Privacy Policy - Europe

Privacy Policy for Applicants, Customers, and Business Partners

1. Data Controller

ITW Fastener Products GmbH
Am Pulverhäuschen 7
67677 Enkenbach-Alsenborn

2. Data Protection Officer

Data Protection Officer
c/o ITW Fastener Products GmbH
Am Pulverhäuschen 7
67677 Enkenbach-Alsenborn, Germany
Email: datenschutz@itwfasteners.com

3. General Information on Data Processing

We process personal data in accordance with the provisions of the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and other relevant data protection regulations. This Privacy Policy informs you about the nature, scope, and purpose of collecting and using personal data in the context of job applications, customer relationships, and business partnerships.

4. Data Processing of Applicants

Purpose of Processing:

Execution of the application process
Communication with applicants
Documentation of selection procedures
Defense against potential legal claims related to the application process

Types of Data Processed:

Master data (name, contact details)
Application documents (cover letter, résumé, certificates, etc.)
Qualifications, potentially health-related data (if relevant to the position)

Legal Basis:

Art. 6(1)(b) GDPR (pre-contractual steps)
Sec. 26 BDSG (data processing in the employment context)
Art. 6(1)(c) GDPR (legal obligation), Art. 6(1)(f) GDPR (legitimate interests)
Art. 6(1)(a) GDPR (consent)

Retention Period:

Data is retained for a maximum of six months after completion of the application process, unless an employment relationship is established. Longer retention may occur to protect our legitimate interests under Art. 6(1)(f) GDPR, especially for the defense of legal claims related to the application process (e.g., based on the German General Equal Treatment Act – AGG).
If you consent to being included in an applicant pool, data will be retained according to the duration specified in the consent.

5. Data Processing of Customers and Business Partners

Purpose of Processing:

Initiation, execution, and settlement of contractual relationships
Communication
Accounting and invoicing
Legal obligations (e.g., tax-related retention duties)

Types of Data Processed:

Contact and address data
Contractual content, payment details
Communication records
Contact persons’ data within your company, if applicable

Legal Basis:

Art. 6(1)(b) GDPR (performance of a contract)
Art. 6(1)(c) GDPR (legal obligation)
Art. 6(1)(f) GDPR (legitimate interest)

Our legitimate interests include responding to your inquiries and defending against potential legal claims.

Retention Period:

Retention periods depend on the purpose for which the data is processed and the specific system or tool in which it is stored. It is not feasible to list all applicable retention periods in a comprehensive format. In general, data will be retained:

As long as necessary for the respective purpose
Beyond the duration of the business relationship if required
In accordance with applicable legal retention obligations
If needed for the establishment, exercise, or defense of legal claims

6. Disclosure to Third Parties

We only share your personal data with parties that require it to fulfill our contractual and legal duties. This may include service providers and other entities within our corporate group. Your data may specifically be shared with:

Our parent company and affiliated companies
IT service providers
Waste disposal providers
Public authorities, offices, banks
Individuals providing goods or services to the controller (e.g., financial, tax, or legal advisors, other consultants)
Other service providers assisting in the recruitment process

Some recipients may be located in countries outside the EU that may not provide an adequate level of data protection compared to EU standards. In such cases, data transfers are generally carried out based on EU Standard Contractual Clauses. You may request a copy of these safeguards by emailing datenschutz@itwfasteners.com.

7. Your Rights

You have the following rights at any time:

Right of access (Art. 15 GDPR)
Right to rectification (Art. 16 GDPR)
Right to erasure (Art. 17 GDPR)
Right to restriction of processing (Art. 18 GDPR)
Right to data portability (Art. 20 GDPR)
Right to object (Art. 21 GDPR)
Right to withdraw consent with future effect (Art. 7(3) GDPR)

To withdraw consent, simply send an email to datenschutz@itwfasteners.com.

You also have the right to lodge a complaint with the supervisory authority of your choice (Art. 77 GDPR).

8. Obligation to Provide Data

In the context of applications, contracts, or business relationships, the provision of certain personal data is necessary. Without this data, we cannot proceed with the application process or establish a business relationship.

9. Automated Decision-Making

Automated decision-making or profiling does not take place.

Right to Object under Art. 21 GDPR

You have the right to object at any time to the processing of your personal data based on Art. 6(1)(f) GDPR due to reasons arising from your particular situation. We will cease processing your personal data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.

You may object to the processing of your personal data for direct marketing purposes, including profiling related to such marketing, at any time and without stating reasons.

Latest revision of this Privacy Policy: April 2025