Data Protection Policy

Data Protection Officer:

  • Document prepared by: Brian Crotty, Owner
  • Contact at [email protected]
  • Document became operational on: 01-December-2018
  • Next review date: 01.12.2019


WillowFlex, Brian Crotty, Salomon-Goldschmidt-Straße 12, 16225 Eberswalde (afterwards WillowFlex, we, our or us) is operating and related websites and microsites. WillowFlex is a data controller and needs to gather and use certain information (data processing) about individuals (data subjects) that can identify directly or indirectly a natural person – processing of a data subject´s personal data.

These include visitors to our website, customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact for business or information delivery. This policy describes:

  • which reasons we have to process your personal data
  • what data is processed
  • where the data is being processed
  • what is the legal purpose for data processing
  • what rights the data subject has and how he or she can exercise these rights

Furthermore it will describe how this personal data is collected, handled and stored through internal processes to meet the company’s data protection standards and to comply with the law.

Privacy Notice

Why do we process your personal data?

Depending on the object of business we have different reasons for processing your personal data.

Such reasons can be:

  • providing information about our products including usage examples, pricing changes, new launches, etc.
  • improving the user experience
  • analyzing user behavior
  • informing our audience about news regarding our industry
  • engaging potential clients

What personal data do we process?

Depending on the depth of the business relationship, we collect personal data to provide a better service and offering.

Such data can include:

  • personal data that can directly identify you, such as, but not limited to your name, your address, your e-mail address, voluntary responses to questions about your business and needs, your behavior within our website while actively logged in to an account, notes about business relationship and potential projects or production requests.
  • personal data that can indirectly identify you, such as, but not limited to your IP-address (which is anonymized as often as possible), data we gather for statistical analysis (browsing behavior). We use multiple tracking tools to collect information about the use of our website including Google Analytics and Hubspot which provide an anonymous dataset that indicates how and where users interacted with our website, duration of visit, entry and exit points to our website and for those who have also opted in to Google’s Data Policy, demographic statistics about the user.
  • personal data that can indirectly identify you, such as, specific tracking of website use and behavior in response to emails or online ad behaviors who have opted-in to a further level of tracking of personal behavior as part of a request to better serve them as potential customers for our software platforms.

Where the data is being processed

Our data is stored on servers provided by 1&1 IONOS SE web services, Google LLC and Hubspot, Inc. with which WillowFlex has order data processing agreements and which are all active members of the EU-US privacy shield.

Where it is needed and only for as long as necessary is personal data also processed and stored on local machines such as laptop and desktop computers.

What is the legal purpose for processing data?

WillowFlex only processes personal data when we have a legitimate purpose for doing so. These purposed vary with the different reasons and objects of businesses.

Some of the purposes can include:

  • you giving us consent
  • processing is necessary for the performance of a contract
  • processing is necessary for compliance with a legal obligation to which the controller is subject

What rights does the data subject have

The data subject can exercise certain rights such as, but not limited to, the right to be informed what, where and who is processing and controlling data by reading this privacy notice. Further rights can be exercised by writing an E-mail to our data protection officer who will answer to all inquires in a reasonable period of time.

Further rights include:

  • the right to erasure of his or her personal data (the right to be forgotten)
  • the right to rectification of his or her personal data
  • the right to restrict the processing of his or her personal data
  • the right to receive all personal data concerning him or her in a commonly used, machine-readable format
  • all rights detailed in EU-GDPR Art. 12 – 23

WillowFlex Data Protection Policy

Why this policy exists

This data protection policy ensures that WillowFlex:

  • Complies with data protection law and follow good practice
  • Protects the rights of their staff, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach


The EU General Data Protection Regulation describes how organizations — including WillowFlex must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or in other formats. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act is underpinned by eight important principles.

These principles state that personal data must:

  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Be processed in accordance with the rights of data subjects
  • Be protected in an appropriate manner
  • Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, Risks and Responsibilities

Data Protection Policy scope

This policy applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR.

This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals that supports the purpose of our business.

Data Protection Risks

This policy helps to protect WillowFlex from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.


Everyone who works for or with WillowFlex shares responsibility for ensuring that data is collected, stored and handled appropriately. Each employee that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

General Staff Guidelines

  • The only people able to access data covered by this policy are those who need it for their work.
  • Data must not be shared informally. When access to confidential information is required, employees can request it from their direct managers.
  • WillowFlex will provide training to all employees to help them understand their responsibilities when handling data.
  • Employees must keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorized people, either within the company or externally.
  • Data must be regularly reviewed and updated if it is found to be out of date. If no longer required, it must be deleted and disposed of.
  • Employees must request help from their manager or the data protection officer if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it must be kept in a secure place where unauthorized people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees must make sure paper and printouts are not left where unauthorized people could see them, like at the printer.
    • Data printouts must be shredded and disposed of securely when no longer required.
    • When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:
  • Data must be protected by strong passwords that are changed regularly and never shared between employees.
  • If data is stored on removable media (like a CD or DVD), these must be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data is backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data are not saved to not approved devices such as laptops, USB-sticks or other mobile devices like tablets or smartphones.
  • All servers and computers containing data are protected by approved security software and a firewall.

Personal Data Use

Personal data is of no value to WillowFlex unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, employees will ensure the screens of their computers are always locked when left unattended.
  • Personal data will not be shared informally.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

The law requires WillowFlex to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort WillowFlex should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • WillowFlex will make it easy for data subjects to update the information WillowFlex holds about them. For instance, via the company website.
  • Data must be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it must be removed from the database.
  • It is the individual sales representative’s responsibility to ensure that databases are checked against industry suppression files every six months.

Subject Access Requests

All individuals who are the subject of personal data held by WillowFlex are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.
  • Ask WillowFlex to delete all their personal data (right to be forgotten)
  • Ask for machine readable copy of their personal data

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at [email protected] The data controller can supply a standard request form, although individuals do not have to use this.

The data controller will provide the relevant data within a reasonable time frame. The data controller will always verify the identity of anyone making a subject access request before handing over any personal information.

Disclosing Data for other Reasons

In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, we will disclose the requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing Information

WillowFlex aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used.
  • How to exercise their rights.

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.


Liability for Content

We make every effort to keep the information on our Web site current, but accept no liability whatsoever for the content provided. Pursuant to §7 par. 1 of TMG (German Tele-Media Act), the law limits our responsibility as a service provider to our own content on these Web pages.

According to §§8 to 10 of TMG, we are not obligated to monitor third party information provided or stored on our Web site. However, we shall promptly remove any content upon becoming aware that it violates the law. Our liability in such an instance shall commence at the time we become aware of the respective violation.

Liability for Links

Our site contains links to third-party Web sites. We have no influence whatsoever on the information on these Web sites and accept no guaranty for its correctness. The content of such third-party sites is the responsibility of the respective owners/providers.

At the time third-party Web sites were linked to ours, we found NO GROUNDS WHATSOEVER of any likely contravention of the law. We shall promptly delete a link upon becoming aware that it violates the law.


The content and works provided on these Web pages are governed by the copyright laws of Germany. Duplication, processing, distribution, or any form of commercialization of such material beyond the scope of the copyright law shall require the prior written consent of its respective author or creator.

Data Protection

Please be aware that there are inherent security risks in transmitting data, such as e-mails, via the Internet, because it is impossible to safeguard completely against unauthorized access by third parties. Nevertheless, we shall safeguard your data, subject to this limitation. In particular, personal information will be transmitted via the Internet only if it does not infringe upon third-party rights, unless the respective party has given its prior consent in view of such security risks. Accordingly, as the Web site provider, we shall not be held liable for any damages incurred as a consequence of such security risks or for any related acts of omission on our part.

We oppose the use of any available contact information by a third party for sending unsolicited advertisements. As the Web site provider, we reserve the express right to take legal action against unsolicited mailing or e-mailing of spam and other similar advertising materials.

source: S&K Rechtsanwälte supported by;