1. RESPONSIBLE FOR DATA PROCESSING

SAXONIA Technical Materials GmbH
Rodenbacher Chaussee 4
63457 Hanau
Tel.: 0049 6181 9061 0
Fax: 0049 6181 9061 4000
E-Mail: technical.materials@saxonia-tm.de

You can reach our data protection officer at:

SAXONIA Holding GmbH
Datenschutzbeauftragter
Dr.-Külz-Ring 10
01067 Dresden
Tel.: 0049 351 484 585 190
E-Mail: datenschutz@saxonia.de

2. SOURCES OF PERSONAL DATA

2.1 When visiting the website

Every time you access content on the website, data is temporarily stored that may allow identification. The following data is collected:

• Date and time of access
• IP-address
• Host name of the accessing computer
• Website from which the website was accessed
• Websites accessed via the website
• Page visited on our website
• Message as to whether the retrieval was successful
• Amount of data transferred
• Information about the browser type and version used
• Operating system

The temporary storage of the data is necessary for the course of a website visit in order to enable delivery of the website.

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. When providing the website, this is the case when the respective session has ended.

2.2 As part of the business relationship

We process personal data that we receive from our customers and interested parties in the course of our business relationship.

In order to provide our services, we also process, where necessary, personal data that we legitimately obtain from publicly accessible sources (e.g. Internet, commercial register, creditworthiness data) or that are legitimately transmitted to us by other companies in the SAXONIA Group.

This can be personal data such as name, address, contact details, job titles, birthday and place, nationality, identification data (e.g. ID or passport data) and authentication data (e.g. sample signature). This can also include order data from the fulfillment of our contractual obligation (including sales data and payment transaction data), information about the financial situation (creditworthiness data, scoring data, asset data), sales documentation data (e.g. visit reports) and other data comparable to the categories mentioned.

If you contact us by email or via a contact form on our website, we will store your details in order to answer your question(s). The storage serves the sole purpose of answering your query.

3. PURPOSE OF PROCESSING / LEGAL BASIS

We process your personal data based on the data protection provisions of the EU General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and all other relevant laws.

3.1 Consent (Art. 6 Para. 1a GDPR)

If you have given us your consent to process personal data for specific purposes, the lawfulness of this processing is based on your consent. Consent given can be revoked at any time. This also applies to the revocation of declarations of consent that were given by you before the GDPR came into force.

Please note that the revocation only applies to future processing. Processing that took place before the revocation is not affected by this.

3.2 To fulfill contractual obligations (Art. 6 Para. 1b GDPR)

The processing of data is carried out to provide recycling services, product manufacturing, commercial services, transport services, etc. as part of the implementation of our contracts with our customers or to carry out pre-contractual measures upon request. The purposes of data processing depend on the specific product or service and also include pre-contractual measures such as offers, information, advice, analyses, etc.

3.3 Due to legal requirements (Art. 6 Para. 1c GDPR)

We are subject to various legal obligations and legal requirements (e.g. commercial and tax retention regulations according to the Commercial Code and the Tax Code). The purposes of processing include creditworthiness checks, identity verification (legitimation of the contractual partner, its owner and the persons acting on behalf of the contractual partner), fraud and money laundering prevention and embargo checks. Furthermore, the purposes of processing include the fulfillment of tax control obligations, reporting obligations and information obligations as well as risk assessment and risk control within the company and within the SAXONIA Group.

3.4 As part of the balancing of interests (Art. 6 Para. 1f GDPR)

If necessary, we process your data beyond the actual fulfillment of the contract to protect our legitimate interests or those of third parties, examples:

• Assertion of legal claims and defense in legal disputes
• Measures to ensure house rules
• Prevention and investigation of crimes
• Measures for building and system security (e.g. access controls, video surveillance). Video surveillance is used for property security and law enforcement. They serve to protect our customers and employees as well as your and our valuables (e.g. robberies and fraud).
• Ensuring IT security and IT operations
• Measures for business management and the further development of services and products, including customer and supplier reviews
• Advertising or market and opinion research unless you have objected to the use of your data
• Testing and optimization of procedures and processes
• Consultation with credit agencies and credit insurers to determine and hedge against creditworthiness and default risks
• Risk management in the SAXONIA Group

4. TRANSFER OF DATA TO THIRD PARTIES

We only pass on your data to third parties if this is necessary to fulfill our contractual and legal obligations.

The service providers carefully selected for these processes and services are based within the EU and work in compliance with the EU General Data Protection Regulation (GDPR).

4.1 Data processing in the SAXONIA Group

Central areas of our group of companies handle certain data processing tasks for the companies affiliated with the group. If there is a contractual or pre-contractual relationship with one or more companies in our group, your data may be processed by a company in the group for the purpose of preparing offers, checking customer acceptance, processing contracts and services or assessing risks.

Companies in the SAXONIA Group are:

Company of the SAXONIA Group	Place of business
SAXONIA Holding GmbH	Dresden / Germany
SAXONIA Edelmetalle GmbH	Halsbrücke / Germany
SAXONIA Technical Materials GmbH	Hanau / Germany
BRAZETEC GmbH	Alzenau / Germany
Wieland Edelmetalle GmbH	Pforzheim / Germany
Italbras SpA	Vicenza / Italy
Doduco Contacts and Refining GmbH	Pforzheim / Germany
Doduco Solution GmbH	Pforzheim / Germany
Doduco Technical Solution GmbH	Sinsheim / Germany
Doduco Espana S.L.	Madrid / Spain

4.2 External service providers

We sometimes use external service providers to fulfill our contractual and legal obligations. The following service providers work for the companies in the SAXONIA Group:

Service provider	Order data processing according to
File and data shredder	Archiving and destruction of files and data carriers/storage media
Freight forwarding, postal and parcel services	Shipping and collection of goods and mail
IT service provider	Maintenance and support for the data processing programs used
Credit insurers	Credit insurance
Debt collection company	Collection of receivables
Lawyers	Legal services
Credit reporting agencies	Obtaining information

4.3 Public bodies and institutions

These are, for example, tax authorities if there is a legal, judicial or official obligation or order to fulfill our legal reporting obligations.

4.4 More recipients

Other data recipients may include those entities for which you have given us your consent to transfer data.

5. DATA TRANSFER TO COUNTRIES OUTSIDE THE EUROPEAN UNION (THIRD COUNTRY)

Personal data will only be transferred to locations outside the European Union (so-called third countries) if this is necessary to carry out your orders (e.g. payment orders, transport orders for deliveries and collections, transfer orders), is required by law or you have given us your consent have granted.

6. DURATION OF DATA STORAGE

We process and store your personal data for as long as it is necessary to fulfill our contractual and legal obligations. It should be noted that our business relationship can be a long-term business relationship (e.g. managing precious metal accounts).

If the data is no longer required to fulfill contractual or legal obligations (e.g. statutory retention requirements), it will be deleted. The legal retention obligations with a commercial and tax law background are based, among other things, on the requirements of the Commercial Code (HGB) and the Tax Code (AO).

7. RIGHTS OF THE DATA SUBJECT

7.1 Right to object

You have the right to object to the processing of your personal data. If we process your data to protect legitimate interests, you can object to this processing for reasons relating to your particular situation.
To do this, send us an email to datenschutz@saxonia.de

7.2 Right to information

You have the right to information about the personal data we store about you.
To do this, send us an email to datenschutz@saxonia.de

7.3 Right to deletion / right to rectification

You have the right to correct incorrect data, block your data, transfer data and delete your personal data.

To do this, send us an email to datenschutz@saxonia.de

7.4 Right of appeal

You have the right to contact our data protection officer or the data protection supervisory authority with a complaint.

7.5 Revocation of consent

If you have given your consent, you have the right to revoke your consent at any time. This does not affect the lawfulness of the processing carried out based on consent until its revocation.