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Project Halyard
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Customer portal Halyard Online

Privacy policy

Draft – pending legal review. This text has not been approved yet and contains open items.

This is a translation for your convenience; only the German version is legally binding.

As of: [Date]

1. Controller

The controller responsible for processing personal data on this website, in the customer portal and in Halyard Online is:

Project Halyard GmbH i.G.
Harburger Schloßstraße 6–12
21079 Hamburg
Germany
Represented by
Christian Werner, Managing Director
Phone
+49 163 7820880
Email
c.werner@project-halyard.com
Data protection officer
[Name and contact details – if appointed, otherwise delete this line]

2. Hosting

The website, the customer portal and Halyard Online run on servers of [Hosting provider: company and address], location [Data centre, country]. A data processing agreement pursuant to Art. 28 GDPR is in place with the hosting provider [check and add date].

The website does not load any content from third parties. Fonts, images and scripts are served exclusively from our own server.

3. Server logs

When you visit the website, our web server processes technically necessary access data: [Data categories, e.g. IP address, date and time, requested address, status code, browser identifier – check against the actual logging].

The purpose is to provide the website securely and reliably, in particular to detect and fend off faults and attacks. The legal basis is Art. 6(1)(f) GDPR [check]. The data is deleted after [Retention period].

4. Login (Keycloak) and cookies

The website itself does not set any cookies. For logging in to the customer portal and to Halyard Online we use the Keycloak software on our own server. Login data (username or email address, password and – for Halyard Online – a verification code) is processed, and technically necessary cookies are set to maintain the login session and to store the selected language [check list of cookies and lifetimes, e.g. AUTH_SESSION_ID, KC_RESTART, KEYCLOAK_IDENTITY, KEYCLOAK_SESSION, KEYCLOAK_LOCALE].

The legal basis for setting the cookies is Section 25(2) No. 2 TDDDG (German Telecommunications Digital Services Data Protection Act), and for processing the login data Art. 6(1)(b) GDPR [check]. The session ends after [Session lifetime per Keycloak setting] or when you log out.

The applications store settings such as language and display mode in your browser's local storage (localStorage); this data does not leave your device.

[Processing within the applications, e.g. log of control commands (audit log) and operational emails – possibly a separate section]

5. Contact by email

If you write to us by email, we process your details (email address, name, content of the message) in order to answer your enquiry. The legal basis is Art. 6(1)(b) GDPR if the enquiry relates to a contract, otherwise Art. 6(1)(f) GDPR [check].

Email provider: [Provider, data processing agreement, transfers to third countries if any]. Retention period: [Period].

6. Rights of data subjects

You have the following rights with regard to the personal data concerning you:

  • Access (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Objection to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR)

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example with [competent supervisory authority with address].

For any request, an email to c.werner@project-halyard.com is sufficient.

Project Halyard GmbH i.G.

Harburger Schloßstraße 6–12
21079 Hamburg
Germany
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