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Data Protection Notice

It is very important to voestalpine Wire Rod Austria GmbH, Drahtstraße 1, 8792 St. Peter-Freienstein (hereinafter “we,” “us,” or “our”) to protect your personal data. We comply with the legal requirements applicable to the protection, lawful handling, and confidential treatment of data as well as with those pertaining to data security, specifically the European General Data Protection Regulation (“GDPR”) and pertinent national data privacy rules and regulations.

This Data Protection Notice informs you of the type, scope, and purposes of the collection and use by us of your personal data when you visit and use our website www.voestalpine.com/wiretechnology/en/ and our social media accounts (Instagram, YouTube und LinkedIn), when you contact us, when you use our online shop, and when you subscribe to our newsletter.

Here you will find separate Data Protection Notices applicable to separate issues:

1. Who is responsible for data processing and whom can you contact?

Controller:

voestalpine Wire Rod Austria GmbH

Drahtstraße 1,

8792 St. Peter-Freienstein

Email address: wire@voestalpine.com

Email address of the data protection officer (DPO) or data protection manager (DPM): group-dataprotection@voestalpine.com

2. What is personal data?

The term “personal data” refers to information concerning an identified or identifiable natural person ( “data subject”). For example, this includes the person’s name, email address, or IP address.

3. Processing of data when you use our website

Your data is processed for the following purposes:

3.1 Availability and protection of the website

Purpose: You may visit our website without disclosing your particulars. When you use our website, your end device sends data to our web server. This data is processed by our web servers and automatically stored in so-called “log files.” The processing of your data is necessary in order for us to make our website available to you. We must store the data in log files so that we can ensure the security and functionality of our website.

Categories of data: Network protocol and identification data (IP address, HTTP header fields, browser type, previously visited website (so-called “referrer”), date and time of access, other web traffic data, such as information on the device used, the volume of data sent, etc.)

Legal basis: It is in our legitimate business interest to make a secure, functional, and user-friendly website available. That is why we process data in accordance with Art. 6 (1) (f) of the General Data Protection Regulation (GDPR).

Retention period: The aforementioned data will be stored and deleted after expiry of the statutory retention period, unless the data is still needed for investigating a security-related event (e.g., a cyber attack) on our website after it has occurred.

Categories of recipients: Processors (IT service providers); in case of a security-related event, possibly also: law enforcement agencies, attorneys, courts, and administrative agencies.

3.2 Use of cookies, Google Tools and other social plugins

Please see the cookie banner for information on the data protection provisions that apply to the use of cookies and Google Analytics. Among other things, this information explains the type, scope, purposes, data categories, legal basis, retention periods, and categories of recipients of or related to the cookies used.

3.2.1 Cookies

Our website uses cookies that allow the website to recognize your browser when you visit the website again. Cookies are small text files that the browser stores on your device. This allows the website to be optimally adapted to your interests. If you do not want cookies to be stored on your computer, you can set up your browser to inform you when cookies are set so that you can decide whether to allow them on a case-by-case basis. You can also deactivate use of cookies in your browser. Please note that in this case, you may not be able to use all of the website functions to their full extent.

When visiting our website for the first time, visitors can decide whether to accept all cookies or to assign individual settings for each cookie. You can also alter these settings at a later date here.

In addition, you can switch web-tracking on and off at http://www.youronlinechoices.eu for the providers listed there.

3.2.2  Google Analytics

We use the functions of the web analysis service Google Analytics on our website in order to analyze user behavior and optimize our Internet presence. The provider of this service is Google Ireland Limited, Barrow Street, Dublin 4, Ireland.

Purpose: In using Google Analytics, we are able to analyze information about website visitors in a simplified way. This enables us to further optimize our website.

Data categories: During your visit to the website, among others, the following data are collected: The pages you access, your “click path”, the achievement of the “website goals” (conversions, such as newsletter registrations, downloads, purchases), your user behavior (such as clicks, length of stay, bounce rates), your approximate location (region), your IP address (in shortened form), technical information about your browser and the devices you use (such as language settings, screen resolution), your Internet provider, the referrer URL (from which website/advertising medium you came to our website), app updates, JavaScript support, widget interactions as well as the date and time of your visit.

Legal basis: The processing of your data with the use of Google Analytics is based on your express consent in terms of point (a) of Art. 6 (1) GDPR. You can withdraw your consent at any time, with effect for the future.

Storage period: The data on your use of our website will be erased immediately after the end of the storage period set by us. Google Analytics issues us with the following options for the retention period: 14 months, 26 months, 38 months, 50 months, do not erase automatically. You can ask us about the current storage period we have set at any time.

Categories of recipient: On our behalf, Google will use information to evaluate the use of our website, to compile reports on the activities on our website and in order to provide us with further services connected to the use of our website. The information generated is transferred by Google to a server in the USA for analysis and stored there. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by public authorities in the US to the data stored by Google cannot be ruled out. Google LLC, which is based in the USA, however, is certified for the US-European data protection agreement, the “EU-U.S. Data Privacy Framework”, which guarantees compliance with the level of data protection that applies in the EU. Google only transfers such data to third parties on the basis of statutory provisions or within the scope of contracted data processing. We have no influence on the scope or further use of the data collected by Google through the use of this tool.

3.2.3 Google Maps

We use the Google Maps service of the company Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland on our website. The use of Google Maps is subject to special terms of use, which you can find here: https://policies.google.com/terms?hl=de&gl=en and https://www.google.com/intl/de_de/help/terms_maps.html

Purpose: The integration of map material from Google Maps is used for the professional presentation of the contents of our website. We use this service to offer the localization of objects.

Data categories: For the processing itself, the service, and/or we, shall collect the following data:
Data required for the visualization and display of location data in the form of a map, in particular IP address, information from Google background services such as Google Apis, search terms, IP address, coordinates, the start location and destination when using the route planner, location data, Google advertising ID, Android advertising ID.

Legal basis: The collection, storage and evaluation take place in accordance with point (f) of Art. 6 (1) GDPR on the basis of the legitimate interest of Google in the display of personalized advertising, market research and/or the needs-based design of Google websites. You have the right to object to the creation of these user profiles; you must contact Google to exercise this right. If you do not agree to the future transfer of your data to Google when using Google Maps, you also have the option to completely deactivate the Google Maps web service by switching off the JavaScript application in your browser. In this case, Google Maps and therefore the map display cannot be used on this website.

Storage period: Google anonymizes data in server logs by erasing part of the IP address and cookie information after 9 and/or 18 months respectively. Depending on your decision, your location and activity data will be stored for either 3 or 18 months and then erased. You can also erase the history manually at any time in your Google account. If you want to completely prevent your location from being recorded, you must deactivate the “Web and App Activity” section in your Google account. Further information is available in the data protection information of Google, which you can access here: https://www.google.com/policies/privacy/

You can find out exactly where the Google data centers are located here: https://www.google.com/about/datacenters/inside/locations/. The data processing conditions for Google products and the standard contractual clauses for the data transfer to third countries are available at https://business.safety.google/adsprocessorterms/.

Categories of recipient: The information generated is transferred by Google to a server in the USA for analysis and stored there. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by public authorities in the US to the data stored by Google cannot be ruled out. Google LLC, which is based in the USA, however, is certified for the US-European data protection agreement, the “EU-U.S. Data Privacy Framework”, which guarantees compliance with the level of data protection that applies in the EU. Google only transfers such data to third parties on the basis of statutory provisions or within the scope of contracted data processing. We have no influence on the scope or further use of the data collected by Google through the use of this tool.

Data recipients:

Google Ireland Limited

Google LLC (United States of America)

Alphabet Inc (United States of America)

3.2.4 Google Tag Manager

Our website uses the Google Tag Manager service from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Purpose: Tag Manager is a service with which we can manage website tags through an interface. This allows us to integrate code snippets such as tracking codes or conversion pixels on websites without interfering with the source code.

Data categories: Google Tag Manager itself does not create any user profiles, does not store any cookies and does not carry out any independent analyzes. It is only used to manage and display the tools that integrated through its use. Google Tag Manager records your IP address, however, which may also be transferred to the parent company of Google in the United States.

Legal basis: The use of Google Tag Manager takes place on the basis of point (f) of Article 6 (1) GDPR. We have a legitimate interest in the fast and uncomplicated integration and management of various tools on its website.

Storage period: Apart from your IP address, no data is collected. To ascertain how long the individual tracking tools store your data, please refer to the respective data protection texts for the individual tools.

Categories of recipient: As no data is collected by Google Tag Manager, the various web analysis tools are considered as primary categories of recipient.

A transfer of data to the USA and access by public authorities in the US to the data stored by Google cannot be ruled out, however. Google LLC, which is based in the USA, however, is certified for the US-European data protection agreement, the “EU-U.S. Data Privacy Framework”, which guarantees compliance with the level of data protection that applies in the EU. Google only transfers such data to third parties on the basis of statutory provisions or within the scope of contracted data processing. We have no influence on the scope or further use of the data collected by Google through the use of this tool.

3.2.5 JWPlayer

Our website uses the “JWPlayer” service. JWPlayer is a video player with which we are able to display videos. (Operator: Longtail Ad Solutions, 8 West 38th Street, 6th Floor, NY 10018 New York, USA). When you visit a page on our website on which a JWPlayer video is embedded, a connection is automatically established between your browser and the JWPlayer servers and the embedded video is displayed on the website through a message to your browser.

Purpose: Your (temporarily) stored data is used to deliver the video to you, to place advertisements, to suggest videos to you and to create reports about the video activities on our website. The stored information also helps to increase the quality of the recommended videos and to carry out further analyzes in order to recognize user trends and technical problems and to maintain and improve the service.

Data categories: When using the JWPlayer (such as when clicking the start button or other interactions with the JWPlayer plugins), data, especially statistical usage data, is transferred to JWPlayer. This includes your IP address, local ID, global ID, viewer ID, device type, browser type and version, times of use and duration of use.

Legal basis: The legal basis is your consent in accordance with point (a) of Art. 6 (1) GDPR.

Storage period: The length of time for which JWPlayer stores your data is not definitively and clearly stated and is not known to us. However, your data will be erased as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. In the case of the storage of the data in log files, this is the case after 30 days. No further storage takes place. In this case, your IP address will be erased. The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website.

Categories of recipient: JWPlayer initializes the Google Analytics tracker via an iFrame in which the video is accessed. This is the tracking system of JWPlayer, to which we have no access. You can prevent the tracking by Google Analytics by using the deactivation tools that Google offers for some Internet browsers. You can prevent any data created by Google Analytics and relating to website usage on your part (including your IP address) from being transferred to and processed by Google by downloading and installing the browser plug-in available at the link below:
http://tools.google.com/dlpage/gaoptout?hl=de.

Google LLC, which is based in the USA, however, is certified for the US-European data protection agreement, the “EU-U.S. Data Privacy Framework”, which guarantees compliance with the level of data protection that applies in the EU. Google only transfers such data to third parties on the basis of statutory provisions or within the scope of contracted data processing. We have no influence on the scope or further use of the data collected by Google through the use of this tool.

We are also unable to rule out the possibility of JWPlayer transferring the information collected to the operator Longtail Ad Solutions in the USA. Longtail Ad Solutions is not yet certified according to the “EU-U.S. Data Privacy Framework” at the present time (October 2023). To ensure an adequate level of data protection, we have concluded standard data protection clauses with Longtail Ad Solutions in accordance with point (c) of Art. 46 (2) GDPR. For further information regarding the handling of user data, please see the privacy policy of JWPlayer: https://jwplayer.com/legal/privacy/.

Data recipients:

Google Analytics

Longtail Ad Solutions

3.2.6  YouTube

We use the YouTube service of the company Google Ireland Limited, Gordon House, Barrow Street, 4 Dublin, Ireland on our website.

Purpose: Videos from the YouTube platform are integrated on our website via the YouTube service. The integration allows us to show you videos directly on our website. In this way, you can view videos about our services without having to visit the YouTube platform.

Data categories: For the processing itself, the service, and/or we, shall collect the following data:
Data for displaying the stream, referrer URL, data on visited videos, created play lists, reviews and comments, information on the end device used as well as the date and time of the visit, the IP address and browser of the user and other data from Google services for providing the video in accordance with the Google Privacy Policy.

Legal basis: YouTube is used to ensure a uniform and appealing presentation of our website. This constitutes a legitimate interest in terms of point (f) of Art. 6 (1) GDPR. Consent that has been granted can be withdrawn at any time. The only consequence of not granting or withdrawing consent is that the YouTube content will not be made available.

Storage period: If you are logged in to your YouTube account, YouTube allows you to assign your browsing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account. We have no influence on the data collection and its further use. There is no information on the extent to which, where and for how long the data is stored, to which extent the networks comply with the existing erasure obligations, which evaluations and links are made with the data, and to whom the data is forwarded. Your data will remain stored for as long as this is necessary for the purpose of the service, however.

Categories of recipient: If YouTube is activated on our website and a video is played, our website establishes a connection to the company’s servers in the USA and transfers the data required to display the stream or the video. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by public authorities in the US to the data stored by Google cannot be ruled out. Google LLC, which is based in the USA, however, is certified for the US-European data protection agreement, the “EU-U.S. Data Privacy Framework”, which guarantees compliance with the level of data protection that applies in the EU. Google only transfers such data to third parties on the basis of statutory provisions or within the scope of contracted data processing. We have no influence on the scope or further use of the data collected by Google through the use of this tool.

Data recipients:

Google Ireland Limited

Google LLC (United States of America)

Alphabet Inc (United States of America)

3.2.7 Facebook Social Plugins

We have integrated plugins from the social network Facebook.com (company headquarters in the EU: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland) on our website as part of the “two-click solution” from Shariff. You can recognize these by the Facebook logo “f” or the addition “Like”, “Gefällt mir” or “Share”.

Purpose: The temporary storage of the data is necessary for the use of the plugin in order to ensure extensive visibility in social media.

Data categories: The standard social media buttons that are used to transfer user data such as the dynamic IP address, browser type and browser version to Facebook each time a page is accessed, and therefore provide information about the user behavior of the website visitor to these social networks. It is not necessary to be a member of the relevant network or to be logged in.

Legal basis: The use of the Facebook plugins takes place on the basis of point (f) of Article 6 (1) GDPR.

Storage period: The data collected directly by us via the social media profile will be erased from our systems as soon as you ask us to erase it, withdraw your consent to its storage, or the purpose for the data storage no longer applies. Stored cookies remain on your end device until you erase them. Mandatory statutory provisions—in particular retention periods—remain unaffected. We have no influence on the storage period of your data which is stored by the operators of the social networks for their own purposes. For details, please contact the operators of the social networks directly (as provided in their privacy policy, for example).

Categories of recipient: When you visit our websites, the plug-in establishes a direct connection between your browser and the Facebook server. In the event that the data you transfer to us is also or exclusively processed by Facebook, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland, is the controller which is responsible for the data processing within the meaning of the GDPR, either in addition to us or in our place. In this way, Facebook receives the information that you have visited our website with your IP address. If you click the Facebook “Like button” while you are logged into your Facebook account, you can link the contents of our websites to your Facebook profile. If you do this, Facebook will be able to assign the visit to our websites to your user account. Please note that we, the website provider, do not have access to the content of the data transferred or its use by Facebook. For more information, please refer to the privacy policy of Facebook at: https://de-de.facebook.com/privacy/explanation. If you do not want Facebook to be able to assign the visit to our websites to your Facebook user account, please log out of your Facebook user account. The parent company of Facebook, Meta Platforms Inc., is based in the USA. A transfer of data to the USA and access by public authorities in the US to the data stored by Meta cannot be ruled out. Meta Platforms Inc., which is based in the USA, is, however, certified for the US-European data protection agreement, the “EU-U.S. Data Privacy Framework”, which guarantees compliance with the level of data protection that applies in the EU.

3.2.8 AccessWidget

We use solutions from AccessiWay GmbH, located in Vienna, Austria, to produce a highly accessible website. To make our website technically accessible, purely technical data is transmitted to the AccessiBe Ltd, Israel (GDPR compliant by adequacy decision) server located in the USA (GDPR compliant by adequacy decision for the EU-U.S. Data Privacy Framework). This data is SSL3 encrypted and deleted immediately after the accessible, technical information has been retrieved. No data is stored. Only the IP address and user agent (web browser) are transmitted. See website. No cookies are set or stored; the data transfer is purely technical in nature and is used to produce an accessible website.

 

3.3 How to contact us

Purpose: You may contact us by email, telephone, or fax if you have any questions about our company, our products, and our services. If you do so, we will process your data for the purpose of processing your inquiry; as a result, your data may also be processed in one of our customer management systems.

Categories of data: Personal data (e.g., salutation, title, first and last name); contact information (e.g., address, telephone number, email address); correspondence data (e.g., content of the inquiry); network protocol and identification data (e.g., date and time of the inquiry); as well as all data you make available to us by uploading or attaching documents.

Legal basis: Inquiries are processed either by carrying out (pre-)contractual steps (Art. 6 (1) (b) GDPR) or pursuant to our legitimate business interest (Art. 6 (1) (f) GDPR), specifically, our interest in communicating with our customers and website users.

Retention period: We retain your data as long as necessary to process your inquiry. Once your inquiry has been completed, your data will be erased subject to statutory retention periods, unless holding the data is necessary to establish, fend off, or defend legal claims and to enforce them in governmental or court proceedings.

Categories of recipients: Processors (IT service providers). In order to fulfill the intended purposes, in some cases, we may also have to transfer your data to specific Group companies (www.voestalpine.com/locations) in order to ensure rapid processing of your inquiry.

 

3.4 Newsletter subscription

Purpose: You have the option of subscribing to our newsletter through our website. If you subscribe to our newsletter, we need to process your data in order to send you our newsletter. As a result, your data may be processed in one of our customer management systems.

Categories of data: Contact information (e.g., email address)

Legal basis: We process your data for the newsletter only if you give us your consent to do so (Art. 6 (1) (a) GDPR). You may revoke your consent at any time (e.g., via email to group-dataprotection@voestalpine.com or by clicking the unsubscribe link located in the footer of the newsletter that was sent to you).

Retention period: We retain your data for the purpose of sending you the newsletter as long as you do not revoke your consent to receive it.

Categories of recipients: Processors (IT service providers)

4. Data transfers to third countries

Given the complexity of prevailing data processing processes, we engage so-called processors to process your data. To the extent possible in this connection, we only engage processors that are domiciled within the European Union (EU) or the European Economic Area (EEA) and are thus subject to the GDPR.

There are scenarios, however, where we process data in third countries (i.e. outside the EU and/or the EEA) or where the processing takes place in connection with the use of service providers domiciled outside of the EU and/or the EEA. The level of data protection in some of these third countries may not correspond to EU standards. For example, the processing of personal data by law enforcement agencies may not be restricted to that which is absolutely necessary, and data subjects may only have limited rights of legal recourse.

We do, however, always ensure that European data protection and data security standards are maintained.

  • First of all, under certain circumstances, we may be able to transfer data to those third countries that the European Commission has certified, pursuant to an adequacy decision under Art. 45 GDPR, as possessing an adequate level of data protection.
  • If the European Commission has not adopted an adequacy decision regarding a specific third country, we only transfer data subject to appropriate safeguards pursuant to Art. 46 GDPR. In particular, we then apply the standard contractual data protection clauses approved by the European Commission or binding internal data protection regulations; we may also ensure by other means that an adequate level of data protection is put in place (e.g., recipient’s participation in an approved certification system)
  • In individual cases, the aforementioned appropriate guarantees pursuant to Art. 46 GDPR as well as the additional measures taken may not be effective enough, thus leaving gaps in legal protections. In cases like these, we process your data in accordance with the exemption under Art. 49 GDPR. Depending on the case at hand, therefore, and to legitimize data transfers we rely on a variety of factors, including (i) your express consent (Art. 49 (1) (a) GDPR); (ii) the need to fulfill the contract (Art. 49 (1) (b) GDPR); or (iii) the need to establish, exercise, or defend our legal claims (Art. 49 (1) (e) GDPR).

You may use the contact information provided to obtain further information as well as a copy of the implemented measures.

5. Rights of data subjects and option to file a complaint 

Article 15 GDPR gives you the right to request confirmation as to whether your data is processed by the controller and the right to access information regarding this data.

Article 16 GDPR gives you the right to request immediate rectification of inaccurate data concerning your person and/or completion of incomplete data.

Article 17 GDPR gives you the right to have your data erased.

Article 18 GDPR gives you the right to restrict the processing of your data.

Article 20 GDPR gives you the right to data portability.

Article 21 GDPR gives you the right to object to the processing of your data.

Finally, you also have the option of filing a complaint with the competent regulatory authority.

If your data is processed pursuant to your consent thereto, you have the right to withdraw your consent at any time; doing so, however, does not affect the legality of the processing carried out until you withdrew your consent.

 

6. Contact information
If you have any questions regarding issue of data protection and the assertion of your rights as enumerated in the foregoing, you may contact our data protection organization at group-dataprotection@voestalpine.com or by postal mail to voestalpine Wire Rod Austria GmbH, Drahtstraße 1, 8792 St. Peter-Freienstein. 

This data protection policy will be revised from time to time.