GDPR

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General data policy regulation
We are very pleased that you have shown your interest in our company. In the business of C.E.P. Scherdel Springs Ltd. has an exceptionally high data protection priority. The web pages of C.E.P.
Scherdel Springs Ltd. can be used without any personal information. However, if the person concerned wants to use specific services through our website, processing of personal data is necessary. If the processing of personal data is necessary and exists for a legitimate reason, we generally obtain approval from the person concerned. The processing of personal data such as the name, address, e-mail address or telephone number of the person concerned will always be in accordance with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to C.E.P. Scherdel Springs Ltd. With this Privacy Statement, we want our company to inform the general public of the nature, scope and purposes of personal data that we collect, use and process. In addition, we inform the persons concerned, through this Privacy Statement, of their rights. C.E.P. Scherdel Springs Ltd. introduced numerous technical and organizational measures as operator to ensure the most secure protection of personal data processed through its website. However, data traffic on the Internet may have security differences, so absolute protection can not be guaranteed. For this reason, each person concerned has the possibility to provide us with his or her personal data in alternative ways, e.g. by phone.

1. Definitions
Data Protection Statement by C.E.P. Scherdel Springs Ltd. is based on the terms used by the European legislator in adopting the General Data Protection Regulation (GDPR). Our data protection statement should be clear and comprehensible to the general public as well as to our customers and business partners. Therefore, we would first like to explain the terminology used. In this privacy statement, we use, inter alia, the following terms:

a) Personal information
Personal data is any information regarding an identified or identifiable natural person ("the person concerned"). An identifiable natural person is a person who can be identified directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, identifier or reference to one or more elements that are specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

b) The person concerned
The person concerned is any identified or identifiable person whose personal data is processed by the operator responsible for the processing.

c) Processing
Processing is a transaction or set of operations involving personal data or personal data files, such as retrieving, recording, organizing, structuring, storing, reprocessing or modifying, searching, browsing, using, transmitting, spreading or otherwise providing, regrouping or combining, erasure or disposal, regardless of whether they are performed by automated or non-automated means.

d) Restriction of processing
Restriction of processing is the indication of the stored personal data in order to limit its processing in the future.

e) Profiling
Profiling is any form of automated processing of personal data that involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular analyzing or anticipating aspects of the individual concerned relating to performance at work, property, health, personal preferences, interests, reliability, behavior, position or movement.

f) Pseudonymization
Pseudonymization is the processing of personal data in such a way that personal data can no longer be attributed to a particular person concerned without the use of additional information unless such additional information is kept separate and is subject to technical and organizational measures to ensure that personal data are not assigned to the identified or identifiable natural person.

g) Operator or operator responsible for processing
The operator or operator responsible for processing is a natural or legal person, a public authority, an agency or other entity which, alone or jointly with others, determines the purposes and means of processing personal data; where the purposes and means of such processing are laid down in Union law or in the law of a Member State, the operator or the specific criteria for designation may be determined by Union law or by the law of a Member State.

h) Intermediary
An intermediary is a natural or legal person, a public authority, an agency or other entity that processes personal data on behalf of an operator.

i) Recipient
The recipient is a natural or legal person, a public authority, an agency or other entity to whom personal data are provided irrespective of whether it is a third party. However, public authorities which may receive personal data in a particular survey in accordance with Union law or the law of a Member State shall not be considered as recipients; the processing of such data by the public authorities shall be carried out in accordance with the applicable data protection rules, depending on the purpose of the processing.

j) Third Party
A third party is a natural or legal person, a public authority, an agency or other entity than the person concerned, an operator, an intermediary and persons who, under the direct authority of the
operator or intermediary, are entrusted with the processing of personal data.

k) Consent
The consent of the person concerned is any free, specific, informed and unambiguous manifestation of the will of the person concerned who, by means of a declaration or a clear confirmatory act, agrees with the processing of the personal data concerning him.

2. Name and address of operator
For the purposes of the General Data Protection Regulation (GDPR), other data protection laws in force in the Member States of the European Union and other data protection provisions, the operator is:

C.E.P. Scherdel Pružiny s.r.o.
Javorinská 1200/4
907 01 Myjava
Slovakia
Phone: +421 34 64 700
E-mail: cep@cep.scherdel.sk
Website: www.scherdel.sk

3. Name and address of the person responsible
The operator is responsible for:
Jens Täubert
c / o SCHERDEL GmbH
Scherdelstrasse 2D
956 15 Marktredwitz

Phone: +49 (0) 9231 603-0
Email: info@scherdel.de

Every person concerned can contact our responsible person at any time, with any questions and suggestions on data protection.

4. Cookies
Web of C.E.P. Scherdel Springs Ltd. uses cookies. Cookies are text files that are stored on a computer system via an Internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID. Cookie ID is a unique cookie. It consists of a string of characters that allow websites and servers to be assigned to the specific Internet browser on which the cookie was stored. This allows the websites and servers visited to distinguish individual browsers of the persons concerned from other Internet browsers that contain other cookies. A particular Internet browser can be identified and identified using a unique cookie ID. By using cookies, C.E.P. Scherdel Springs Ltd. to provide users of this website with more user-friendly services that would not be possible without setting cookies.

Using a cookie, it is possible to optimize information and offers on our website for a specific user. As we have already mentioned, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to work with our website. A user of a website that uses cookies, e.g. they do not need to enter access data whenever they open a web page because their page loads automatically and a cookie is stored on their computer system. Another example is the shopping cart cookie in the online store. The online cookie stores items that the customer has saved in the virtual shopping cart. The person in question can, at any time, prevent the cookies from being set up on our website by the appropriate settings of their internet browser, thereby permanently refusing to store cookies. In addition, saved cookies can be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the person concerned deactivates the cookie setting in their internet browser, some of the features of our website may not work.

5. Collection

Collectionof general data and information C.E.P. Scherdel Springs Ltd. collects general data and information files when a person or an automated system enters a website. These general data and information are stored in server log files. The following types of information can be collected (1) the types and versions of used browsers, (2) the operating system used by the entry system, (3) the website to which the entry system enters our web site (the so-called referer), (4) , (5) the date and time of access to the website, (6) the Internet Protocol address (IP address), (7) the ISP of the input system, and (8) any other similar data and information that may be used in the case of attacks to our information technology systems. Using these general data and information, C.E.P. Scherdel Springs Ltd. does not conclude any conclusions about the person concerned. This information is necessary to (1) properly deliver the content of our website, (2) optimize the content of our website, and promote it; (3) ensure the long-term viability of our IT systems and website technologies; and (4) necessary for criminal prosecution by law enforcement authorities in the event of a cyber attack. Therefore, C.E.P. Scherdel Springs Ltd. analyzes anonymously collected data and information in a statistical way, in order to increase the data protection and data security of our company, and to ensure the optimal level of protection of the personal data we process. Anonymous server log file data is kept separate from any personal data provided by the affected person.

6. Contact via web site
The C.E.P. Scherdel Springs Ltd. webpage contains information that enables to quickly contact us electronically, as well as communicate directly with us, which includes the general address of the so-called e-mail (electronical mail address). If the person concerned contacts the operator by e-mail or via the contact form, the personal data transferred by the person concerned is automatically retained. Such personal data that the person concerned delivers voluntarily to the operator is retained for processing or contacting the data subject. These personal data are not transferred to any third party.

7. Routine deletion and blocking of personal data
The data controller processes and stores the personal data of the data subject only for the period necessary to achieve the purposes of retention or as required by the European legislator or other
legislators in the laws or regulations to which the operator is subject. If the purpose of storage is not applicable or if the retention period prescribed by the European legislator or other relevant lawmaker expires, personal data are routinely blocked or deleted in accordance with legal requirements.

8. Rights of the person concerned
a) The right to confirmation
Each person concerned has the right, granted by the European legislatos, to obtain a confirmation from the operator as to whether or not his or her personal data is processed. If the person concerned wishes to exercise this right of acknowledgment, he or she may at any time contact the employee of the operator.

b) Right of access Each person concerned has a right granted by the European legislator to obtain free information from the operator about their personal data held at any time and a copy of that information. In addition, European directives and regulations grant the persons concerned the right to the following information:

for processing purposes; the category of personal data concerned; the recipients or categories of recipients to whom personal data have been made available, namely recipients in third countries or international organizations;
as far as possible, the envisaged period for which the personal data will be stored or, if that is not possible, the criteria for determining that period;
the existence of the right to require the operator to repair or delete personal data or to restrict access to the person's personal data or the purpose of such processing;
the existence of the right to lodge a complaint with the supervisory authority;
o if personal data were not obtained from the person concerned, any available information on their source; on the existence of automated decision-making, including profiling, in relation to Article 22 (1) and (4) of the GDPR, and at least in those cases, meaningful information on the logic used, as well as the significance and foreseeable consequences of such processing for the person concerned.

In addition, the person concerned has the right to obtain information as to whether personal data are being transferred to a third country or to an international organization. If this is the case, the person concerned will have the right to information on the appropriate security measures relating to the transfer. If the person concerned wishes to exercise this right of access, he may at any time contact the employee of the operator.

c) Right to repair
Each person concerned has the right, granted by the European legislator, to obtain from the operator without undue delay the correction of inaccurate personal data relating to his or her person. For processing purposes, the person concerned is entitled to supplement incomplete personal data, including in the form of a supplementary statement. If the person concerned wishes to exercise this remedy, he may at any time contact the operator´s staff.

d) Right of wiping (right to forfeit)
Each person concerned has a right, granted by the European legislator, to obtain immediate removal from the operator of personal data relating to his or her person and the operator is obliged to delete personal data without delay if one of the following reasons is true and processing is not necessary:

o Personal data are no longer necessary in relation to the purposes for which they were acquired or
otherwise processed.
o The person concerned withdraws the consent on which the processing is based pursuant to Article 6 (1) (a) GDPR or Article 9 Article (2) (a) GDPR, and unless there is any other legal reason for
processing. o The person concerned opposes processing under Article 21 (1) GDPR and there are no overriding legitimate reasons for processing, or the person concerned objects to processing under Article 21 (2) GDPR. o Personal data was processed illegally.
o Personal data must be erased in order to comply with legal obligations under the laws of the Union or the Member State to which the operator is subject.
o Personal data were obtained in relation to the offer of information society services under Article 8 (1) GDPR. If one of the above reasons is true and the person concerned wishes to delete the personal data retained by C.E.P. Scherdel Springs Ltd. can contact the operator at any time. Employee of C.E.P. Scherdel

Springs Ltd. will promptly ensure that the deletion request is immediately completed. Where an operator has disclosed personal data and is required by Article 17 (1), the operator, taking
into account available technology and implementation costs, shall take appropriate steps, including technical measures, to inform other operators processing personal data that the data subject requests them to delete all references to such personal data, copy or replica , unless processing is necessary. Employees of C.E.P. Scherdel Springs Ltd. will provide the necessary measures in individual cases.

e) Right to limit processing
Each person concerned has the right, granted by the European legislator, to achieve a processing restriction on the operator if one of the following options is available:
o The person concerned questions the accuracy of personal data for a period sufficient to ensure that the operator has verified the accuracy of the personal data.
o The processing is illegal and the person concerned does not agree with the deletion of the personal data and instead requests the limitation of their use.
o The operator no longer requires personal data for processing purposes but the person concerned requests them to establish, exercise or protect legal claims.
o The person concerned objected to the processing under Article 21 (1) GDPR to verify that the legitimate reasons for the operator are superior to the reasons of the person concerned.

If one of the above conditions is true and the person concerned wishes to limit the processing of personal data retained by C.E.P. Scherdel Springs Ltd., this person can contact the employee of the operator responsible for the processing of personal data at any time. This employee of C.E.P. Scherdel Springs Ltd. will provide processing restrictions.

f) Right to data portability
Each person concerned shall have the right,granted by the European legislator, to obtain personal data concerning him / her which he has provided to the operator in a structured, commonly used and machine-readable format. The data subject shall have the right to transfer such data to another operator without the provider to whom that personal data has been provided has been prevented if the processing is based on the consent referred to in Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR or the contract referred to in Article 6 (1) (b) GDPR, and processing is carried out by automated means, unless processing is necessary for the performance of a task performed in the public interest or in the exercise of public authority entrusted to the operator. In addition, in exercising its right to data portability under Article 20 (1) GDPR, the person concerned is entitled to transfer personal data directly from one operator to another, as far as technically feasible and insofar as it does not adversely affect the rights and freedoms of others.

If the person concerned wants to exercise the right to data portability, he or she can contact any employee of C.E.P. Scherdel Springs Ltd.

g) The right to object
Each person concerned shall at any time have the right, granted by the European legislator, to object, on grounds relating to his or her particular situation against the processing of personal data concerning him, which is carried out pursuant to Article 6 (1) e) or f) GDPR. This also concerns profiling based on these provisions. C.E.P. Scherdel Springs Ltd. will no longer process personal data in the case of an objection unless we can prove the necessary legitimate reasons for processing that outweigh the interests, rights and freedoms of the person concerned, or reasons for proving, applying or defending legal claims. If C.E.P. Scherdel Springs Ltd. processes personal data for the purposes of direct marketing, the person concerned has the right at any time to object to the processing of personal data concerning him / her for the purposes of such marketing. This also applies, including profiling, to the extent that it relates to such direct marketing. If the person concerned complains to C.E.P. Scherdel Springs Ltd. against processing for direct marketing purposes, C.E.P. Scherdel Pružiny Ltd. will no longer process personal data for
such purposes. In addition, the person concerned is entitled, on grounds relating to his particular situation against the processing of personal data relating to him by C.E.P. Scherdel Pružiny Ltd. for the purposes of scientific or historical research or for statistical purposes under Article 89 (1) GDPR, except where processing is necessary for the performance of a task on grounds of public interest. If the person concerned wishes to invoke the right to appeal, he or she may contact any of C.E.P. Scherdel Springs Ltd. In addition, the person concerned may, in the context of the use of the information society services and notwithstanding Directive 2002/58 / EC, exercise his right to object by automated means using the technical specifications.

h) Automated individual decision making including profiling
Each person concerned has the right, granted by the European legislator, not to be covered by a decision based solely on automated processing, including profiling, and which has legal effects which affect him or are of such a significant effect. (2) permitted by Union law or by the law of the Member State to which the operator is subject, and which also lays down appropriate measures guaranteeing the protection of rights and freedoms; and the legitimate interests of the person concerned, or (3) based on the explicit consent of the person concerned. If the decision (1) is necessary for the conclusion or performance of the contract between the person concerned and the operator, or (2) based on the express consent of the person concerned, C.E.P. Scherdel Springs Ltd. will take appropriate measures to protect the rights and freedoms and legitimate interests of the person concerned, at least the right to human intervention by the operator, the right to express its opinion and the right to challenge the decision.

If the person concerned wishes to assert his / her rights with regard to automated individual decision- making, he / she may at any time contact a C.E.P. Scherdel Springs Ltd.

i) Right to withdraw consent to processing at any time
Each person concerned has the right, granted to European legislators, at any time to withdraw his consent to the processing of his or her personal data.

If the person concerned wishes to exercise the right to withdraw consent, he may at any time contact a C.E.P. Scherdel Springs Ltd.

9. Data protection for job applications and process of processing applications
The operator collects and processes the personal data of jobseekers for processing the application submission process. Processing can also take place electronically. This is the case if the applicant
submits the relevant application documents to the operator in the form of an e-mail or web form on the web site. If the operator concludes an employment contract with the tenderer, the provided data will be stored for the purpose of processing the employment relationship in accordance with legal requirements. If the operator does not enter into a contract with the tenderer, the application documents shall be automatically erased two months after the denial notification, provided that the deletion is not in contradiction with any other legitimate interests of the operator. Other legitimate interests in this context include, for example, the burden of proof in the proceedings under the General Law on Equal Treatment (AGG).

10. Data protection provisions for the application and use of Google Analytics (with anonymization function)
The web site operator has integrated Google Analytics (with anonymization). Google Analytics is a web analytics service. Web analytics involves obtaining, collecting, and analyzing website visitors;
behavior data. The web analytics service collects, inter alia, information about the site visited by the visitor (the so-called referer) who visited the site, or how often and for how long time he ́s wieving the site. Web analytics is primarily used to optimize websites and to conduct a cost-benefit analysis of Internet advertising. Google Analytics is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, United States of America. Webmaster uses Google Analytics to use "_gat._anonymizeIp". Through this Google app, it shortens the IP address of the person's Internet connection and anonymizes it when visiting our site from a MemberState of the European Union or another contracting state of the European Economic Area. The purpose of the Google Analytics component is to analyze the movement on our website. Google uses the data and information obtained, inter alia, to evaluate the use of our website and to provide online statements that show activity on our website and to provide additional services related to the use of our website to C.E.P. Scherdel Springs Ltd.

Google Analytics places cookies in the person's IT system. The definition of cookies is listed above. According to the cookie setting, Google can analyze the use of our website. Each time a single page is visited on this web site managed by the operator for which the Google Analytics component is integrated, the internet browser in the affected person's IT system automatically sends the data through the Google Analytics component for online advertising and billing commissions for Google. During this technical process, Google learns about personal information such as the IP address of the affected person that serves Google, among other things, to identify the origin of visitors and clicks, and then create commission billing.

The cookie is used to store personal information such as the date of access, the location from which access was made, and the frequency of visits to our website by the person concerned. Every timeour website is visited, these personal information, including the IP address of the person´s internet access, will be transferred to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data obtained through the technical process to third parties. The person in question may, as above, at any time prevent cookies from being set up on our website by the appropriate settings of their Internet browser, thereby permanently refusing to store cookies. Such an Internet browser also prevents Google Analytics from placing cookies of the person concerned in the IT system. In addition, cookies already used by Google Analytics can be deleted at any time via an Internet browser or other software. In addition, the person concerned may object to the collection of Google Analytics data relating to the use of this website, as well as to the processing of this data by Google and the possibility of preventing all of the foregoing. For this purpose, the person concerned must download and install the browser addon link. This browser plug-in tells Google Analytics, through

JavaScript, that any data and information about website visits can not be transferred to Google Analytics.The installation of plug-ins is considered by Google to be an objection. If the person´s IT
system is later erased, formatted or re-installed, the person concerned must reinstall the browser plugins to re-enable Google Analytics. If the person concerned or any other person under their
jurisdiction uninstalls the browser plug-in or deactivates it, it can be re-installed or activated. For more information on the relevant Google data protection provisions, please visit
link and link Google Analytics is further explained in the following link https://www.google.com/analytics/.

11. Data protection provisions for the use and use of Google AdWords
On this website, the operator has integrated Google AdWords. Google AdWords is an internet ad service that allows an advertiser to place ads on Google search results and on the Google ad network. Google AdWords allows the advertiser to define in advance specific keywords that will only show a specific ad in Google search results if the user uses the search engine to get a keyword-relevant result. On the Google Display Network, ads are distributed to relevant websites using an automatic algorithm, with respect to predefined keywords. Google AdWords is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, United States of America. The purpose of Google AdWords is to support our website by including relevant advertising on third-party websites and Google search results, and to include third-party ads on our website. If a person gets to our site via a Google ad, a conversion cookie is placed in the person's IT system. You can find the definition of cookies above. The conversion cookie will expire after 30 days and will not be used to identify the person concerned. During its validity, the conversion cookie is used to check if certain sub-pages have been triggered on our site, e.g. shopping cart in online shop. Through a conversion cookie, both Google and the operator can understand if the person who received the AdWords ad on our website generated a sale, that is, whether it has made or canceled the sale of the goods.

The data and information obtained through the use of a conversion cookie is used by Google to generate traffic statistics for our website. These traffic statistics are used to determine the total number of users who have used our services through AdWords ads, and thus to track the success or failure of each AdWords ad while optimizing our AdWords ads in the future. Neither our company nor other Google AdWords advertisers obtain information from Google that could identify the person concerned. Conversion cookie stores personal information, e.g. website visited by the person concerned. Every time we visit our website, these personal information, including the IP address of the person´s internet access, will be transferred to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data obtained through the technical process to third parties. The affected person may at any time prevent the cookies from being set on our website as above, with the appropriate settings of their Internet browser, and thus permanently refuse to store cookies.
Such an Internet browser setting will also prevent Google from placing a conversion cookie in the persons IT system. Additionally, a set of cookies set up by Google AdWords can be deleted at any time via an Internet browser or other software programs. The person in question has the option to object to a Google interest-based ad. In this case, the person concerned must use the link www.google.de/settings/ads on each of their browsers and specify the required settings. For more information about the relevant Google data protection provisions, visit https://www.google.com/intl/en/policies/privacy/.

12. Legal basis of data processing
Article 6 (1) (a) of the GDPR Regulation serves as a legal basis for the processing operations for which we obtain consent for a specific purpose of processing. Where the processing of personal data is necessary for the performance of a contract to which the person concerned is a party, for example where the processing is necessary for the supply of goods or for the provision of other services, the processing is carried out on the basis of Article 6 (1) b) GDPR. The same applies to such processing as is necessary to perform pre-contractual arrangements, for example in the case of queries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as the fulfillment of tax obligations, processing takes place on the basis of Article 6 (1) c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the person concerned or another natural person. This would be the case, for example, if a visitor in our company was injured and his name, age, health insurance or other life information would have to be passed to a doctor, hospital or other third party. In that case, the processing would take place in accordance with Article 6 (1) d) GDPR. Lastly, processing may also take place under Article 6 (1) f) GDPR. This legal basis is used for processing that is not covered by any of the above legal bases unless the processing is necessary for the legitimate interest of our company or third party unless the interests of the fundamental rights and freedoms of the data subject , which require the protection of personal data. Such processing is permissible in particular because it is specifically mentioned by the European legislator. It is considered that a legitimate interest can be assumed if the person concerned is the client's operator (Preamble 47 clause 2 GDPR).

13. Eligible interests pursued by the operator or by a third party
Where the processing of personal data is based on Article 6 (1) f) GDPR, our legitimate interest is to conduct business for the benefit of all our employees and shareholders.

14. Retention period of personal data
The criterion used to determine the retention period for personal data is the appropriate legal retention period. Upon expiration of this period, the relevant data will be routinely deleted if they are no longer required for performance of the contract or conclusion of the contract.

15. Providing personal data as a statutory or contractual requirement

The requirement for the conclusion of the contract; the obligation of the person concerned to provide personal data; possible consequences of failure to provide such data.

We would like to clarify that the provision of personal data is partly required by law (eg, tax rules) or may result from contractual provisions (eg information about the contractor). Sometimes it may be necessary to conclude a contract that the person concerned provides us with personal data , which we then have to process. For example, the person concerned is required to provide us with personal information when our company signs a contract with it. In the case of failure to provide personal data, the conclusion of the contract with the person concerned would be impossible. Prior to providing personal data, the person concerned must contact any employee. Employee clarifies to the person concerned whether the provision of personal data requires a law or contract, or whether it is necessary to conclude a contract, whether there is an obligation to provide personal data and the consequences of non-disclosure of personal data.

16. Existence of automated decision making
We do not use automated decision making or profiling in our company.