Privacy policy

We are very pleased about your interest in our company. Data protection has a particularly high priority for the management of HW PARTNERS AG, Bonn. The use of our website is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, processing of personal data could become necessary. If processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to us. By means of this data protection declaration, we would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this data protection declaration.

As the controller, HW PARTNERS AG, Bonn  has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can always be subject to security vulnerabilities, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

  1. Definitions

The privacy policy is based on the terms used in the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain terminology in advance.

We use the following terms, among others, in this Privacy Policy:

a) personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Person concerned

Data subject is any identified or identifiable natural person whose personal data are processed by the controller.

c) Processing

Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

e) Controller or person responsible for processing.

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

f) Processor

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

g) Recipient

Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

h) Third Party

Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

i) Consent

Consent shall mean any freely given indication of the data subject's wishes for the specific case in an informed and unambiguous manner, in the form of a statement or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.


  1. Name and address of the controller or person responsible for processing

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:


Rheinwerkallee 3

53227 Bonn

Tel.: 0228 / 4334 1000

Fax: 0228 / 4334 1200




  1. Name and address of the data protection officer

The data protection officer of the controller is:

Günter Hilgers

EcoVisio GmbH

Rheinwerkallee 3

53227 Bonn


Any data subject may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.


  1. Contact details of the supervisory authority

The competent supervisory authority for the data controller is:

Name:    Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen

Street:    Kavalleriestraße 2 – 4

Location:    40213 Düsseldorf

Telefone:    +49211/38424-0

Fax:     +49211/38424-10



  1. Cookies

A cookie is a small data record that is stored on your terminal device and contains data such as personal page settings and login information. This data record is generated by the web server with which you have established a connection via your web browser and sent to you. In general, we use cookies to analyze interest in our websites and to improve the user-friendliness of our websites. In principle, you can also access our web pages without cookies. However, if you wish to use our web pages to their full extent or comfortably, you should accept those cookies that enable the use of certain functions or make the use more comfortable. The purposes of the cookies used by us can be found in the following overview.

By using our websites, you agree to the use of these cookies, insofar as cookies are accepted according to your browser settings. Most browsers are set by default to accept all cookies. However, you have the option of setting your browser in such a way that cookies are displayed before they are stored, only certain cookies are accepted or rejected, or cookies are generally rejected.

We would like to point out that changes to settings only ever affect the browser in question. If you use different browsers or change the end device, the settings must be made again. In addition, you can delete cookies from your storage medium at any time. For information on cookie settings, how to change them and how to delete cookies, please refer to the help function of your web browser.

The most common types of cookies are explained below for your understanding:

  • Session cookies

While you are active on a website, a session cookie is temporarily stored in the memory of your computer, in which a session identifier is stored, for example, to prevent you from having to log in again each time you change pages. Session cookies are deleted when you log out or lose their validity once their session has automatically expired.

  • Permanent or protocol cookies

A persistent or protocol cookie stores a file on your computer for the period of time specified in the expiration date. These cookies allow websites to remember your information and settings the next time you visit. This results in faster and more convenient access, as you do not have to set your language preferences for our portal again, for example. When the expiration date passes, the cookie is automatically deleted when you visit the website that generated it.

  • Third-party cookies

Third-party cookies come from providers other than the website operator. For example, they may be used to collect information for advertising, custom content, and web statistics.

  • Flash cookies

Flash cookies are stored on your computer as data elements of web pages when they are powered by Adobe Flash. Flash cookies have no time limit.


  1. Collection of general data and information1

Our website collects a series of general data and information with each call of the website by a data subject or an automated system. This general data and information is stored in the log files of the server. The following data may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of an access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is required in order to (1) correctly deliver the content of our website, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, we statistically evaluate this anonymously collected data and information on one hand, and on the other hand, with the aim of increasing the data protection and data security of our enterprise, so that we can ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.


  1. SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.


  1. Scope and purpose of the collected data

8.1 HW PARTNERS Web Pages - In General

Whenever a web page or a file accessible via a browser program is requested, the following data is stored:

  • the requested web page or file,
  • the date and time of the request
  • the amount of data transferred,
  • the description of the type of web browser and operating system used,
  • the IP address of the requesting computer,

This information is used to optimize the HW PARTNERS websites and to log possible attacks via the Internet on our services.

The data listed will be deleted automatically or by employees of HW PARTNERS AG after one year.

8.2 HW PARTNERS websites - registration

During registration for the HW software via the website, the user's e-mail address is stored. The password for the HW PARTNERS software entered during registration is stored exclusively in encrypted form and cannot be decrypted even by HW PARTNERS AG.

HW PARTNERS AG explicitly points out that the e-mail addresses of all active (i.e. not deleted) users are used to send messages to these users concerning the availability of our contractually guaranteed services; e.g. the notification of maintenance periods. As this is contract performance information, unsubscribing from these communications is not possible.

8.3 HW PARTNERS Websites - Contact Form

The HW PARTNERS web pages include the possibility to contact HW PARTNERS AG in general. At least the following data from the mandatory fields are stored:

  • E-mail adress,
  • Free text.

This data is used by HW PARTNERS AG to respond to inquiries.

The data stored in individual cases correspond to the fields specified in the forms and can therefore be seen directly from the forms. Data is only passed on to third parties with the consent of the respective user.

8.4 Cooperation partners

The personal data collected by HW PARTNERS AG may also be passed on to cooperation partners for use within the scope of the previously stated purpose if consent has been given. In order to offer the most comprehensive services possible, HW PARTNERS AG works with carefully selected cooperation partners. These are not included in the present data protection declaration and will possibly collect and use additional data outside the sphere of influence of HW PARTNERS AG.

7.9 Extended data use

After the user has given his recorded consent to "extended data processing", HW PARTNERS AG is entitled to collect, process and use personal data as well as profile data and demographic data for the purpose of optimizing the HW PARTNERS services. After the user has given his consent, HW PARTNERS AG is not obliged to delete the usage data as soon as possible, i.e. at the latest immediately after the end of the respective usage, but is entitled to store it.

Furthermore, HW PARTNERS AG is entitled, with the user's consent, to pass on the user's personal data to cooperation partners for the purposes of advertising, market research, information about products and services, the delivery of offers for the conclusion of contracts for services and further information optimally tailored to the user's interests by means of a newsletter.

Consent is given by placing a check mark in the appropriate box. The given consent is logged and can only be revoked by written request of the user to the addresses listed under 2).


  1. Deletion and blocking of personal data

The controller processes and stores personal data of the data subject only for the period of time necessary to achieve the purpose of storage or if this has been provided for in laws or regulations to which the controller is subject.

If the storage purpose ceases to apply or if a storage period prescribed by another competent legislator expires, the personal data shall be blocked or deleted in accordance with the statutory provisions.


  1. Rights of the data subject

a)    Right to information

You can exercise your right to information from us at any time in accordance with Art. 15 DSGVO as to whether personal data relating to you is being processed by us.

b)    Right to rectification

You may exercise your right of rectification in accordance with Art. 16 DSGVO towards us at any time and request the correction of any inaccurate personal data concerning you.

c)    Right to restriction of processing

You may exercise your right to restrict processing in accordance with Art. 18 DSGVO at any time and request the restriction of processing, provided that the legal requirements for this are met.

d) Right to erasure

You may exercise your right to erasure pursuant to Art. 17 DSGVO towards us at any time, and request that personal data concerning you be deleted without undue delay if such data is no longer necessary for the purposes for which it was collected or otherwise processed. This right to erasure may be opposed by other legal obligations (e.g. retention obligations).

e)    Right to information

You can assert your right to information in accordance with Art. 19 DSGVO against us at any time. If you have asserted a right to erasure, rectification or restriction of processing of personal data relating to you, we are obliged to inform all recipients to whom the personal data relating to you has been disclosed of the rectification or erasure of the data or the restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.

f)     Right to data portability

You may exercise your right to data portability in accordance with Art. 20 DSGVO at any time. You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller if this is technically feasible.

g)    Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the DS-GVO.

We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defense of legal claims.

If we process personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to processing of personal data processed for such marketing. If the data subject objects to us to the processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In order to exercise the right to object, the data subject may contact us directly. The data subject is also free to exercise his or her right to object by means of automated procedures.

h)      Right to revoke consent granted under data protection law.

You have the right to revoke your consent to the processing of personal data under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

i)       Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

  1. Privacy policy on the use and application of Facebook1

The controller has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is a social meeting place operated on the Internet, an online community that generally allows users to communicate with each other and interact in virtual space. A social network can serve as a platform for sharing opinions and experiences or enables the Internet community to provide personal or company-related information. Among other things, Facebook enables users of the social network to create private profiles, upload photos and network via friend requests.

The operating company of Facebook is Facebook, Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. The controller of personal data, if a data subject lives outside the USA or Canada, is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the data controller is called up and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the information technology system of the data subject is automatically caused by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins can be found at Within the scope of this technical procedure, Facebook receives knowledge of which specific sub-page of our website is visited by the data subject.

If the data subject is logged in to Facebook at the same time, Facebook recognizes which specific sub-page of our website the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject activates one of the Facebook buttons integrated on our website, for example the "Like" button, or if the data subject makes a comment, Facebook assigns this information to the personal Facebook user account of the data subject and stores this personal data.

Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is logged into Facebook at the same time as calling up our website; this takes place regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want this information to be transmitted to Facebook, he or she can prevent the transmission by logging out of his or her Facebook account before accessing our website.

The data policy published by Facebook, which can be accessed at provides information about the collection, processing and use of personal data by Facebook. It also explains which setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

  1. Privacy policy on the use and application of Google Analytics (with anonymization function)1

The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, compilation and evaluation of data about the behavior of visitors to websites. A web analysis service collects, among other things, data on which website a data subject came to a website from (so-called referrers), which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is mainly used for the optimization of a website and for the cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.</p>

The controller uses the addition "_gat._anonymizeIp" for web analysis via Google Analytics. By means of this addition, the IP address of the Internet connection of the data subject is shortened and anonymized by Google if access to our Internet pages is from a Member State of the European Union or from another State party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us that show the activities on our website, and to provide other services related to the use of our website.

Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. By each call of one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently enable commission calculations.

By means of the cookie, personal information, such as the access time, the location from which an access originated and the frequency of visits to our website by the data subject, is stored. Each time the data subject visits our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the possibility to object to the collection of data generated by Google Analytics and related to the use of this website as well as to the processing of this data by Google and to prevent such processing. For this purpose, the data subject must download and install a browser add-on under the link  This browser add-on informs Google Analytics via JavaScript that no data and information regarding visits to Internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the information technology system of the data subject is deleted, formatted or reinstalled at a later point in time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. Provided that the browser add-on is uninstalled or deactivated by the data subject or another person attributable to his or her sphere of control, there is the option of reinstalling or reactivating the browser add-on.

Further information and the applicable Google privacy policy can be found at and at  Google Analytics is explained in more detail under this link .

  1. Legal basis of processing

Art. 6 I lit. a DS-GVO serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation by which a processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GVO.

Finally, processing operations could be based on Art. 6 I lit. f DS-GVO. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, Sentence 2 DS-GVO).

  1. Legitimate interests in the processing pursued by the controller or a third party.

If the processing of personal data is based on Article 6 I lit. f DS-GVO, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.

  1. Duration for which the personal data is stored.

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the performance of the contract or the initiation of the contract.

  1. Legal or contractual requirements for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision1

We inform you that the provision of personal data is sometimes required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner).

Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.

Before providing personal data by the data subject, the data subject must contact one of our employees. Our employee will explain to the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.

(1) This data protection declaration was created in the marked points by the data protection declaration generator, which is operated and provided in cooperation between DGD Deutsche Gesellschaft für Datenschutz GmbH, Dachau (available at:  and the law firm Wilde/Beuger/Solmecke Rechtsanwälte GbR, Cologne (available at: These texts are subject to the copyright of DGD Deutsche Gesellschaft für Datenschutz GmbH, Dachau and the law firm Wilde/Beuger/Solmecke Rechtsanwälte GbR, Cologne.