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.
Insofar as those cookies are not strictly necessary for the provision of www.htcycle.ag services, we will ask you to consent to our
the right to update this policy from time to time by publishing a new version
When this policy refers to HTCycle GmbH, it means HTCycle GmbH as the controller
of your data, namely the HTCycle GmbH
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
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
- Identification and contact
data such as name, surname, company, phone number, email, address
- 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.
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
Information collected by
cookies (for further information please see the Cookie
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.
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
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
will use your Personal Data for the following
- 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
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
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
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;
- 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
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.
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.
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
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.
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
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
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.
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''.