Data protection declaration

This data protection declaration explains the type, extent and purpose of the processing of personal data (hereinafter: “data”) in our online offer and the websites, functions and contents linked to it, in addition to external online presences e.g. our Social Media Profile (hereinafter collectively referred to as: “online offer”). With regard to the terminology used, e.g. “processing” or “controller”, we refer you to the definitions in Article 4 of the German “Datenschutzgrundverordnung” (DSGVO) (= General Data Protection Regulation, hereinafter referred to as: GDPR).


Flühs Drehtechnik GmbH
Lösenbacher Landstraße 2
58515 Lüdenscheid

Tel.: +49 2351 / 975-0
Email address:
Authorised Chief Executive Officers: Herr Uwe vom Dahl, Herr Carsten vom Dahl

Data protection officer:
Herr Ulf Vormbrock
Fritz-Vomfelde-Str. 34
40547 Düsseldorf

Type of processed data:

- Basic data (e.g. names, addresses).
- Contact data (e.g. e-mail, telephone numbers).
- Contents data (e.g. text entries, photographs, videos).
- Usage data (e.g. websites visited, interest in contents, access times).
- Meta/communication data (e.g. device information, IP addresses).

Categories of data subjects

Visitors to and users of the online offer (hereinafter referred to collectively as: “users”).

Purpose of processing

- Making available the online offer, its functions and contents.
- Answering of contact enquiries and communication with users.
- Safety measures.
- Reach measurement/Marketing.


“Personal data” means all information which relates to an identified or identifiable natural person (hereinafter: “data subject”). An identifiable natural person is deemed to be one who can be identified, directly or indirectly, and in particular by means of assignment to a form of identification such as a name, an identification number, location data, a form of online identification (e.g. cookie) or to one or more special characteristics which are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

“Processing” means every procedure carried out with or without the aid of automated processes or every such set of operations carried out in connection with personal data. The term is extensive and comprises practically every example of handling data.

“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, location or movements.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or with others, determines the purposes and means of the processing of personal data.

”Processor” means any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Decisive legal basis

In accordance with Art. 13 GDPR, we inform you about the legal basis for our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to enquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfil our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR acts as the legal basis.

Processing of supplier, customer and prospect data

We process the data of our suppliers and customers in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR for the fulfilment of our contractual obligations. If you require additional information, please do not hesitate to contact us. Insofar as no customer or supplier relationship exists, we process your data - for example, if you have contacted us - in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR on the basis of legitimate interest. It is only possible for us to contact you by means of data processing. Otherwise, we refer to the representation of your rights as a data subject. For saving and processing personal and other data, we also use cloud storage; the servers are subject to GDPR (General Data Protection Regulation).

Security measures

We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures in order to ensure a level of protection which is appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to them, as well as their access, input, disclosure, availability and separation. In addition we have set up procedures which ensure the enjoyment of data subject rights, data deletion and the reaction to data vulnerability. Furthermore, we take into account the protection of personal data during the development or selection of hardware, software and procedures phases in accordance with the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).

Collaboration with processors and third parties

Insofar as in the context of our processing we disclose data to other persons and companies (contract processors or third parties), transmit them to these or otherwise provide access to the data, this will only be done on the basis of legal permission (e.g. if transmission of the data to third parties, for example to payment service providers, in accordance with Art. 6 (1) (b) GDPR, is required in order to fulfil the contract), you have consented to a legal obligation, this is provided for by a legal obligation, or is based on our legitimate interests (e.g. the use of agents, webhosters, etc.).

If we commission third parties to process data on the basis of a so-called "contract processing contract", this takes place on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permission, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. This means that the processing is for example on the basis of specific guarantees, such as the officially recognised level of data protection (e.g. for the US via the Privacy Shield) or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

Rights of data subjects

You have the right to ask for confirmation as to whether the data in question are being processed and for information about these data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR you have the right to demand the completion of the data about you or the correction of the incorrect data about you.

In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, in accordance with Art. 18 GDPR, to demand a restriction of the processing of the data.

You have the right to demand that the data relating to you which you have provided to us be maintained in accordance with Art. 20 GDPR and to call for their transmission to other persons responsible.

Furthermore, in accordance with Art. 77 GDPR you have the right to file a complaint with the competent supervisory authority.


You have the right to revoke granted consent in accordance with. Art. 7 para. 3 GDPR with effect for the future.

Right of objection

You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right of objection in respect of direct mail

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his or her browser. For example, the contents of a shopping cart in an online shop or a login status are saved in such a cookie. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. So, for example, the login status will be saved if users visit it after several days. Likewise, the interests of the users can be stored in such a cookie and are used for range measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, these are referred to as "first-party cookies").

We can make use of temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies to be stored on their computer, they will be asked to disable the option in their browser's system settings. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can result in restrictions to the functions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website or the EU site Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that in this case it may not be possible to use all the features of this online offer.

Deletion of data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this data protection declaration, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data are deleted because they are required for other and legally required, processing them will be restricted. This means that the data are blocked and not processed for other purposes. This applies for example to data that must be kept for commercial or tax reasons.

According to the legal requirements in Germany, the storage takes place in particular for 10 years in accordance with §§ 147 Abs. 1 AO, 257 paras. 1 no. 1 and 4, para. 4 HGB (= Commercial Code) (books, records, status reports, accounting documents, trading books, documentation relevant for taxation purposes etc.) and 6 years in accordance with § 257 (1) nos. 2 and 3, para. 4 HGB (commercial letters).

Data protection provisions in the application process

We process the applicants’ data only for the purpose and in the context of the application process in accordance with the legal requirements. Processing of the applicants’ data takes place in order to meet our (pre-)contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if the data processing for example is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).

The application process requires applicants to provide us with their data. Insofar as we provide an online form, the application data required are marked, otherwise they result from the job descriptions and as a basic principle include the information about the person, postal and contact addresses and the relevant application documents, such as the cover letter, CV and the certificates. In addition, applicants can voluntarily provide us with additional information.

By submitting the application to us, the applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set out in this data protection declaration.

Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b GDPR (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).

If it is made available, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us according to the state of the art.

Furthermore, applicants can send us their applications via e-mail. However, please note that as a basic principle e-mails are not sent in encrypted form and that applicants themselves must provide encryption. For this reason we can take no responsibility for the transmission of the application from the sender and its reception on our server and consequently we recommend the use of an online form or postal delivery. Instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by post.

In the event of a successful application, the data provided by the applicants may be further processed by us for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.

Subject to a legitimate rescission on the part of the candidate, deletion will take place after the expiration of a period of six months so that we can answer any follow-up questions about the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.

Contacting us

When contacting us (for example, by contact form, e-mail, telephone or via social media) the information of the user provided is processed in order to deal with the contact request and its processing in accordance with. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other enquiries) GDPR. User information can be stored in a customer relationship management system or similar enquiry organisation.

We delete the enquires if they are no longer required. We check the necessity every two years. Furthermore, the legal archiving obligations apply.

Hosting and e-mailing

The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services which we use in order to operate this online service.

In doing so, we, or our hosting provider, process the personal data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f GDPR in connection with Art. 28 GDPR (conclusion of contract processing contract).

Collection of access data and log files

On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we or our hosting provider collect data on every access to the server on which this service is located (so-called server log files). The access data include the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message regarding successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information is stored for security purposes (for example, to clarify abusive or fraudulent activities) for a maximum period of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the deletion until final clarification of the incident.

Reach measurement with Matomo

We measure the reach of our website with Matomo, an open source tool that we operate on our own server.

No cookie is set on the user's device and the user's IP address is automatically shortened, so that it is no longer possible to draw conclusions about individual persons. Among other things, the approximate geographical location, device type, screen resolution, browser and pages visited, including the length of stay, are evaluated.

The processing of the data is based on Art. 6 para. 1 UAbs. 1 letter f) DSGVO. Our legitimate interest is the optimization of our website, the improvement of our offers and online marketing.


Integration of service and contents of third parties

On the basis of our legitimate interests (i.e. our interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to provide their content and services such as videos or fonts (hereinafter collectively referred to as "content").

This always presupposes that the third-party providers of this content are aware of the users’ IP address, as they would be unable to send the content to the users’ browser without the IP address. For this reason, the IP address is required for the presentation of this content. We endeavour to use only content whose respective providers use the IP address solely for delivery of the content. Furthermore, third parties may use pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the users’ device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and information from other sources regarding the use of our online offer.