With this Data Protection Statement, we, Research Engineering and Manufacturing Inc. (REMINC), together with our sister company Conti Fasteners AG (CONTI), describe how we collect and further process Personal Data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements are applicable to specific circumstances.
The term “Personal Data” in this Data Protection Statement shall mean any information that identifies, or could reasonably be used to identify any person.
If you provide us with Personal Data of other persons (such as work colleagues, etc.), please make sure the respective persons are aware of this Data Protection Statement and that you only provide us with their data if you are allowed to do so and that such Personal Data is correct. We collect and process your Personal Data carefully and only for the purposes described in this Data Protection Statement, to the extent necessary for this purpose and within the scope of the applicable legal provisions. In cooperation with our hosting providers, we make every effort to protect our databases from unauthorized access, loss, misuse or falsification.
This Data Protection Statement is in line with the EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union («EU»), it may be relevant for us. The Swiss data protection legislation (FADP) is heavily influenced by the law of the European Union. In addition, companies outside of the European Union or the European Economic Area («EEA») must comply with the GDPR in certain cases.
1. Data Protection Controller
The controllers of data processing as described in this data protection statement are the following:
REMINC (North America)
Tim Egan, President
phone: +1 401-841-8880
Ed Hebert, Vice President of Innovation & Technology
phone: +1 401-841-8880
CONTI FASTENERS AG (outside of North America)
Matthias Jokisch, Director
phone: +41 (0) 41 761 58 22
You may notify us of any data protection related concerns via the mentioned contact details.
2. Collection and Processing of Personal Data
We primarily process Personal Data that we obtain from our clients and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users in order to operate our websites, apps and other applications.
Insofar as it is permitted to us, we obtain certain Personal Data from publicly accessible sources (e.g., commercial registers, internet, press) or we may receive such information from affiliated companies, from authorities or third parties. Apart from data you provided us directly with, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities, information about you in correspondence and discussions with third parties, credit rating information, information about you given to us by individuals associated with you (consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g. references, your delivery address, power of attorneys), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g. payments made, previous purchases), information about you found in the media or internet (insofar as indicated in the specific case, e.g. in connection with job applications, media reviews, marketing/sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP-address, MAC-address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).
3. Purpose of Data Processing and Legal Grounds
We primarily use collected data in order to conclude and process contracts with our clients and business partners, in particular in connection with the legitimate business interests of RENMINC and/or CONTI, and the procurement of products and services from our suppliers and subcontractors, as well as in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such a client or business partner.
In addition, in line with applicable law and where appropriate, we may process your Personal Data and Personal Data of third parties for the following purposes, which are in our or, as the case may be, any third parties’ legitimate interest, such as:
- maintaining our internal Customer Relationship Management (CRM) software for purposes of facilitating follow-up business communication with you;
- providing and developing our products, services and websites, apps and other platforms, on which we are active;
- communication with third parties and processing of the requests (e.g., job applications, media inquiries);
- review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining Personal Data from publicly accessible sources for customer acquisition;
- advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose; (note: if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);
- market and opinion research, media surveillance;
- asserting legal claims and defense in legal disputes and official proceedings;
- prevention and investigation of criminal offences and other misconduct (e.g., conducting internal investigations, data analysis to combat fraud);
- ensuring our operation, including our IT, our websites, apps and other appliances;
- video surveillance to protect our domiciliary rights and other measures to ensure the safety of our premises and facilities as well as protection of our employees and other individuals (e.g., access controls, visitor logs, network and e-mail scanners, telephone recordings);
- acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of Personal Data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of REMINC and/or CONTI.
If you have given us your consent to process your Personal Data for certain purposes (for example when registering to receive newsletters or carrying out a background check), we will process your Personal Data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.
4. Cookies / Tracking and Other Techniques Regarding the Use of our Website
We may use Google Analytics or similar services on our website. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google LLC is in the U.S., www.google.com) and which allow us to measure and evaluate the use of our website. For this purpose, permanent cookies are used, which are set by the services provider. The service provider does not receive and does not retain any Personal Data from us, but the service provider may track your use of the website, combine this information with data from other websites you have visited and which are also tracked by the respective service provider and may use this information for its own purposes. If you have registered to the service provider, the service provider will also know your identity. In this case, the processing of your Personal Data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website.
In addition, we may use plug-ins from social networks such as Facebook, Twitter, Youtube, Google+, Pinterest or Instagram on our websites. This is visible for you, typically based on the respective symbols. We have configurated these elements to be disabled by default. If you activate them (by clicking on them), the operators of the respective social networks may record that you are on our website and where on our website you are exactly and may use this information for their own purposes. This processing of your Personal Data lays in the responsibility of the respective operator and occurs according to its data protection regulations. We do not receive any information about you from the respective operator.
5. Data Transfer and Transfer of Data Abroad
In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or their own purposes. In particular, the following categories of recipients may be concerned:
- our service providers (e.g., banks, insurances) including processors (e.g., IT providers);
- dealers, suppliers, subcontractors and other business partners;
- domestic and foreign authorities or courts;
- the media;
- the public, including users of our websites and social media;
- competitors, industry organizations, associations, organizations and other bodies;
- acquirers of parties interested in the acquisition of business divisions, companies or other parts of REMINC and/or CONTI;
- other parties in possible or pending legal proceedings.
Certain recipients may be within Switzerland and the USA, but they may be also located in any country worldwide. In particular, you must anticipate your data to be transmitted to any country in which RENMINC and/or CONTI is represented by affiliates, branches or other offices as well as to other countries worldwide where our service providers are located.
6. Retention Periods for your Personal Data
We process and retain your Personal Data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e., for the duration of the entire business relationship as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes).
7. Data Security
We have taken appropriate technical and organizational security measures to protect your Personal Data from unauthorized access and misuse such as IT and network security solutions, access controls and restrictions. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information, that information is encrypted and transmitted to us in a secure way. Always verify this by looking for a lock icon in the URL/address bar and looking for “https” at the beginning of the address of the websites.
8. Obligation to Provide Personal Data To Us
In the context of our business relationship, you must provide us with any Personal Data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations. Without this information, we will usually not be able to enter into or carry out a contract with you or the entity or person you represent. In addition, the website cannot be used unless certain information is disclosed to enable data traffic (e.g., IP address).
9. Your Rights
In accordance with and as far as provided by applicable law, you have the right to access, rectification and erasure of your Personal Data, the right to restriction of processing or to object to our data processing in addition to the right to receive certain Personal Data for transfer to another controller. Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, having an overriding interest or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent in Section 3 above. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in consequences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.
In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents). In order to assert these rights, please contact us via the addresses provided in Section 1 above.
In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch).
10. Amendments of this Data Protection Statement
We may amend this Data Protection Statement at any time and without prior notice. The current version published on our website shall apply. If the Data Protection Statement is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.