We appreciate your visit on our website https://www.reazn.com/ and your interest in our company. The protection of your personal data such as your ip-number, your date of birth, your name, telephone number and your address, etc. is important to us.

The purpose of this Privacy Policy is to inform you about the personal data we collect when you visit our site and how we use it.

Our data protection practice complies with the legal regulations, in particular those of the law of 1 August 2018 relating to the organization of the Commission Nationale pour la Protection des Données and on the general system of data protection (the “Law of 1 August 2018”), the law of 30 May 2005 relating to the protection of privacy in the electronic communications sector as amended (the “Law of 30 May 2005”) and the General Data Protection Regulation of the EU (the “GDPR”).

This means that we will only process your personal data insofar as it is necessary for the functional provision of this website and our contents and services, as well as for the processing of enquiries and, if applicable, for the processing of orders/contracts, but only insofar as there is a justified interest within the meaning of art. 6 (1) (f) GDPR or any other valid legal ground for the processing of personal data.

Your personal data will be used for other purposes than the one defined in this Privacy Policy only to the extent that you have given your prior and specific consent separately, e.g. for the sending of promotional information by newsletter.

1. Controller

The controller regarding this website within the meaning of art. 4(7) GDPR and other national data protection laws of the Member States and other provisions under the GDPR is:

NFM ALLOYZ S.A.
19-21, route d’Arlon
L-8009 Strassen
Luxembourg

E-Mail: info@nfm.lu
Fax: +352 44 75 47

2. Name and Address of the data protection officer

With regard to art. 37 GDPR we have designated a data protection officer.

Queries regarding data protection matters shall be addressed to gdpr@reazn.com.

3. Creation of log files

Each time you access our website, our system automatically collects data and information of your accessing device. The processing of personal data carried out in this context is as follows:

  • Scope of the processing and personal data processed
  • Information concerning the browser type and the Browser version used
  • The operating system of the accessing device
  • The IP address of the accessing device
  • Date and time of access
  • Websites and resources (images, files, additional page content) which were accessed
  • Websites which refers to our website and which directed the users device to our website (referrer tracking)

This data is stored in the log files of our system. This data is not stored together with personal data of a specific user in such a way that individual users can be identified.

  • Legal basis for the processing of personal data

Art. 6(1)(f) GDPR (legitimate interest). Our legitimate interest lies in the following, outlined purpose.

  • Purpose of data processing

Logging is carried out for maintaining compatibility as far as possible, for combating misuse and for troubleshooting reasons. In order to achieve those purposes it is necessary to log the technical data of the accessing devices. We also use this technical data to optimize the website and to ensure the security of our IT-systems.

  • Duration of storage

The aforementioned technical data is erased as soon as it is no longer required to achieve the aforementioned purposes, but at the latest 3 months following the use of our website.

  • Possibility to object and demand deletion

You may object to this processing according to art. 21 GDPR and demand deletion of data according to art. 17 GDPR by following the indications under point 9 of this Privacy Policy.

4. Special functions

Our site offers different functions which collect personal data as follows:

Contact Form

  • Scope of the processing of personal data

The data entered by you in our contact forms. Especially the data which you have entered in the input mask of the contact form. This includes your name, your E-Mail, the subject of the contact and everything you enter into the message field.

  • Legal basis for the processing of personal data

Art. 6(1)(a) GDPR (consent by clear confirmatory act or conduct)

  • Purpose of data processing

We will only use the data that you have entered via our contact form for the processing of the specific contact enquiry received. Please note that in order to fulfil your contact request, we may also send you e-mails to the address provided. The purpose of this is to enable you to receive confirmation from us that your request has been correctly forwarded to us. And to provide you with the proper answer to your request. However, the sending of this confirmation e-mail is not binding on us and is for your information only.

  • Duration of storage

After processing your request, the collected data will be deleted immediately, unless there is a legal retention period.

  • Possibility to object, withdraw consent and demand deletion

You can withdraw your consent relating to art. 7(3) GDPR by following the indications under point 9 of this Privacy Policy.

  • Characteristics of the provision of personal data

The provision of personal data is neither a statutory nor contractual requirement. It is also not a requirement necessary to enter into a contract. Furthermore you are not contractually obliged to provide the personal data and it has no contractual consequences if you fail to provide such data. The only consequence is that you are not able to communicate with us over the contact form.

5. Statistical evaluation of the visits to the website – Webtracker

We collect, process and store the following data when you access this website or individual files on the website: IP address, website from which the file was retrieved, name of the file, date and time of the retrieval, transferred data volume and notification of the success of the retrieval (so-called web log).

We use this access data exclusively in non-personalized form for the continuous improvement of our Internet offer and for statistical purposes. We also use the following web trackers to evaluate visits to this website:

5.1 Google-Analytics
  • Scope of the processing of personal data

On our site we use the web tracking service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter Google Analytics). Google Analytics uses cookies within the framework of web tracking, which are stored on your computer and which enable an analysis of the use of our website and your surfing behaviour (so-called tracking). We carry out this analysis on the basis of Google Analytics’ tracking service in order to constantly optimise our website and make it more readily available. When you use our website, data such as your IP address and your user activities are transferred to servers operated by Google Ireland Limited.

By activating IP anonymization within the Google Analytics tracking code of this website, your IP address will be anonymized by Google Analytics before transmission. This website uses a Google Analytics tracking code, which has been extended to allow only an anonymized collection of IP addresses (so-called IP masking).

  • Legal basis for the processing of personal data

The legal basis for data processing is, in accordance with art. 6 (1) (a) GDPR, your consent in our information banner regarding the use of cookies and web tracking (consent by clear confirming action or behaviour).

  • Purpose of data processing

On our behalf, Google will use this information to evaluate your visit to this website, to compile reports on website activity and to provide us with other services relating to the use of the website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not merged with other data of Google Ireland Limited.

  • Duration of storage

According to Google, they will store the data relevant for the provision of web tracking as long as it is necessary to fulfil the web service. Data is collected and stored anonymously. If there is a personal reference, the data will be deleted immediately, unless they are subject to legal storage obligations. In any case, the deletion will take place after expiry of the storage obligation.

  • Possibility to withdraw consent

If you have given us express permission to process your personal data (art. 6(1) (a) GDPR or art. 9 (2) (a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.

You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser, installing a script blocker in your browser or activating the “Do Not Track” setting of your browser.

You can also prevent the collection of data generated by the Google 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 plug-in available at the following link (https://tools.google.com/dlpage/gaoptout?hl=de).

The security and privacy policy of Google Analytics can be found at https://policies.google.com/privacy?hl=de.

5.2 Google Tag Manager
  • Scope of the processing of personal data

On our site we use the service of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Tag Manager). Google Tag Manager provides a technical platform to run and bundle other web services and web tracking programs using so-called ‘tags’. Google Tag Manager stores cookies on your computer in this context and analyses your surfing behaviour (so-called ‘tracking’), as long as web tracking tools are executed using Google Tag Manager. This data sent by individual tags integrated in Google Tag Manager is combined, stored and processed by Google Tag Manager under a uniform user interface. All embedded tags are listed separately in this privacy policy. For more information about the privacy practices of the tools included with Google Tag Manager, please see the appropriate section of this privacy statement. When using our website with activated integration of Google Tag Manager tags, data such as your IP address and your user activities are transferred to servers of Google Ireland Limited and processed and stored outside the European Union, e.g. in the USA. The EU Commission has determined that an adequate level of data protection may exist in the USA if the data processing company has submitted to the US-EU Privacy Shield Agreement and the data export to the USA has been made permissible in this way. This is the case with Google Ireland Limited. With regard to the web services integrated via Google Tag Manager, the regulations in the respective section of this privacy policy apply. The tracking tools used in Google Tag Manager ensure that the IP address of Google Tag Manager is made anonymous prior to transmission by IP anonymizing the source code. Google Tag Manager only allows the anonymized collection of IP addresses (so-called IP masking).

  • Legal basis for the processing of personal data

The legal basis for data processing is, in accordance with art. 6 (1) (a) GDPR, your consent in our information banner regarding the use of cookies and web tracking (consent by clear confirming action or behaviour).

  • Purpose of data processing

On our behalf, Google will use the information obtained using Google Tag Manager to evaluate your visit to this website, to compile reports on website activity and to provide us with further services related to website and internet usage.

  • Duration of storage

According to Google, they will store the data relevant for the provision of web tracking as long as it is necessary to fulfil the web service. Data is collected and stored anonymously. If there is a personal reference, the data will be deleted immediately, unless they are subject to legal storage obligations. In any case, the deletion will take place after expiry of the storage obligation.

  • Possibility to withdraw consent

If you have given us express permission to process your personal data (art. 6(1) (a) GDPR or art. 9 (2) (a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.

You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser, installing a script blocker in your browser or activating the “Do Not Track” setting of your browser.

You can also prevent the collection of data generated by the Google 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 plug-in available at the following link (https://tools.google.com/dlpage/gaoptout?hl=de).

The security and privacy policy of Google Analytics can be found at https://policies.google.com/privacy?hl=de.

6. Integration of external web services and processing of data outside the EU

On our website we use active contents from external providers, so-called web services. By calling up our website, these external providers may receive personal information about your visit to our website. It is possible that data may be processed outside the EU. You can prevent this by installing an appropriate browser plug-in or by deactivating the execution of scripts in your browser. This can lead to functional restrictions on Internet pages that you visit.

We use the following Tools:

Vimeo

We use the Service Vimeo by the company , Vimeo, Inc., 555 West 18th Street, 10011 New York, United States of America (hereinafter: Vimeo).

This service is integrated in our website. We use the data to ensure the complete functionality of our website. In this context, your browser may transmit personal data to Vimeo. The legal basis for the data processing is art. 6(1) (f) GDPR. The legitimate interest is an error-free functioning of the website. With the help of Vimeo we are able to show you videos embedded into our Webpage, that are originally hosted by vimeo.

The data is erased as soon as the purpose for its collection has been fulfilled. You can find additional information on the handling of the transferred data in the data privacy statement of vimeo: https://vimeo.com/privacy.

Vimeo, Inc. has certified itself in accordance with the EU-US Privacy Shield Agreement (see https://www.privacyshield.gov/list). Here you will find the link to the EU adequacy finding regarding the EU-US Privacy Shield: http://data.europa.eu/eli/dec_impl/2016/1250/oj.

8. Information concerning the use of cookies
  • Scope of the processing of personal data

On various pages, we and the web services integrate and use cookies to enable certain functions of our website. The so-called ‘cookies’ are small text files that your browser can store on your accessing device. These text files contain a characteristic string of characters that uniquely identify the browser when you return to our site. The process of storing a cookie file is also called ‘setting a cookie’. Details are given in the table below.

  • Legal basis for the processing of personal data

art. 6 (1) (f) GDPR (legitimate interest) or art. 6 (1) (a) or art. 9 para. (1) (a) GDPR (consent).

Which legal basis is relevant can be seen from the cookie table listed later in this section.

In general, in the case of cookies that are collected on the basis of a legitimate interest, our legitimate interest is to ensure the functionality of our website and the services integrated into it (technically necessary cookies). It is also possible that the cookies increase their user-friendliness and enable a more individual approach. In this case we have weighed up your interests against ours.

With the help of cookie technology, we can only identify, analyse and track individual website visitors if the website visitor has consented to the use of the cookie in accordance with Art. 6 (1) (a) GDPR.

  • Purpose of data processing

The cookies are set by our website or external web services in order to maintain the full functionality of our website, to improve the user-friendliness or for the purpose Cookie technology also enables us to recognize individual visitors by means of pseudonyms, e.g. an individual or random ID, so that we can offer more individual services. Details are shown in the following table.

  • Duration of storage

Our cookies are stored in your browser until they are deleted or, in the case of a session cookie, until the session has expired. Details are given in the table below:

Cookie-Name Server Purpose Category Legal Basis Storage Duration Type
_ga reazn.com  

Google-Analytics

Used to distinguish users via an unique user id.

analytics consent 2 years https
_gid reazn.com  

Google-Analytics

Used to distinguish users via an unique user id.

analytics consent 1 day https

 

  • Possibility to object, withdraw consent and demand deletion

You can adjust your browser according to your wishes so that the setting of cookies is generally prevented. You can then decide on the acceptance of cookies on a case-by-case basis or accept cookies in principle. Cookies can be used for various purposes, e.g. to recognise that your accessing device has already been connected to our website (permanent cookies) or to save recently viewed offers (session cookies). If you have given us express permission to process your personal data (art. 6(1)(a) GDPR or art. 9(2)(a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.

8. Data security and data protection, communication by e-mail

Your personal data is protected by technical and organizational measures during collection, storage and processing such that they are not accessible to third parties. In case of unencrypted communication by e-mail, we cannot guarantee complete data security on the transmission path to our IT systems, so that we recommend encrypted communication or mail for information with a high confidentiality requirement.

9. Right to access and correct data – deletion of data – limitation of processing -withdrawal of consents – right to object
9.1 Right of access

You have the right to request confirmation as to whether we process your personal data. If this is the case, you have a right of access and information specified in art. 15(1) GDPR, provided that the rights and freedoms of other persons are not infringed (art. 15(1) GDPR). We will also be happy to provide you with a copy of the data.

9.2 Right to correction

Pursuant to art. 16 GDPR, you have the right to have incorrectly stored personal data (such as address, name, etc.) corrected by us at any time.

9.3 Right to erasure

Pursuant to art. 17(1) GDPR, you have the right to demand that we delete the personal data collected about you in the following cases:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
  • the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and there is no other legal ground for the processing
  • you have objected to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR
  • the personal data have been unlawfully processed
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject
  • the personal data have been collected in relation to the offer of information society services referred to in art. 8 (1) GDPR

Pursuant to art. 17(3) GDPR, the right does not exist insofar as the processing is necessary for the exercise of the right to freedom of expression and information. Moreover, it does not exist if it has been collected on the basis of a legal obligation, or if the data serve the assertion, exercise or defence of legal claims.

9.4 Right to limitation of processing

According to art. 18(1) GDPR you have the right in individual cases to demand the restriction of the processing of your personal data.

This is the case if

  • the accuracy of the personal data is disputed
  • the processing is unlawful
  • the data are no longer required for the processing purpose but are used for the assertion, exercise or defence of legal claims
  • an objection has been filed against the processing pursuant to art. 21(1) GDPR and it is still unclear which interests predominate.
9.5 Right to withdraw consent

If you have given us express permission to process your personal data (art. 6(1) a GDPR or art. 9(2)(a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.

9.6 Right to object to data processing

Pursuant to art. 21 GDPR, you may at any time object to the processing of your personal data if such processing is carried out on the basis of art. 6(1)(f) GDPR e.g. where the processing is carried out on the basis of the legitimate interests.

9.7 How can I obtain my rights?

You can obtain your rights, if you inform us:

NFM ALLOYZ S.A.
19-21, route d’Arlon
L-8009 Strassen
Luxembourg

E-Mail: info@nfm.lu
Fax: +352 44 75 47

10. Data Portability

You have the right to receive the personal data that you have transmitted to us in a structured, common and machine-readable format and transfer it to another data controller provided that:

  • the processing is based on consent pursuant to art. 6(1)(a) GDPR or a contract pursuant art. 6(1)(b) GDPR ; and
  • the processing is carried out by automated means.

You can also request your personal data to be directly transferred to another controller, insofar as this is technically feasible. The exercise of this right shall not adversely affect the rights and freedoms of others.

11. Right to lodge a complaint to the CNPD or any other competent supervisory authority

If you suspect that your data is being illegally processed on our site, you can take legal actions in order bring the problem to a judicial clarification. This option does not interfere with any other legal option you might have.

Regardless of this, you have the option of contacting the CNPD or any other competent supervisory authority. You have the right to lodge a complaint to the competent supervisory authority in the EU Member State of your place of residence, workplace and/or place of alleged infringement, i.e. you can choose the supervisory authority to which you will be lodging a complaint in the above places. The supervisory authority to which the complaint was submitted will then inform you of the status and results of your complaint, including the possibility of a judicial remedy under art. 78 GDPR.

Drafted by:
© IT-Recht-Kanzlei DURY – www.dury.de