URSA › Privacy statement (EU)

Privacy statement (EU)

Data protection information regarding our website

We are pleased about your visit on this Website. We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive ("GDPR").

In this data protection information, we explain which information (including personal data) are processed by us in connection with your visit and use of out aforementioned digital offer ("Website") the employment relationship.

  1. Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is ursa.ru. Any reference to "we" or "us" in this data protection information is a reference to the aforementioned entity.

  1. Which principles do we observe?

In order compliance with applicable data protection law, we only process your personal data on the basis of a statutory authorization or if you have declared your consent. This also applies for the processing of personal data for marketing purposes.

On this Website we may collect information that does not allow us to draw any direct conclusions about your person. In certain cases - especially when combined with other data - this information can nevertheless be considered as "personal data" under applicable data protection law. Furthermore, we may also collect information on this Website that does not enable us to identify you, directly or indirectly; this is the case, for example, with aggregated information about all users of this Website.

  1. Which data do we process?

You can access our Website without entering personal data (such as your name, your postal address or your e-mail address). Also in this case we must process certain information to enable you to access our Website. In addition, we use certain analysis methods on this Website and have integrated third-party functionalities ("social plug-ins").

  1. Logfiles: When you visit this Website, our web server automatically stores the domain name or IP address of the requesting computer (usually a computer of your internet access provider) including the date, time and duration of your visit, the subpages/URLs you visit and information about the application(s) and terminal(s) you use to view our pages.
  2. Cookies: In order to make our Website as user-friendly as possible, we - like many other website operators - use cookies. Cookies are small text files that are stored in your browser. These files help us to recognize certain preferences of our visitors when surfing and to design our site accordingly. Most of the cookies we use are session cookies. They are automatically deleted at the end of your visit. However, we also use permanent cookies. These serve to improve user guidance. Our cookies do not collect any personal data and are not suitable for identifying you on third-party Websites. You can set your browser so that it informs you about the placement of cookies so that the use of cookies becomes transparent for you. In principle, you can also refuse the acceptance of cookies via your browser settings. However, this may mean that you may not be able to use all the functions of the Website.
  3. Website analysis via Google Analytics: We use Google Analytics, a web analysis service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"), on our Website to continuously improve our Website. Google Analytics uses cookies which are stored on your computer and which enable analysis of the use of the Website. The information generated by the cookie about your use of this Website is usually sent to a Google server in Europe (or in a member state of the European Economic Area) for the anonymization of the IP address, so that a personal reference is excluded. Only after the IP address was anonymized the shortened IP address is transferred to a Google server in the US and stored there. Only in exceptional cases the full IP address will be transferred to a Google server in the US and shortened there. This Website uses Google Analytics with an extension for the anonymous collection of IP addresses (so-called IP masking). On our behalf, Google will use the collected information to evaluate your use of the Website, to compile reports on Website activity and to provide us with other services relating to Website use. The IP address transmitted by your browser in the context of Google Analytics is not combined with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, we would like to point out that in this case you may not be able to use all functions of this Website in full. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the Website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
  4. Alternatively, you can use the link below to prevent data from being sent to Google or processed by Google: To opt-out please click here. An opt-out cookie is set which prevents the future collection of your data when you visit this Website. Further information on data protection at Google Analytics can be found at here http://www.google.com/analytics/terms/de.html and here http://www.google.com/intl/de/analytics/privacyoverview.html.
  5. Google Remarketing: We also use the remarketing function of Google on our website. This enables us to show you targeted advertising of presumed interest based on your usage behavior during previous visits to our website. If you have consented to Google, your visits will also be recorded across devices. This advertisement appears only on Google advertising spaces, either on advertising spaces of Google Adwords or the Google Display Network. Google uses cookies to analyze website usage as a basis for displaying interest-based advertising. Cookies are used to record visits to a website and anonymous data about website usage. No personal data of visitors to the website is stored. If you then visit another website in the Google Display Network, you will see ads that are highly likely to include previously accessed product and information areas. You can permanently deactivate the use of cookies by Google by following the following link and downloading and installing the plug-in provided there: https://www.google.com/settings/ads/plugin. Alternatively, you can deactivate the use of cookies by third parties by implementing the deactivation page of the Network Advertising Initiative under http://www.networkadvertising.org/choices/aufrufen and the further information mentioned there to the contradiction. For more information about Google Remarketing and Googles privacy policy, please visit http://www.google.com/privacy/ads/.
  6. DoubleClick: We also use Double-Click, a service also provided by Google, to display advertisements relevant to you. Google assigns a pseudonymous identification number (ID) to your browser to check which ads have been displayed in your browser and which ads have been viewed. The cookies do not contain any personal information. The use of DoubleClick cookies only allows Google and its partner websites to serve ads based on previous visits to our or other websites on the Internet. The information generated by the cookies is transmitted by Google to a server in the USA for analysis and stored there. A transfer of data by Google to third parties only takes place due to legal regulations or within the scope of commissioned data processing. Google will not match your data with other data collected by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. You can also prevent Google from collecting the data generated by the cookies and relating to your use of the website and from processing this data by Google by downloading and installing the browser plug-in available at https://adssettings.google.com/u/0/authenticated?hl=en-GB under the item Double-Click deactivation extension. Alternatively, you can disable the Doubleclick cookies on the website of the Digital Advertising Alliance - http://optout.aboutads.info.
  7. Facebook Pixel: We use the Facebook pixel of Facebook, Inc. (1601 South California Avenue, Palo Alto, CA 94304, USA - www.facebook.com - "Facebook") on our website. The Facebook pixel provides an option to track users behavior after they have been redirected to one of our websites by clicking on a Facebook ad. This process is designed to evaluate the effectiveness of Facebook ads for statistical and market research purposes and may help to optimize future advertising efforts. The data collected is anonymous to us, so we cannot draw any conclusions about the identity of the users, and we do not transmit any personal data to Facebook ourselves. However, Facebook stores and processes the data so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook Data Usage Guidelines (https://www.facebook.com/about/privacy/). You can enable Facebook and its partners to serve ads on and off Facebook. A cookie may also be stored on your computer for these purposes. If you are a Facebook member and do not want Facebook to collect data about you via the Facebook pixel and link it to your membership data stored on Facebook, you can object to the use of the Facebook pixel here. The contradiction refers to the browser you are using.
  8. LinkedIn Conversion Tracking: We use the analysis and conversion tracking technology of LinkedIn Corporation (2029 Stierlin Court, Mountain View, CA 94043, USA - www.linkedin.com - "LinkedIn") on our website. With this LinkedIn technology you advertising can be displayed to you based on your interests. We also receive aggregated and anonymous reports from LinkedIn about ad activity and information about how you interact with our website. Further information on data protection at LinkedIn can be found here: https://www.linkedin.com/legal/privacy-policy#choices-oblig. You can object to the analysis of your usage behavior by LinkedIn and the display of interest-based recommendations by clicking on "Reject to LinkedIn" (for LinkedIn members) or "Reject" (for other users) under the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  9. Web analysis via Mouseflow: We use Mouseflow on our website, a web analysis tool of Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark, to record randomly selected individual visits (with anonymous IP address only). This results in a protocol of mouse movements, mouse clicks and keyboard interaction, with the intention of randomly displaying individual visits to this website as so-called session replays and evaluating them in the form of so-called heatmaps and deriving potential improvements for this website. The data collected by Mouseflow is not personal and will not be passed on to third parties. The data collected is stored and processed within the EU. If you do not wish that data from your website visits is collected by Mouseflow, you can object to this on all websites that use Mouseflow under the following link: https://mouseflow.de/opt-out/ .
  10. Facebook Social Plugin: We have integrated a button of Facebook on our Website. You can recognize the Facebook buttons by the Facebook logo or the "Like" button.

In order to prevent the automatic collection of information by Facebook as soon as our Website is accessed, we have implemented the so-called "two-click solution": Next to the Facebook button there is another area that looks like a switch. Only when you press this switch and then click the Facebook button again, information (such as the address of our Website and your user ID) is sent to Facebook.

As the operator of this Website, we have no knowledge of the content of the transmitted data or its use by Facebook. We do not know when you clicked which button. For more information on how Facebook uses your information, please see Facebooks Privacy Policy http://de-de.facebook.com/policy.php#.

Twitter button: Our Website uses the buttons of the Twitter service. These buttons are provided by Twitter Inc, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. They are recognizable by terms such as "Twitter" or "Follow", combined with a stylized blue bird. With the help of the buttons it is possible to share a post or page of this offer on Twitter or to follow the provider on Twitter. When you access an area of our Website that contains such a button, your browser establishes a direct connection to Twitters servers. The content of the Twitter button is transmitted directly from Twitter to your browser. We therefore have no influence on the amount of data Twitter collects with the help of these plug-ins and inform you exclusively on the basis of the information available to us. Thereafter, only your IP address and the URL of our Website will be transmitted when the button is purchased, but will not be used for any other purposes than the display of the button. Further information can be found in the Twitter data protection declaration at http://twitter.com/privacy

  1. Google+ Schaltfläche: Our Website uses the "+1″ button of the social network Google Plus, which is operated by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google"). The button can be recognized by the sign "+1″ on a white background. When you visit an area of our Website that contains such a button, your browser establishes a direct connection to Googles servers. The content of the "+1″ button is transmitted by Google directly to your browser and integrated into the Website. We therefore have no control over the amount of data Google collects using the button, but we assume that your IP address will also be recorded. The purpose and scope of the data collection and the further processing and use of the data by Google as well as your rights and setting options for the protection of your privacy can be found in Googles privacy policy for the "+1″ button: http://www.google.com/intl/de/+/policy/+1button.html. If you are a Google Plus member and do not want Google to collect data about you via our Website and link it to your membership data stored on Google, you must log out of Google Plus before visiting our Website.
  2.  Informations- und Beratungsmöglichkeiten

We provide a variety of information and consulting options via the contact options on our Website. Depending on the option you choose, we process different personal data:

a)             Contact

If you contact us via one of the channels indicated on our website, we will process any personal data contained in your message and provided by you in order to process and respond to your request.

b)             Informantion via mail / email

If you have asked for information material to be sent, we will process the data you provide in the contact form, at least your name and surname and the details of the contact channel you have chosen (mail and/or e-mail) for the one-off dispatch of the material you have requested.

c)             Consulting via telephone

If you have asked for consulting via telephone, we will process the data you provide in the contact form, at least your surname and first name as well as your telephone number in order to provide the desired consultation via telephone.

d)            Personal consultation

If you have asked for a personal consultation, we will process the data you provide in the contact form, at least your surname and first name as well as your telephone number and/or e-mail address, in order to contact you to arrange a personal consultation appointment.

e)             Email newsletter

If you have registered for our email newsletter, we will process the data you provide in the contact form, at least your surname and first name as well as your e-mail address, in order to send you our email newsletter

In addition, we use the other information you provide in the contact form (such as in-formation about your activity or area of interest) to send you content tailored to your interests. We also analyze the data generated during delivery and retrieval of these e-mails in aggregated form (delivery rate, opening rate, click rates, conversion rate, unsubscription rate, bouncer rate) to analyze the success and use of the e-mails. On the other hand, we also evaluate the data generated when you access and use these e-mails (time of opening, hyperlinks clicked on, documents downloaded) in order to provide you with personalized information on this basis in future email newsletters that best takes your interests and needs into account.

  1. Online orders

You can place an order on our Website without registering and creating an account. In this case, the information required to process the order (e.g. your first and last name, your billing address or a different delivery address, your e-mail address as well as necessary payment information, delivery modalities and order information) will be requested and processed by us.

  1. Registration / Account

When registering as a user - especially when creating a customer account - we collect personal and process the data specified in the registration form on our Website. We may request the re-entry of data already collected during registration (in particular for your identification) and process further personal data if you wish to use certain content on our Website or place an order.

  1. For which purposes and on which legal basis do we process your personal data?
  2. We process personal data possibly contained in logfiles to enable you to use our Website. Article 6 para 1 f) GDPR for the purposes of our justified interest in operating our Website.
  3. We process the data collected by the use of cookies and pseudonymized user profiles in order to perform direct marketing, market research and further develop our digital offers on the basis of user needs. Article 6 para 1 f) GDPR for the purposes of our justified interest in analysing the use of our Website.
  4. The processing of personal data for handling one of your requests via one of the channels indicated on our website is carried out in any case for the purposes of our legitimate interest in establishing and maintaining business contacts on the basis of Article 6 (1) f) GDPR. If your request relates to the conclusion of a contract or pre-contractual measures, your personal data will be processed on the basis of Article 6 (1) b) GDPR.
  5. We process the data provided to use our information and consulting options to provide you with the selected option and, if you have chosen to register for our email newsletter to register you and to provide you with the email newsletter. We process this personal data on the basis of your consent and according to Article 6 (1) a) GDPR. Please note that can revoke your consent at any time without giving reasons with effect for the future by simply contacting us via the contact channels indicated on the first page of this data protection information. You will also find a link to unsubscribe in each e-mail.
  6. If you place an order via our Website or register on our Website as a user or for a customer account, we process the data collected in this connection for the execution of the contracts concluded with you on the basis of Article 6 paragraph 1 b) GDPR.
  7. We may process the data processed in connection with your use of our Website also for compliance with legal obligations to which we are subject; this processing is based on Article 6 para 1 c) GDPR
  8. To extent necessary, we process personal data (in addition to the processing for the purposes of the employment relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6 para 1 f) GDPR. Justified interest may include

a)             the establishment of or defence against legal claims

b)             the prevention and investigation of criminal offences

c)             management and further development of our business operations including risk management

  1. Are you obliged to provide data?

The information required for the registration for our newsletter, the provision of information and consulting, the execution of online orders or the registration as user or the creation of a customer account are marked as mandatory information in the corresponding area of the Website (e.g. an online form); without the provision of mandatory information, we cannot enable you to use the respective functionality.

If we collect additional data from you, we will inform you if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

  1. Who obtains or has access to your data?

Your personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the departments responsible for our digital offers (e.g. Websites) and our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include

­          affiliated companies, to which we may transfer personal data

­          service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers;

­          private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.

  1. Do we use automated decision-making?

In connection with the operation of our Websites we generally do not use automated decision-making (including profiling) within the meaning of Arti-cle 22 GDPR. If we apply such processes in the future, we will inform you separately in accordance with the applicable statutory provisions.

                   Are data transferred to countries outside the EU / the EEA?

Personal data is processed generally within the European Union or the European Economic Area; we do not intend to transfer personal data to other countries.

Only in connection with the use of service providers to provide web analysis services information may be be transferred to recipients in so-called "third countries". "Third countries" means countries outside the European Union or the Agreement on the European Economic Area, where a level of data protection comparable to that in the European Union cannot be readily assumed.

If the information transferred contain personal data, we ensure before such a transfer that the necessary adequate level of data protection is guaranteed in the respective third country or with the recipient in the third country. This may result in particular from a so-called "adequacy resolution" of the European Commission, which establishes an appropriate level of data protection for a certain third country as a whole. Alternatively, we can also base data transmission on the so-called "EU standard contract clauses" agreed with a recipient or - in the case of recipients in the USA - on compliance with the principles of the so-called "EU-US Privacy Shield". We will be happy to provide you with further information on the appropriate and appropriate guarantees for maintaining an appropriate level of data protection upon request; the contact details can be found at the beginning of this data protection information. Information on the participants of the EU-US Privacy Shield can also be found here www.privacyshield.gov/list.

  1. How long are your data stored?

We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail. Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

As far as the aforementioned processing is concerned, we regularly

-      delete the log data within seven days, if if further storage is not required for purposes provided for by law, such as the detection of misuse and the detection and rectification of technical faults;

-      delete the data processed in the context of an online order after the expiration of statutory retention periods; and

-      delete the data processed in the context of a registration as user or a customer account after termination of registration or the deletion oft he customer account

If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

  1. What are your rights as a data subject?

As a data subject, you may

­          request access to your personal data, Article 15 GDPR;

­          request the rectification of incorrect personal data, Article 16 GDPR;

­          request the erasure of your personal data, Article 17 GDPR;

­          request the restriction of the processing of your personal data, Article 18 GDPR;

­          exercise your right to data portability, Article 20 GDPR;

­          object the processing of your personal data, Article 21 GDPR.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, you may also get in touch with our data protection officer.

In addition, you are entitled to lodge a complaint regarding the handling of your personal data with the competent supervisory authority, Article 77 GDPR.

* * *

GDPR.

* * *

Data protection information to our customers

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive ("GDPR") and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information, we explain which information (including personal data) are processed by us in connection with the business relationship between you and us.

I. Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to "we" or "us" in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy@ursa.com.

II. Which data do we process?

The performance of our business relationships requires the processing of data related to our customers. If this data concern a natural person (e.g. if you are a single trader and enter into a business relationship with us), it is considered as personal data. Regardless of the legal form of our contract partners, we process data concerning the contact persons acting for a customer.

Please make this data protection information available to the persons within your organization that are involved in the business relationship with us ("contact persons")

    1. Basic data: We process certain general data concerning our customers and the contact persons as well as the business relationship with us, collectively "basic data". Basic data include

      a) any information provided to us in the course of establishing a business relationship or requested by us from our customers or a contact person (e.g., name, address and other contact details; and

    2. b) any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)

    3. Performance data: We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as "performance data". Performance data include

a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into;

b) Information on the performance of contractual obligations by us on the basis of the agreements entered into;

c) Information provided by a customer or a contact person in the course of our business relationship, be it actively or upon our request; and

d) personal data that are provided to us in the course of our business relationship by our customer, a contact person or by third parties;

  1. To the extent permitted by law, we can add personal data provided by third parties to the aforementioned basic and performance data. Such data may include information regarding the commercial standing / rating of our customers if necessary for the assessment of financial risks (e.g. late payments).a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into.

III. For which purposes and on which legal basis do we process your personal data?

  1. We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6para1b)GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our justified interest in the performance of the business relationship on the basis of Article 6para1f)GDPR.
  2. We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6para1c)GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities.
  3. To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6para1f)GDPR. Justified interest may include

    a) group-wide processes for internal administration of customer data

    b) the establishment of or defence against legal claims

    c) the prevention and investigation of criminal offences

    d) maintenance of security for our information technology systems

    e) the maintenance of security of our premises and infrastructure

    f) management and further development of our business operations including risk management

  4. If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6para1a)GDPR.

    Please note that

  5. the declaration of consent is voluntarily,
  6. that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent
  7. consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice

IV. Is there an obligation to provide personal data?

The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.

If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

V. Who has access to personal data?

Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the Sale department and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include

  • affiliated companies within Xella group.
  • service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers;
  • private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject;

VI. Do we use automated decision-making?

In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

VII. Are data transferred to countries outside the EU / the EEA?

Personal data is processed only within the European Union or the European Economic Area; we do not intend to transfer personal data to other countries ("third countries").

VIII. How long are your data stored?

We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

IX. What are the rights of a data subjects?

A data subject may

  • request access to his/her personal data, Article15GDPR;
  • request the rectification of incorrect personal data, Article16GDPR;
  • request the erasure of his/her personal data, Article17GDPR;
  • request the restriction of the processing of his/her personal data, Article18GDPR;
  • exercise the right to data portability, Article20GDPR;
  • object the processing of his/her personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, you may also get in touch with our data protection coordinator.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article77GDPR.

* * *

Data protection information to our suppliers

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive ("GDPR") and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information, we explain which information (including personal data) are processed by us in connection with the business relationship between you and us.

I. Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to "we" or "us" in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy@ursa.com.

II. Which data do we process?

The performance of our business relationships requires the processing of data related to our customers. If this data concern a natural person (e.g. if you are a single trader and enter into a business relationship with us), it is considered as personal data. Regardless of the legal form of our contract partners, we process data concerning the contact persons acting for a customer.

Please make this data protection information available to the persons within your organization that are involved in the business relationship with us ("contact persons")

  1. Basic data: We process certain general data concerning our customers and the contact persons as well as the business relationship with us, collectively "basic data". Basic data include

    a) any information provided to us in the course of establishing a business relationship or requested by us from our customers or a contact person (e.g., name, address and other contact details; and

    b) any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)

  2. Performance data: We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as "performance data". Performance data include

    a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into;

    b) Information on the performance of contractual obligations by us on the basis of the agreements entered into;

    c) Information provided by a customer or a contact person in the course of our business relationship, be it actively or upon our request; and

    d) personal data that are provided to us in the course of our business relationship by our customer, a contact person or by third parties;

  3. To the extent permitted by law, we can add personal data provided by third parties to the aforementioned basic and performance data. Such data may include information regarding the commercial standing / rating of our customers if necessary for the assessment of financial risks (e.g. late payments).a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into.

III. For which purposes and on which legal basis do we process your personal data?

  1. We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6para1b)GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our justified interest in the performance of the business relationship on the basis of Article 6para1f)GDPR.
  2. We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6para1c)GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities.
  3. To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6para1f)GDPR. Justified interest may include

    a) group-wide processes for internal administration of customer data

    b) the establishment of or defence against legal claims

    c) the prevention and investigation of criminal offences

    d) maintenance of security for our information technology systems

    e) the maintenance of security of our premises and infrastructure

    f) management and further development of our business operations including risk management

  4. If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6para1a)GDPR.

    Please note that

  5. the declaration of consent is voluntarily,
  6. that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent
  7. consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice

IV. Is there an obligation to provide personal data?

The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.

If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

V. Who has access to personal data?

Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the Sale department and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include

  • affiliated companies within Xella group.
  • service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers;
  • private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject;

VI. Do we use automated decision-making?

In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

VII. Are data transferred to countries outside the EU / the EEA?

Personal data is processed only within the European Union or the European Economic Area; we do not intend to transfer personal data to other countries ("third countries").

VIII. How long are your data stored?

We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

IX. What are the rights of a data subjects?

A data subject may

  • request access to his/her personal data, Article15GDPR;
  • request the rectification of incorrect personal data, Article16GDPR;
  • request the erasure of his/her personal data, Article17GDPR;
  • request the restriction of the processing of his/her personal data, Article18GDPR;
  • exercise the right to data portability, Article20GDPR;
  • object the processing of his/her personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, you may also get in touch with our data protection coordinator.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article77GDPR.

* * *

Data protection information to our employees

Processing of employee data

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Regulation ("GDPR") and we only process your personal data on the basis of a statutory provision, your employment contract, or our legitimate interests, or if you have declared your consent.

In this data protection notice, we explain which information (including personal data) are processed by us in connection with your employment relationship.

I.Who is responsible for the processing of personal data?

The controller responsible for the processing of your personal data is URSA Insulation, S.A., Paseo de Recoletos, 3, 28004 Madrid, Spain, as your employer. Therefore, any reference to "we" or "us" in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy@ursa.com.

II. Which data do we process?

The performance of your employment relationship requires the processing of personal data:

  1. Basic data: We process certain general data in relation to your person and your employment relationship with us, collectively "basic data". Basic data include

    a)any information provided by you in the course of the recruitment process or that we requested from you (e.g., gender treatment, name, surname, address, telephone number, email address, date of birth, marital status, nationality, national identity card/ passport number, tax identification number, social security number, and information on your education and previous employment; and

    b)any information stored in connection with our hiring decision (in particular the details of your employment agreement and information on your position and seniority within our organization).

  2. Performance data: We process personal data collected in the course of your employment other than by merely updating your basic data and that we refer to as "performance data". Performance data include

    a)Information on the performance of your employee tasks, such as your work / absence times, skills, and the assessment of your performance, if applicable;

    b)Information on our performance of the employment relationship, such as our payments to you or other benefits or compensation, banking data, contribution bases, or taxes or contributions paid or payable on your behalf;

    c)Personal data provided to us in the course of your employment, either by you actively or upon our request, or by third parties (in particular public bodies such as social insurance bodies or (tax) authorities). This may include information on sick leave, pregnancy, the birth of a child, maternity leave, disabilities, a marriage or comparable changes of marital status.

  3. Usage data: We process personal data collected in the course of your employment due to your use of our company infrastructure. Usage data include

    a)Information regarding your use of our information technology infrastructure (such as your business email account, internet access, landline and mobile services –data and voice-, or other applications, programs or devices provided to you); and

    b)Information on your use of other company infrastructure such as infrastructure collecting user data when accessed by an employee, like connected machines or time management applications.

  4. The aforementioned categories of data may include special categories of personal data in the sense of Article 9.1 GDPR, in particular

    a)Health data (e.g., the information on your inability to work due to illness, or whenever there is a claim under the insurance policies contracted to insure the employees;

    b)Trade union membership data (only whenever this information is provided by you); and

    c)Biometric data –photographs- (only whenever they are provided by you).

III. For which purposes and on which legal basis do we process your personal data?

  1. We process basic, performance and usage data for the performance of your employment relationship with us on the basis of Article 6.1(b)GDPR.
  2. We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6.1(c)GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to social insurance bodies and (tax) authorities, together with general retention mandatory provisions.
  3. To the extent necessary, we process personal data (in addition to the processing for the purposes of the employment relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6.1(f)GDPR. Justified interest may include

    a) group-wide processes for internal administration of employee data;

    b) the establishment of or defence against legal claims;

    c) the prevention and investigation of criminal offences;

    d) maintenance of security for our information technology systems;

    e) the maintenance of security of our premises and infrastructure;

    f) management and further development of our business operations including risk management;

    g) costs and headcount control within the Human Resources Department;

    h) filling of vacancies, promotion of employees or management of geographical and functional mobility;

    i) to obtain subsidies and subsidized financing of the available Public Aid Lines; and

    j) recruitment and career development processes.

  4. If the categories of data specified in section II above contain special categories of personal data (e.g. health data, trade union membership, biometric data), we process these data either for carrying out the obligations in the field of employment and social security and social protection law on the basis of Article 9.2(b) GDPR; on the basis of your making the data manifestly public according to Article 9.2.(e) GDPR; or for the establishment, exercise or defense of legal claims on the basis of Article 9.2(f) GDPR.
  5. If we provide – during the recruitment process or in the course of the employment – the option to declare a consent in the processing of personal data, we process the personal data covered by your consent for the purposes specified in such consent on the basis of Article 6.1(a)GDPR. If the consent refers to special categories of personal data (such as health data), the processing is based on Article 9.2(a) GDPR.

    Please note that

    • the declaration of your consent is always voluntarily, and neither the declaration of consent nor a later withdrawal of consent has negative consequences for the performance of your employment relationship;
    • that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform you about such consequences before you are given the option to declare your consent;
    • you may withdraw your consent at any time with effect for the future, e.g. by providing notice to us via mail, email using the contact information specified on the first page of this data protection notice.

IV. Are you obliged to provide data?

The provision of the basic, performance and usage data specified in section II above is necessary for entering into and maintaining an employment relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain an employment relationship with you.

If we collect additional data from you, we will inform you if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement (in particular your employment agreement). We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

V.Who obtains or has access to your data?

Your personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the HR department, your managers, the Legal department in case of establishment of or defence against legal claims, and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include

  • affiliated companies within Xella group, to which we may transfer personal data for internal administration of employee data;
  • service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers;
  • private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject; and
  • business partners, to the extent the transfer of personal data (e.g. your business contact details) is necessary for the performance of your employment relationshwip with us.

VI. Do we use automated decision-making?

In the course of the recruitment process and the employment relationship we do not use automated decision-making (including profiling) within the meaning of Article22GDPR. If we apply such processes in the future, we will inform you separately in accordance with the applicable statutory provisions.

VII.Are data transferred to countries outside the EU / the EEA?

Generally your personal data are processed only within the European Union or the European Economic Area; we do not intend to transfer your personal data to other countries ("third countries") except for testing of applications and maintenance of the servers of the external service provider dealing with your payroll.

In those exceptional cases where we transfer your personal data also to "third countries", those countries do not necessarily ensure an adequate level of data protection comparable to the level in the European Union.

Prior to such third country transfer, we apply appropriate safeguards to ensure the necessary level of data protection at the recipient or in the recipients country. Appropriate safeguards may, in particular, consist in an adequacy decision in which the European Commission has decided that the country ensures an adequate level of protection. Alternatively, we may transfer personal data on the basis of the EU Model Clauses or – in case of recipients in the U.S – its adherence to the "EU US Privacy Shield" principles.

We provide additional information on the appropriate or suitable safeguards upon request; our contact information can be found on the first page of this data protection notice. Information on the participants in the EU US Privacy Shield can also be found here www.privacyshield.gov/list.

VIII. How long are your data stored?

We generally store your personal data as long as we have a justified interest in the retention of such data and there your interests in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete your personal data even without an action from your side as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, your basic data and the additional data collected in the course of your employment are retained at least until the end of your employment. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of your employment relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

IX. What are your rights as a data subject?

As a data subject, you may

  • request access to your personal data, Article15GDPR;
  • request the rectification of incorrect personal data, Article16GDPR;
  • request the erasure of your personal data, Article17GDPR;
  • request the restriction of the processing of your personal data, Article18GDPR;
  • exercise your right to data portability, Article20GDPR;
  • object the processing of your personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection notice.

In case of further questions, you may also get in touch with our data protection coordinator.

In addition, you are entitled to lodge a complaint regarding the handling of your personal data with the competent supervisory authority, Article77GDPR.

* * *

Data protection information to our business partners

Processing of business partner data

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive ("GDPR"), and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information we inform you which information we process from our business partners. For the purpose of this data protection information business partners are to be those companies, function of persons, with which we do not have a contractual relationship regarding the delivery of our goods or the rendering of services, but with which we conduct nevertheless business contacts and relationships. These business contacts may be used for providing information about goods and services in single cases or also regularly. Business partners are for us i.e. official or private house builder, project developer, investors, architects, construction engineers, craftsmen and authorizes experts, who are involved in building projects or other projects, for which our products and services may be relevant (“projects”).

I.- Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to "we" or "us" in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy@ursa.com.

II. Which data do we process?

For the purposes of our business - namely for information about our products and services - we process data of our business partners. Insofar as these data allow conclusions to be drawn about a natural person (for example, if we process information about sole traders as business partners), these are personal data. Regardless of the legal form of our business partners, we also process data on the contact persons at our business partners.

Please make this data protection information available to the persons within your organization that are involved in the business relationship with us ("contact persons")

Basic data: We process certain general data concerning our business partners and the contact persons as well as the business relationship with us, collectively "basic data". Basic data include

· all information about our business partner, which we ourselves or third parties can extract from publicly available sources about our business partner (such as name, address, other contact details and information about projects involving the respective business partner);

· the information provided to us by you or third parties working with you, if any, through a contact person (such as the details given on a business card given to us and the information provided to us in addition, such as a telephone call or telephone call) Meeting); as

· any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)

Performance data:

We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as "performance data". Performance data include

· information about the activities of our business partner (e.g. projects under involvement of our business partner), which we may extract ourselves or through third parties from publicly available sources;

· information about the activity of our business partner, communicated to us by them or by third parties who work with them, possibly through a contact person

· Information about the projects planned or carried out with the participation of the respective business partner with regard to our products and services or the products and services of third parties.

III. For which purposes and on which legal basis do we process your personal data?

We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6para1b)GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our legitimate interest in the performance of the business relationship on the basis of Article 6para1f)GDPR.

We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6para1c)GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities.

To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our legitimate interests or the legitimate interests of a third party on the basis of Article 6para1f)GDPR. Legitimate interest may include

  • group-wide processes for internal administration of customer data
  • the establishment of or defense against legal claims
  • the prevention and investigation of criminal offences
  • maintenance of security for our information technology systems
  • the maintenance of security of our premises and infrastructure management and further development of our business operations including risk management

If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6para1a)GDPR.

Please note that

  • the declaration of consent is voluntarily,
  • that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent
  • consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice

IV. Is there an obligation to provide personal data?

The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.

Please also note our advice on the right to object to the processing of personal data in order to safeguard legitimate interests in para. IX.

If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

V. Who has access to personal data?

Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the [#Sale department#] and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include

  • affiliated companies within Xella-group, to which we may transfer personal data for the purpose of internal administration of employee data;
  • other business partners to whom we may transfer personal information in order to safeguard the legitimate interests of the business partner to whom the data transmitted relates;
  • service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers;
  • private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject;

VII. Do we use automated decision-making?

In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

VIII. Are data transferred to countries outside the EU / the EEA?

Personal data are processed only within the European Union or the European Economic Area; we do not intend to transfer personal data to other countries ("third countries").

IX. How long are your data stored?

We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

X. What rights does an data subject have?

Right of objection according to Art. 21 GDPR

An data subject has the right, at any time for reasons arising from your particular situation, to object to the processing of his/ her personal data relating pursuant to Article 6 (1) (e) or (f) GDPR; this also applies to a profiling based on these provisions. In the event of such objection, we will no longer process the personal data concerning that person, unless we can demonstrate compelling legitimate reasons for processing that outweigh the interests, rights and freedoms of the data subject, or the processing is for assertion, exercise or defense of legal claims.

When we process personal data to operate direct marketing, you have the right to object at any time to the processing of your personal data for the purposes of such advertising; this also applies to a profiling insofar as it is associated with such direct mail. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

A data subject may

- request access to his/her personal data, Article15GDPR;

- request the rectification of incorrect personal data, Article16GDPR;

- request the erasure of his/her personal data, Article17GDPR;

- request the restriction of the processing of his/her personal data, Article18GDPR;

- exercise the right to data portability, Article20GDPR;

- object the processing of his/her personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, the data subject may also approach our data protection officer.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article77GDPR.

* * *

Data protection information marketing

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive ("GDPR") and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information, we provide you with the mandatory information on the processing of your personal data. In relation to this processing, we comply with applicable data protection law, in particular the EU General Data Protection Regulation ("GDPR").

I. Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to "we" or "us" in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy@ursa.com.

II. Which data do we process? For which purposes and on which legal basis do we process your personal data?

We would like to inform you about products, services, offers and promotions. For this purpose, we offer you the opportunity to choose between different contact channels when you give your consent.

Depending on your choice of one or more contact channels, we will process the necessary data as provided by you in the contact form, at least your surname and first name and the details of the contact channel (post, e-mail, telephone, SMS) selected by you.

We process this personal data on the basis of your consent and according to Article6(1) a) DSGVO

III. Is there an obligation to provide personal data? Can I withdraw my consent?

You give your consent and choose your contact channel on a purely voluntary basis. You are therefore not obliged to provide personal data. In order that we can send you the information via the desired contact channel, we require the data marked as mandatory fields in the contact form.

You can revoke your consent at any time without giving reasons with effect for the future by simply contacting us. You will also find a link to unsubscribe in each e-mail.

IV. Who has access to personal data?

We will never sell your email address of other contact data to third parties. The data will only be transferred if this is necessary to send you our information. In this context, we can also commission external service providers and other group companys, taking into account the applicable statutory regulations.

We will only share your information with the following categories of recipients to prepare and send our information to you:

· Service providers within our group of companies (e.g. to provide statistical analysis and technical maintenance for our systems).

· External service providers who provide services on our behalf and on a separate contractual basis, such as collecting your data, hosting our websites, maintaining our call center, sending e-mails or written information or providing personal advice.

In addition, we may transfer data to other recipients (e.g. public authorities) to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject

V. Do we use automated decision-making?

In the course of our direct marketing activities we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

VI. Are data transferred to countries outside the EU / the EEA?

Personal data is processed only within the European Union or the European Economic Area; we do not intend to transfer personal data to other countries.

VII. How long are your data stored?

1. We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail. Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

2. As far as the aforementioned processing is concerned, we will store your personal data as long as you have not withdrawn your consent or indicated otherwise that you do not want to be provided with further information from us. Also in this case, we store your contact data in order to ensure that you are not contacted following your withdrawal or objection (so called blacklist).

3. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

VIII. What are your rights as a data subject?

As a data subject you may

request access to your personal data, Article15GDPR;

request the rectification of incorrect personal data, Article16GDPR;

request the erasure of your personal data, Article17GDPR;

request the restriction of the processing of your personal data, Article18GDPR;

exercise the right to data portability, Article20GDPR;

object the processing of your personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, you may also get in touch with our data protection coordinator by sending an e-mail to: privacy@ursa.com.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article77GDPR.

* * *