Data Protection Policy of Harmonic Drive AG, Limburg an der Lahn



Art. 1 Information on the collection of personal data

(1) In the following, we inform you about the collection of personal data during use of our website and for participation in our online application procedure. Personal data are all data that can be related to you personally, e.g. name, address, email addresses, user behaviour.

(2) The “controller” within the meaning of Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is Harmonic Drive AG, Hoenbergstr. 14, 65555 Limburg an der Lahn, phone: +49 6431 5008-0, fax: +49 6431 5008-119, email: info@harmonicdrive.de, represented by the management board, namely Ekrem Sirman (CEO), Masanao Kobayashi, Norimitsu Ito.

Our external data protection officer, Mr. Martin Schwehn, can be contacted at LAN Security, Gesellschaft für Netzwerktechnik und Netzwerksicherheit, Konnwiese 13, D-56477 Rennerod, phone.: +49 2664 9971-90, fax: +492664 99719-19, datenschutz@lan-security.de.

(3) When you contact us by email or using of a contact form, the data provided by you (your email address, and name and telephone number, where applicable) will be stored by us for the purpose of responding to your questions. We will erase the data generated in this context when storage of it is no longer necessary, or will restrict the processing of it in cases where statutory preservation duties apply.

(4) In cases where we avail ourselves of contract service providers for particular functions of our offer or wish to use your data for advertising purposes, we will inform you in detail below about the respective processes. We will also state the specified criteria relating to the duration of storage.

(5) We will store your data in particular for the purpose of contract implementation and pre-contractual contacts, but also for the purpose of direct advertising and for maintenance of the customer relationship (Art. 6 (1) Sentence 1 f) GDPR).

(6) We will store your data for no longer than the duration of the statutory preservation duties or, if no such period is specified, for 24 months at most. Beyond that, we will store your data only if a legitimate interest exists, in particular if we continue to need your data for the implementation of a contract.



Art. 2 Your rights

(1) You have the following rights towards us with regard to your personal data:

– Right to information,

– Right to rectification or erasure,

– Right to restriction of processing,

– Right to object to processing,

– Right to data portability.

(2) You also have the right to complain to a data protection supervisory authority concerning the processing of your personal data by us.



Art. 3 Collection of personal data during visits to our website

(1) In the case of use of our website for purely informational purposes, i.e. if you do not register or otherwise provide us with information, we will only collect the personal data transmitted by your browser to our server. If you wish to view our website, we will collect the following data which we need for technical reasons in order to display our website to you and to ensure stability and security (the legal basis for this is Art. 6 (1) Sentence 1 f) GDPR):

– IP address

– Date and time of inquiry

– Difference in time zone from Greenwich Mean Time (GMT)

– Content of the request (concrete page)

– Access status/HTTP status code

– Data volume transmitted

– Website from which the request came

– Browser

– Operating system and its interface

– Language and version of the browser software.

(2) In addition to the aforesaid data, when you use our website, cookies will be stored on your computer. Cookies are small text files which are stored on your hard drive by the browser used by you and which allow certain information to be channelled to the body initiating the cookie (in this case ourselves). Cookies cannot execute any programs or transmit viruses to your computer. Their purpose is to make the website altogether more user-friendly and efficient.

(3) Use of cookies:

a) This website uses the following types of cookies, the scope and functioning of which is explained below:

– Transient cookies (see b)

– Persistent cookies (see c).

b) Transient cookies are deleted automatically when you close the browser. One form of transient cookies are “session cookies”. These store a so-called session ID, which enables several inquiries from your browser to be attributed to the joint session. This allows your computer to recognize when you return to our website. Session cookies are deleted when you log off or close the browser.

c) Persistent cookies are automatically deleted after a specified period of time, which may differ from cookie to cookie. You can delete the cookies at any time via the security settings of your browser.

d) You can configure your browser settings in line with your personal wishes and, for example, refuse to allow third-party cookies or indeed any cookies on your computer. We would, however, point out that in that case you may not be able to use all the functions of this website.

e) [The flash cookies used are not registered by your browser but through your flash plug-in. We also use HTML5 storage objects, which are stored on your terminal device. These objects store the necessary data independently of the browser used by you and have no automatic expiry date. If you do not wish the processing of flash cookies, you must install an appropriate add-on, e.g. “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe-Flash-Killer-Cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using the private mode on your browser. We also recommend you to regularly delete your cookies and browser history manually.]



Art. 4 Further functions and features of our website

(1) As well as use of our website for purely informational purposes, we also offer various features which you can make use of in case of special interest. In order to do so, you normally have to provide further personal data which are used by us in order to provide the service concerned and which are subject to the data processing principles detailed above.

(2) In some cases, we make use of external service providers for processing your data. They are carefully selected and contracted by us, are bound by our instructions and are regularly monitored.

(3) We may also transmit your personal data to third parties in cases where participation in special offers or competitions, the conclusion of contracts or other such services are offered by us jointly with other partners. Further information on this will be provided on submission of your personal date or in the description at the bottom of the offer.

(4) In cases where our service providers or partners are domiciled in a country outside of the European Economic Area (EEA), we will inform you of the consequences of this in the description of the offer.



Art. 5 Objection to or withdrawal of consent to processing of your data

(1) If you have given consent to the processing of your data, you may withdraw your consent at any time. Such withdrawal will affect the admissibility of processing of your personal data after you have issued it to us.

(2) If we base our processing of your personal data on a balance of interests, you may lodge an objection to the processing. This is the case if, in particular, the processing is not necessary for the fulfilment of a contract with you, which will in each case be detailed by us in the subsequent description of the functions. If you exercise your right to object, we would request you to state the reasons why we should not process your personal data in the manner performed by us. In the case of a reasoned objection, we will review the matter and will either discontinue the data processing, or modify it, or inform you of our compelling legitimate grounds for continuing to process the data.

(3) You can naturally object to the processing of your personal data for purposes of advertising and data analysis at any time. You can inform us of your objection to advertising by using the following contact data: Harmonic Drive AG, Hoenbergstr. 14, 65555 Limburg an der Lahn, phone: +49 6431 5008-0, fax: +49 6431 5008-119, email: info@harmonicdrive.de.



Art. 6 Social Media

1. Use of Social Media plug-ins

(1) We currently use the following Social Media plug-ins: Facebook, Xing, LinkedIn, YouTube. We thereby make use of the so-called two-click solution. That means that when you visit our website, no personal data is initially transmitted to the plug-in providers. The plug-in providers can be recognized by the marking in the box above their initials or logos. We offer you the possibility to communicate directly with the plug-in provider via the button. Only if you activate the marked field by clicking on it is the plug-in provider informed that you have accessed the corresponding website of our Internet offering. At the same time, the data indicated in Art. 3 of this Policy Statement are transmitted. In the case of Facebook and Xing, the IP address is, according to the respective providers in Germany, anonymized immediately after collection. Activation of the plug-in therefore causes personal data to be transmitted by you to the plug-in provider and stored by the latter (in the case of US providers, in the USA). As the plug-in provider performs data collection in particular through cookies, we recommend you to delete all cookies via the security settings of your browser before clicking on the greyed-out box.

(2) We have no influence on the data collected or the data processing operations, nor are we informed of the full scope of the data collection, the purposes of processing or the storage periods. Nor do we have any information on deletion of the collected data by the plug-in provider.

(3) The plug-in provider stores the data gathered on you in the form of usage profiles and uses them for purposes of advertising, market research and/or customisation of its website. Such evaluation is performed (even for non-logged-on users) in particular for the presentation of individualized advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of such user profiles, although to exercise this right you must contact the plug-in provider concerned. Through use of the plug-ins, we offer you the possibility to interact with the social networks and other users, with the purpose of enabling us to improve our offering and enhance its interest to you as the user. The legal basis for use of the plug-ins is Art. 6 (1) Sentence 1 f) GDPR.

(4) The data transfer takes place irrespective of whether you have an account with the plug-in provider and are logged on there or not. If you are logged on with the plug-in provider, the data collected on you on our site will be directly assigned to the account existing with the plug-in provider. If you click on the activated button and e.g. create a link to the site, the plug-in provider will also store this information on your user account and communicate it publicly to your contacts. We recommend you to regularly log off after using a social network, but also and in particular before activating the button, as this will enable you to prevent assignment to your profile with the plug-in provider.

(5) Further information on the purpose and scope of data collection and processing of it by the plug-in provider can be found in the data protection policy statements of the providers which are detailed below. The policy statements also contain further information on your rights in this context and on the settings possibilities for protecting your privacy.

(6) Addresses of the various plug-in providers and URL with their data protection notices:

a) Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; www.facebook.com/policy.php; further information on data collection: www.facebook.com/help/186325668085084, www.facebook.com/about/privacy/your-info-on-other, and www.facebook.com/about/privacy/your-info. Facebook has subscribed to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.

b) LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; www.linkedin.com/legal/privacy-policy. LinkedIn has subscribed to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

c) Xing AG, Dammtorstr. 29-32, 20354 Hamburg, https://www.xing.com/app/share?op=data_protection

d) YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066 USA www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has subscribed to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework



2. Integration of YouTube videos

(1) We have integrated YouTube videos into our online offering; the videos are stored at www.YouTube.com and can be played directly from our website. [They are all included in the “enhanced data protection mode”, i.e. such that no data relating to you as the user are transmitted to YouTube if you do not play the videos. Only when you actually play the videos are the data referred to in paragraph 2 transmitted. This data transmission is beyond our control.]

(2) Through your visit to the website, YouTube is informed that you have accessed the corresponding sub-site of our website. Additionally, the data detailed in Art. 3 of this Policy Statement are transmitted. This takes place irrespective of whether YouTube is providing a user account through which you are logged on, or whether no user account exists. If you are logged on with Google, your data are directly assigned to your account. If you do not wish assignment with your profile on YouTube, you must log off before activating the button. YouTube will store your data as usage profiles and use them for purposes of advertising, market research and/or customisation of its website. Such evaluation is performed (even for non-logged-on users) in particular for the presentation of individualized advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of such user profiles, although to exercise this right you must contact YouTube itself.

(3) Further information on the scope and purpose of collection and processing of the data by YouTube can be found in the data protection policy statement. It also contains further information on your rights and the settings possibilities for protecting your privacy: www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has subscribed to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.



Art. 7 Web Analytics

1. Use of Google Analytics

(1). This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies”, i.e. text files which are stored on your computer and which enable analysis of your use of the website. The information generated by the cookie on your use of this website is generally transmitted to a Google server in the USA, where it is stored. In Member States of the European Union or other signatory states to the Treaty on the European Economic Area, however, the IP anonymization function on the website, if activated, means that your IP address is shortened by Google before transmission of the data. Only in exceptional cases is the full IP address sent to a Google server in the USA and then shortened there. Google uses this information on behalf of the operator of this website to evaluate your usage of the website, compile reports on the website activities and provide the website operator with other services associated with use of the website and of the Internet.

(2) The IP address transmitted by your browser in the context of Google Analytics will not be merged with other Google data.

(3) You can prevent storage of the cookies by choosing the corresponding setting of your browser software; we would, however, point out that in this case you may then not be able to make full use of all the functions on this website. You can additionally prevent transmission of the data generated by the cookie and relating to your use of the website (including your IP address) to Google and processing of the data by Google by downloading and installing the browser plug-in available from the following link: tools.google.com/dlpage/gaoptout.

(4) This website uses Google Analytics with the extension “_anonymizeIp()”. This causes IP addresses to be shortened before further processing, so that reference to a specific person can be ruled out. As soon as the data collected on you acquires a personal reference, therefore, this is immediately ruled out and the personal data are immediately deleted.

(5) We use Google Analytics to analyse the use of our website and make regular improvements to it. The statistical information obtained allows us to improve our offering and enhance its interest to you as a user. For the exceptional cases in which personal data are transmitted to the USA, Google has subscribed to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 (1) Sentence 1 f) GDPR.

(6) Information of the third-party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, FAX: +353 (1) 436 1001. User terms: www.google.com/analytics/terms/de.html, data protection overview: www.google.com/intl/de/analytics/learn/privacy.html, and the data protection policy statement: www.google.de/intl/de/policies/privacy.

(7) This website also uses Google Analytics for cross-device analysis of visitor flows, which is conducted on the basis of user IDs. You can deactivate the cross-device analysis of your use in your customer account under “My data”, “personal data”.

2. Use of von Google Tag Manager

Google uses information on your usage behaviour for the purpose of evaluating your usage behaviour. This serves as the basis for the generation of reports on website usage and user behaviour. There is no link-up of your usage behaviour to your IP address. For provision of the service, Google uses pseudonyms instead.

In connection with use, we have the possibility to manage so-called website tags via an interface. The Google Tag Manager is a cookieless domain which does not collect any personal data. The Google Tag Manager may, however, cause further tags to be triggered, which on their part can collect data. The Google Tag Manager does not access this data.

You can deactivate the tags implemented with Google Tag Manager by making the appropriate settings on your browser at domain or cookie level.

Information on the third-party provider can be found above under “Google Analytics”.

The legal basis for the use of Google Analytics is Art. 6 (1) Sentence 1 f) GDPR.

3. Use of Wired Minds

For analysing visitor behaviour, our website uses tracking pixel technology from wiredminds GmbH, Lindenspürstr. 32, 70176 Stuttgart, https://www.wiredminds.de. This may involve the collection, processing and storage of data, from which usage profiles are generated under a pseudonym. Wherever possible and meaningful, such usage profiles are completely anonymized. Cookies may be used for this purpose. Cookies are small text files which are stored on the visitor’s browser and are used for re-recognizing the internet browser. The collected data, which may also include personal data, are transmitted to Wired Minds or gathered directly by Wired Minds. Wired Minds may use information which is left behind by visits to the websites in order to generate anonymized usage profiles. Except with the specific consent of the visitor, the data so obtained are not used to personally identify the visitor to the website, and they are not merged with personal data through the carrier of the pseudonym. Where IP addresses are recorded, they are immediately anonymized through deletion of the last block of numbers.

The legal basis for the use of Wired Minds is Art. 6 (1) Sentence 1 f) GDPR.

4. DoubleClick by Google

(1) This website also uses DoubleClick, an online marketing tool from Google. DoubleClick employs cookies in order to activate advertisements that are relevant for the user, improve reports on the performance of campaigns or prevent a user being shown the same advertisements several times. With the aid of a cookie ID, Google registers what advertisements are being shown on which browser and so can prevent them from being shown repeatedly. With the aid of cookie IDs, DoubleClick can also record so-called conversions which have a reference to advertising requests. That is the case, for example, if a user sees a DoubleClick advertisement and later accesses the advertiser’s website and purchases an item there using the same browser. According to Google, DoubleClick cookies do not hold any personal information.

(2) Through the marketing tools employed, your browser automatically generates a direct connection to the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you to the best of our knowledge as follows: Through the involvement of DoubleClick, Google is informed that you have accessed the corresponding section of our website or have clicked on one of our advertisements. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged on, it is still possible that the provider may acquire knowledge of your IP address and store it.

(3) You can prevent participation in this tracking procedure in a number of ways: a) by choosing the appropriate setting on your browser software, with the suppression of third-party cookies, thus ensuring that, in particular, you do not receive adverts from any third parties; b) through deactivation of the conversion tracking cookies, by setting your browser so as to block cookies from the “www.googleadservices.com” domain, www.google.de/settings/ads, whereby this setting is deleted if and when you delete your cookies; c) through deactivation of the interest-related advertisements of suppliers who are part of the “About Ads” self-regulation campaign via the link www.aboutads.info/choices, whereby this setting is deleted if and when you delete your cookies; d) through permanent deactivation on your Firefox, Internet Explorer or Google Chrome browsers under the link www.google.com/settings/ads/plugin. We would draw your attention to the fact that in this case, you may not be able to make full use of all the functions of this offering.

(4) The legal basis for the processing of your data is Art. 6 (1) Sentence 1 f) GDPR. Further information on DoubleClick by Google can be found at www.google.de/doubleclick and support.google.com/adsense/answer/2839090, and on data protection at Google in general at www.google. de/intl/de/policies/privacy. Alternatively, you can visit the Network Advertising Initiative (NAI) website at www.networkadvertising.org. Google has subscribed to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.



Art. 8 Participation in our application procedure

  1. If you decide to apply for employment in our company via our jobs portal, we wish to provide you with the following information relating to handling of your data and your rights. Responsibility for data processing lies with Harmonic Drive AG, Hoenbergstr. 14, 65555 Limburg an der Lahn, phone: +49 6431 5008-0, fax: +49 6431 5008-119, email: info@harmonicdrive.de, represented by the management board, namely Ekrem Sirman (CEO), Masanao Kobayashi, and Norimitsu Ito.

  2. We will process and store the data you transmit to us in connection with the application procedure.

  3. The purpose of the processing and storage is to implement the application procedure and review your suitability for the advertised post or for other vacancies within our company, if applicable.

  4. The legal basis for the data processing is Section 26 BDSG [German Data Security Act]. This permits the processing of data in connection with the formation of an employment relationship. On completion of the application procedure, we will continue to store your claims to ensure effective assertion of rights. This has the purpose, in turn, of ensuring the ability to defend claims and is a matter of legitimate interest to us pursuant to Art. 6 (1) Sentence 1 f) GDPR. We will store your data for a period of 6 months and, with your consent, also in our applicant pool for 2 years. The data will then be erased. If we select you for the advertised post, your application data will be placed on our HR system.

  5. All data processing is done at computer centres located in Germany.

  6. Your rights correspond to those set forth in Arts. 2 and 5 above. In Art. 2, you will find information on how to contact the data protection officer.