1. Controller

The controller responsible for processing personal data on millerweldseurope.com is:

ITW Welding GmbH
Spechttal 1a
67317 Altleiningen
Germany

Email: sales.DE@itwwelding.com

Represented by Managing Director Ralf Kiermaier.

2. Data protection contact

If you have any questions about data protection or wish to exercise your data protection rights, please contact:

ITW Welding GmbH
Data Protection
Spechttal 1a
67317 Altleiningen
Germany

Email: datenschutz@itwwelding.com

3. General information about data processing

We process personal data only to the extent necessary to provide our website, respond to enquiries, register products, handle warranty and service cases, conduct recruitment procedures, or pursue the other purposes described below.

Depending on the processing activity, we rely in particular on the following legal bases:

• Article 6(1)(a) GDPR where you have given consent;
• Article 6(1)(b) GDPR for contracts and steps taken before entering into a contract;
• Article 6(1)(c) GDPR for compliance with legal obligations;
• Article 6(1)(f) GDPR for legitimate interests, in particular the secure and user-friendly operation of the website, the handling of business enquiries, and the prevention of misuse.

Where we store information on your terminal device or access information stored there, this is done in accordance with section 25 TDDDG. We use cookies, storage technologies and third-party services that are not strictly necessary only with your consent.

4. Provision of the website and server logs

When you access our website, technically necessary data are processed. These may include:

• IP address;
• date and time of access;
• page or file requested;
• amount of data transferred;
• HTTP status code;
• previously visited page or referrer;
• browser, operating system and device type.

The processing is necessary to deliver the website, ensure its stability and security, identify technical errors, and prevent attacks and abusive access.

The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the secure, reliable and economical operation of the website.

Server logs are deleted or anonymised as soon as they are no longer required for secure operation and error analysis. Data relating to a specific security incident may be retained for longer until the incident has been fully investigated and, where necessary, for the establishment, exercise or defence of legal claims.

We use specialised IT service providers as processors for hosting, maintenance and technical operation. They may process data only on our instructions and in accordance with the data protection agreements concluded with them.

5. Consent management with Cookiebot

We use Cookiebot, a consent management service provided by Usercentrics A/S, Havnegade 39, 1058 Copenhagen K, Denmark.

Cookiebot is used to obtain, implement and document your choices concerning cookies, local storage and external services. In particular, the following data are processed:

• your decision to consent or refuse;
• date and time of your decision;
• consent or device identifier;
• website and language settings;
• IP address in truncated form or to the extent technically necessary;
• browser and device information.

Storing your choice is necessary so that the website can respect your decision and we can demonstrate any consent you have given. The legal bases are section 25(2) no. 2 TDDDG and Article 6(1)(c) and (f) GDPR. Our legitimate interests are the legally compliant management and documentation of your privacy choice.

The CookieConsent cookie stores your choice for up to one year. Once this period has expired, or if the services used change significantly, the website may ask you to make a new choice.

You can change your choice at any time in the website’s cookie or privacy settings, or withdraw consent with effect for the future.

Further information is available in the Usercentrics Privacy Policy and the Cookiebot legal documents.

6. Cookies and similar technologies

Our website uses cookies and comparable browser storage technologies. We distinguish between the following categories:

Necessary technologies

These technologies are required for basic functions, storing your privacy choice, security and page display. They include Cookiebot, necessary Elementor settings and the Cloudflare Turnstile security service.

They are used on the basis of section 25(2) no. 2 TDDDG. Where personal data are processed, the legal basis is Article 6(1)(f) GDPR.

Preferences

Preference technologies store, in particular, the selected language or country version. The website uses WPML functions for this purpose. Depending on the entry, the storage period ranges from the current session to one day.

Where the storage is not strictly necessary, it takes place only with your consent under section 25(1) TDDDG and Article 6(1)(a) GDPR.

Statistics and marketing

Statistics, analytics, video and marketing services are activated only with your consent. These may include Google Analytics, Google marketing features and YouTube.

The legal bases are section 25(1) TDDDG and Article 6(1)(a) GDPR. Consent is voluntary and can be withdrawn at any time via the cookie settings.

The current list of cookies and storage technologies used, including provider, purpose and duration, can be found in the Cookiebot Cookie Declaration.

7. Language settings

The website uses WPML to provide content in several languages and store your language selection. The selected language, the current session and a country setting derived from the IP address may be processed.

The purpose of the processing is to display the appropriate language and country version. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the user-friendly, multilingual provision of the website. For storage that is not strictly necessary, we obtain your consent under section 25(1) TDDDG and Article 6(1)(a) GDPR.

8. Website search

When you use the search function, we process the search term you enter and technically necessary connection data in order to provide relevant results.

The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is to make our products and content easy to find.

Please do not enter personal, confidential or sensitive information in the search field. Search and server data are deleted as soon as they are no longer required for provision, error analysis and security.

9. Google Tag and Google Analytics

Our website uses Google Tag and, with your consent, Google Analytics. The provider in the European Economic Area is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland may transfer data to Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA, and other Google companies.

Google Analytics helps us understand how the website is used and which content is relevant to visitors. In particular, the following data may be processed:

• IP address and approximate region;
• browser, device and operating system information;
• pages viewed and time spent on them;
• referrer and campaign parameters;
• language settings;
• interactions with page content;
• cookie and online identifiers;
• your consent setting.

The website sets Google storage types to “denied” by default. Analytics and marketing functions are not activated until you consent. Consent may include cookies such as _ga and _ga_#. According to the current Cookie Declaration, these may be stored for up to two years.

The legal bases are section 25(1) TDDDG and Article 6(1)(a) GDPR. You can withdraw your consent at any time via the cookie settings.

Google LLC is certified under the EU-US Data Privacy Framework. Google also uses contractual safeguards for international data transfers. Further information is available in the Google Privacy Policy and the information on international data transfers.

10. Google Fonts

To display fonts, the website retrieves a stylesheet from Google Fonts. The provider is Google Ireland Limited; technical processing by Google LLC in the USA is possible.

When the stylesheet is retrieved, your IP address, browser and device information, the website requested, and the date and time of the request are transmitted to Google. Other fonts used on the website are provided directly by our web server.

The processing serves to provide a uniform and technically compatible display of the website. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the consistent display of our website across devices.

Google LLC is certified under the EU-US Data Privacy Framework. Further information is available in the Google Privacy Policy.

11. Cloudflare Turnstile

We use Cloudflare Turnstile to protect forms and the website against automated access, spam and misuse. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, California 94107, USA.

Turnstile performs automated security checks in the browser to distinguish human visitors from bots. In particular, the following data may be processed:

• IP address;
• browser, device and operating system information;
• information about the page requested;
• timing and interaction signals;
• results of technical security checks;
• a security identifier in browser storage.

Cloudflare states that Turnstile does not access the contents of form fields or other user communications. The processing is used exclusively to detect and prevent abusive or automated access.

The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is to protect our forms, systems and communications against spam, manipulation and attacks. Browser storage required for the security check is based on section 25(2) no. 2 TDDDG.

Cloudflare is certified under the EU-US Data Privacy Framework and additionally uses Standard Contractual Clauses. Further information is available in the Turnstile Privacy Addendum and the Cloudflare Privacy Policy.

12. YouTube videos

We offer videos from YouTube on certain pages. The provider in the European Economic Area is Google Ireland Limited; processing by Google LLC in the USA is possible.

YouTube content and associated cookies or browser storage are not activated until you consent to the external media or marketing category, or open an external YouTube link.

When activated, the following data may be processed in particular:

• IP address;
• browser, device and operating system information;
• page requested and referrer;
• information about playback and interactions;
• YouTube or Google identifiers;
• data from a Google account to which you may be signed in.

The legal bases for embedding the service on our website are section 25(1) TDDDG and Article 6(1)(a) GDPR. You can withdraw your consent at any time via the cookie settings.

Google LLC is certified under the EU-US Data Privacy Framework. Further information is available in the Google Privacy Policy.

13. Google Docs Viewer

Some older PDF documents are displayed on the website using Google Docs Viewer. This establishes a connection to Google. Google receives at least your IP address, browser and device information, and the address of the document requested. Depending on your settings and whether you have a Google account, additional Google cookies or identifiers may be processed.

The integration is used to display PDF documents in the browser. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is to make the documents available independently of the browser used.

Further information is available in the Google Privacy Policy. Alternatively, the documents can be accessed via the relevant direct PDF link.

14. PrintFriendly

We use functions provided by PrintFriendly, Print Friendly LLC, on certain careers pages to present job advertisements in a print-friendly format or provide them as PDFs.

When the associated script is loaded, technically necessary network data, such as the IP address, browser information, page requested and time of access, are transmitted to PrintFriendly. If you use the print or PDF function, PrintFriendly may also process the publicly visible content of the relevant page to create a print-friendly version.

The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the user-friendly provision, print-friendly presentation and saving of job advertisements. The actual print or PDF function is used only at your express request.

PrintFriendly may process data in the USA. International transfers are based on the data protection safeguards specified by PrintFriendly. Further information is available in the PrintFriendly Privacy Policy.

15. Contact and service enquiries

If you contact us by email or telephone, we process:

• your name and contact details;
• company and role, if provided;
• content and time of your enquiry;
• documents submitted;
• communication and technical metadata.

We use these data to process your enquiry, communicate with you and document the matter.

Where the enquiry relates to a contract or steps taken before entering into a contract, the legal basis is Article 6(1)(b) GDPR. In other cases, the processing is based on Article 6(1)(f) GDPR. Our legitimate interest is the proper handling of customer, dealer, press and business enquiries. Retention required by law is based on Article 6(1)(c) GDPR.

Your enquiry may be forwarded to the ITW company, employees, dealers or service partners responsible for the relevant country, product or matter, insofar as this is necessary for processing.

Simple enquiries are deleted once they have been fully dealt with, unless statutory retention, evidence or limitation periods require otherwise. Contractual and business-related communications are stored for the applicable statutory period.

16. Product registration

When you register a product, we process in particular:

• part number;
• product name;
• serial number;
• contact and customer details entered during the subsequent registration steps;
• purchase, dealer and product information;
• communication and technical form data.

We process these data to associate the product with you or your company, provide proof of ownership or purchase, provide registration-related services, and inform you about relevant software, service or safety information concerning the registered product.

The legal basis is Article 6(1)(b) GDPR where you request the registration or where it serves to provide warranty, support or service activities. Safety and recall information may also be based on Article 6(1)(c) or (f) GDPR. Our legitimate interest is product safety, the handling of service cases and the reliable allocation of registered products.

Mandatory information is required to complete the registration. We cannot register the product without this information.

Recipients may include the responsible ITW company, internal service and sales teams, IT and CRM service providers and, where necessary for the matter, dealers or authorised service partners.

Registration data are stored for the duration of the registration and the relevant product life cycle. They are then deleted unless warranty, safety, evidence, retention or limitation requirements necessitate longer storage.

Product information, reviews and exclusive offers

We send product reviews, general product news, promotional offers and other marketing information not required for registration or safety by email only if you have given separate consent or if the statutory requirements for existing-customer marketing under section 7(3) UWG are met.

The legal basis for consent is Article 6(1)(a) GDPR. You can withdraw your consent at any time using the unsubscribe link in the message or by emailing datenschutz@itwwelding.com. After withdrawal, we store your email address on a suppression list to the extent necessary to prevent further unwanted messages.

17. Warranty claims via Qualtrics

We use an external form on the Qualtrics platform for warranty claims. The provider is Qualtrics, LLC, 333 W River Park Drive, Provo, Utah 84604, USA. Qualtrics processes the data collected in the form on our behalf.

Depending on the warranty or service case, we process in particular:

• name, company and contact details;
• country and responsible sales region;
• product, part and serial numbers;
• purchase, dealer and warranty information;
• description of the fault and service history;
• uploaded photos, receipts and other documents;
• communication and technical form data.

The processing is used to review, handle and document warranty, statutory warranty and service claims. The legal basis is Article 6(1)(b) GDPR. Where statutory documentation or retention obligations apply, the legal basis is Article 6(1)(c) GDPR. The processing may also be based on Article 6(1)(f) GDPR for the prevention of misuse and fraud.

Information marked as mandatory is required for processing. Without it, a warranty or service claim may not be reviewed.

Recipients are the responsible ITW company, warranty and service teams, Qualtrics and, where their involvement is required, dealers, distributors and authorised service partners.

The data are stored for the duration of the case and subsequently in accordance with applicable warranty, statutory warranty, retention and limitation periods.

Qualtrics may process data in the USA. For transfers from the European Economic Area, Qualtrics uses, in particular, EU Standard Contractual Clauses and is certified under the EU-US Data Privacy Framework. Further information is available in the Qualtrics Privacy Statement.

18. Applications

If you apply for a position through our website, we process in particular:

• title;
• full name;
• email address and other voluntary contact details;
• position applied for;
• CV;
• cover letter;
• other documents uploaded by you;
• salary expectations, where applicable;
• communication and technical form data.

The processing is carried out to receive your application, assess your suitability, conduct the recruitment procedure and communicate with you.

For applications for positions in Germany, the legal basis is section 26(1) BDSG in conjunction with Article 6(1)(b) GDPR. Where data are required for the establishment, exercise or defence of legal claims, the processing is additionally based on Article 6(1)(f) GDPR. For positions with other European ITW companies, Article 6 GDPR and the applicable national employment data protection provisions apply.

Recipients are limited to the responsible human resources department, managers involved in the selection procedure, the ITW company advertising the position, and technical service providers insofar as their access is necessary.

Please do not submit information that is not required for the application. This applies in particular to special categories of personal data, such as health information or information concerning ethnic origin, religion or sexual orientation, unless exceptionally required for the specific application.

If your application is unsuccessful, we generally delete the application data no later than six months after the recruitment procedure has ended. Data are stored for longer only if there is a legal reason, legal proceedings are pending, or you have separately consented to inclusion in a candidate pool. Consent to a talent pool can be withdrawn at any time.

19. Social media links

Our website contains links to social media services, in particular LinkedIn, YouTube, Instagram, Facebook and X.

Simply viewing our website does not result in data being transferred to the relevant social network through a normal link. Only when you click a link do you leave our website and establish a direct connection to the platform operator. From that point onwards, the respective provider processes data in accordance with its own privacy terms. If you are signed in to the platform, the provider may associate your visit with your account.

20. External links and merchandise shop

Our website contains links to external services, including the merchandise shop at shop.millerweldseurope.com and websites operated by other ITW companies and partners. When you open an external link, the privacy information of the relevant service applies.

Accounts, orders, payments and other processing activities in the merchandise shop are described in its own privacy policy.

21. Recipients of personal data

Depending on the processing activity, personal data may be disclosed to the following categories of recipients:

• responsible employees and departments of ITW Welding GmbH;
• other ITW companies where they are responsible for the relevant country, product or matter;
• hosting, IT, security, consent, analytics, CRM, email, form, recruitment and support service providers;
• dealers, distributors and authorised service partners;
• legal, tax and other professional advisers;
• authorities, courts and other public bodies where we are legally required to disclose the data.

Service providers that process data exclusively on our behalf are contractually bound in accordance with Article 28 GDPR. Data are disclosed only where this is necessary for the relevant purpose or where there is a legal basis.

22. Data transfers outside the European Economic Area

Some service providers and ITW companies are located outside the European Economic Area or permit support and administrative access from such countries.

Data are transferred only where the requirements of Articles 44 to 49 GDPR are met. In particular, we use:

• adequacy decisions of the European Commission;
• the EU-US Data Privacy Framework for certified US recipients;
• Standard Contractual Clauses of the European Commission;
• additional technical and organisational safeguards where required.

You can request a copy of the essential safeguards by emailing datenschutz@itwwelding.com. Trade secrets and security-related information may be redacted.

23. Storage period

We store personal data only for as long as required for the relevant purpose. The data are then deleted or anonymised unless statutory retention, evidence or limitation periods apply.

The relevant criteria include, in particular:

• duration of a website session and technically necessary security logs;
• validity of your cookie and consent choice;
• time required to process an enquiry;
• duration of a contractual, registration, warranty or service relationship;
• duration of a recruitment procedure;
• statutory commercial, tax, product, warranty and employment-related periods;
• necessity for the establishment, exercise or defence of legal claims.

Data contained in backups are overwritten in accordance with normal backup cycles and, until then, are used exclusively for recovery and security purposes.

24. Rights of data subjects

Subject to the statutory requirements, you have the following rights:

• right of access to the data processed about you under Article 15 GDPR;
• right to rectification of inaccurate data under Article 16 GDPR;
• right to erasure under Article 17 GDPR;
• right to restriction of processing under Article 18 GDPR;
• right to data portability under Article 20 GDPR;
• right to object to processing based on Article 6(1)(e) or (f) GDPR under Article 21 GDPR;
• right to withdraw consent with effect for the future under Article 7(3) GDPR;
• right to lodge a complaint with a data protection supervisory authority under Article 77 GDPR, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

The lawfulness of processing based on your consent before its withdrawal is not affected.

To exercise your rights, please contact datenschutz@itwwelding.com. We may request additional information where necessary to confirm your identity.

25. Right to object

Where we process personal data on the basis of Article 6(1)(e) or (f) GDPR, you have the right to object to such processing at any time on grounds relating to your particular situation. We will then no longer process the data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.

You may object at any time, without stating reasons, to the processing of your data for direct marketing, including any related profiling. Your data will then no longer be processed for these purposes.

You can submit your objection informally to datenschutz@itwwelding.com. You can also change or withdraw cookie and tracking consent at any time via the cookie settings.

26. Requirement to provide data

Mandatory information is marked accordingly on contact, registration, warranty and application forms. This information is required to carry out the process you request. Without the mandatory information, we may not be able to process an enquiry, product registration, warranty review or application.

All information not marked as mandatory is voluntary.

27. Data security

We take appropriate technical and organisational measures to protect personal data against loss, manipulation, unauthorised access and other misuse. These include encrypted transmission, access restrictions, authorisation controls, backups and measures to detect attacks.

Nevertheless, data transmission over the internet may be subject to security vulnerabilities. Please send particularly confidential information only through the secure channels provided for that purpose.

28. Changes to this Privacy Policy

We update this Privacy Policy when the website, services used or legal requirements change. The current version is available at millerweldseurope.com.

We will not implement material changes requiring new consent without offering you a new choice in the consent manager.