Data Privacy Policy

We are committed to protecting your personal data. The principles for processing personal data under the General Data Protection Regulation (GDPR) – transparency, lawfulness, purpose limitation, data accuracy and data minimization – also determine how we handle your data. We want to uphold the trust you place in us in this regard as well. For this reason, we protect your personal data in particular from access by unauthorized persons. 

The extent of collection, processing and use of your data depends on the form in which you use our services. By visiting our home page, you agree that we can collect, process, use and store personal data from you, to the extent outlined below. Naturally, we treat this data as confidential. We will revise and amend our Data Privacy Policy on a regular basis. This policy was last updated in May 2018.

The controller is: 

AISWEI Technology Co., Ltd.

Room 903-905, No. 757 Mengzi Road, Huangpu District,

Shanghai, P.R. China

Tel.: 021 - 8040 1346
www.aiswei-tech.com

I. General information: 

1.  Personal data           

Personal data is information about an identified or identifiable individual. This includes all information about your identity, such as your name, your e-mail address or your address. In contrast, information that cannot be connected to your identity (e.g. statistical information, such as on the number of online service users) is not considered personal information. 

As a rule, our online service can be used without disclosing your identity and without providing personal data. Only general information about your visit to our online site will be collected. However, personal data will be collected from you for some of the services offered. This information will then be processed by us only for the purpose of using this online service, especially for providing the desired information. When collecting personal data, only the data that is mandatory must be provided. Further information can be provided on a voluntary basis. We will indicate whether it is a required field or optional details. We provide specific details on this in the corresponding section of this Data Privacy Policy. 

Automated decision-making based on your personal data is not applied to the use of our online service.

2. Collection, processing and use of personal data when visiting our home page 

When you visit our home page, certain data is collected automatically and in an anonymous form. This includes, but is not limited to, data about 

• the identity of your internet service provider,
• the browser type you use and the respective software version,
• screen resolution,
• the operating system you use,
• whether you are accessing our page from a desktop PC or mobile device,
• which of our pages you visit,
• the length of time you spend on our site,
• the referrer URL; this is information about the previous page you visited that linked you to our home page,
• the IP address of your device,
• date and time of the server query and
• the location of your device.

We collect all of this data for analytical purposes. It will be evaluated to improve our service. Each piece of information per se cannot identify a particular person. The aforementioned data is mainly device-related. However, when combined with other data it might be able to identify specific persons in some cases. We use the data collected for statistical purposes, to evaluate the attractiveness of our offers, and to evaluate user behavior, so that we may improve and expand our service range in this manner, as well as identify errors and optimize processes. Data is combined only if needed for the aforementioned purposes. Therefore, the purpose of data processing is the interest of our company and the interest of our customers in a wide range of information (Art. 6 (1) (1) f) GDPR).

Your personal data will be encrypted when transmitted on the internet. For data transmission, we use an SSL encryption (Secure Sockets Layer).

The data we save will be deleted if it is no longer needed for the purposes indicated. The data will be deleted after completion of the purposes indicated if it is not, or does not need to be, stored further for documentation purposes (such as due to applicable retention obligations).

3.  Legal basis for data processing

Insofar as we obtain consent to process your personal data, Article 6 (1) a) GDPR serves as the legal basis for data processing.

Insofar as your personal data is processed because it is required to fullfil a contract or as part of a contract-like relationship with you, Article 6 (1) b) GDPR serves as the legal basis for data processing.

Insofar as we process your personal data to fullfil a legal obligation, Article 6 (1) c) GDPR serves as the legal basis for data processing.

As a legal basis for data processing, Article 6 (1) f) GDPR is taken into further consideration if the processing of your personal data is required to protect a legitimate interest of our company or a third party and your interests, basic rights and freedoms do not require personal data to be protected.

In line with this Data Privacy Policy, we always indicate on which legal basis we process your personal data.

4. Analytical program

a) This website uses MATOMO, a service from the provider InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand. MATOMO uses cookies. These are text files that are saved on your computer and allow for analysis of the use of the website (for more details see I. 3.) The information generated by the cookie about your use of the website will generally be transmitted to and saved by a server of MATOMO in New Zealand. In the event that IP anonymization is activated on this website, however, your IP address will be abbreviated in advance by MATOMO within the member states of the European Union or in other countries that are members of the European Economic Area agreement. Only in exceptional cases will the full IP address be sent to a MATOMO server in the New Zealand and abbreviated there. For more details, see https://matomo.org/.

On behalf of the operator of this website, MATOMO will use the information to evaluate your use of the website, to collect reports on the website activities, and to perform other services related to the website use and internet use for the website operator. The IP address sent by your browser for MATOMO will not be combined with other data of MATOMO.

For more data privacy information about MATOMO Analytics please visit:  https://matomo.org/privacy-policy/.

If you do not agree to the storage and analysis of this data on your visit, you can object to the storage and use at any time with one click. In this case, your browser will store an "opt-out cookie" and MATOMO will not collect any session information. Please note that full deletion of your cookies will mean that the opt-out cookie is deleted as well and may have to be reactivated by you.

The analysis and evaluation of personal or anonymized data by MATOMO is for the purposes set forth in I. 1. We are of the opinion that due to the protective measures taken (anonymization and the right of withdrawal), data processing to optimize our online service can be considered a legitimate interest in data processing pursuant to Article 6 (1) f) GDPR.

b) We also use Google Analytics for statistical evaluations. Google Analytics is a web analytics service from Google Inc. (“Google”). Google Analytics uses "cookies," which are text files saved on your computer to help the website analyze how users use the site. The information generated by these cookies about your use of the website will generally be transmitted to and saved by Google in the United States. In the event that IP anonymization is activated on this website, however, your IP address will be abbreviated in advance by Google within the member states of the European Union or in other countries that are members of the European Economic Area agreement. Only in exceptional cases will the full IP address be sent to a Google server in the U.S. and abbreviated there. On behalf of the operator of this website, Google will use the information to evaluate your use of the website, to collect reports on the website activities, and to perform other services related to the website use and internet use for the website operator. The IP address sent by your browser for Google Analytics will not be combined with other data of Google. You can prevent cookies from being stored on your computer by using the relevant setting in your browser software. However, please note that in this case you may not be able to use all functions of this website. You can also prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by opening the following link and downloading and installing the browser plug-in: tools.google.com/dlpage/gaoptout.

For more information, see tools.google.com/dlpage/gaoptout or www.google.com/intl/de/analytics/privacyoverview.html (general information about Google Analytics and data protection). Please note that on our websites Google Analytics was expanded by the code “anonymizeIp();” to anonymize IP addresses, in which case the last byte is deleted.

We are of the opinion that due to the protective measures taken (anonymization and the right of withdrawal), data processing to optimize our online service can be considered a legitimate interest in data processing pursuant to Article 6 (1) f) GDPR.

5.   Use of cookies

We use cookies to give you the most customized offers possible. When visiting our home page, you have the option to reject the use of cookies. We recommend that you permit the use of cookies, because otherwise the use of our home page and our offers will be available to a limited extent only.

Cookies are small text files stored by your browser on your device. Until the end of your browser session, the cookies remain stored. They can also automatically complete certain information if you close our home page and re-open it. One example is the content of your shopping cart.

If you log in to our web shop with your personal login information, you can check the option "remember me." In this case, a cookie will be stored on your browser that identifies your computer the next time you visit our page. If you log off, this cookie will be deleted. 

a) This website uses the following kinds of cookies. Their scope and function are explained below:

• Transient cookies (see b)
• Stored cookies (see c).

b) Transient cookies are deleted automatically when you close your browser. This includes session cookies in particular. These store a session ID that can identify various queries of your browser from the session. This can recognize your computer when you return to our website. The session cookies will be deleted when you log out or close the browser.

c) Stored cookies are deleted automatically after a predefined time, which depends on the cookie. You can delete the cookies from the security settings of your browser at any time.

d) You can configure your browser settings as you choose and reject third-party cookies or all cookies, for instance. Note that in this case, you may not be able to use all functions of this website.

e) We use cookies to identify you during subsequent visits if you have an account with us. Otherwise you would have to log in each time you visit. 

f) The flash cookies used are not collected by your browser, but by your Flash plug-in. We also use HTML5 storage objects stored on your device. These objects store the required data independently of the browser you use and do not expire automatically. If you do not want the Flash cookies to be processed, you must install an Add-on, such as "Better Privacy" for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash Killer Cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. We also recommend deleting your cookies and browser history manually on a regular basis. 

Cookies are also used to make our services as effective, seamless and user-friendly as possible for the benefit of our customers. In the interest of the fastest and easiest possible use of our home page and service offers, we have also decided to use cookies. The legal basis is Art. 6 (1) (1) f) GPDR.

6.  Data subject rights

We place strong emphasis on explaining the processing of personal data as transparently as possible and informing you of your rights. If you would like more detailed information or wish to exercise your rights, you can contact us at any time so that we can take care of your concerns.

With regard to processing your personal data, you are entitled to extensive rights. In addition, you have a comprehensive right to information and can demand the correction and/or deletion or blocking of your personal data, if applicable. You can also demand a restriction of processing and have the right to lodge a complaint. With regard to the personal data you have transferred to us, you also have the right to data portability.

If you wish to exercise your rights and/or receive more information about them, please contact our customer service.

Any consent that you have provided can be withdrawn on request at any time with effect for the future. Withdrawing consent will not affect the lawfulness of the processing that was carried out between the time of consent and withdrawal. Please contact our customer service for more information.

Insofar as processing your personal data is not based on consent but another legal basis, you can object to this data processing. Once you object, there will be a review and, if necessary, termination of data processing. You will be informed of the results of the review and receive – if the data processing is to continue nevertheless – detailed information from us about why data processing is permitted.

Please note that even after the completion of a business relationship, we still store personal data. We can delete the personal data unless this is contraindicated by legal retention periods. Only after the end of the retention periods would we be able to fulfil a request for deletion. If you wish for your data to be deleted during the retention period, we will block the personal data from use until the retention period ends, i.e. we will not use it any further.

7. Service requests, contact, and other correspondence 

If you use the option to contact us, personal data will be collected and stored. The actual correspondence including the related personal data (name, e-mail address, etc.) you provide will be stored accordingly. The data is used only to conduct correspondence; we will ask your name in order to determine whether you are a commercial client or natural person. After completion of the correspondence, the personal data and content of the correspondence will be stored for documentation purposes, in order to ensure a consistent service practice in the event of any questions or similar cases. Of course, the personal data obtained in this regard will not be shared with unauthorized third parties. 

Processing takes place in your interest and upon your consent, as well as in the company's interest in specific handling of the correspondence (Art. 6 (1) a) f)).

8. Protection of minors

Children and youths below the age of 18 should not send personal data to us without the consent of their parents or guardians.

9. Links

Our home page includes links to offers from other providers. These links are marked accordingly. We have no influence on the content of the pages linked. If needed, see the linked page for information about its data privacy policies.

10. Newsletter

When you register for our newsletter, your e-mail address will be used for our own advertising purposes until you unsubscribe. You will receive regular information via e-mail on current topics and e-mails on special occasions, e.g. for special promotions. These e-mails may be personalized and tailored based on our information about you.

For subscribing to our newsletter, if you have not provided your consent in writing, we use what is known as the double opt-in process, which means that we will only send you a newsletter by e-mail when you have expressly confirmed to us in advance that we should activate newsletter delivery.  We will then send you a notification e-mail and ask you to confirm that you want to receive our newsletter by clicking the link included in the e-mail.

The personal data you send to us for your newsletter request is also processed in the US for the purposes of sending the newsletter and for marketing activities. We send this data to the company Salesforce.com EMEA Limited (Salesforce), village 9, floor 26 Salesforce Tower, 110 Bishopsgate, London, UK, EC2N 4AY. Pardot is software from this company for marketing automation. This software is also used for the above purposes with regard to customer data. Thus, in cooperation with Salesforce.com we are better able to customize our communications by evaluating the specific interests of our customers. We believe that communications that specifically address our customers' interests also benefit the customers. Because Salesforce.com is also a member of Privacy Shield in the US (https://www.privacyshield.gov/participant_search), we are confident that customer data is also processed in the US with a similar level of data protection to that provided under German law.

We use provider MailChimp to send our newsletter. MailChimp is a service of The Rocket Science Group, LLC, 512 Means Street, Suite 404, Atlanta, GA 30318 (“Rocket”). Rocket has signed the "Safe Harbor Agreement" on July 22, 2008, which is a data protection agreement between the EU and US.

The data stored upon registration will be sent to Rocket and stored by Rocket. The data entered at the time of registration will not be sent to other third parties. After registration, MailChimp will send you an e-mail to confirm your registration. MailChimp also offers a number of analysis options about how the newsletters are opened and used, e.g. the number of users to whom an e-mail was sent, whether e-mails were rejected and whether users unsubscribed from the list after receiving an e-mail . However, these analyses are group-related only and we do not use them for individual evaluation. MailChimp also uses the analytical tool Google Analytics (see above) from Google, Inc and in some cases includes it in the newsletter.

For more information about data privacy at MailChimp please visit: mailchimp.com/legal/privacy/

Because Rocket is also a member of Privacy Shield in the US (https://www.privacyshield.gov/participant_search), we are confident that customer data is also processed in the US with a similar level of data protection to that provided under German law. 

The legal basis for processing your data is your consent in accordance with Article 6 (1) a) GDPR, if you have expressly subscribed to the newsletter. In line with the legal specifications, it may also be possible for you to receive our newsletter from us without express consent because you have ordered goods or services from us, we obtained your e-mail address in this context and you did not object to receiving information by e-mail. In this case, the legal basis is our legitimate interest to communicate direct advertising to you in accordance with Article 6 (1) f) GDPR.

If you do not want to receive a newsletter from us at all, you can withdraw your given consent at any time with effect for the future or object to further receipt of e-mails, without other additional costs on top of the cost of the telephone call. Just use the unsubscribe link included in every newsletter or send a message to us or our data protection officer. 

Please note that we will analyze your user behavior when we send the newsletter. For the purpose of this analysis, the sent emails contain web beacons or tracking pixels, which are 1x1 pixel image files stored on our website. For the analyses, we link the data transmitted and the web beacons with your e-mail address and a personalized ID. We use the data thereby obtained to create a user profile so that we can tailor the newsletter to your particular interests. When you read our newsletter, we record which links you click to infer your personal interests. We link this data to actions that you carry out on our website. If you do not want us to do this, you should cancel your subscription. Tracking of this nature will also not be possible if your email application default settings have disabled the display of images. In this case, you will not see the full content of the newsletter and may not be able to use all functions. If you manually display the images, the tracking referred to above will take place.

The information will be stored for as long as you are subscribed to the newsletter. If you unsubscribe, we will store data anonymously and purely for statistical purposes.

11. Use of Pardot, Salesforce

We store only the personal data belonging to website users that have registered voluntarily / on their own initiative on our websites or used our newsletter offers (see I. 10) in order to receive information on products and services or download documents. If they have given their consent, they can also receive promotional e-mails that are relevant to their interests.

The forms on our websites are linked with Pardot. Pardot is marketing automation software by Salesforce.com EMEA Limited (Salesforce), village 9, floor 26 Salesforce Tower, 110 Bishopsgate, London, UK, EC2N 4AY.

Voluntarily provided personal data is initially stored in Pardot to then be processed using the Salesforce CREM system for the purpose of contacting and/or sending you information. Salesforce does not store any IP addresses but uses the individual assignment references “unique visitor ID” and “unique identifier.” Deriving personal information is not possible.

Here you can learn about how Salesforce processes your data when visiting websites. 

If you do not want Salesforce to carry out an pseudonymized analysis of your website use, you can object to this at any time. This objection also applies to the future. If you click on the link to object, you will save an opt-out cookie on your device, which will prevent your data from being collected during another visit to this website. 

We use Pardot as a marketing analysis service that makes it possible to maintain, assess and expand our online service and marketing communication and optimize the content on our websites. Furthermore, to protect users and partners, fraud and security risks can be detected and eliminated, if necessary. Data will be processed in Salesforce on our behalf using cookies. 

You can deactivate the storage of cookies in your web browser settings.

Registration for the Newsletter is done via the double opt-in process, which requires a personal reconfirmation via e-mail approval. You can unsubscribe from the newsletter at any time. 

Deactivate Pardot for our websites

If you choose this option, it can lead to functions being restricted and to the online service being less user-friendly.

12. Contact

There are a variety of ways to contact us, including via the contact form on our website. In addition, you can stay up to date with our newsletter by e-mail.

If you wish to use the contact form on our website, we will collect the personal data that you enter in the contact form, especially your name and e-mail address. We also store the IP address, date and time. We process the data sent via the contact form only for the purpose of responding to your queries or concerns.

You can decide for yourself which information to send us in the contact form. The legal basis for processing your data is your consent in accordance with Article 6 (1) a) GDPR. 

After your concerns have been addressed, we will store your data temporarily in the event of any other questions. You can request at any time that your data be deleted, otherwise it will be deleted after the matter has been addressed in full. This is without prejudice to legal retention obligations.

II. Integration of social media

We currently use these social media plug-ins:

• Twitter and
• LinkedIn. 

We use the "double-click solution." This means that when you visit our page, initially no personal data is shared with the plug-in providers. You can identify the plug-in providers with the first initial or logo shown in the box. We give you the option of communicating directly with the provider of the plug-in using the button. Only if you click on the area marked to activate it will the plug-in provider be informed that you accessed the website from our online services. The data listed under I. 2 will also be collected. Once the plug-in is activated, your personal data will be sent to the plug-in provider and stored there (in the US for US providers). Because the plug-in provider collects data using cookies in particular, we recommend that before clicking on the gray box, you delete all cookies in the security settings of your browser. 

We have no influence on the data collected or data processing methods, nor are we aware of the full extent of data collection, the purposes of processing, or the storage periods. We also do not have any information about the deletion of the data collected by the plug-in provider. 

The plug-in provider stores the data collected on you as a usage profile and uses it for purposes of advertising, market research and/or custom design of its website. An evaluation of this kind is made in particular (even for users not logged in) to show custom advertising and to inform other users of the social network about your activities on our website . You have the right to object to the creation of this usage profile, but to do so you must contact the relevant plug-in provider. Using the plug-ins we provide you with the option of interacting with the social networks and other users so that we can improve our offers and make them more interesting for you as the user. The legal basis for using the plug-ins is Art. 6 (6) (1) (1) f) GDPR.

Data will be shared regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged into the plug-in provider, the data that we collect on you will be associated directly with your account with the plug-in provider. If you click on the button and link the page, for instance, the plug-in provider will also store this information in your user account and make this public to your contacts. We recommend that after using a social network you log out regularly, especially before activating the button, in order to avoid association with your profile by the plug-in provider. 

More information about the purpose and scope of data collection and its processing by the plug-in provider can be found in the data privacy policies of these providers. There you will also find more information about your corresponding rights and setting options to protect your privacy.

Addresses of the plug-in providers and URL with their data privacy policies: 

a) Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; twitter.com/privacy. Twitter is part of the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.

b) LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; www.linkedin.com/legal/privacy-policy. LinkedIn is part of the EU-US-Privacy-Shield, www.privacyshield.gov/EU-US-Framework.

III. Contact persons for data protection

If you have questions about the collection, processing or use of your personal data that this Data Privacy Policy has not answered, or want to request the correction or deletion of your data, or withdraw previous consent, please contact:

AISWEI Technology Co., Ltd.

Room 903-905, No. 757 Mengzi Road, Huangpu District,

Shanghai, P.R. China

Tel.: 021 - 8040 1346
www.aiswei-tech.com

IV. Right to lodge a complaint

You have the right to report suspected infringements of provisions of the data protection laws and lodge a complaint with the responsible supervisory authority. You can send the complaint to:

Federal Commissioner for Data Protection and Freedom of Information
Husarenstrasse 30
53117 Bonn, Germany 

Tel.: 0228/9977990
Fax: 0228/997799-5550
E-mail: poststelle@bfdi.bund.de