Privacy Policy of HD Hyundai Infracore Deutschland GmbH

This Privacy Policy (hereinafter: “Privacy Policy“) will govern the processing of your personal data during your visits to our website []  (hereinafter referred to as “Website”), in your communication with us by e-mail, contact form, telephone, fax and via social networks (hereinafter referred to as “social media channels”) such as Facebook, LinkedIn, Twitter, Pinterest, Google+ and Instagram).

NOTE 1: This privacy policy does not apply to the processing of personal data of applicants who apply for a job with us via our website, in particular by e-mail.

NOTE 2. For information about how we process personal data using cookies, social network plug-ins and other types of tracking technologies, please see our Cookie Policy.

1. General

1.1. Controller within the meaning of the EU General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations, for your personal data is HD Hyundai Infracore Deutschland GmbH, Seckenheimer Landstraße 210-220, 68163 Mannheim, ( hereinafter: “Develon”, “we”, “us”, “our”). We can be reached by e-mail at

1.2. Our data protection officer is: ………,

1.3. Where reference is made to specific laws or regulations, such reference shall also include any amendment, replacement or repeal of such laws or ordinances and any related requirements that are mandatory for us.

1.4. Develon reserves the right to change this Privacy Policy from time to time. Such changes, adjustments or additions will be communicated via the Website.

2. Type of personal data we process and collect

2.1. Whenever you use our website or social media channels, we collect the following types of data:

  • technical information about the device you are using, such as the shortened and anonymized IP address, browser type, geographical location and operating system
  • Information about your browsing behavior, e.g. surfing time, links opened, pages visited and number of page views

2.2. When you fill out the contact form on our website or contact us by email, telephone, fax, in person or via our social media channels, we collect the following types of data: 

  • Personal information such as name, e-mail address, address, telephone number, company where you are employed, your function there
  • Content of your message, technical details of the message, e.g. Your communication partner with us as well as date and time
  • Your preferences regarding receiving our email and telephone communications, if you have opted in to receive such communications and have indicated your preferences in the contact form. 
  • Publicly available information about your social network profiles 

2.3. We receive all personal data listed above directly from you. It may happen that we receive additional information about your preferences and surfing behavior from partners such as Google, Facebook, etc. Further information about the personal data processed by these partners and made available to external parties can be found in their respective privacy statements:

3. Verarbeitungszwecke

3.1. Develon processes your personal data in order to provide you with the information, products and services you request via the Website, email, telephone, fax, personal and our social media channels.

3.2. Develon processes your personal data for marketing purposes, i.e. to send you targeted communications, promotions, offers and other advertisements from Develon and selected partners.

3.3. If you are not an existing customer, and have not yet purchased similar goods or services from us and have not yet received our sales information, Develon will not send you promotions, offers, newsletters and other advertising by email or other direct electronic means of communication unless you have expressly consented to receive such communications, promotions, offers, newsletters and other advertising.

3.4. Develon also processes your personal data to comply with legal obligations and legitimate requests from relevant law enforcement authorities or representatives, judicial authorities, government authorities or bodies such as the relevant data protection authorities.

Your personal data may be transmitted as evidence to the police or judicial authorities at Develon’s initiative. This is also possible if there is reasonable suspicion of an unlawful act or criminal offence that you may have committed through your registration or use of the website, our social media channels or in the context of any other communication with us.

3.5. We may need to collect and transfer your personal information to our financial institution or payment processor to enable them to comply with their legal obligations, such as:  obligations under applicable anti-money laundering and terrorist financing laws.

3.6. Develon processes your personal data for statistical purposes. This serves to improve our websites, products and services or to develop new products and services.

3.8. Develon may process your personal data for the legitimate interests of Develon, Develon’s partners or third parties if your registration on or use of the Website, social media channels or other communication channels is considered (a) a violation of the applicable Terms of Use or the intellectual property rights or other rights of third parties, or (b) a threat to the security or integrity of the Website;  social media channels or other communication channels, or (c) may be considered a threat to the Website, social media channels or other communication channels or to the underlying systems of Develon or Develon’s subcontractors due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) hateful, obscene, discriminatory, racist, defamatory, malicious, hurtful or otherwise  may be considered inappropriate or illegal.

3.7. Develon may process your personal data in order to provide information to an external entity in the context of a possible merger, acquisition or demerger by that external entity. This is possible even if this external body concerned is located outside the EU.

4. Legal bases for processing your personal data

4.1. For the processing of your personal data under the conditions set out in clause 3.3, Develon as the responsible party asks for your consent.

4.2. The processing of your personal data for the execution of an enquiry made by you or an order placed is necessary for the performance of the agreement between you and Develon.

4.3. The processing of your personal data for the purposes set out in provisions 3.4 and 3.5 is necessary for Develon to comply with legal obligations.

4.4. The processing of your personal data for the purposes set out in Regulations 3.1, 3.6  ,  3.7  and 3.8 may be necessary for the pursuit of Develon’s legitimate interests:

  • continuous improvements to Develon’s website, social media channels, products and services in order to provide you as a customer with the best possible offer
  • Protecting our website, social media channels, products and services from misuse and illegal activities
  • Sales and promotion of our products, services, brands as well as a generally successful marketing of our products and services

5. Receiver

5.1. BBG does not send your personal data to external parties without your express permission. Except for those required to fulfil our contractual and legal obligations or in the context of processing and implementing our legitimate interest. These could be:

  • external service companies that process data on our behalf as processors or functional transferees (e.g. external data centers, support/maintenance of EDP/IT applications, archiving, document processing, call center services, compliance services, controlling, data screening for anti-money laundering purposes, data validation or plausibility check, data destruction, purchasing/procurement, customer management, lettershops, marketing, media technology, research,  risk controlling, billing, telephony, website management, auditing services, credit institutions, printers or companies for data disposal, courier services, logistics);

5.2. In order to provide the Website and process your personal data, Develon relies on external parties to carry out this processing on our behalf. These third parties may only process your personal data on the express written instruction of Develon and only on behalf of Develon. Develon guarantees that all third-party data processors are selected with due diligence and are required to respect the security and integrity of your personal data.

5.3. Develon may share your personal data with other companies in the Develon Group. However, we will ensure that all business units of the Develon Group ensure that the processing of your personal data is in accordance with the provisions of this Privacy Policy.

6. Location and transfer

6.1. Develon processes your personal data mainly within the European Economic Area (EEA). In order to process your personal data for the purposes set out in clause 3 above  , we may also transfer your personal data  to other Develon Group entities or to external entities that process on our behalf and are located outside the EEA. However, if your personal data is processed outside the EEA, the relevant bodies are obliged to put in place appropriate safeguards when processing your personal data.  Such safety precautions result from the following circumstances:

  • The beneficiary country is subject to legislation which can be considered to provide the same level of protection as the provisions applicable to the EEA. 
  • There is a contractual agreement between Develon and the third party concerned. The Develon entities have entered into a joint arrangement based on the EU Controller-to-Controller (Commission Decision C(2004)5721).

6.2. Develon may transfer anonymised and/or aggregated data to organisations outside the EEA. For such transfers, Develon ensures the security and integrity of the data and all rights with respect to the personal data under applicable laws.

7. Quality assurance

7.1. For Develon, the obligation to limit the processing of personal data to the purposes referred to in point 3 is a top priority.

7.2. Your personal data will only be processed as long as it is necessary for the purposes set out in clause 3 of this Privacy Policy and as long as there is no objection on your part. Please note that the withdrawal of your consent may result in you no longer being able to use the website, social media channels and other communication channels in whole or in part. Once your personal data is no longer necessary for the  purposes set out in clause 3, it will be anonymised by Develon. The following exceptions apply: 

  • Overriding interest of Develon, your financial institution, the payment processor or other third party to keep your personal data identifiable
  • legal or regulatory obligation or court or governmental order prohibiting Develon from anonymizing

7.3. We would like to point out that an essential aspect of our sales effort is to make our advertising material more relevant to you. This means that Develon will create a profile of you based on the relevant characteristics described in clause 2 . This profile is used to send you communications, promotions, offers, newsletters and other product and service advertisements that are of interest to you.

7.4. Develon takes the appropriate technical and organisational measures to protect your personal data from unauthorised access or theft, as well as against accidental loss, manipulation and accidental destruction. Access by employees of Develon or our third-party data processors is based solely on a knowledge requirement basis and is subject to strict confidentiality obligations. However, we would like to point out that security and security are subject to the best-effort principle and can therefore never be guaranteed.

7.5. If you wish to change your preference for receiving communications, promotions, offers, newsletters and other advertisements by e-mail or other electronic direct communication channels, you can do so by sending an e-mail to . 

8. Your rights

8.1. You have the right to access all personal data processed by Develon. Develon reserves the right to charge a processing fee for multiple consecutive access requests if such access requests are intended to disrupt or damage Develon’s operations.

8.2. You have the right to rectification of incorrect personal data concerning you free of charge. Requests for rectification shall be accompanied by evidence of the inaccuracy of the data for which correction is requested.

8.3. With regard to your previously given consent to the processing of your personal data, you have a right of withdrawal. In this case, clause 8.4 shall apply.

8.4. If the personal data concerned is no longer necessary for the purposes referred to in clause 3 or you have  withdrawn your consent to the processing, you can have the data concerned deleted. Please note, however, that all deletion requests from Develon will check for the existence of one of the following cases:

  • Primary interest of Develon, your financial institution, the payment processor or any other external entity
  • legal or regulatory obligations or administrative or court orders that may conflict with the erasure request

Instead of requesting erasure, you can also request limited processing of your personal data by Develon. This is possible if (a) you dispute the accuracy of the data, (b) the processing is prohibited or (c) the data is no longer necessary for the purposes set out in clause 3 , but is still required by you for the defense in a legal dispute.

8.5. You have the right to object to the processing of personal data if there are evidence of serious and legitimate grounds relating to the particular circumstances of such an objection. If the processing we intend to do is considered direct marketing, you may object to such processing free of charge and without giving reasons.

8.6. You have the right to receive the personal data you have provided from us in a structured, commonly used and machine-readable form.

8.7. To make a request to exercise one or more of the above rights, contact by email. A request to exercise such a right made by e-mail will not be interpreted as consent to the processing of your personal data beyond what is necessary for the processing of the application. Such a request shall clearly indicate which right is to be exercised. If necessary, the reasons for this should also be stated. In addition, such an application must be dated and signed. In addition, a scan of a valid identification document must be accompanied by which your identity can be proven. When using the contact form, Develon may request your signed confirmation and proof of identity.

Develon will send an acknowledgement of receipt immediately upon receipt of your request. Valid applications will be processed by Develon within a reasonable time and no later than thirty (30) days after receipt of the request.

If you have any complaints regarding Develon’s processing of your personal data, you may contact Develon at any time at the email address provided in this provision. If you are not satisfied with Develon’s response, you may lodge a complaint with the relevant data protection authority. 

9. Cookies

9.1. A cookie is a small file, typically consisting of letters and numbers, downloaded onto a device when the user accesses certain websites (including the Web Site). Cookies are then sent back to originating website on each subsequent visit. Cookies are useful because they allow a website to recognize a user’s device. There are various types of cookies, such as:
Session cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put their shopping basket as they browse around a site. These session cookies expire after a browser session so would not be stored longer term. Persistent cookies – are stored on a users’ device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target adverting. First and third party cookies – Whether a cookie is ‘first’ of ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user – the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third party cookie.

9.2. The Web Site uses cookies, as almost all websites do, to help provide you with the best user experience. Our Cookies help us to:

  • Remember your settings during and between visits.
  • Improve the speed/security of the site.
  • Allow you to share pages with social networks like Facebook or Twitter.
  • Continuously improve our website for you.
  • Make our marketing more efficient.

9.3. We do not use cookies to:

  • Collect any personally identifiable information (without your express permission).
  • Collect any sensitive information (without your express permission).
  • Pass data to advertising networks.
  • Pass personally identifiable data to third parties.

9.4. We use cookies to ensure the Web Site performs to its most efficient capacity. This includes:

  • Google Analytics: to gather site performance information.
  • Yahoo Web Analytics: to gather site performance information.
  • JavaEE: remembering your setting for our website.
  • SiteLanguage: remembering your language selection on the site between visits.

9.5. The Web Site, like most websites, includes functionalities provided by third parties. A common example is an embedded YouTube video. The Web Site includes the following third party links which use cookies:

  • YouTube – Privacy Policy power the videos on our site
  • Google – Privacy Policy

9.6. As we’ve explained above, cookies help you to get the most out of our websites. The first time you accessed our website you should have seen an overlay which explained that by continuing to access our site, you are consenting to our use of cookies.

We communicate with you to provide information, products and services that you have requested. It is your choice to send us these requests. Through your internet browser, you may have the option to reject this Web Site’s cookies and still use this Web Site. However, your access to this Web Site will be limited. You may always opt out of receiving marketing emails by following the instructions on the marketing email.

Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly.