Privacy policy


  1. General information
  2. Data processing on the website
  3. Data processing within the scope of business relations
  4. Handling of applicant data
  5. Overarching provisions

1. General

1.1. Scope of this privacy statement

This data protection declaration contains explanations on the handling of personal data in our company. Unless explicitly differentiated in the following, it applies uniformly both to data processing procedures on our website and to all other types of handling of personal data, such as data processing for the purpose of fulfilling contracts. Supplementary explanations of specific online functionalities can be found in the attachment at the end of this data protection declaration.

1.2 Designation of the responsible body

The person responsible for data processing on this website is:

Texpak Vertriebsgesellschaft für Kautschukverpackungen mbH
Meinrad-Thoma-Straße 14
D-79674 Todtnau

Represented by: Alessandro Cangeri

The responsible body decides alone or jointly with others on the purposes and means of processing personal data (e.g. names, contact details, etc.)

1.3. Subject of data protection

The subject of data protection is the processing of personal data. This is all information relating to an identified or identifiable natural person (so-called data subject), e.g. a contact person in your company. This includes information such as name, address, e-mail address or telephone number, but also information that necessarily arises during our business relationship with you, such as details of individual orders and the conclusion of contracts.

We process personal data in compliance with the relevant data protection regulations. This means that your data will only be processed by us if we have your consent or a legal permission, e.g. if the data processing is necessary or legally required for the provision of our contractual services (e.g. processing of orders).

1.4 Technical security measures

We take organisational and technical security measures in accordance with the state of the art to ensure that the data protection regulations are observed and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.

For security reasons and to protect the transmission of confidential content that you send to us as the site operator, our website uses SSL or TLS encryption. This means that data that you transmit via the website cannot be read by third parties. You can recognise an encrypted connection by the "https://" address line of your browser and the lock symbol in the browser line.

2. Data processing on the website

2.1. calling up our website

When you call up our website, the browser used on your end device automatically and without your intervention

  • Date and time of access and the time zone difference to Greenwich Mean Time (GMT)
  • The method of access (verb, e.g. "GET")
  • Content of the request (concrete page) and possible parameters ("query")
  • The IP address of the user
  • The user's version of the HTTP protocol
  • Information about the type of browser and the language/version used, preferences for displaying multilingual websites (e.g. EN, DE), information about the user's operating system and installed plug-ins or used NDK / SDK
  • Any cookies set at the user
  • Websites from which the user's system accesses our website
  • Access status / HTTP (sub)status code
  • The amount of data transmitted in each case
to the server of our website and temporarily stored in a so-called log file for the following purposes:
  • To ensure a smooth connection setup,
  • Guarantee a comfortable use of our website,
  • Evaluation of system security and stability.
  • The legal basis for the processing of the IP address is Article 6 paragraph 1 letter f) DSGVO. Our legitimate interest lies in the purposes of data processing listed above.
The data is stored for a period of 7 days and then automatically deleted.

2.2. Cookies - General information

We use so-called cookies on our website on the basis of article 6 paragraph 1 letter f) DSGVO. Our interest in optimizing our website and its user-friendliness is considered justified in the sense of the aforementioned regulation. Cookies are small files that are stored on your end device (laptop, tablet, smartphone or similar) when you visit our website. Cookies do not cause any damage on your terminal device, do not contain viruses, trojans or other malware. Information is stored in the cookie that is related to the specific terminal device used. This does not mean, however, that we obtain direct knowledge of your identity. The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted when you leave our website. In addition, we also use temporary cookies to improve user-friendliness, which remain stored on your end device for a certain defined period of time. If you visit our site again to use our services, we will automatically recognize that you have already been with us, what entries/settings you have made so that you do not have to perform these actions again.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or so that a message always appears before a new cookie is created. However, disabling cookies completely may mean that you will not be able to use all the features of our website.

2.3. Contact us

Personal data that you provide us with when filling out contact forms on the website, on the phone or by e-mail will of course be treated confidentially. We use your data exclusively for the purpose of processing your inquiry. The legal basis for data processing is either article 6 paragraph 1 letter b) or article 6 paragraph 1 letter f) DSGVO. Our legitimate interest in this data processing arises from the common goal of answering your enquiries, solving any problems that may arise and thus maintaining and promoting your satisfaction as a customer or user of our website.

If you participate in one of our customer surveys, this is done on a purely voluntary basis. Any personal information you provide while answering our survey is considered voluntary. Please refrain from mentioning names or the like in the free text fields, which would allow conclusions to be drawn about you or other persons. In the event that a declaration of consent is submitted as part of a customer survey, Article 6 paragraph 1 letter a) DSGVO is the applicable legal basis for data processing based on the consent. If consent has been given by you in the course of a customer survey, you have the possibility of revoking this consent at any time with effect for the future. Further details are regulated in the special data protection information for the respective customer survey.

2.4. Specific website functionalities

A description of the other functions of our website with data protection relevance or other online contact options can be found in the attachment at the end of this data protection declaration.

3. Data processing within the scope of business relations

3.1. Performance of the contract

We process personal data if this is necessary for the preparation, conclusion or implementation of a contract with you. The purposes depend on the specific contract and include in particular

  • the preparation and processing of offers
  • the execution of the contracts concluded
  • the processing of payments
  • the support and service before, during and after the business relationship with you
  • the handling of any warranty claims
The processing of your personal data is carried out on the basis of Art. 6 para. 1 lit. b) DSGVO, insofar as it is necessary for the above-mentioned purposes. Without this data we will not be able to conclude and fulfil the contract with you.

The data collected by us will only be stored as long as it is necessary to achieve the purpose for which the data was collected. As a rule, this requirement is waived when the contractual services have been completely fulfilled and the applicable warranty periods have expired, unless we are entitled and obliged to store the data beyond this period due to statutory storage obligations, which result in particular from commercial and tax law.

3.2. Fulfilment of legal obligations

We also process your personal data to fulfil our legal obligations. These may arise, for example, from commercial, tax, money laundering, financial or criminal law. The purposes of the processing result from the respective legal obligation; as a rule, the processing serves the purpose of complying with state obligations to provide information. In this respect, data processing is based on Art. 6 para. 1 lit. c) DSGVO. We delete the data after the legal obligation ceases to apply, unless another legal basis intervenes.

3.3. Protection of legitimate interests

We also process your personal data to protect our legitimate interests or those of our affiliated companies, e.g. for the following purposes:

  • Storage in our customer database, e.g. to enable follow-up communication after an initial contact at a trade fair
  • Answering questions not relevant to the contract and business correspondence
  • Sending of information material, price lists, event information
  • Implementation of credit assessments
  • Optimization of our business processes
In this respect, data processing is based on Art. 6 Para. 1 letter f) DSGVO. Our legitimate interest in this respect results from the purposes described above and also from our general interest in the ongoing maintenance of our customer relations. We also reserve the right to process personal data, namely your name and contact details, which you have provided us with in the course of the initiation of or business relationship with us, in order to send you information on our own similar products or services, whereby we will comply with the competition law regulations which may be applicable in addition to the DSGVO in such measures. If you have concluded a contract with us, we will treat you as an existing customer. In this case, we will process your postal contact data, irrespective of whether you have given your specific consent, in order to send you information about new products and services. We process your e-mail address in order to send you information about our own similar products and services. You can object to the implementation of marketing measures at any time.

3.4. Consent

Should we process personal data on the basis of your consent, the purposes are determined by the content of the respective declaration of consent. In these cases, data processing is carried out on the basis of Art. 6 Para. 1 lit. a) DSGVO. You may revoke any consent you have given at any time without affecting the lawfulness of the processing that has taken place on the basis of the consent until revocation. We delete the data if they are no longer required for the purposes we pursue or if you have revoked your consent and no other legal basis intervenes.

4. Handling of applicant data

If you apply to us, e.g. also by e-mail, for an open position, we process the data you send us in connection with your application in order to check your suitability for the advertised position (or other open positions within our group of companies, if applicable) and to carry out the application procedure. After receipt of your application, your applicant data will be reviewed by the personnel department and the departmental managers at our company. Within the company, only those persons who need access to your data to carry out the application procedure have access to it.

The legal basis for processing your personal data in an application procedure is in particular § 26 BDSG. According to this law, the processing of data is permissible insofar as it is necessary in connection with the decision on the establishment of an employment relationship. The storage of any additional information that you may have provided voluntarily is based on Art. 6 Para. 1 letter f) DSGVO, as we have a legitimate interest in also processing the additional information you have provided voluntarily for the purposes of carrying out the application procedure. If you agree to the further storage of your personal data in our applicant pool after - unsuccessful - completion of the application procedure, the legal basis for the associated further processing is your consent pursuant to Art. 6 para. 1 lit. a) DSGVO. You can revoke your consent at any time with effect for the future without giving reasons.

Personal data of applicants will be deleted by us in the event of a rejection after four, but at the latest after six months. In the event that you have consented to further processing of your personal data in our applicant pool, the data will be deleted if they are no longer necessary for the purposes for which they were collected and processed, as a rule after a period of 2 years after inclusion in the applicant pool. If you are selected for a position as part of the application procedure, your data will be transferred to our personnel administration system and processed there, insofar as they are necessary for the establishment and execution of the employment relationship.

5. Übergreifende Bestimmungen

5.1. Transfer of data and categories of recipients

As part of the heco group of companies, we work together with other group companies and exchange data with them. However, personal data is only transferred to other group companies if there is a legal basis for this and the transfer is necessary for the purposes of the data processing. For example, data relating to customers and suppliers are exchanged within the Group, in particular in the context of contract fulfilment on the basis of Art. 6 Para. 1 lit. b) DSGVO and on the basis of our legitimate interests pursuant to Art. 6 Para. 1 lit. f) DSGVO. Our legitimate interest lies in particular in the optimisation of our internal administrative processes to conserve resources and improve customer service.

We will only pass on your personal data to external third parties if this is necessary for processing the contract, if another legal permission exists or if we have your consent. The transmission is then carried out in each case on the basis of Art. 6 para. 1 lit. a), lit. b), lit. c) and/or lit. f) DSGVO.

External recipients can be service providers that we commission to provide services within the scope of order processing in accordance with Art. 28 DSGVO (e.g. in the field of IT services, marketing services or document destruction). Such contract processors are carefully selected by us and regularly checked. They may use the data exclusively for the purposes specified by us and in accordance with our use instructions. In addition, on the basis of a legal obligation or in order to protect our legitimate interests, data is also passed on by us to external service providers who, under their own responsibility, provide external specialist services for us, such as shipping service providers, tax consultants or auditors.

Furthermore, it is possible that for legally binding reasons we may have to transmit personal data to authorities and state institutions, such as public prosecutors, courts, customs or tax authorities.

If a data transfer takes place to entities whose registered office or place of data processing is not located in a member state of the European Union or in another state that is a party to the Agreement on the European Economic Area, we will ensure before the transfer that, apart from exceptional cases permitted by law, the recipient either has an adequate level of data protection or your consent to the data transfer has been obtained.

5.2. Storage duration

The storage period of personal data can be found primarily in the respective description of the corresponding offer or service in this privacy policy. In addition, or unless otherwise stated in the respective description of the offer or service, applies generally:

We only store your personal data for as long as this is necessary for the fulfilment of the processing purposes or - in case of consent - as long as you have not revoked your consent. In the event of an objection, we will delete your personal data, unless further processing is permitted under the relevant legal provisions. We also delete your personal data if we are obliged to do so for legal reasons. If and for as long as statutory storage obligations exist, we will only delete the data after the expiry of the corresponding periods.

5.3. Your rights of data subjects

5.3.1. Overview

In addition to the right to revoke your consent granted to us, you are entitled to the following further rights if the respective legal requirements are met:

  • Right to information about your personal data stored by us in accordance with Article 15 DSGVO and § 34 BDSG,
  • Right to correct incorrect data or to complete incomplete data in accordance with Article 16 DSGVO,
  • Right to delete your data stored with us in accordance with article 17 DSGVO and § 35 BDSG,
  • Right to limit the processing of your data in accordance with Article 18 DSGVO,
  • Right to data transferability according to Article 20 DSGVO,
  • Right of objection under Article 21 DSGVO

5.3.2. Right of access under Article 15 DSGVO

In accordance with Article 15 Paragraph 1 DSGVO, you have the right to request information free of charge about the personal data we have stored about you. This includes in particular:

  • the purposes for which the personal data are processed
  • the categories of personal data which are processed;
  • the recipients or the categories of recipients to whom the personal data concerning you have been or will be disclosed;
  • the planned duration of storage of the personal data relating to you or, if it is not possible to specify this, criteria for determining the duration of storage;
  • the existence of a right of rectification or erasure of personal data concerning you, a right to have the processing limited by the controller or a right to object to such processing;
  • the existence of a right of appeal to a supervisory authority;
  • any available information as to the source of the data where the personal data are not collected from the data subject;
  • the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) FADP, and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject.
If personal data are transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards pursuant to Article 46 FADP in connection with the transfer.

5.3.3. Right of rectification under Article 16 FADP

You have the right to ask us to correct incorrect personal data concerning you without delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

5.3.4. Right of cancellation under Article 17 DSGVO

You have the right to demand that we delete any personal data relating to you immediately if one of the following reasons applies:

  • the personal data is no longer necessary for the purposes for which it was collected or otherwise processed
  • you withdraw the consent on which the processing was based under Article 6(1)(a) or Article 9(2)(a) FADP and there is no other legal basis for the processing;
  • you object to the processing pursuant to Article 21(1) or 21(2) FADP, and there are no overriding legitimate reasons for the processing in the case of Article 21(1) FADP;
  • the personal data have been processed unlawfully;
  • the deletion of the personal data is necessary to comply with a legal obligation;
  • the personal data have been collected in relation to information society services offered in accordance with Article 8(1) of the DPA.
If we have made the personal data public and are obliged to delete them, we will take reasonable measures, taking into account the available technology and the implementation costs, to inform the third parties processing your data that you also require them to delete all links to these personal data or copies or replications of these personal data.

5.3.5. Right to restrict processing under Article 18 FADP

You have the right to demand that we restrict processing if one of the following conditions is met:

  • you dispute the accuracy of the personal data
  • the processing is un-lawful and you request the restriction of the use of the personal data instead of its deletion;
  • the controller no longer needs the personal data for the purposes of the processing, but the data subject needs them in order to exercise or defend his rights; or
  • has lodged an objection to the processing pursuant to Article 21 paragraph 1 FADP, as long as it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.

5.3.6. Right to data transferability pursuant to Article 20 DSGVO

You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format and you have the right to transfer this data to another responsible person without hindrance from us, provided that

  • the processing is based on a consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b) of the DSGVO, and
  • the processing is carried out by means of automated procedures.
When exercising your right to data transferability, you have the right to obtain that the personal data be transferred directly from us to another controller, as far as this is technically feasible.

5.3.7. Right of withdrawal in case of consent

You have the right to withdraw your consent at any time, without this affecting the lawfulness of the processing carried out so far. If the consent is revoked, we will stop the corresponding data processing. 5.3.8 Right of objection under Article 21 DSGVO.

5.3.8. Right of objection under Article 21 DSGVO

Under Article 21(1) of the DPA, you have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(f) of the DPA. We will then no longer process the personal data unless there are demonstrably compelling reasons for processing that are worthy of protection and outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

In addition, under Art. 21 (2) DS-GVO you have the right to object to the processing of your personal data for the purposes of direct marketing, the exercise of which leads to the termination of processing for the purposes of direct marketing or the protection of legitimate interests.

5.4. Amendment of our data protection declaration

We reserve the right to adapt this data protection declaration so that it always meets the current legal requirements or to implement changes to our services in the data protection declaration, e.g. when introducing new services. The most current version of this data protection declaration applies in each case.

Version 1.0, status September 2018