Important note on the privacy policy

In the following, we inform you in accordance with the statutory provisions of data protection law (in particular the new Federal Data Protection Act and the European General Data Protection Regulation (GDPR)) about the type, scope and purpose of the processing of personal data by our company. This data protection declaration also applies to our websites and social media profiles. For the definition of terms such as “personal data” or “processing”, please refer to Art. 4 GDPR.


Name and contact details of the person responsible.
Our person responsible (hereinafter “person responsible”) within the meaning of Art. 4 No. 7 GDPR is:

Tromag UG (limited liability)
Bismarckstr. 5
50672 Cologne
Managing Director: S. Langhammer
Email address: sl@tromag.de


Types of data, purposes of processing and categories of persons affected.

Below we will inform you about the type, scope and purpose of the collection, processing and use of personal data.

1. Types of data we process
Usage data (access times, websites visited, etc.), inventory data (name, address, etc.), contact data (telephone number, e-mail, fax, etc.), contract data (subject of the contract, term, etc.), communication data (IP address, etc.).

2. Purposes of processing in accordance with Art. 13 Para. 1 c) GDPR
Processing of contracts, technically and economically optimizing the website, enabling easy access to the website, fulfilling contractual obligations, fulfilling statutory retention periods, optimizing and statistically evaluating our services, improving user experience, making the website user-friendly, marketing / sales / advertising, avoiding SPAM and misuse, processing an application process, customer service and customer care, processing contact requests, providing websites with functions and content.

3. Categories of data subjects in accordance with Art. 13 Para. 1 e) GDPR
Visitors / users of the website, customers, suppliers, interested parties, applicants.
The data subjects are collectively referred to as “users”.




Legal basis for the processing of personal data.

Below we inform you about the legal basis for the processing of personal data:

1. If we have obtained your consent to process personal data, Art. 6 Paragraph 1 Clause 1 Letter a) of GDPR is the legal basis.

2. If processing is necessary to fulfill a contract or to carry out pre-contractual measures that are carried out at your request, Art. 6 Paragraph 1 Clause 1 Letter b) of GDPR is the legal basis.

3. If processing is necessary to fulfill a legal obligation to which we are subject (e.g. statutory retention periods), Art. 6 (1) S. 1 lit. c) GDPR is the legal basis.

4. If processing is necessary to protect the vital interests of the data subject or another natural person, Art. 6 (1) S. 1 lit. d) GDPR is the legal basis.

5. If processing is necessary to protect our legitimate interests or the legitimate interests of a third party and your interests or fundamental rights and freedoms do not outweigh them, Art. 6 (1) S. 1 lit. f) GDPR is the legal basis.




Transfer of personal data to third parties and processors.

We do not pass on any data to third parties without your consent. Should this be the case, then the data will be passed on on the basis of the legal bases mentioned above, e.g. when data is passed on to online payment providers for contract fulfillment or due to a court order or due to a legal obligation to release the data for the purposes of criminal prosecution, to avert danger or to enforce intellectual property rights.
We also use processors (external service providers, e.g. for web hosting of our websites and databases) to process your data. If data is passed on to the processors as part of an agreement for order processing, this is always done in accordance with Art. 28 GDPR. We select our processors carefully, monitor them regularly and have been granted the right to give instructions with regard to the data. In addition, the processors must have taken suitable technical and organizational measures and comply with the data protection regulations in accordance with the BDSG nF and GDPR. Data transfer to third countries The adoption of the European General Data Protection Regulation (GDPR) created a uniform basis for data protection in Europe. Your data will therefore be processed primarily by companies to which the GDPR applies. Should the processing take place through third-party services outside the European Union or the European Economic Area, these must meet the special requirements of Art. 44 ff. GDPR. This means that the processing is carried out on the basis of special guarantees, such as the officially recognized determination by the EU Commission of a level of data protection equivalent to that of the EU or compliance with official recognized special contractual obligations, the so-called “standard contractual clauses”.
Insofar as we obtain your express consent to the transfer of data to the USA due to the ineffectiveness of the so-called “Privacy Shield”, in accordance with Art. 49 Paragraph 1 Clause 1 Letter a) of GDPR, we point out the risk of secret access by US authorities and the use of the data for surveillance purposes, possibly without legal remedies for EU citizens.




Deletion of data and storage period.

Unless expressly stated in this data protection declaration, your personal data will be deleted or blocked as soon as you revoke the consent given for processing or the purpose for storage no longer applies or the data is no longer required for the purpose, unless their further storage is necessary for evidentiary purposes or this is contrary to statutory retention periods. These include, for example, commercial retention obligations for business letters according to Section 257 Para. 1 HGB (6 years) and tax retention obligations for documents according to Section 147 Para. 1 AO (10 years). When the prescribed retention period expires, your data will be blocked or deleted unless storage is still required to conclude or fulfill a contract.




Existence of automated decision-making

We do not use automated decision-making or profiling.




Provision of our website and creation of log files

1, If you only use our website for information purposes (i.e. no registration or other transmission of information), we only collect the personal data that your browser transmits to our server. If you would like to view our website, we collect the following data:
– IP address;
– User’s Internet service provider;
– Date and time of retrieval;
– Browser type;
– Language and browser version;
– Content of the retrieval;
– Time zone;
– Access status/HTTP status code;
– Volume of data;
– Websites from which the request comes;
– Operating system.
This data is not stored together with other personal data about you

2. This data serves the purpose of delivering our website to you in a user-friendly, functional and secure manner with functions and content as well as their optimization and statistical evaluation.

3. The legal basis for this is our legitimate interest in data processing in accordance with Art. 6 Paragraph 1 Clause 1 Letter f) of GDPR, which also lies in the above purposes.

4. For security reasons, we store this data in server log files for a storage period of days. After this period, the data is automatically deleted, unless we need to keep it for evidential purposes in the event of attacks on the server infrastructure or other violations of the law.




Google Adsense

1. We have integrated advertisements from the Google service “Adsense” (service provider: Google Ireland Limited, registration number: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) on our website. The advertisements are marked with the (i) note “Google Ads” in each ad.

2. Data categories and description of data processing: Usage data / communication data;
When you visit our website, Google receives the information that you have accessed our website. To do this, Google places a web beacon or cookie on your computer. The data is also transferred to the USA and analyzed there. If you are logged in with a Google account, Adsense can assign the data to your account. If you do not want this, you must log out before visiting our website. But Google can also use other information for this purpose:
– the type of websites you visit and the mobile apps installed on your device;
– cookies in your browser and settings in your Google account;
– websites and apps you have visited;
– your activities on other devices;
– previous interactions with Google ads or advertising services;
– your Google account activities and information.
When you click on an Adsense ad, the user’s IP is processed by Google (usage data), whereby the processing is pseudonymized (so-called “advertising ID”) by shortening the IP by the last two digits. For personalized advertising, Google does not link identifiers from cookies or similar technologies with special categories of personal data according to Art. 9 GDPR, such as ethnic origin, religion, sexual orientation or health.

3. Purpose of processing:
We have activated personalized ads to show you more interesting advertising that supports the commercial use of our website, increases the value for us and improves the user experience for you. With the help of personalized advertising we can reach users via Adsense based on their interests and demographic characteristics (e.g. “sports enthusiasts”). In addition, the processing is used for tracking, remarketing and conversion measurement as well as to finance our website.

4. Legal basis:
If you have given your consent for the processing of your personal data using “Google Adsense with personalized ads” (“opt-in”), then Art. 6 Para. 1 S. 1 lit. a) GDPR is the legal basis. Otherwise, the legal basis for the processing of your data is Art. 6 Para. 1 S. 1 lit. f) GDPR due to our legitimate interests in the analysis, optimization and efficient economic operation of our advertising and website.

5. Data transfer/recipient category:
Google Ireland, USA; This website has also activated Google AdSense ads from third parties. The aforementioned data may also be transferred to these third-party providers “Certified External Vendors” named at https://support.google.com/dfp_sb/answer/94149.

6. Storage period:
The data is stored for up to 24 months after the last visit.

7. Objection and removal options (“opt-out”):
You can object to or prevent the installation of cookies by Google Adsense in various ways:
– You can block cookies in your browser by setting “do not accept cookies” , which also includes cookies from third-party providers;
– You can deactivate personal ads on Google directly via Google using the link https://adssettings.google.com , although this setting only remains until you delete your cookies. You can find instructions on how to deactivate personalized advertising on mobile devices here: https://support.google.com/adsense/troubleshooter/1631343;
– You can deactivate the personalized ads of third-party providers who participate in the advertising self-regulation initiative “About Ads” via the link https://optout.aboutads.info for US sites or for EU sites at http://www.youronlinechoices.com/de/praferenzmanagement/ , whereby this setting only remains in effect until you delete all your cookies;
– You can permanently deactivate cookies using a browser plug-in for Chrome, Firefox or Internet Explorer at the link https://support.google.com/ads/answer/7395996. This deactivation may mean that you can no longer fully use all the functions of our website.

8. In the privacy policy for advertising by Google at https://policies.google.com/technologies/ads you can find further information about the use of Google cookies in ads and their advertising technologies, storage duration, anonymization, location data, functionality and your rights.




Google AdWords with Conversion Tracking

1. We use the “Google Ads with Conversion Tracking” service (service provider: Google Ireland Limited, registration number: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) to draw attention to our website on third-party websites by means of advertisements.

2. Data categories and description of data processing: Usage data / communication data.
When you click on one of our Google ads, a cookie is stored in your browser which is valid for around 30 days. When you then visit our website, we and Google can use the cookie to evaluate whether you have visited our website and which page you visited on our website. Google creates statistics about this. The data is also transferred to the USA and analyzed there. If you are logged in with a Google account, AdWords can assign the data to your account. If you do not want this, you must log out before visiting our website.

3. Purpose of data processing:
This conversion tracking serves the purpose of analysis/success measurement, optimization and the economic operation of our advertising and website.

4. Legal basis:
If you have given your consent (“opt-in”) for the processing of your personal data using “Google Ads with Conversion Tracking”, then Art. 6 Para. 1 S. 1 lit. a) GDPR is the legal basis. Otherwise, the legal basis for the processing of your data is our legitimate interest in the analysis, optimization and efficient economic operation of our advertising and website in accordance with Art. 6 Para. 1 S. 1 lit. f) GDPR.

5. Data transfer/recipient category:
Google Ireland.

6. Storage period:
up to 540 days.

7. Opt-out and removal options:
You can object to or prevent the installation of cookies by Google in various ways:
– You can prevent cookies in your browser by setting “do not accept cookies”, which also includes cookies from third parties;
– You can deactivate conversiontracking directly on Google via the link https://adssettings.google.com, although this setting will only remain in place until you delete your cookies
– You can prevent the personalized ads of third parties who are involved in the You can participate in the advertising self-regulation initiative “About Ads” via the link https://optout.aboutads.info for US sites or for EU sites at http://www.youronlinechoices.com/de/praferenzmanagement/ , although this setting only remains in place until you delete all your cookies;
– You can permanently deactivate cookies using a browser plug-in for Chrome, Firefox or Internet Explorer at the link https://support.google.com/ads/answer/7395996. This deactivation may mean that you can no longer fully use all functions of our website.

8. For more information, see Google’s privacy policy at https://policies.google.com/privacy?hl=de&gl=de and https://services.google.com/sitestats/de.html.




Google AdWords Remarketing / “Similar Target Groups”

1. We use the Google Analytics Remarketing / “Similar Target Groups” application (service provider: Google Ireland Limited, registration number: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) to draw attention to our website by means of advertisements on third-party websites and other Internet offerings.

2. Data categories and description of data processing: Usage data / communication data:
With the remarketing or “Similar Target Groups” function in Ads, we can reach you there if you have already visited our website and address you with a suitable message via an ad. With remarketing, we can bring our previous visitors back to our website with a click. If you then visit other websites or Internet offerings, we and Google can use the cookie to evaluate whether you have already visited our website and whether you see our advertising there too. Google creates statistics about this. We do not know the full extent of the data processing. The data is also transferred to the USA and analyzed there. According to Google, the data collected through remarketing is not merged with your personal data stored by Google, but is processed using a pseudonym.

3. Purpose of processing:
This remarketing serves the purpose of analyzing, optimizing and economically operating our advertising and website.

4. Legal basis:
If you have given your consent to the processing of your personal data using “Google Ads Remarketing / “Similar Target Groups” (“opt-in”), then Art. 6 Para. 1 Clause 1 Letter a) of GDPR is the legal basis. The legal basis for the processing of your data is otherwise our legitimate interest in the analysis, optimization and efficient economic operation of our advertising and website in accordance with Art. 6 Paragraph 1 Clause 1 Letter f) GDPR.

5. Data transfer/recipient category:
Google Ireland.

6. Storage period:
When you visit certain of our pages, a cookie is stored in your browser which is valid for 30 days.

7. Objection and removal options (“opt-out”):
You can object to or prevent the installation of cookies by Google in various ways:
– You can prevent cookies in your browser by setting “do not accept cookies”, which also includes third-party cookies;
– You can deactivate personalized ads directly from Google using the link https://adssettings.google.com, although this setting only remains in place until you
delete your cookies.
– You can deactivate the personalized ads of third-party providers that participate in the advertising self-regulation initiative “About Ads” via the link https://optout.aboutads.info for US sites or for EU sites at http://www.youronlinechoices.com/de/praferenzmanagement/ , although this setting only remains in place until you delete all your cookies;
– You can permanently deactivate cookies using a browser plug-in for Chrome, Firefox or Internet Explorer at the link https://support.google.com/ads/answer/7395996. This deactivation may mean that you can no longer fully use all of the functions of our website.

8. Further information can be found in Google’s privacy policy at https://policies.google.com/privacy?hl=de&gl=de.




Data protection for applications and in the application process

1. Applications that are sent electronically or by post to the person responsible are processed electronically or manually for the purpose of handling the application process.

2. We expressly point out that application documents containing “special categories of personal data” according to Art. 9 GDPR (e.g. a photo that allows conclusions to be drawn about your ethnic origin, religion or marital status), with the exception of a possible severe disability that you wish to disclose of your own free will, are undesirable. You should submit your application without this data. This will not affect your chances of being accepted.

3. The legal basis for processing is Art. 6 Para. 1 Clause 1 Letter b) GDPR and Section 26 BDSG n.F.

4. If an employment relationship is entered into with the applicant after completion of the application process, the applicant data will be stored in compliance with relevant data protection regulations. If you are not offered a position after completion of the application process, your submitted application letter and documents will be deleted 6 months after the rejection is sent in order to be able to meet any claims and proof obligations under the AGG




Rights of the data subject

1. Objection to or revocation of the processing of your data.
If the processing is based on your consent in accordance with Art. 6 Para. 1 S. 1 lit. a), Art. 7 GDPR, you have the right to revoke your consent at any time. This does not affect the legality of the processing carried out on the basis of the consent until the revocation. If we base the processing of your personal data on the balancing of interests in accordance with Art. 6 Para. 1 S. 1 lit. f) GDPR, you can object to the processing. This is the case if, in particular, the processing is not necessary to fulfill a contract with you, which we will explain in the following description of the functions. If you exercise such an objection, we ask you to explain the reasons why we should not process your personal data as we do. In the event of your justified objection, we will examine the situation and will either stop or adapt the data processing or show you our compelling legitimate reasons on the basis of which we continue processing. You can object to the processing of your personal data for advertising and data analysis purposes at any time. You can exercise your right of objection free of charge. You can inform us of your objection to advertising using the following contact details : Tromag Bismarckstr. 5 50672 Cologne Managing Director S. Langhammer E-mail address: sl@tromag.de

2. Right to information.
You have the right to request confirmation from us as to whether personal data concerning you is being processed. If this is the case, you have a right to information about your personal data stored by us in accordance with Art. 15 GDPR. This includes in particular information about the purposes of processing, the category of personal data, the categories of recipients to whom your data was disclosed or will be processed, the planned storage period, the origin of your data, unless it was collected directly from you.

3. Right to rectification
You have the right to have incorrect data rectified or correct data completed in accordance with Art. 16 GDPR.

4. Right to erasure
You have the right to have your data stored by us erased in accordance with Art. 17 GDPR, unless statutory or contractual retention periods or other legal obligations or rights to further storage conflict with this.

5. Right to restriction
You have the right to request that the processing of your personal data be restricted if one of the requirements in Art. 18 Para. 1 lit. a) to d) GDPR is met:
– If you contest the accuracy of the personal data concerning you for a period that enables the controller to verify the accuracy of the personal data;
– the processing is unlawful and you refuse to erase the personal data and instead request that the use of the personal data be restricted;
– the controller no longer needs the personal data for the purposes of processing , but you need it to assert, exercise or defend legal claims , or
– if you have objected to processing pursuant to Art. 21 Para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.

6. Right to data portability.
You have a right to data portability pursuant to Art. 20 GDPR, which means that you can receive the personal data we have stored about you in a structured, common and machine-readable format or you can request that it be transmitted to another controller.
7. Right to complain.
You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority, in particular in the member state of your residence, place of work or place of the alleged infringement. Data security In order to protect all personal data that is sent to us and to ensure that we and our external service providers adhere to data protection regulations, we have taken appropriate technical and organizational security measures. This is why, among other things, all data between your browser and our server is transmitted via a secure SSL connection and is transmitted encrypted.

A clear and transparent privacy policy is important to gain the trust of your website visitors and build a reputation as a responsible and trustworthy company. Be clear about what information you collect, how you use it, who you share it with, and how you protect it. This will help protect you from legal issues and ensure your website visitors are aware of their rights and how their personal data will be used.