Data privacy statement

A. Information regarding the collection of personal data

(1) In the following, we provide information regarding the collection of personal data
when using our website. Personal data is defined as all data that relates to you
personally, e.g. name, address, e-mail addresses, user behavior.

(2) Controller in accordance with article 4(7) of the EU General Data Protection
Regulation (GDPR) is

dormakaba International Holding GmbH

DORMA Platz 1
58256 Ennepetal, Germany

Our data protection officer can be contacted at [email protected] or

using our postal address and adding “The data protection officer”.

(3) When contacting us by e-mail or using a contact form, the data you supply (your e-
mail address, your name and phone number if necessary) are stored by us in order to
answer your questions. We delete the data gathered in this regard once storage of such
data is no longer required, or limit processing of such data should statutory storage
obligations apply.

(4) Should we require contracted providers to carry out individual functions of our
offering or should we like to use your data for commercial purposes, we shall inform you
in detail of the respective actions. In doing so, we shall also inform you of the defined
criteria regarding duration of storage.

B. Your rights

You have the following rights vis-à-vis ourselves with regard to your personal data:

• Right of access
• Right to rectification or erasure
• Right to limitation of processing
• Right to object to processing
• Right to data portability,
• Right to lodge a complaint with a regulatory authority.
 C. Collection of personal data when visiting our website

(1) When using our website for purely informational purposes, i.e. without registering or
otherwise submitting information to us, 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 that we require from a technical point of view to display our website to you
and guarantee stability and security (the legal basis here is article 6(1) sentence 1, lit. f
GDPR):

• IP address
• Date and time of enquiry
• Time zone difference to Greenwich Mean Time (GMT)
• Content of request (specific page)
• Access status/HTTP status code
• Volume of data transmitted
• Website from which the request originated
• Browser
• Operating system and its interface
• Language and version of browser software.

(2) In addition to the aforementioned data, when using our website, cookies will be
stored on your computer. Cookies are small text files stored on your hard drive by the
web browser you are using, enabling certain information to be collected by the website
owner who sets the cookie (in this case us). Cookies cannot execute programs or
transmit viruses onto your computer. They are designed to make the internet service as
a whole more user-friendly and effective.

(3) Use of cookies:

a) This website uses the following types of cookies, the scope and functioning of which
shall be described below:

• Transient cookies (b)

• Persistent cookies (c).

b) Transient cookies are automatically deleted when you close the browser. These
include session cookies in particular. They store a so-called session ID with which the
various requests from your browser are assigned to the session as a whole. This means
your computer can be recognized when you return to our website. The session cookies
are deleted when you log out or close the browser.
c) Persistent cookies are deleted automatically after a specified length of time, which
may differ depending on the cookie. You can delete the cookies at any time in your
browser’s security settings.

d) You can configure your browser settings according to your needs and decline
acceptance of third-party cookies or all cookies, for example. We advise you that you
may not be able to use all functions of this website.

e) The Flash cookies used are not collected by your browser but by your Flash Plug-in.
We also use HTML5 storage objects, which are stored on your terminal. These objects
store the data required independently of your browser used and have no automatic
expiry date. If you do not want Flash cookies to be processed, you have to install a
corresponding add-on. The use of HTML5 storage objects may impede you as they use
private mode in your browser. We also recommend manually deleting your cookies and
browser history regularly.

f) This website uses Google Analytics, a web analysis service of Google Inc.
(“Google”).

D. Google Analytics

(1) Google Analytics uses so-called “cookies”, text files that are stored on your
computer and enable analyses to be carried out regarding your use of the website. The
information generated by the cookie about your use of this website is generally
transmitted to a server of Google in the USA and stored there. In the event that IP
anonymization is activated on this website, your IP address will be shortened in advance
by Google, however, within Member States of the European Union or in other
Contracting States to the Agreement on the European Economic Area. Only in
exceptional cases will the full IP address be transmitted to a server of Google in the USA
and shortened there. On behalf of the operator of this website, Google shall use this
information to analyze your use of the website to compile reports on website activity and
perform further services associated with website usage and internet usage for the
website operator.

(2) You can prevent cookies being stored by selecting the corresponding setting in your
browser software; we advise, however, that you may not be able to use the functionality
of this website to its fullest extent in this case. You may also prevent the gathering of
data generated by the cookie relating to your use of the website (including your IP
address) by Google as well as the processing of this data by Google by downloading and
installing the browser plug-in available at the following
link: https://tools.google.com/dlpage/gaoptout?hl=en.

(3) This website uses Google Analytics with the extension “_anonymizeIp()”. Here, IP
addresses are further processed in shortened form meaning individual identification of
the user is not possible. Should the data gathered about you enable identification, this
will be immediately precluded and the personal data immediately deleted.

(4) We use Google Analytics to analyze and regularly improve use of our website.
Using the statistics obtained, we can improve our offering and make it more interesting
for you as a user. For exceptional cases in which personal data is transmitted to the
USA, Google is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-
US-Framework. The legal basis for use of Google Analytics is article 6(1) sentence 1, lit.
f GDPR.

(5) Third-party provider information: Google Dublin, Google Ireland Ltd., Gordon House,
Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User
conditions: https://www.google.com/analytics/terms/us.html, overview of data
protection: https://support.google.com/analytics/answer/6004245?hl=en, and data
privacy statement: https://policies.google.com/privacy?hl=en&gl=en.

E. Learning Management System

(1) When subscribing to our Learning Management Platform in which we offer learning
content required for product utilization, mandatory certification training and the possibility
to register for available classroom training, you will be asked to grant your consent to the
use of your personal data in a separate registration process.

(2) We use a separate registration process to ensure certificates, level of completion and
prerequisites for advanced content and scheduled offerings are made available only to
specific participants. This means that after successful registration all certificates and
learning progress are tracked to the individual participant. We also store your IP
addresses and the times of your registration and confirmation. The purpose of this
procedure is to verify and validate your registration and to discover any possible misuse
of your personal data.
(3) The mandatory information required to send information on assigned content and
scheduled classroom training is your e-mail address. In order to complete the billing
process for chargeable content, the shipping address and name of the employer is
required. Provision of further data shown separately is voluntary and is used to address
you personally. After your confirmation we store your e-mail address and shipping
information to communicate personalized content and bookings from the Learning
Management System. The legal basis is Art. 6 (1) s. 1 a GDPR.

(4) You may revoke your consent at any time and unsubscribe from the Platform. You
may revoke your consent by clicking on the help link provided in the HELP section of the
platform. The administrator will trigger a ticket to the IT responsible to purge all
associated data (including the learning progress, past events, certificates earned,
feedback provided, and all personal data provided during the account creation process).
Upon completion a final email will be sent, to confirm the execution of the data deletion.