the area of public health in accordance with Art. 9 Para. 2 lit. h and Art. 9 Para. 3 GDPR
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art, 89 Para. GDPR in so far as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
- for the establishment, exercise or defense of legal claims.
5. Right to information
If you have asserted the right to rectification, erasure or restriction of the processing to the controller, the controller shall be obligated to inform all recipients to whom the personal data was provided of this correction or erasure of the data or the restriction of processing, unless it is impossible or associated with unreasonable efforts.
You have the right towards the controller to be informed about such recipients.
6. Right to data portability
You have the right to receive the personal data you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where:
- the processing is based on consent pursuant to Art. 6 Para. 1 lit. a (a) GDPR or Art. 9 Para. 2 lit. a GDPR or on a contract pursuant to Art. 6 Para. 1 lit. b GDPR, and
- the processing is carried out by automated means.
In exercising this right to data portability, you shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. This shall not adversely affect the rights and freedoms of others.
The right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. Right to object
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Art. 6 Para. 1 lit. e or f GDPR, including profiling based on those provisions.
The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Where personal data is processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
8. Right to withdraw the data protection consent declaration
You have the right to withdraw your data protection consent declaration at any time. The withdrawal of the consent shall not affect the processing carried out until the withdrawal of the consent.
9. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects for you or similarly significantly affects you. This shall not apply if the decision
- is necessary for entering into, or performance of, a contract between yourself and the controller
- is authorized by Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
- is based on your explicit consent.
Decisions referred to in Art. 9 Para. 2 lit. a or g GDPR shall not be based on special categories of personal data referred to in Art. 9 Para. 2 lit. a unless Art. 9 Para. 2 lit. a or g GDPR apply and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.
In the cases referred to in points (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.
10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes this Regulation.
The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.
11. Information for job applications regarding data protection at VPF
Purpose of data processing:
pursuant to § 26 Para. 1 C. 1 Var. 1 BDSG new version as well as Art. 88 GDPR
– Job application process
– Applicant selection process
Duration of data collection:
We save your data until the application process has been completed pursuant to § 26 Para. 1 C. 1 Var. 1 BDSG new version. Your personal data will be deleted in case of non-justification of an employment relationship after 6 months at the latest, unless you provide consent to longer storage.
Recipients or categories of recipients of personal data (applicant data):
Application process / Applicant selection process: internal only
Department requesting personnel
Data transfers to third parties:
No data is transferred to third countries.
Rights of the data subject:
You can request information about the personal data stored about you. Furthermore, you may request the deletion or correction of your data under certain circumstances. You may also have the right to restriction or objection to the processing of your data as well as a right to disclosure of the data provided by you in a structured, common and machine-readable format. You also have the right to lodge a complaint with a supervisory authority.
Please note that a conclusion and performance of an employment agreement or the aforementioned matters is not possible without processing your personal data. Automated decision-making does not take place.
Contact in case of questions or requests for information:
Our HR staff will gladly answer your questions about the application process.
Phone: +49 2339 12050
12. Social media
Our online presence on LinkedIn and Xing
Insofar as you have given your consent to this in accordance with Art. 6 Para. 1S. 1 lit. a DSGVO to the respective social media operator, your data will be automatically collected and stored for market research and advertising purposes when you visit our online presences on the social media mentioned above, from which usage profiles are created using pseudonyms. These can be used, for example, to place advertisements within and outside the platforms that presumably correspond to your interests. Cookies are generally used for this purpose. For detailed information on the processing and use of data by the respective social media operator, as well as a contact option and your rights and setting options in this regard to protect your privacy, please refer to the data protection notices of the providers linked below. Should you still require assistance in this regard, don´t hesitate to contact us.
LinkedIn is a service of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”). The information automatically collected by LinkedIn about your use of our online presence on LinkedIn is generally sent to a server of LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA and stored there. The European Commission has not issued an adequacy decision for the USA. Our cooperation is based on standard data protection clauses of the European Commission.
„Xing“ is a service of New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany.