Group

Privacy Policy Statement

Thank you for your interest in our company. The protection of your personal data is of paramount concern for us. We therefore want to inform you comprehensively about the information we collect on our websites, the purpose for which we use it, who we might make it available to and what rights you have (Art. 12 and 13 of the General Data Protection Regulation – GDPR).

Our personal privacy measures are guided by the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679), effective May 25, 2018, and the Federal Data Protection Act (BDSG). Should personal data be processed in a particular instance, we want to express which standard is used to justify the data processing through a simple parenthetical citation of a regulation.

Controller in terms of data protection law:

WAGO Corporation
N120 W19129 Freistadt Road
Germantown, WI 53022 
Phone: 262-255-6222 
Fax: 262-255-3232
Email: info.us@wago.com

We take the company’s internal privacy policy very seriously. We contractually obligate our employees and the processors (service companies) we engage to maintain confidentiality and to observe the IT/security rules and the applicable data protection provisions.

Generally, it is not required that you provide personal data to visit our website. Technically, however, the IP address transmitted from your system is necessary to transfer the data from our website to you. Beyond the freely accessible area of our website—in the context of your registration, for example—we may need your personal data in order to be able to personally respond to you.

We need a legal basis to process your data. Art. 6 GDPR presents a nonexclusive list of legal bases. Under Art. 6 GDPR, processing is permitted when:

• You have consented to the processing of your personal data for one or more specific purposes (Art. 6 (1)(a) GDPR);
• The processing is required to perform a contract in which the contracting party is the affected person. This also applies to contractual measures undertaken at the request of the data subject (Art. 6 (1)(b) GDPR);
• • The data processing is required to fulfill a legal obligation we are subject to (Art. 6 (1)(c) GDPR);
• • The processing is required to protect the vital interests of the affected person or another natural person. This may include the exceptional case that an affected person is severely injured, which mandates that their personal data must be sent to medical personnel (Art. 6 (1)(d) GDPR).
• • The processing is required to maintain the legitimate interests of the responsible parties or any third parties, to the extent that the vital interests, legal rights and fundamental freedoms of the person for which protection of personal data is required are not infringed (art. 6 para. 1 f) GDPR). This legal basis also entitles us to enact processing procedures not covered by any of the above-mentioned legal bases, if this processing is required to maintain the legitimate interests of the our company or any third parties and to the extent that the vital interests, legal rights and fundamental freedoms of the affected person are not infringed. We are also particularly entitled to these processing procedures since they have been specifically granted by European legislation. This legislation supports the contention, an entitled interest may be assumed when the affected person is a customer of the responsible party (Recital 47 sen. 2 GDPR).

When you visit our website, we receive your complete IP address from your computer. Only with this IP address are we able to transmit the data of our website to you so that the website displays for you (Art. 6 (1)(b) and (f) GDPR). Beyond processing for transmission of the retrieved data, the full IP address is stored for only two (2) days in order to be in a position to initiate defensive measures against attacks on our IT, such as a block of IP addresses as well as possible criminal prosecution (Art. 6 (1)(f) GDPR).

We save the date and time of the page view and the page from which you have retrieved our website. We do not save other personal data, unless you log in.

If the programming of our website prompts your browser to load data from servers operated by third parties, we are not, as such, involved in these data transmissions. Our third-party providers have requested that we inform you of the following:

Please visit our website with special information on the subject of cookies.

We offer you free online project-planning software for the configuration of our products. You can register there to store your own projects and view finished projects again at a later time. There

The recorded data is used for self-initiated price inquiries and orders arising from the projects from the configurator and displayed with the created project documentation Art. 6 (1)(b) and (f) GDPR) you will have to give at least the following information about yourself: last name, first name, email, company name, address (street address, number, postal code, town), country, password.

The recorded data is used for self-initiated price inquiries and orders arising from the projects from the configurator and displayed with the created project documentation (Art. 6 (1)(b) and (f) GDPR).

You can select “do not accept cookies” in your browser settings in order to prevent the use of cookies. In such case, it is not possible to use Smart Designer.

If you have additionally registered for our newsletter in Smart Designer, we will also use your email address for account management as well as for any price queries, project planning and orders pertaining to projects created with the configurator that you initiate. However, this only applies to our own advertising purposes, which are described in detail in the newsletter registration, until you cancel your newsletter subscription (objection option, Art. 6 1(a) and (b) GDPR). The provisions in article V, “Collection, storage and utilization of usage data when visiting our website with registration and after log-in” and section 5 there, “Email newsletter and other direct advertising” apply accordingly.

Who provides us the software and how can we contact the data privacy office at this provider?

Microsoft Corporation
1 Microsoft Way
Redmond, Washington 98052, USA
(also "Microsoft" herein)

Data Protection at Microsoft
Microsoft Corporation
Chief Privacy Officer
1 Microsoft Way
Redmond, Washington 98052, USA

Microsoft Ireland Operations Limited is the data privacy representative of Microsoft for the European Economic Area and Switzerland.

The data protection officer at Microsoft Ireland Operations Limited can be reached at the following address:

Microsoft Ireland Operations, Ltd.
Data Protection
One Microsoft Place
South County Business Park
Leopardstown
Dublin 18, D18 P521, Ireland
For what purposes and on what legal grounds do we process your personal data? We process your personal data for easy and mutual collaboration when using the Office365 range of products from Microsoft.

The type and purpose of processing therefore consist of the provision of professional services in accordance with WAGO's volume license and all service agreements concluded between WAGO and Microsoft.

We process your personal data on the basis of Art. 6 (1)(f) GDPR. Our legitimate interests reside within the group of companies for internal administration purposes and in an appropriate relationship between the data subject and the controller. Should processing be authorized through a different legal basis, we will inform you of this separately at an appropriate place.

What personal data of yours do we process? Prior registration is required before the Office365 product range can be made available to you. At least the following data is required for this form of processing:

• Display name (can consist of your first and last name, for example)
• Email address

After you have registered, you also have the option to personally supply the following data within your profile:

• First and last name
• Position in company
• Contact information
• Business phone numbers
• Business address (street, number, postal code, town)
• Profile photo

In the course of the collaboration, we process personal data contained in emails, documents and other electronic data in the context of online services.

Depending on the specific use of the Office365 range of products, this can include:

• Basic personal data (such as place of birth, street name and address, postal code, place of residence, country of residence, cell phone number, first name, last name, initials, email address, gender, date of birth), including basic personal data of family members and children;
• Authentication data (e.g., user name, password or PIN, security question, audit trail);
• Contact information (e.g., addresses, email addresses, telephone numbers, social media names, emergency contact information);
• Unique ID numbers and signatures (e.g., social security number, bank account number, passport and ID number, driver's license number, vehicle registration data, IP address, personnel number, student number, patient number, signature, unique identification for tracking of cookies or similar technologies);
• Pseudonymized identifiers;
• Financial and insurance data (e.g., insurance number, bank account name and number, credit card name and number, invoice number, income, type of insurance, payment history, credit rating);
• Business data (e.g., purchase history, special offers, subscription information, payment timeline);
• Biometric data (e.g., DNA, fingerprints and iris scans),
• Location data (e.g., mobile communications ID, geolocation data, location at beginning/end of call; location data obtained through use of WLAN access points);
• Photos, videos and audio;
• Internet activities (e.g., browser history, search history, reading, watching television, listening to radio);
• Device identification (e.g., IMEI number, SIM card number, MAC address);
• Profiling (e.g., based on observed criminal or anti-social behavior or pseudonymized profiles based on visited URLs, click streams, surfing protocols, IP addresses, domains, installed applications or profiles based on marketing preferences);
• Personnel and hiring data (e.g., indication of employment status, hiring information (such as CV, employment history, training/education history), function and position data, including hours worked, evaluations and salary, information on work permit, availability, employment conditions, tax details, payment details, insurance details and location and company);
• Training data (e.g., training history, current training, grades and results, highest qualification, learning disability);
• Nationality and residence information (e.g., citizenship, naturalization status, marital status, nationality, immigration status, passport data, information on place of residence or work permit);
• Information processed for performing a task executed in the public interest or in the exercise of public authority;
• Special categories of data (e.g., ethnic origin, political views, religious or philosophical beliefs, union membership, genetic data, biometric data for unequivocal identification of a natural person, data on health, sexual relationships or sexual orientation of a natural person, or data on criminal convictions or criminal offenses); or
• all other personal data cited in Article 4 GDPR.

For all other protocol and telemetry data we refer to the privacy policy of the provider at: https://privacy.microsoft.com/de-de/privacystatement.

From whom do we receive your data?
We process only the data we have received from you personally, or data we receive as a function provider within our group of companies (see https://www.wago.com/de/wago-gruppe/international).

In some cases we may receive your personal data from a representative of your organization, from your employer or from another third party as part of an existing or future partnership or customer relationship.

Who receives your personal data (internal and external functions)? Internal functions: Communication partners and holders of functional positions at WAGO

External functions: Please note here that on collaboration platforms in particular, it may be possible for third parties (such as members of other organizations) besides us, you and your organization to also obtain access to your personal data transferred during communication (e.g., via TEAMS). It cannot be ruled out that your transmitted personal data will be used by such third parties or passed on to other third parties.

We therefore refer you here to your own organization's internal data privacy rules and also to the rules of any third party involved in the collaboration.

In a non-member state of the EU, we transfer your personal data solely in consideration of the following appropriate or adequate safeguards:

• Adequacy decision (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)
• In addition, we have entered into an agreement with Microsoft for processing in accordance with Art. 28 GDPR.

Would there be any disadvantages for you if you do not provide us your data? If you do not provide us your data, we may not be able to render our contractually owed services.

Is automatic decision-making/profiling performed?
WAGO does not conduct any automatic decision-making or profiling when processing your personal data within the entire Office365 range of products.

We maintain publicly accessible profiles on social networks.

Normally, social networks such as Facebook can analyze every aspect of your user behavior when you visit their websites or a website with integrated social media content (e.g., “like” buttons or advertising banners). Visiting our social media presences triggers numerous processing procedures relevant to data protection. In particular:

If you are logged into your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. However, under some circumstances your personal data may also be collected if you are not logged in or do not have any account with the respective social media portal. In this case, your data is collected through cookies, for example, which were saved on your end device or through logging of your IP address.

The social media portal operator can then use such collected data to create user profiles based on your preferences and interests. In this way advertisements reflecting your interests can be displayed to you both on the respective social media presence and off it. If you have an account at the particular social network, these advertisements tailored to your interests can be displayed on all devices to which you are or were logged in.

Please also note, we can neither monitor nor control all processing procedures employed by social media portals. Depending on the provider, the operators of the social media portals can therefore perform further processing procedures. You will find relevant information in the terms of use and privacy policies of the specific social media portal.

Legal basis
Our appearances on social media are intended to provide us with the widest possible presence across the Internet. This constitutes a legitimate interest in terms of Art. 6 (1)(f) GDPR. The analysis process initiated by the social networks may be founded on different legal bases, which must then be disclosed by the operators of the social networks (e.g., consent in terms of Art. 6 (1)(a) GDPR).

Controller and assertion of rights
When you visit one of our social media sites (e.g., Facebook), we are jointly responsible with the operator of the social media platform for the data processing procedures triggered by your visit. You are fundamentally entitled to exercise your rights (access, rectification, erasure, restrictions to processing, data portability and lodging a complaint) against us and/or the operator of the respective social media portal (e.g., Facebook).

Nonetheless, please note that despite our joint responsibility with the social media portal operators, we do not have complete control over the data processing procedures employed by the social media portal. The options open to us are primarily subject to the respective provider's company policy.

Duration of storage
The data we collect directly via the social media presence will be erased from our systems as soon as any purpose for its storage lapses, you ask us to erase it or you withdraw your consent to the storage. Stored cookies remain on your end device until you delete them. Mandatory statutory provisions—in particular, retention periods—remain unaffected.

We have no control over the duration of storage of your data which the operators of the social network store for their own purposes. For details on this, please contact the operators of the social networks directly (e.g., in their privacy policy; see below).

Individual social networks
We do not use any automatically activated social plug-ins (e.g., iFrames) from social networks or platforms on our website. Our buttons on social networks or platforms, such as Facebook, Twitter, YouTube, LinkedIn, XING, etc., serve only to point you to the respective provider's website. If you click these links, you will be routed to the website of the respective social network or platform. The data privacy information published by the supplier there is applicable. The respective provider is responsible for ensuring operation that is compliant with data protection requirements. In addition, we also have online presences in some of these social networks or platforms in order to inform users engaged there about our products and services and to communicate with them. The underlying promotional purpose is to be regarded as a legitimate interest in terms of Art. 6 (1)(f) GDPR. Although WAGO has no access to this profile data processed by the platforms, by using these platforms, however, under some circumstances WAGO assumes shared responsibility under data privacy law.

For detailed information about the processing of your personal data and your options to object (opt-out), we refer you to the following information:

Facebook

We maintain a profile on Facebook. The provider is Facebook Inc. (1 Hacker Way, Menlo Park, CA 94025, USA). 

We have entered into an agreement with Facebook on joint control over data processing (Controller Addendum). This agreement specifies which data processing procedures we and/or Facebook bear responsibility for when you visit our Facebook fan page. You can examine this agreement at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.

You can independently customize your advertising preferences in your user account. To do so, click on the following link and log on: https://www.facebook.com/settings?tab=ads.

You can find details in the Facebook Data Policy: https://www.facebook.com/about/privacy/.

Opt out at: https://www.facebook.com/settings?tab=ads.

Twitter

We maintain a profile on Twitter. The provider is Twitter International Company (One Cumberland Place, Fenian Street, Dublin 2, Ireland). 

You can find the privacy policy at: https://twitter.com/de/privacy, opt out at: https://twitter.com/personalization.

YouTube

We maintain a profile on YouTube. The provider is YouTube LLC (901 Cherry Ave, San Bruno, CA 94066, USA) represented by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). 

You can find the privacy policy at: https://www.google.de/intl/de/policies/privacy/, opt out at: https://adssettings.google.com/authenticated.

LinkedIn

We maintain a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. 

You can find the privacy policy at: https://www.linkedin.com/legal/privacy-policy, opt out at: https://www.linkedin.com/psettings/advertising.

XING

We maintain a profile on XING. The provider is XING S, (Dammtorstraße 30, 20354 Hamburg, Germany).

You can find the privacy policy at: https://privacy.xing.com/de/datenschutzerklaerung, opt out at: https://privacy.xing.com/de/datenschutzerklaerung.

Whistle-blowers who report unethical, illegal and irresponsible action are not denouncers. But please bear in mind that the information about yourself, your coworkers or any other aspect of business operations which you supply can result in decisions that affect other persons. Therefore, please only provide information which, to the best of your knowledge, you assume is correct. Even when you have no sanctions to expect, when you impart information in good faith, even when it afterwards turns out to be incorrect, the intentional supplying of false or misleading information is not tolerated.

When you report incidents through our whistle-blower system, we protect your personal data so that the reporting does not disadvantage you in any way.

When you supply personal data through the reporting form, we use it exclusively to investigate the reported incident in the framework of our whistle-blower system. Your personal data is processed based on a legitimate interest pursuant to Art. 6 (1)(f) GDPR. The legitimate interest for the processing of your personal data lies in the efficient investigation of the incident reported by you.

Naturally, it may happen that you have to impart personal data within your report. The information may, for example, be within the subject area of your concern or within the circumstances of how knowledge of the incident was acquired. We likewise process this data for the efficient investigation of the incident reported by you.

If we forward personal data to individuals whose profession obligates them to secrecy (such as lawyers and auditors) or to other third parties who are bound to confidentiality by separate contract (e.g. detective agencies) for further clarification of the reported incident and so that any civil claims against the reported person can be asserted, this happens based on our legitimate interest in terms of Art. 6 (1)(f) GDPR and so that legal obligations can be satisfied (Art. 6 (1)(c) GDPR).

If in the case of criminally relevant acts of the reported person, we have to forward personal data to law enforcement agencies for purposes of criminal prosecution, this happens based on our legitimate interest in terms of Art. 6 (1)(f) GDPR and so that legal obligations can be satisfied (Art. 6 (1)(c) GDPR).

When you use the system uprightly, you have no detriments to fear. If the whistle-blower system is used improperly for the purpose of causing detriments to reported persons, we reserve the right to proceed against the whistle-blower. This occurs based on our legitimate interest under Art. 6 (1)(f) GDPR to protect upright whistle-blowers and safeguard our whistle-blower system against improper use.

We store your data for different lengths of time depending on the required purpose of processing.

If no express storage period is indicated upon collection (for instance, as part of a declaration of consent), personal data is erased when it is no longer required for fulfilling the purpose of storage unless legal retention obligations (such as commercial and tax retention obligations) preclude erasure. We therefore normally process your data for the duration of the entire business relationship (from initiation, execution up to termination of a contract and to the end of any interest in information you may have).

In addition, we store your data in compliance with and within the framework of legal retention and documentation obligations, with applicable guarantee, warranty and limitation periods and, in the event of legal disputes, until the end of such disputes in which this data is required as evidence.

You can, at any time with future effect and without stating reasons, withdraw the consents you have given us to collect and use data without thereby affecting the lawfulness of the processing that occurred based on your consent up through the withdrawal. After withdrawal has occurred, WAGO may further process your personal data only if the processing is required because of another legal basis or statutory obligation. You can send your withdrawal to controllers or to the contact address indicated in the site notice. If technically possible, we will also make withdrawal options available to you in your account.

Confirmation and acknowledgment of the data privacy agreement is absolutely required to make use of our offering.

Please bear in mind that data protection regulations and handling on data privacy can change continually and the content of this data privacy statement must be conformed. If this should be the case, we will present changes in a transparent form for you. In addition, it is advisable to inform yourself about changes in the legal provisions and the practice of our company.