Privacy Policy

HTCycle GmbH (its affiliate, associate, and subsidiary companies) is committed to safeguarding the privacy of www.htcycle.ag users. Therefore, we ensure a responsible handling and protection of your Personal Data.

We have created this policy to provide you with clear and understandable information regarding our privacy practices when you are accessing or using our website (www.htcycle.ag) so that you can make informed choices about the use of your Personal Data by HTCycle GmbH.

When accessing other services or applications through our website, please read the specific privacy conditions which may apply to them.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of www.htcycle.ag  services, we will ask you to consent to our use of cookies when you first visit our website.

HTCycle GmbH reserves the right to update this policy from time to time by publishing a new version online.

When this policy refers to HTCycle GmbH, it means HTCycle GmbH as the controller of your data, namely the HTCycle GmbH subsidiary(s) with which you had, have or will have a business relationship or that otherwise decides which of your data is collected and how it is used).

1.  PERSONAL DATA WE COLLECT

HTCycle GmbH collects Personal Data that you provide to us directly when you request information about our services; subscribe to our website services, email notifications and/or newsletters; make an enquiry through our enquiry forms or carry out a transaction or place an order through our website. This may include:

• Identification and contact data such as name, surname, company, phone number, email, address and country;
• Financial and transactional data such as credit card details;
• Any information that you voluntarily share with us such as feedback, opinions or information provided via any of our enquiry forms.

HTCycle GmbH also collects Personal Data automatically when you visit our website. This may include:

Device information such as IP address, referring website, HTCycle GmbH pages your device visited and the time that your device visited our website;

Information collected by cookies (for further information please see the Cookie Policy).

2.  LAWFUL BASIS

We collect and process Personal Data only if we have a lawful reason to do so HTCycle GmbH collects and processes Personal Data only to the extent that either:

(i)   a valid and informed consent was given; or

(ii) if it is required by HTCycle GmbH legitimate business interests, such as entering into or performing contracts, processing and receiving payments, carrying out contractual obligations and complying with statutory or regulatory commitments.

3. CONSENT

Any consent given by you to the collection and use of your Personal Data must be given freely and in response to a clear information by HTCycle GmbH about the intended use of the data. You can withdraw anytime such consent without undue complications. The date, content and validity of such consent must always be documented.

4. USE OF PERSONAL DATA

HTCycle GmbH will use your Personal Data for the following different purposes:

• To improve our website with the objective of ensuring that content is presented in the most effective manner for you and for your device.
• To send email and communicate with you via email regarding our services and events which may be of interest to you if this is in accordance with your marketing preferences.
• To analyze your use of our website for trend monitoring and promotional purposes.
• To respond to enquiries and comments and provide you with support via communication channels, such as customer or contact center support.
• To keep our website safe and secure and comply with our legal requirements and obligations.
• To perform or finalize any transaction or order which you have placed on HTCycle GmbH companies’ websites.
• To set up and manage your user account.
• To share it with HTCycle GmbH companies so that they may offer you their products or services.
• For any other new purpose for which we notify you before collecting any Personal Data.

5.  SHARE AND TRANSFER OF PERSONAL DATA

HTCycle GmbH shares and transfers your Personal Data as described here and only in accordance with all privacy practices and local privacy requirements. We may occasionally share non-personal, anonymized and statistical data with third parties for our own business purposes.

The following are the parties with whom we may share personal information and why:

1.  To other HTCycle GmbH companies and those companies in which HTCycle GmbH owns more than 50%  of share capital where it is necessary to meet the purpose for which you have submitted your Personal Data and in particular if necessary for the provision of services, account administration, sales, marketing and support. We take steps to ensure that HTCycle GmbH companies, including the ones located outside the EEA, follow our global data privacy policy and applicable local law when handling personal data.

2. Occasionally, to third party contractors and providers which perform certain functions on behalf of HTCycle GmbH, such as such as account creation, quality assurance testing, technical support, email delivery and database management services, analyzing data and processing credit card payments, direct marketing services, and cloud hosting services. These parties only have access to such information as necessary to perform their functions and may not use it for any purpose other than to provide services to us.

3. Occasionally, to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

4. For any reason if, at HTCycle GmbH's sole discretion, HTCycle GmbH believes it is reasonable to do so, including to satisfy any laws, regulations, or governmental or legal requests for such information; in the event of a merger, sale, restructure, acquisition, joint venture or assignment to disclose information that is necessary to identify, contact or bring legal action against someone who may be violating our Business Principles values or other terms and conditions; or to otherwise protect the HTCycle GmbH companies.

6.  INTERNATIONAL TRANSFER OF PERSONAL DATA

When Personal Data is transferred, we ensure that we have taken steps to protect your Personal Data before HTCycle GmbH transfers Personal Data across national boundaries within the HTCycle GmbH companies or outside the HTCycle GmbH holding only when:

• this is justified for business purposes; and
• safeguards exist to ensure that Personal Data will continue to be protected at a minimum with the same level of protection required in the jurisdiction of origin.

7.   RETENTION OF YOUR PERSONAL DATA

We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Please keep in mind that in certain cases a longer retention period may be required or permitted by law or to allow HTCycle GmbH to pursue its business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

8.  ORGANISATIONAL AND TECHNICAL SAFEGUARDS

HTCycle GmbH follows strict security procedures in the storage and disclosure of information which you have given us in order to prevent unauthorized access, loss or destruction of your Personal Data. These may include:

• Physical safeguards, with locked doors, alarms, security lighting or CCTV, controlled access to our facilities and secure destruction of media containing your Personal Data;
• Technology safeguards, like the use of anti-virus and endpoint protection software, and monitoring of our systems and data centers to ensure that they comply with our security policies;
• Organizational safeguards, such like implementing risk assessment procedures, policy training and awareness programs on security and privacy, to make sure employees understand the importance and means by which they must protect your Personal Data.

9.  SPECIAL CATEGORIES OF PERSONAL DATA

HTCycle GmbH does not seek to collect sensitive Personal Data (also known as special categories of data). If we do so we will always collect the data in accordance with local data privacy requirements. If you choose to provide us with unsolicited sensitive Personal Data, you will be asked to consent to our processing of such data on a case-by-case basis by using a specific express consent form.

10. CHILDREN’S PRIVACY

HTCycle GmbH does not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are aged under 16, please speak to your parent/guardian to get their permission before you provide any personal information to HTCycle GmbH because without this consent, you are not allowed to provide us with your Personal Data. If we learn that we have collected data from a person aged under 16, we reserve the right to delete such data with no prior notification or consent.

11. ACCESS AND CONTROL OF PERSONAL DATA

We are committed to ensure that you can exercise your right of access and you can control your data.

HTCycle GmbH recognizes your right to:

• Request access to the Personal Data collected on you by HTCycle GmbH and the reason for HTCycle GmbH having such data;
• Obtain a copy of the Personal Data held on you;
• Request the rectification, restriction or erasure of inaccurate or incomplete Personal Data;
• Withdraw consent given to HTCycle GmbH for the collection of your Personal Data at any time, including the right to unsubscribe or to opt out of marketing communications and commercial publications of HTCycle GmbH ;
• Object to HTCycle GmbH legitimate interests as the basis of our processing of your personal information that impacts your rights.

All requests shall be addressed via our contact [email protected]  or by contacting us in writing as described in the section “contact us”.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us by email-[email protected]or as described in the section “contact us” or submit a complaint to the data protection regulator in your jurisdiction.

12. DATA PROTECTION IMPACT ASSESSMENT

HTCycle GmbH conducts Personal Data Impact Assessments to identify risks that the processing of your Personal Data by HTCycle GmbH may cause to your privacy rights in order to eliminate or reduce such risks. Such prior Personal Data Impact Assessments will be part of any development of new services or business opportunities and acquisitions by HTCycle GmbH .

13. PRIVACY BREACH

HTCycle GmbH will inform you promptly of any privacy breach that has compromised your Personal Data and will report such incident to the relevant authorities as required by applicable laws.

14.  CONTACT

If you have questions or concerns about your privacy, please write to us:

• By email, using the email address [email protected] ;
• In writing, using the address as described in the section “Contacts''.