The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit the website of the Association of European Refrigeration Component Manufacturers (or “ASERCOM”). The term “personal data” (also referred to as “data” in the present policy) comprises all data that can be used to personally identify you (e.g. names, addresses, etc.).
1. Data processing on this website
Who is the responsible party for the processing of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, namely ASERCOM (referred to as the “controller” in the GDPR)”, whose contact information is provided below:
Association of European Refrigeration Component Manufacturers
President Wolfgang Zaremski
35, Rue du Congrès
Belgium – 1000 Brussels
Phone: +49 160 6355564
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and means for the processing of personal data.
How do we collect your personal data?
We collect your data directly from you, as a result of your sharing of your data with us and/or of you visiting our website. In particular: :
- Through your acceptance of cookies and other analysis tool listed in this policy;
– When you fill our contact form;
- When you send us a request by e-mail, telephone, or fax;
- When you ask to receive our newsletter.
For more details in this regard, please refer to Section 2 below (How do we collect your personal data from you?).
Which data are we processing?
We collect and process the following data about you:
- Identification and contact information: e.g. your name, physical address and electronic address, phone number;
- Electronic data: e.g. operating system, IP address, URL, referrer URL, IP address, device and browser characteristics.
- Connection and tracking data: e.g. cookies, the time at which the site was accessed, the pages accessed, time spent on each page, etc;
Why do we process your data for?
We process your personal data for the following purposes:
- To guarantee the error free provision of the website;
- For IT management, including infrastructure management, business continuity and IT security;
- To analyze your user patterns on the website;
- To create statistics to optimize the content of the website;
- To optimize the website;
- To provide you with information regarding our services;
- To assist you and answer your requests;
- To provide you with our newsletter;
- To evaluate if we can offer you services;
- To improve the quality of our services;
- To generate reports on website activities.
With who do we share your personal data?
Access to the data is limited to those staff members who need to have access to the data in the context of their mission within ASERCOM. The personnel concerned are required to keep your data confidential and must comply with the technical instructions imposed by us in this respect.
- Judicial authorities (upon request of a court order) and our attorneys, auditors and notaries
We also share your personal data with the following services providers, with who we have concluded a data processing agreement (DPA). This agreement is mandatory under the GDPR, to ensure that data processors process personal data only based on our instructions and in compliance with the GDPR.
We host our website with Hetzner. The provider is the Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter referred to as Hetzner).
We share your data with Hetzner on the basis of our legitimate interest (Art. 6(1)(f) of the GDPR).
- IT and social medias Service providers (such as Google, Facebook and LinkedIn)
Newsletter services are provided by Mailingwork GmbH, Birkenweg 7, 09569 Oederan, Germany (hereinafter referred to as Mailingwork).
Amplifir Media GmbH, Rückertstr. 5, 80336 Munich, Germany
How long do we keep your personal data for?
If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
Data transfer to the USA and other non-EU countries
Among other things, we use tools of companies domiciled in the United States or in other countries outside the European Economic Area (“EEA”). If these tools are active, your personal data may potentially be transferred outside the EEA. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed.
For transfers to non-EEA countries whose level of protection has not been recognized by the European Commission, we will implement one of the following safeguards to ensure the protection of your personal data.
For Google: Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
For LinkedIn: Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
For Facebook: Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
You may access or obtain a copy of these safeguards by sending us a request via email at : firstname.lastname@example.org
What rights do you have as far as your personal data is concerned?
You can obtain information relating to the processing of your personal data and a copy of such personal data.
- Revocation of your consent to the processing of data
Some data processing operations are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
- Right to object to the collection of data in special cases; right to object to direct advertising
In the event that data are processed on the basis of article 6(1)(E) or (F) GDPR, you have the right at any time to object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defense of legal entitlements (objection pursuant to article 21(1) GDPR). If your personal data is being processed in order to engage in direct advertising, you have the right to object to the processing of your affected personal data for the purposes of such advertising at any time. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to article 21(2) GDPR).
- Right to log a complaint with the competent supervisory authority
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory
authority, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
- Right to data portability
You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
- Rectification and eradication of data
You may also have a right to have your data rectified if it is inaccurate or eradicated (if one of the grounds of article 17 of the GDPR applies).
- Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be
- weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their storage – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons of the European Union or a member state.
In any case, please do not hesitate to contact us at any time by email at email@example.com if you have questions about this or any other data protection related issues.
2. How do we collect and process your personal data from you?
Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.
In some cases, it is possible that third-party cookies are stored on your device once you enter our site (thirdparty cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., for playing Youtube videos).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free provision of the operator’s services.
Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies) shall be stored on the basis of Art. 6(1)(f) GDPR, we request your consent.
The purpose of other cookies may be the analysis of user patterns or the display of promotional messages. In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.
If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
The cookies we use are described below in Section 3.
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions.
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested.
The information you have entered into the contact form shall remain with us during 14 days after the purpose for which the information is being archived no longer exists, when we have concluded our response to your inquiry. If, after you submitted the contact form, we enter into a contractual relationship with you, your personal data will be retained during the whole relationship for a reasonable period thereafter. Certain personal data included in the agreement we concluded with you may be retained for a ten-year period starting from contract expiry/termination date. This shall be without prejudice to any other mandatory legal provisions, in particular retention periods.
Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data will be stored and processed by us for the purpose of processing your request.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained.
The data sent by you to us via contact requests remain with us during 14 days after the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail
address as well as information that allow us to verify that you are the owner of the e-mail address provided, and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties, except the services providers listed above.
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f)GDPR). The storage in the blacklist is limited to 12 month. You may object to the storage if your interests outweigh our legitimate interest.
3. Cookies, analysis tools and advertising
Word press Cookies
The use of these cookies is necessary for the functioning of our website.
WordPress cookies comprise user cookies, recording sessions and authentication details of users, and comments cookies, remembering names and email addresses so that the visitors do not have to enter their information every time they want to leave a comment. Sessions cookies are stored for 15 days and comment cookies for maximum one year.
Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
For the use of the Google Tag Manager, your consent has been requested, the processing is then carried out exclusively on the basis of Art. 6(1)(a)GDPR; the consent can be revoked at any time.
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.
This analysis tool is used on the basis of you consent (that will be asked beforehand) and the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at any time.
These cookies are stored for 14 months.
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.
You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link:
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at:
Demographic parameters provided by Google Analytics
This website uses the “demographic characteristics” function of Google Analytics, to be able to display to the website visitor compatible ads within the Google advertising network. This allows reports to be created that contain information about the age, gender, and interests of the website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third-party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.
The website operator uses Google Ads. Google Ads is an online promotional program of Google.
Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.
The use of Google Ads is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in marketing the operator’s services and products as effectively as possible.
This website uses the functions of Google Analytics Remarketing. The provider of these solutions is Google.
Google Remarketing analyzes your user patterns on our website (e.g. clicks on specific content), to allocate a certain advertising target groups to you and to subsequently display matching online offers to you when you visit other online offers (remarketing or retargeting).
Moreover, it is possible to link the advertising target groups generated with Google Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a manner tailored to you as well as on any of your devices (e.g., tablet or PC).
If you have a Google account, you have the option to object to personalized advertising under the following link:
The use of Google Remarketing is based on your consent which we has been requested (Art. 6(1)(a) GDPR); the given consent may be revoked at any time.
For further information and the pertinent data protection regulations, please consult the Data Privacy
Policies of Google at:
Formation of Target Groups with Customer Reconciliation
For the formation of target groups, we use, among other things, the Google Remarketing customer reconciliation feature. To achieve this, we transfer certain customer data (e.g., email addresses) from our customer lists to Google. If the respective customers are Google users and are logged into their Google accounts, matching advertising messages within the Google network (e.g., YouTube, Gmail or in a search engine) are displayed for them to view.
This website uses Google Conversion Tracking. The provider of this service is Google.
We use Google Conversion Tracking on the basis of your consent which has been requested (Art. 6(1)(a) GDPR); the given consent may be revoked at any time.
For more information about Google Conversion Tracking, please review Google’s data protection policy at:
To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.
This tool allows (i) the tracking of page visitors visit after they have been linked to our website after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns and (ii) the display by Facebook of our ads to users that have previously visited our website.
For us as the operators of this website, the data received from Facebook is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the
Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data by Facebook.
The use of Facebook Pixel on our website is based on your consent which has been requested Art. 6(1)(a) GDPR; the agreement can be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Facebook are jointly responsible for this data processing (Art. 26 of the GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at:
You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.
If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance:
LinkedIn Insight Tag
This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited
Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”).
Data processing by LinkedIn Insight tag
We use the LinkedIn Insight tag to obtain anonymous information about visitors to our website. Once a website visitor is registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience.
We can also use LinkedIn Insight tags to measure whether visitors to our websites make a purchase or perform other actions on our website (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of the advertising addressee takes place.
LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized).The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days.
The data collected by LinkedIn and provided to us in the form of anonymous reports cannot be assigned by us as a website operator to specific individuals.
The use of LinkedIn Insight is based on your consent which has been requested (( Art. 6(1)(a) GDPR); the consent can be revoked at any time.
Objection to the use of LinkedIn Insight Tag
You can object to LinkedIn’s analysis of user behavior and targeted advertising at the following link:
In addition, LinkedIn members can control the use of their personal information for promotional purposes in the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.
YouTube with expanded data protection integration
Our website embeds videos of the website YouTube. The website operator is Google.
We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video.
Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.
As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.
Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.
Under certain circumstances, additional data processing transactions may be triggered by YouTube after you have started to play a YouTube video, which are beyond our control.
The use of YouTube is based on your consent, which has been requested (Art. 6(1)(a) GDPR); the agreement can be revoked at any time.
4. Security measures
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.