Data Protection

The symotion GmbH, (hereinafter “Symotion”), is pleased that you are visiting our website. Data protection and data security are very important to us. Therefore, we would like to inform you about the personal data we collect during your visit to our website and about the intended purposes.

As changes to the law or changes to our corporate processes may require an adaptation of this privacy statement, we ask you to read this privacy policy regularly. The privacy policy can be accessed any time under “Privacy Policy”, saved and printed out.

§ 1 Data Controller and Scope

The controller according to the EU General Data Protection Regulation (hereinafter: GDPR) and other national data protection acts of the Member States, as well as other data protection regulations, is:

Symotion GmbH
Mühlenfeldstraße 1
37603 Holzminden

Phone: +49 (0) 5531 90-0
Fax: +49 (0) 5531 90-1617

This privacy policy applies to the online presence of Symotion, which is available at (hereinafter referred to as “our website”).

§ 2 Data Protection Officer

The external Data Protection Officer of the data controller is:

Herr Rechtsanwalt Dr. Karsten Kinast, LL.M.
KINAST Rechtsanwaltsgesellschaft mbH
Hohenzollernring 54
D-50672 Cologne

Phone: +49 (0)221 – 222 183 – 0

§ 3 Principles of Processing Personal Data

Personal data are all information relating to an identified or identifiable natural person. This includes information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behavior. Information that cannot (or only with a disproportionate effort) be referred to your person, e.g. by anonymizing the information, is not personal data. The processing of personal data (e.g. the collection, retrieval, use, storage or transmission) always requires a legal basis or your consent.
Processed personal data will be deleted as soon as the purpose of the processing has been fulfilled and no legally prescribed retention obligations are to be observed.

In case we process your personal data for the provision of certain offers, please find below information about the specific processes, the scope and purpose of data processing, the legal basis for processing and the respective storage period.

§ 4 Data Processing

1. Access and Use of the Website

a. Scope and Purpose of the Processing

When you access and use our website, we only collect the personal data that your browser automatically transmits to our server. This information is temporarily stored in a so-called log file.
The following personal data is recorded to the extent necessary for the provision of a functional website and our contents and services:

b. Legal Basis

Article 6 (1) lit. f)GDPR serves as the legal basis for the data processing. The processing of the mentioned data is necessary for the provision of our services and thus serves the protection of a legitimate interest of our company.

c. Data Deletion and Storage Time

The data subject’s personal data are deleted or blocked as soon as the purpose of the storage is fulfilled. Data older than seven days is getting deleted. The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection for the user. Further storage may take place in individual cases if this is required by law.

2. Contact

a. Scope and Purpose of Processing

You have the opportunity to contact us. In the course of sending your inquiry via the contact form, reference is made to this data protection declaration in order to obtain your consent. If you write us an e-mail, the following personal data will be processed:

In addition, we process other (personal) data that you provide to us voluntarily by contacting, on which we have no influence.

By using our contact options, your personal data will not be forwarded to third parties.

b. Legal Basis

The data processing described above (cf. § 4 2. a.) for the purpose of establishing contact is carried out voluntarily in accordance with Article 6 (1) lit. a) GDPR on the declaration of consent submitted by you.

c. Storage Time  

As soon as the request you have made has been dealt with and the relevant facts have been finally clarified, your personal data processed by the contact form will be deleted. Further storage may take place in individual cases if this is required by law.

§ 5 Recipients of Personal Data and Data Transfers in-/ouside of the European Economic Area

1. When and why may we share your personal data

We will only share your personal data with third parties and other recipients where we have an appropriate legal ground under the GDPR, which permits us to do so. Commonly, this could include situations where we are legally obliged to provide the information (e.g. to data protection authorities), to comply with our contractual duties (e.g. to an affiliated company, if necessary in terms of our business relation.), where it is necessary in our legitimate interest (e.g. for compliance reasons), or where you have given your express consent to do so (e.g. to third-party Cookie providers).

We have also engaged certain service providers that process your data on our behalf and, therefore, are so-called data processors (e.g. our provider of the website and agencies that help us managing our content thereof). Such data processors are contractually obliged to solely process your personal data based on our contractual agreement and in line with our predefined instructions. As data processors our service providers are also recipients of your personal data.

2. Data Transfers in-/outside the European Economic Area

In general, the processing of your personal data is based inside the European Economic area (EEA). However, in terms of providing this website and its functionalities we may use certain service providers and/or third-party service provider (in the following recipients) that receive your personal data (see under 3.), which may not process your personal data inside, but in a country outside the EEA. The transfer to service providers outside the EEA takes place on the basis of the so-called adequacy decision by the EU Commission pursuant to Art. 45 GDPR or on the basis of the Standard Data Protection Clauses of the European Union as an appropriate safeguard according to Art. 46 GDPR to ensure an adequate level of data protection in regard of the processing of your personal data.

However, when sharing your personal data with a recipient that is established in a country outside the EEA based on Standard Data Protection Clauses, it may be that the processing is not appropriately safeguarded due to the specific national laws applying to the recipient in such a country. This includes sharing your personal data with and the transfer of your personal data to recipients in the USA. Such transfers of personal data may not be based on appropriate safeguards due to the fact that US authorities are allowed under US law to access and use such data transferred from the EU to the US without any specific exemptional reasons and means of a right to object to such illegitimate access for affected non-US American data subjects. Furthermore, these transfers are not regulated in such a way that would meet requirements equivalent to those existing under EU law specifically regarding the principle of proportionality as monitoring programs based on US legislation are not limited to what is strictly necessary.

Therefore, when we are aware that your personal data may be transferred to the US, e.g. to Google LLC or other recipients, we ensure to collect your express consent and inform you in this Privacy Policy about the corresponding risk that your data may not be appropriately safeguarded regarding illegitimate access or use, before such transfer takes place.

3. List of Recipients of your personal data

Recipient/Category of RecipientPurpose of transfer/disclosureLegal basis of the processingData transfer outside the EEA
Maxcluster GmbHHosting and support of our IT-systems and infrastructureLegitimate interestGermany
Die Medialen GmbHSupport on providing the website and the content thereofLegitimate interestGermany
Google Ireland LimitedAnalysis of website usage (Google Analytics)ConsentEU and US
Subsidiaries and affiliated companiesQuotes, Sales, Marketing, fraud protection, storage etc.– Contractual relation or pre-contractual steps
– Legitimate interest; or, if required,
– Consent
National and EU Authorities and Law Enforcement AgenciesOnly as an exemption, where no rights and freedoms of the affeted data subjects overweigh: Ensure compliance with laws or in exceptional situations (e.g. data security incidents)– Legal obligation; or
– Legitimate interests

§ 6 Cookies

We use Cookies on our website. Cookies are small files which are sent by us to the browser of your terminal device and stored there as part of your visit to our internet pages. Some functions of our website cannot be offered without the use of technically necessary Cookies. Other Cookies allow us to perform various analyses. Cookies are, for example, able to recognize the browser you are using when you visit our website again and to transmit various information to us. We can use Cookies to make our internet offer more user-friendly and effective, for example, by tracking your use of our website and by determining your preferred settings (e.g. country and language settings). In case third parties use Cookies to process information, they will collect the information directly from your browser. Cookies do not cause any damage to your device. They cannot run programs or contain viruses.

Before we set any, not technically necessary, Cookies on our website, we obtain your consent via the Cookie Banner respectively the Cookie Settings in accordance with Article 6 (1) lit. a) GDPR. You can of course change your preferences at any time in the Cookie Settings in the footer of the website.

Further information can be obtained from our Cookie Policy

§ 7 Tools for Tracking and Analysis

We use tracking and analysis tools to ensure continuous optimization and user-oriented design of our website. With the help of tracking measures it is also possible for us to statistically record the use of our website by visitors and to further develop our online offer for you with the help of the knowledge gained.
On the basis of these interests, the use of the tracking and analysis tools described below is justified in accordance with Article 6 (1) lit. f)GDPR. If you have given us your consent to the use of Cookies on the basis of the Cookie Banner provided by us on the website, the legality of the use is additionally governed by Article 6 (1) lit. a) GDPR.

Further information can be obtained from our Cookie Policy

§ 8 Hyperlinks

Our website contains hyperlinks to websites of other providers. When you activate these hyperlinks, you will be directed directly to the other providers’ website. You will recognize this when the URL is changed. Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

§ 9 Your Rights as a Data Subject

The GDPR provides you as a Data Subject with the following rights in case you are subject to a data processing:

§ 10 Right to Object

In case the processing of your personal data is based on legitimate interest in accordance with Article 6 (1) lit. f)GDPR, you have the right to object to the processing of your personal data in accordance with Article 21 GDPR insofar as there are reasons which arise from your particular situation or if the objection refers to direct marketing. In the case of direct marketing, you have a general right of objection which will be considered without mentioning any particular situation.

§ 11 Data Security and Security Measures

We are committed to protecting your privacy and treating your personal information confidentially. In order to avoid any manipulation, loss or misuse of your data stored by us, we take extensive technical and organizational security measures that are regularly reviewed and adapted to technological progress. This includes, among other things, the use of recognized encryption methods (SSL or TLS).

However, we would like to point out that due to the structure of the internet, it is possible that the rules of data protection and the above mentioned security measures may not be observed by other persons or institutions for which we are not responsible. In particular, unencrypted data – e.g. if this is done by e-mail – can be read by third parties. We have no technical influence on this. It is the responsibility of the user to protect the data provided by him against misuse by encryption or in any other way.