Privacy Policy

We, BWT Holding GmbH (please find the contact details below) and asso­ci­ated compa­nies, are pleased that you are visiting our website! The protec­tion of your data and your privacy are a special concern for our company.

The use of our website is possible without the indi­ca­tion of personal data. In case you would like to make use of specific appli­ca­tions of our company the processing of personal data may be neces­sary. For the circum­stance, that processing of personal data is neces­sary and a legal base therefor does not exist, we seek your consent.

The processing of personal data takes place in order with the General Data Protec­tion Regu­la­tion (GDPR) and the respec­tive country-specific data protec­tion regu­la­tions. By means of this data protec­tion decla­ra­tion our company would like to inform the public about the type, extent and purpose concerning the personal data collected, used and processed. Further we want to inform you about your rights.

We have taken tech­nical and orga­ni­za­tional measures to protect your data against loss, modi­fi­ca­tion or unau­tho­rized access. We contin­u­ously improve these secu­rity measures according to the tech­no­log­ical devel­op­ment.

The provi­sions below serve to provide infor­ma­tion as to the manner, extent and purpose for collecting, using and processing personal infor­ma­tion by the BWT Holding GmbH and relating sub websites, with excep­tion of web sites that are controlled or run by third parties. Please be aware that we are not respon­sible and cannot take influ­ence on the content of websites or tasks of third parties.

 

1. General

The data protec­tion decla­ra­tion of our company is based on the terms of the GDPR.

“personal infor­ma­tion” is data that, when submitted, is able to deter­mine your iden­tity or enables your iden­tity to be deter­mined. “Only indi­rectly person­ally iden­ti­fi­ably infor­ma­tion” is data by which clients, service providers or recip­i­ents of a commu­ni­ca­tion cannot deter­mine the iden­tity of a specific indi­vidual using means that are permitted by law. “Non-personal infor­ma­tion” is anonymized and cannot, under any circum­stances, be attrib­uted to specific indi­vid­uals and is there­fore infor­ma­tion that is not subject to the Privacy Policy governing personal data.

“data subject” means an iden­ti­fi­able natural person whose personal data is processed by the controller.

“processing” means any oper­a­tion or set of oper­a­tions which is performed on personal data or on sets of personal data, whether or not by auto­mated means, such as collec­tion, recording, organ­i­sa­tion, struc­turing, storage, adap­ta­tion or alter­ation, retrieval, consul­ta­tion, use, disclo­sure by trans­mis­sion, dissem­i­na­tion or other­wise making avail­able, align­ment or combi­na­tion, restric­tion, erasure or destruc­tion.

“controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, deter­mines the purposes and means of the processing of personal data; where the purposes and means of such processing are deter­mined by Union or Member State law, the controller or the specific criteria for its nomi­na­tion may be provided for by Union or Member State law.

“third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are autho­rised to process personal data.

“consent” of the data subject means any freely given, specific, informed and unam­biguous indi­ca­tion of the data subject's wishes by which he or she, by a state­ment or by a clear affir­ma­tive action, signi­fies agree­ment to the processing of personal data relating to him or her.

Personal data is only processed by our company in accor­dance to the data protec­tion regu­la­tions in force. In case you corre­spond with our company or fill in a form with your data, you accept that the data is processed for the mentioned purpose.

 

2. Name and address concerning the controller and contact partner

The body respon­sible for collecting, processing and using your personal data in terms of the GDPR such as Federal data protec­tion laws is:

BWT Holding GmbH
Walter-Simmer-Str. 4
A-5310 Mondsee

The data protec­tion officer volun­tarily appointed by the respon­sible person can be reached under the following contact data:

EY Law – Pelz­mann Gall Größ Recht­sanwälte GmbH  
Wagramer Straße 19/33
1220 Wien, Öster­reich 
Email: daten­[email protected] 

 

3. Processing personal data

We process personal data for in this data protec­tion decla­ra­tion mentioned purpose. Your personal data is not trans­mitted to a third party, with excep­tion for the cases mentioned in this data protec­tion decla­ra­tion or binding national law.

In case of partic­ular offers on our web site – such as user account, newsletter, contact – it may be neces­sary to sign up before, which leads to a needed proces­sion of your personal data. Your data is only used, if you trans­mitted our company your personal data and agreed before­hand. There­fore we kindly ask you to give us your consent. Further we provide infor­ma­tion via a hyper­link.

3.1. Online shop and user-regis­tra­tion

You can order in our online shop without regis­tra­tion or user account. The user account can be deleted at any time. Data, which was announced to our company in accor­dance with your order in the online shop are neces­sary for the trans­ac­tion of the contract such as for the reason of a future customer service. These data is processed and used by our company for that reason only.

By sending the order form without a regis­tra­tion or creating a user account your personal data (title, name, country of origin, e-mail address) are processed.

If you give your consent to this processing, Art. 6 Para. 1 lit. a) GDPR is the legal basis for this processing. If the opening of the user account is also intended to lead to the initi­a­tion of a contrac­tual rela­tion­ship with us or to fulfil an existing contract with us, the legal basis for this processing is also Art. 6 Para. 1 lit. b) GDPR. You may revoke your prior consent to the processing of your personal data at any time under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent.

MPAY24 services of the company mPAY24 GmbH, Grüngasse 16, 1050 Vienna, is used to process purchase trans­ac­tions in the online shop. A data processing agree­ment has been entered into with mPAY24.The data disclosed in the order place­ment is provided to parties involved in the online shop­ping (online retailer, which has been purchased from, and payment system oper­a­tors, where the payment was carried out) in the required extent. The payment settle­ment is carried out by payment system oper­a­tors (banks and credit card orga­ni­za­tions) who are autho­rized to carry out the respec­tive payment proce­dure and have appro­pri­ately secured systems. Data transfer is neces­sary to carry out payments remotely and to enable the use of mPAY24.

MPAY24 does not pass on data to third parties unless mPAY24 is legally or by judi­cial assign­ments obliged to do so or a transfer of the data is neces­sary in order to take legal action against fraud­u­lent access.

Logistic services of the company LKV Logistik GmbH, Salzach­tal­straße 47, 5400 Hallein are used to process purchase trans­ac­tions in the online shop. The data disclosed in the ship­ment process is provided by LKV Logistik GmbH to parties involved in the online shop­ping in the required extent. LKV Logistik GmbH does not pass on data to third parties unless LKV Logistik GmbH is legally or by judi­cial assign­ments obliged to do so.

3.2. User account

A user account is required for the use of the partner portal and for the regis­tra­tion of prod­ucts. The user account can be deleted by you at any time. Data commu­ni­cated in the user account are neces­sary for the purpose of customer service and customer care and are processed and used by us in this respect. Some of the services we provide require coop­er­a­tion with partner compa­nies. If a user makes use of one of these services, we exchange names or other contact infor­ma­tion with these partner compa­nies so that they can carry out their activ­i­ties. However, our partner compa­nies may not use the infor­ma­tion provided for purposes other than those related to the service.

3.3. Newsletter

We offer you different types of newslet­ters via e-mail. You can sign up for a newsletter during regis­tra­tion with your explicit approval or by disclo­sure of your e-mail address for this reason. The personal data collected as part of a regis­tra­tion for the newsletter will only be used to send our newsletter. The newsletter is only trans­mitted to your disclosed e-mail address. In addi­tion we kindly ask you to confirm that you are owner of the e-mail address such as your agree­ment for receiving the newsletter.

During the regis­tra­tion for the newsletter, we process your personal data from the contact fields (title, name, country of origin, e-mail address). Purpose of the process is the ship­ping of infor­ma­tion concerning prod­ucts, services and events.

The legal basis for this is Art. 6 Para. 1 lit. a) GDPR.

You may revoke your prior consent to the processing of your personal data at any time under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent or to use the termination-link in each newsletter.

3.4. Lottery

Lotteries are orga­nized on our web site at times. Partic­i­pa­tion does not require an user account. Your data is only used within the lottery, except some­thing else was agreed in the condi­tions of partic­i­pa­tion.

When regis­tering to take part in the lottery your personal data (title, name, country of origin, e-mail address) are processed. Purpose of the process is supply of infor­ma­tion concerning prod­ucts, services and events.

The legal basis for this is Art. 6 Para. 1 lit. a) GDPR. You may revoke your prior consent to the processing of your personal data at any time under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent. 

3.5. Product regis­tra­tion

The regis­tra­tion of your product on our website for use of free main­te­nance and repair service reminder via e-mail is optional.

Upon regis­tra­tion of the BWT product, your personal data (title, name, country of origin, e-mail address) will be processed. The purpose of data processing is to supply infor­ma­tion about prod­ucts and services.

The legal basis for this is Art. 6 Para. 1 lit. a) GDPR.

You may revoke your prior consent to the processing of your personal data at any time under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent.

You have the option to register your BWT product on our website at www.bwt-service.com and you can avail your­self of our free reminder service for main­te­nance and service steps. The reminder is sent by email. When you register the BWT product, your personal data from the contact fields will be processed (title, name, address, tele­phone number, email address). The purpose of the data processing is to send infor­ma­tion on prod­ucts and services. 
The legal basis for the processing is Article 6 (1) (a) GDPR. You can with­draw your consent to the processing of the data at any time with effect for the future pursuant to Article 7 (3) GDPR. All you need to do is inform us of your with­drawal of consent.

While regis­tering the product, you also have the option of linking your­self and your device with a service partner. This means that a BWT service partner (partner company) that has the code supplied with the product (e.g. executing instal­la­tion company) can view the spec­i­fied customer data, the product as well as the current status of the product on the BWT partner portal. The sharing of this infor­ma­tion with the service partner is for service purposes. Our partner compa­nies are only permitted to use the trans­ferred infor­ma­tion for service purposes for our customers.

The legal basis for the processing is Article 6 (1) (a) GDPR. You can with­draw your consent to the processing of the data at any time with effect for the future pursuant to Article 7 (3) GDPR. All you need to do is inform us of your with­drawal of consent. 

3.6. E-mail Noti­fi­ca­tions (Send­Grid)

The dispatch of account- and product-specific noti­fi­ca­tions (status messages, warning and error messages), as well as e-mail confir­ma­tions from contact forms is carried out via an external service of the company Send­Grid.

• Specif­i­cally, the following personal data will be passed on for processing:
• Recip­ient's e-mail address

Personal salu­ta­tion

In order to better support you with prob­lems regarding your requests, your customer account and your product noti­fi­ca­tions, the following events will be stored for a maximum of 30 days:

• E-mail deliv­ered to receiving server
• Email deliv­ered to receiving server - Spam
• Email deliv­ered to receiving server - Bounce
• E-mail deliv­ered to receiving server - blocked
• E-mail opened
• Link inside the e-mail clicked

An data processing agree­ment pursuant to Art. 28 DSGVO has been concluded with this service provider.

3.7. Contact via our website

Our website contains a contact form that enables a quick elec­tronic contact to our enter­prise, as well as direct commu­ni­ca­tion with us, which also includes a general address of the so-called elec­tronic mail (e-mail address). If a data subject contacts our company via a contact form, the personal data trans­mitted by the data subject are auto­mat­i­cally stored.

In case of contact via the contact form your personal data provided in the contact fields (title, name, country of origin, e-mail address) are processed. Purpose of the process is the handling of your request.

The legal basis for this is Art. 6 Para. 1 lit. b) GDPR.

3.8. Find an installer

You can contact a BWT drinking water profes­sional or BWT partner installer via our website. The data provided by you in the contact fields is auto­mat­i­cally processed and trans­mitted to the installer you chose. A copy of the message is sent to the BWT Holding GmbH.

In case of contacting us your personal data provided (title, name, country of origin, e-mail address) is processed. Purpose of the process is the handling of pre-contrac­tual proce­dures.

The legal basis for this is Art. 6 Para. 1 lit. b) GDPR.

3.9 Part­nerweb

Our BWT drinking water profes­sionals and BWT partner installers are regis­tered in our Part­nerweb (plat­form for installers). Upon regis­tra­tion, the personal data (title, name, country of origin, e-mail address) of the BWT drinking water profes­sional/BWT partner installer will be processed. The personal data is trans­mitted to Connex Marketing GmbH, Dr-Schauer-Straße 26, 4600 Wels, to enable the BWT drinking water profes­sionals and BWT partner installers access to our bonus program Pearls & More. A data processing agree­ment has been entered into with Connex Marketing GmbH.

There is no processing of customer data. Purpose of the process is the handling of pre-contrac­tual and contrac­tual proce­dures.

The legal basis for this is Art. 6 Para. 1 lit. b) GDPR.

3.10. Job portal

3.10.1. Online Appli­ca­tion

Personal data, which is provided by online appli­ca­tion, will be kept confi­den­tial. These data will be used only for the execu­tion of the appli­ca­tion process. As soon you send an online appli­ca­tion via the rele­vant mask you will receive a confir­ma­tion e-mail. Your personal data is stored as long as it is neces­sary for the appli­ca­tion process.

For the appli­ca­tion process the following infor­ma­tion is rele­vant: salu­ta­tion, title, first and last name, address, nation­ality, date of birth, country, tele­phone number, email address, possibly completed pres­ence or civil service, infor­ma­tion on the desired posi­tion.

By providing your appli­ca­tion, you cove consent to the processing of your personal data for the purpose of the appli­ca­tion process as set out in this privacy policy. 

The legal basis for this is Art. 6 Para. 1 lit. b) GDPR and Art. 6 Para. 1 lit. f).If you apply for an adver­tised posi­tion in a third country, your data will be processed at your request to carry out pre-contrac­tual measures according to Art. 49 Para. 1 lit. b) GDPR.

Further legal basis for the processing of special cate­gories of data referred to under Art. 9 Para. 1 GDPR, which is provided during the appli­ca­tion process on a volun­tary basis, is Art. 9 Para. 2 lit. b) GDPR (e.g. health data e.g. severe disability or ethnic origin). Further legal basis for the processing of special cate­gories of data referred to under Art. 9 Para. 1 GDPR, which is requested by us during the appli­ca­tion process is Art. 9 Para. 2 lit. a) GDPR (e.g. health data neces­sary for profes­sional prac­tice)

By filling in this form you can apply for posi­tions in our company. For the appli­ca­tion process, the neces­sary infor­ma­tion and personal details, such as name, address, e-mail address or details of nation­ality and birth dates recorded. You are able to upload indi­vidual appli­ca­tion docu­ments (such as CV, cover letter, letter of moti­va­tion, creden­tials and photo). The spec­i­fied infor­ma­tion and uploaded docu­ments are added to our job portal and stored there.

If you apply for an adver­tised job via the job portal, your data can only be viewed and processed by the respon­sible personnel of the personnel depart­ment as well as by the respon­sible employees of the tendering depart­ment.

With an unso­licited appli­ca­tion via our job portal, you provide us with your personal data for the purpose of finding a suit­able job. Your data can then be viewed by the personnel depart­ments of BWT and by the employees involved in the appli­ca­tion process to check your profile for suit­able job offers.

In addi­tion, we check whether your appli­ca­tion is suit­able for other vacan­cies in Austria, at Euro­pean loca­tions or subsidiaries of BWT Holding GmbH. In the case of a suit­able offer, the specific forwarding of your appli­ca­tion data by the respon­sible personnel depart­ment takes place.

Appli­cant data provided in the online appli­ca­tion process can be forwarded within BWT in Austria as well as to Euro­pean loca­tions of Group subsidiaries. Your answers and infor­ma­tion provided during the appli­ca­tion process will be gener­ally stored with your name up to six months after the appli­ca­tion process has been completed. There­after, the results are stored only in anony­mous form for statis­tical analysis. This statistic record does not allow any conclu­sions about your person.

When regis­tering for the Job Portal, you may give consent that the infor­ma­tion you provide may be kept in evidence. The evidence is held for a period of two years. If there is a posi­tion to be filled in the company, you give consent that BWT and its subsidiaries may match your personal data with the corre­sponding job profile while kept in evidence.

The legal basis for this is Art. 6 Para. 1 lit. a) GDPR. You may revoke your prior consent to the processing of your personal data at any time under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent.

We use tech­nical and orga­ni­za­tional secu­rity measures to protect your data against acci­dental or inten­tional manip­u­la­tion, loss, destruc­tion or access by unau­tho­rized persons. The trans­mis­sion of your data on the Internet is encrypted. Our secu­rity measures are regu­larly reviewed and revised in line with tech­no­log­ical devel­op­ments.

3.10.2. Form for try-out-days

For students, which want to partic­i­pate in BWTs’ try-out-days the following infor­ma­tion is rele­vant: salu­ta­tion, first and last name, date of birth, address, tele­phone number, email address, name and tele­phone of the legal guardian. These data will be used only for the execu­tion of the try-out-days and gener­ally stored up to six months after the appli­ca­tion. There­after, the results are stored only in anony­mous form for statis­tical analysis. Students under the age of 14 need to provide a parental consent.

The legal basis for this is Art. 6 Para. 1 lit. b) GDPR.

3.11. Pearl Water Manager App

Our Pearl Water Manager App is avail­able for iOS (Apple App Store) and Android (Google Play). Upon regis­tra­tion you confirm the processing of your data. The personal data, water quality data collected through the sensor and data about your swim­ming pool will be processed and trans­ferred to Ondilo (Ondilo SAS 81842362600030 – 162 Avenue Robert Schuman ZA la Pile, 13760 Saint-Cannat, France) to enable the func­tion­ality of the App. A data process agree­ment regarding to Article 28 GDPR has been entered into with Ondilo.

The data will be stored for until you request to delete your data. Please contact daten­[email protected] if you wish to delete your data.

The legal basis for this is Art. 6 Para. 1 lit. a) GDPR.

In the context of the processing of personal data, Ondilo collects and processes the following data for the purposes detailed below. Your data will not be shared with other parties.

Purpose of the processing	Cate­gories of Personal Data Processed	Legal basis of the processing oper­a­tion
Manage­ment and follow-up of customer requests, through email or webform on bwt.com	Last name, first name, email, phone number, country, place of purchase of the product, UUID of the product, private or profes­sional status, request detail, type of request, OS used, request history.	The Processing is neces­sary for the perfor­mance of the contract that binds us or for carrying out measures prior to the conclu­sion of a contract with you.
Manage­ment and moni­toring of data collected while providing the service	Pool/SPA data : Treat­ment of the pool/SPA, type of pool/SPA, average number of users of the pool/SPA, stock of disin­fec­tant and/or other main­te­nance prod­ucts, size of the pool/SPA, time of pres­ence and absence, loca­tion of the pool, average water temper­a­ture and in real time, consump­tion of disin­fec­tant and/or other cleaning prod­ucts over the season, consump­tion status of the cleaning prod­ucts, alka­linity level, ORP level, hard­ness level, conduc­tivity level, Ph, chlo­rine or bromine, salt level and average use time of the pool/SPA over the year. The pool/spa equip­ment present such as cover, cover, shel­ters, pump model, type of stairs, chlo­ri­nator, pH control, ozonator, bromi­nator, UV lamp, filter type and model. Rate of filter replace­ment or cleaning. Pack­aging of disin­fec­tant and/or other cleaning prod­ucts. Pool or spa coating (liner, tiles, shell, acrylic, abs, …). Data collected through the sensor: oper­ating system of the smart­phone, UUID number, place of purchase of the sensor, IP addresses, loca­tion data (depending on the permis­sions you have granted us)	The Treat­ment is neces­sary for the provi­sion of the service. Concerning the geolo­ca­tion data, they are collected only with your consent.
Manage­ment and follow-up of recom­men­da­tions	Customer recom­men­da­tion based on data collected through the sensor and the customer infor­ma­tion provided	The Treat­ment is neces­sary for the provi­sion of the service.
Service Improve­ment	Analysis of the profile, inter­ests and behav­iour of users, as well as on the measures carried out by the connected sensor in order to improve the content and func­tion­ality of the services, and to better under­stand customer needs.	The processing of this data is carried out in our legit­i­mate interest but on the basis of anonymised and non-identifying data.

3.12. Microsoft Clarity

This is an analytics tool that provides statis­tics on website usage, session recording, and heatmaps.

Processing Company
Microsoft Ireland Oper­a­tions Limited
One Microsoft Place, South County Busi­ness Park, Leop­ard­stown, Dublin 18
D18 P521, Ireland

Purpose of Data
This list repre­sents the purposes of data collec­tion and processing.

• Customer Behavior Analysis
• Tech­nolo­gies Used
• Tracking Code
• Collected Data

This list contains all (personal) data collected by or through the use of this service.

• Browser Infor­ma­tion
• Country
• Clicked Links
• Mouse Move­ments
• Oper­ating System Infor­ma­tion
• Referrer URL
• User Behavior
• Clicks
• Legal Basis

The following is the required legal basis for data processing.

Art. 6 para. 1 sentence 1 lit. a GDPR
Loca­tion of Processing
United States of America

Reten­tion Period
The reten­tion period is the length of time collected data is stored for processing. The data must be deleted as soon as it is no longer needed for the spec­i­fied processing purposes.

The data will be deleted as soon as it is no longer needed for processing.

Data Recip­i­ents

Microsoft Corpo­ra­tion
Data Protec­tion Officer of the Processing Company

Below is the email address of the data protec­tion officer of the processing company. Data protec­tion officer

Click here to read the privacy policy of the processor. Privacy Policy

 

4. Period for which the personal data will be stored

We store your personal Data, where required, for the dura­tion of the entire busi­ness rela­tion­ship (initi­a­tion, trans­ac­tion, fulfil­ment of a contract) and more­over pursuant to the storage and docu­men­ta­tion oblig­a­tions and for defence of legal claims. The storage period results from the storage oblig­a­tions and periods of limi­ta­tion. The period of limi­ta­tion according to the Austrian Corpo­rate Code and the Austrian Fiscal Code is 7 years, according to the Equal Treat­ment Act 6 months. In certain cases a longer storage oblig­a­tion might be reason­able.

 

5. Rights of the data subject

With regard to the data processing to be described in more detail below, users and data subjects have the right

• to confir­ma­tion of whether data concerning them is being processed, infor­ma­tion about the data being processed, further infor­ma­tion about the nature of the data processing, and copies of the data (cf. also Art. 15 GDPR);
• to correct or complete incor­rect or incom­plete data (cf. also Art. 16 GDPR);
• to the imme­diate dele­tion of data concerning them (cf. also Art. 17 DSGVO), or, alter­na­tively, if further processing is neces­sary as stip­u­lated in Art. 17 Para. 3 GDPR, to restrict said processing per Art. 18 GDPR;
• to receive copies of the data concerning them and/or provided by them and to have the same trans­mitted to other providers/controllers (cf. also Art. 20 GDPR);
• to file complaints with the super­vi­sory authority if they believe that data concerning them is being processed by the controller in breach of data protec­tion provi­sions (see also Art. 77 GDPR). In Austria, this is the Data Protec­tion Authority.

In addi­tion, the controller is obliged to inform all recip­i­ents to whom it discloses data of any such correc­tions, dele­tions, or restric­tions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR. However, this oblig­a­tion does not apply if such noti­fi­ca­tion is impos­sible or involves a dispro­por­tionate effort. Never­the­less, users have a right to infor­ma­tion about these recip­i­ents.

Like­wise, under Art. 21 GDPR, users and data subjects have the right to object to the controller's future processing of their data pursuant to Art. 6 Para. 1 lit. f) GDPR. In partic­ular, an objec­tion to data processing for the purpose of direct adver­tising is permis­sible.

These rights can be enforced at any time, in writing, to BWT Holding GmbH. Please note that infor­ma­tion can only be provided to you in case of a corre­sponding evidence of your iden­tity.

In case you want to delete your customer account finally, the data stored in your customer account is going to be auto­mat­i­cally deleted.

 

01/10/2020