All subsidiaries of

High Performance Plastics and Additives

Data privacy information

This data privacy information informs you about handling your personal data. To make the processing of your data comprehensible, we would like to provide you with the following information to give you an overview of these processing operations. In order to guarantee fair processing, this data protection declaration contains general information about our handling of your data as well as information about your rights according to the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG). 

We will inform you in detail about

  1. General Data Processing
  2. Data processing on our website
  3. Further data processing

The party responsible for data processing is ROWA Inc. / ROWA Group USA, LLC (hereinafter 'we' or 'us').

I. General Data Processing

1. Contact
If you have any questions or feedback concerning this information or wish to contact us to assert your rights, please send your enquiry to

ROWA Inc. / ROWA Group USA, LLC 
110 Phyllis Dr
Croydon, PA 19021
Pennsylvania/USA
Phone: +1-609-567-8600
salesnoSpam@noSpamrowainc.net 

Representative in the European Union:

ROWA GROUP Holding GmbH
Siemensstraße 1-9
25421 Pinneberg
GERMANY
Phone: +49-4101 706-06
Fax: +49-4101-706-201
infonoSpam@noSpamrowa-group.com

2. Legal basis
The data protection term "personal data" refers to all information relating to an identified or identifiable natural person.

We process personal data in compliance with the data protection regulations, primarily the GDPR and the BDSG. Our data processing solely occurs on a legal permission. We will process personal data solely with your consent (Art. 6 Sec. 1 letter a) GDPR), to perform a contract to which you are a party, or to take steps at your request prior to entering into a contract (Art. 6 Sec. 1 letter b) GDPR), for compliance with a legal obligation (Art. 6 Sec. 1 letter c) GDPR) or where processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data (Art. 6 Sec. 1 letter f) GDPR).

3. Period of storage
In the absence of alternative provision ensuing from the following statements, we will only store your data for as long as required to achieve the intended processing purpose or to fulfil our contractual or statutory obligations. Such statutory retention requirements may result from regulations under commercial or tax law.

4. Recipients of data
We may use Service Providers for individual processes. This includes, for example, hosting, maintenance and support of IT-systems, marketing actions or destruction of files and data carriers. These Service Providers process the data only according to strict instructions and are contractually bound to guarantee suitable technical and organisational measures for data protection. In addition, we may transfer personal data of our customers to parties such as postal and delivery services, payment and information services, banks, tax consultants/auditors or the tax authorities. 

5. Processing in the exercise of your rights pursuant to Art. 15 to 22 GDPR
If you exercise your rights pursuant to Art. 12 to 22 GDPR for the purpose of providing information and preparing such information, we will process stored data only for this purpose and for purposes of data protection control and otherwise restrict processing in accordance with Art. 18 GDPR. These processing operations are based on the legal basis of Art. 6 Sec. 1 letter c) GDPR in combination with Art. 15 to 22 GDPR and § 34 Sec. 2 BDSG.

6. Your rights
As the person concerned, you are entitled to exercise your rights against us. In particular, you have the following rights:

  • Pursuant to Art. 15 GDPR and § 34 BDSG, you have the right to request information confirming whether or not and, if so, to what extent we are processing personal data concerning you. 
  • Pursuant to Art. 16 GDPR, you have the right correct your data.
  • Pursuant to Art. 17 GDPR and § 35 BDSG, you have the right to delete personal data.
  • Pursuant to Art. 18 GDPR, you have the right to require that we restrict the processing of your personal data.
  • Pursuant to Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller.
  • Where you have granted us separate consent to process your data, you can withdraw such consent at any time pursuant to Art. 7 Sec. 3 GDPR. Any such withdrawal of consent shall not affect the lawfulness of processing based on that consent prior to its withdrawal.
  • If you consider that the processing of personal data relating to you infringes GDPR provisions, you have the right to lodge a complaint with a supervisory authority pursuant to Art.77 GDPR.

7. Right to object
Pursuant to Art. 21 Sec. 1 GDPR, you have the right to object to processing operations based on the legal basis of Art. 6 Sec. 1 letter e) or letter f) GDPR on grounds arising from your particular situation. If we process personal data about you for the purpose of direct marketing, you may object to such processing pursuant to Art. 21 Sec. 2 and Sec. 3 GDPR.

8. Data protection officer
You can contact our data protection officer using the following address:
datenschutznoSpam@noSpamrowa-group.com

II. Data processing on our website

When using our website, we collect and use information that you provide by yourself. We also automatically collect certain information about your use of the Site during your visit on the Site. In data protection law, the IP address is also considered as a personal date. An IP address is assigned to each device connected to the Internet by the Internet provider so that it can send and receive data.

1. Processing Server-Log-Files
When using our website for purely informative purposes, general information that your browser transmits to our server is initially stored automatically (not via registration). This includes by default: browser type/-version, operating system used, page called, the previously visited page (referrer URL), IP address, date and time of server request and HTTP status code. The processing is carried out to ensure our legitimate interests and is based on the legal basis of Art. 6 Sec. 1 letter f) GDPR. This processing provides the technical administration and security of the website. The stored data will be deleted after 14 days unless there is a justified suspicion of illegal use based on concrete indications and further examination and processing of the information is necessary for this reason. We are not able to identify you as a data subject based on the stored information. Art. 15 to 22 GDPR therefore do not apply pursuant to Art. 11 Sec. 2 GDPR, unless you provide additional information to enable your identification in order to exercise the rights set out in these articles.

2. Data transmission to the USA
Visiting our website may involve the transmission of certain personal data to the USA, as ROWA Inc. / ROWA Group USA, LLC is based in the USA. For the transfer of data to the USA as a non-member country, a country in which the GPDR is not applicable law, the European Commission has decided in accordance with Art. 45 GDPR that an adequate level of data protection is required for companies certified under the EU-US Privacy Shield. The transfer to the USA will then take place in a permissible manner. Certified companies are listed by the U.S. Department of Commerce at https://www.privacyshield.gov/list.

ROWA Inc. / ROWA Group USA, LLC is not certified under the Privacy Shield. An adequate level of data protection can therefore not be guaranteed.

3. Contact form and requests
Our website contains a contact form through which you can use to send us messages. The transfer of your data is encrypted (recognizable by the "https" in the address bar of the browser). All data fields marked as mandatory fields are required to process your request. Non-provision of this information means that we cannot process your request. The provision of further data is voluntary. Alternatively, you can also send us a message via the contact-e-mail. We process the data for the purpose of answering your request. The contact is associated with a transmission of your personal data in the USA, since we have our headquarters in the USA. An adequate level of data protection cannot be guaranteed. The transfer and processing of your data therefore takes place based on your consent according to Art. 6 Sec. 1 letter a) GDPR.

4. Cookies
We use cookies on our website. Cookies are small text files that are stored by your browser when you visit a website. This identifies the browser used and can be recognised by our web server. If the use of cookies results in the processing of personal data, this is based on the legal basis of Art. 6 Sec. 1 letter f) GDPR. This processing serves our legitimate interest in making our website more user-friendly, effective and secure. We used so-called "session cookies", which are deleted when the browser session is closed. You can delete the cookies in the security settings of your browser at any time. You can object to the use of cookies through your browser settings in principle or in certain cases. Further information can be obtained from the Federal Office for Information Security at https://www.bsi-fuer-buerger.de/BSIFB/DE/Empfehlungen/EinrichtungSoftware/EinrichtungBrowser/Sicherheitsmassnahmen/Cookies/cookies_node.html.

5. Integrated services and third-party content
We use services and content (collectively, "Content") provided on our Website by third parties. For such an integration a processing of your IP address is technically necessary, so that the contents can be sent to your browser. Your IP address will therefore be transmitted to the respective third party providers. This data processing is carried out in order to safeguard our legitimate interests in the optimisation and economic operation of our website and is based on the legal basis of Art. 6 Sec. 1 letter f) GDPR.  You can object to this data processing at any time via the settings of the browser used or certain browser extensions. One such extension is the uMatrix matrix-based firewall for the Firefox and Google Chrome browsers. Please note that this may result in functional restrictions on the website. 

We have incorporated into our website content from the following third-party services:

Services provided by Google Ireland Limited (Ireland/EU):

  • “Google Web Fonts” to display fonts.

When using Google services, we cannot exclude the possibility that the processed data may be transferred to Google LLC (USA), which is based in the USA. Google LLC is certified under the EU-US Privacy Shield.

III. Further data processing

1. Contractual relationship
In order to establish or execute the contractual relationship with our customers, it is regularly necessary to process the contact data of the relevant contact persons provided to us. The processing serves our legitimate interest in a fluent course of business. The legal basis for this processing is Art. 6 Sec. 1 letter f) GDPR. In addition, we process customer and potential customer data for evaluation and marketing purposes. This processing takes place on the legal basis of Art. 6 Sec. 1 letter f) GDPR and serves our interest in further developing our offer and informing you specifically about offers from ROWA Inc. / ROWA Group USA, LLC. Further data processing can take place if you have consented (Art. 6 Sec. 1 letter a) GDPR) or if this serves to fulfil a legal obligation (Art. 6 Sec. 1 letter c) GDPR).

2. Applications
When you apply for a position at our company, we process your application data exclusively for purposes related to your interest in current or future employment with us. Your application will only be processed and acknowledged by the responsible contact person. All employees entrusted with data processing are obliged to maintain the confidentiality of your data. If we are unable to offer you an employment, we will retain the data you provide for up to three months for the purpose of potentially answering questions relating to your application and rejection. This does not apply if legal provisions prevent deletion, if further storage is necessary for the purpose of presenting evidence or if you have expressly consented to longer storage. Legal basis for the data processing is § 26 Sec. 1 BDSG. If we keep your applicant data for a period of six months and you have expressly consented to this, we would like to point out that this consent can be freely revoked at any time in accordance with Art. 7 Sec. 3 GDPR. Such a revocation does not affect the legality of the processing, which has taken place until the revocation on the basis of the consent.

3. Offline Orders
If you order a product via our order form or by telephone, we process personal data exclusively for contract processing or to be able to provide you with the ordered product. Within the ordering process, we only process the data that you have provided yourself. In order to be able to deliver the ordered products to you, we transmit the data required for delivery to one of our shipping service providers as specified in the order. The legal basis for the processing is Art. 6 Sec. 1 letter b) GDPR. All data fields marked as mandatory fields are required for processing your order. Non-provision of this information means that we cannot process your order. The provision of further data is voluntary.

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