Data protection information

25.05.2018 

comwrap GmbH (hereinafter referred to as "comwrap" or "we") operates the website accessible at www.comwrap.com (hereinafter referred to as the "website"). In the following, we inform you about the collection of personal data when using this website. Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses, user behaviour.

Your data will be collected, processed and used in accordance with the provisions of the German Telemedia Act (TMG) and data protection law, in particular the German Federal Data Protection Act (BDSG) and the EU General Data Protection Regulation (DSGVO).

With this data protection declaration, we inform about the collection of personal data on and via our website from the data subject in accordance with Art. 13 DSGVO.

(1) During the mere informational use of the website, i.e. if you do not log in to use the website, register or otherwise transmit information to us, we do not collect any personal data, with the exception of the data transmitted by your browser. The purpose of this data collection is to enable you to visit the website and to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. These are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

(2) Furthermore, cookies are stored on your computer when you use the website. Cookies are small text files that are stored on your hard drive associated with the browser you are using and through which the entity that sets the cookie (in this case, us) receives certain information. A cookie typically includes the name of the domain from which the cookie originated, the "lifetime" of the cookie, and a value, regularly a randomly generated unique number. Cookies cannot run programs or transmit viruses to your computer. The purpose of their use is to make our website more user-friendly and effective overall. Some elements of our website require that the calling browser can be identified even after a page change.

This website uses cookies to the following extent:

  • Transient cookies (session cookies) are automatically deleted when you close the browser. These include, in particular, session cookies. These store a so-called session ID, with which various requests of your browser can be assigned to the common session. This allows your computer to be recognized when you return to the website. The session cookies are deleted when you log out or you close the browser.
  • Persistent cookies (permanent cookies) are automatically deleted after a specified period of time, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.
  • Cookies related to third-party services, as described below:
    • The Flash cookies used are not collected by your browser, but by your Flash plug-in. They store the necessary data regardless of the browser you use and have no automatic expiration date. If you do not want Flash cookies to be processed, you must install an appropriate add-on.
    • Web beacons are electronic characters (also called "clear GIFs" or "web bugs") that allow us to count the number of users who have visited the website.

You can configure your browser setting according to your preferences and, for example, refuse to accept third-party cookies or all cookies. Information on the management and deletion of cookies, as well as instructions on how to do this for the most popular browsers, can also be found at www.meine-cookies.org. However, we would like to point out that you may then not be able to use all functions of this website.

(3) This stored information is stored separately from any other data you may have provided to us. In particular, the data of the cookies will not be linked with your other data, if such data is transmitted.

You can revoke your selection decision at any time by clearing the cache of your browser and reloading the page or by adjusting your decision via the following links: 


(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you usually have to provide further personal data, which we use to provide the respective service. If additional voluntary information is possible, this is marked accordingly. We only collect, process and use personal data that is required for your use of the website and/or the fulfillment of a contract concluded with us or that you yourself provide. In particular, this involves the following inventory data and usage data that may be transmitted via forms on our website:

  • Company
  • Name (consisting of title, first name, last name and gender or form of address)
  • Position in the company
  • Website URL of the company
  • Your request in the context of a message field ("Your message to us"), e.g. appointment suggestions
  • Address
  • Telephone number
  • Fax number
  • e-mail address
  • personal application data within the scope of the online application (name, e-mail address, application text, uploaded attachments such as application letter, resume, certificates, references, etc.).

(2) Inventory data and usage data are used by us to establish a contractual relationship with you, if applicable, or to structure, change or terminate the content of such a relationship, to fulfill our contractual obligations and to contact you, if requested by you or required within the scope of the contractual relationship or permitted by law.

The personal data, with the exception of the data collected by the third-party providers mentioned below, will be stored and processed within the European Union.

(3) Email newsletter (blog subscription).

For the registration to our blog subscription, we use the so-called double opt-in procedure. This means that after you have provided your e-mail address, we will send you a confirmation e-mail to the e-mail address you have provided, in which we ask you to confirm that you wish to receive the blog subscription. If you do not confirm this within 48 hours, your subscription will be automatically deleted. If you confirm your wish to receive the blog subscription, we will store your email address until you unsubscribe. The storage serves the sole purpose of informing you about new blog articles. Furthermore, we store your IP addresses and the times of registration and confirmation, respectively, in order to prevent misuse of your personal data.

Mandatory data for sending the blog subscription is only your e-mail address. This date will be completely deleted upon revocation. When registering via a contact form on the site, only the above-mentioned mandatory data for sending the newsletter will be stored.

You can revoke your consent to the sending of the newsletter at any time. You can declare the revocation by clicking on the link provided in every newsletter e-mail, or by sending an e-mail to info(at)comwrap.com.

We would like to point out that we evaluate your user behavior when sending automated mailings. For this evaluation, the sent e-mails contain so-called web beacons, also called tracking pixels. These are single-pixel image files that link to our website and thus enable us to evaluate your user behavior. Links received in the blog subscription also contain this ID. The data is collected on a personal basis, and the IDs are linked to your other personal data in our CRM system for marketing and optimization purposes. The information collected in this way is stored by the third-party provider (Hubspot, Inc., 25 First St, 2nd Floor, Cambridge, MA 02141, USA) on its server in the USA. Hubspot's privacy policy can be found here. HubSpot, Inc. participates in the EU-US Privacy Shield agreement and the "Swiss-US Privacy Shield" agreement and is certified for compliance with them. You can object to this tracking at any time by revoking your blog subscription. You can do this by clicking on the link provided in every newsletter email, or by sending an email to info@comwrap.com. Such tracking is also not possible if you have deactivated the display of images by default in your e-mail program. In this case, however, the newsletter will not be fully displayed to you and you may not be able to use all of its features. If you display the images manually, the above-mentioned tracking will take place.

Unless otherwise described in this privacy policy, we store your data only as long as necessary for the purposes for which they were collected or processed, unless legal retention periods require longer storage. Your personal data will therefore be deleted after processing your request unless otherwise agreed or required by law.

We are entitled to create usage profiles using pseudonyms for the purposes of advertising, market research or to design the website in line with requirements, unless you object to this. In particular, we evaluate the usage data anonymously for statistical purposes in order to design the website in a needs-oriented manner. You can object to this use of your personal data by notifying us.

(1) Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. Google Analytics uses so-called "cookies". These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. However, due to the IP anonymisation on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You may refuse the use of cookies by selecting the appropriate settings on your browser, you can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

We also use Google Analytics to analyse data from Double-Click-Cookie and AdWords for statistical purposes. If you do not want this, you can deactivate it via the Ads Preferences Manager (http://www.google.com/settings/ads/onweb/?hl=de).

We have agreed a data processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Third party information:
Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of use: http://www.google.com/analytics/terms/de.html, Data protection overview: http://www.google.com/intl/de/analytics/learn/privacy.html, privacy policy: http://www.google.de/intl/de/policies/privacy.

(2) Google-Tag-Manager
This website uses Google Tag Manager. Google Tag Manager is a solution that allows marketers to manage website tags through one interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not collect any personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, this remains in place for all tracking tags implemented with Google Tag Manager. Further information from the third-party provider can be found at http://www.google.de/tagmanager/use-policy.html. The guidelines available there apply in addition to the Terms of Use and the Google Privacy Policy.

(3) HubSpot
This website uses HubSpot, a service provided by HubSpot Inc, a software provider based in the USA with a branch office in Ireland (HubSpot Inc, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500), which we use to cover various aspects of our online marketing. These include, among others:

  • Content management (e.g. website content)
  • Email marketing (newsletters as well as automated mailings, e.g. to inform about updates)
  • Social media publishing & reporting (e.g. LinkedIn)
  • Reporting (e.g. traffic sources, hits, etc. ...)
  • Contact management (e.g. user segmentation & CRM)
  • Provision of landing pages and contact forms


HubSpot uses so-called "web beacons" and also "cookies", which are stored on your computer and which enable an analysis of your use of the website by us. HubSpot evaluates the information collected (e.g. IP address, geographical location, type of browser, duration of the visit and pages viewed) on our behalf in order to generate reports about the visit and the pages you visited. If you generally do not want cookies to be collected, you can prevent cookies from being stored at any time by changing your browser settings accordingly.

The data collected by us via HubSpot is used by us exclusively to provide and optimise our marketing and to initiate contracts. Your data may then be used by us to contact you as a visitor to our website and to determine which of our company's services are of interest to you. If you subscribe to our blog and download documents, we can also use HubSpot to record your visits on a personal basis using your additional details (especially name/email address) and, if necessary, provide you with targeted information on topics you prefer. With the help of HubSpot, we also provide our contact service ("Let's talk about your business" or "Make an appointment now" or "Request a digital espresso"). The Contact Us Service allows you, as a visitor to our website, to learn more about our business, download content and provide us with your contact information and other information about yourself and your business or to schedule an appointment with us. Where required by law, we will ask you beforehand and separately for your consent to collect, store and process your data.

The data we collect using Hubspot is stored on servers of the third-party provider HubSpot in the USA. We have created the necessary conditions so that this meets the requirements of the relevant EU data protection law. HubSpot Inc. is certified under the terms of the EU-US Privacy Shield Frameworks and has undertaken to treat all personal data obtained from member states of the European Union (EU) and Switzerland in accordance with the applicable principles of the Privacy Shield agreement.

You can find HubSpot's complete privacy policy here. HubSpot also informs you there regarding compliance with EU data protection regulations by HubSpot Inc. You can also revoke your consent for tracking at a later date (see point 12 below) or deactivate the storage of corresponding cookies (see point 1 above).

(1) We use subcontractors as part of the processing of personal data and conclude a contract with these processors in accordance with the requirements of Art. 28 DSGVO.

The subcontractor used for hosting the website is proIO GmbH, Frankfurt am Main.

(2) Your personal data will not be transferred to companies other than those already mentioned.

We take technical and organisational measures in accordance with the requirements of Art. 32 DSGVO to protect the user's personal data. All our employees who are involved in the processing of personal data are bound to data privacy and security. Personal data of the user is encrypted during transmission to the website using HTTPS.

Nach Maßgabe des Art. 13 DSGVO teilen wir Ihnen die Rechtsgrundlagen unserer Datenverarbeitungen mit.

  • Soweit wir für Verarbeitungsvorgänge personenbezogener Daten eine Einwilligung der betroffenen Person einholen, dient Art. 6 Abs. 1 lit. a DSGVO als Rechtsgrundlage.
  • Bei der Verarbeitung von personenbezogenen Daten, die zur Erfüllung eines Vertrages, dessen Vertragspartei die betroffene Person ist, erforderlich ist, dient Art. 6 Abs. 1 lit. b DSGVO als Rechtsgrundlage. Dies gilt auch für Verarbeitungsvorgänge, die zur Durchführung vorvertraglicher Maßnahmen erforderlich sind.
  • Soweit eine Verarbeitung personenbezogener Daten zur Erfüllung einer rechtlichen Verpflichtung erforderlich ist, der comwrap unterliegt, dient Art. 6 Abs. 1 lit. c DSGVO als Rechtsgrundlage.
  • Rechtsgrundlage für die vorübergehende Speicherung der Daten und der Logfiles ist Art. 6 Abs. 1 lit. f DSGVO.
  • Die Rechtsgrundlage für die Verarbeitung personenbezogener Daten unter Verwendung technisch notweniger Cookies ist Art. 6 Abs. 1 lit. f DSGVO. Die Rechtsgrundlage für die Verarbeitung personenbezogener Daten unter Verwendung von Cookies zu Analysezwecken ist Art. 6 Abs. 1 lit. f DSGVO.
  • Ist die Verarbeitung zur Wahrung eines berechtigten Interesses von comwrap oder eines Dritten erforderlich und überwiegen die Interessen, Grundrechte und Grundfreiheiten des Betroffenen das erstgenannte Interesse nicht, so dient Art. 6 Abs. 1 lit. f DSGVO als Rechtsgrundlage für die Verarbeitung.

In accordance with Art. 13 DSGVO, we inform you of the legal basis for our data processing.

  • Insofar as we obtain the consent of the data subject for processing operations of pers0onal data, Art. 6 (1) lit. a DSGVO serves as the legal basis.
  • When processing personal data that is necessary for the performance of a contract to wh0ich the data subject is a party, Art. 6 (1) (b) DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
  • Insofar as processing of personal data is necessary for compliance with a legal obligation to0 which comwrap is subject, Art. 6 (1) c DSGVO serves as the legal basis.
  • The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.
  • The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO. The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. f DSGVO.
  • If the processing is necessary to protect a legitimate interest of comwrap or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) (f) DSGVO serves as the legal basis for the processing.

We do not use automated decision making or profiling.

The user and other data subjects have the following rights with respect to their personal data:

  • Right of access to the personal data concerned (Art. 15 DSGVO)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (Art. 17 DSGVO)
  • Right to restriction of processing (Art. 18 DSGVO)
  • Right to object to processing if the data processing is based on Art. 6(1)(e) or (f) DSGVO (Art. 21 DSGVO); see also the following reference to the right to object under Art. 21 DSGVO
  • Right to data portability (Art. 20 DSGVO)
  • Right to revoke consent given at any time without affecting the lawfulness of the processing carried out on the basis of the consent until revocation, if the data processing is based on consent pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a DSGVO

You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us (Art. 77 DSGVO).

A. Right to object on the grounds of your particular situation

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) (public security) or (f) (data processing on the basis of a balance of interests) DSGVO; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

B. Right of objection in the case of direct advertising

If we process personal data about you for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data will no longer be processed for these purposes.

C. Exercise of the right to object

The right to object can be exercised informally, for example by sending a letter to comwrap GmbH, Hanauer Landstraße 126-128, 60314 Frankfurt am Main, Germany, or by sending an e-mail to info@comwrap.com.

The service provider pursuant to § 13 of the German Telemedia Act (TMG) and the responsible party within the meaning of the DSGVO, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

comwrap GmbH
Hanauer Landstraße 126-128
60314 Frankfurt am Main

Tel. +49 (0)69 380 795 200
Fax +49 (0)69 380 795 211
E-Mail: info@comwrap.com

All requests for information, correction and deletion, objections or revocations of consent, the assertion of the right to restriction of processing or the right to data portability, as well as comments or questions from the user relating to data protection should be sent to this address.

Our data protection officer is lawyer Christian Welkenbach. You can reach him at datenschutz@comwrap.com or our postal address with the addition "the Data Protection Officer"

The data protection supervisory authority responsible for us, to which a complaint about a breach of data protection law can be submitted, is:

The Hessian Commissioner for Data Protection and Freedom of Information.
Gustav-Stresemann-Ring 1
65189 Wiesbaden

Telephone: 0611-1408 0
Fax: 0611-1408 611

E-Mail: poststelle@datenschutz.hessen.de

From time to time it is necessary to adapt the content of this data protection notice. We therefore reserve the right to amend it at any time. We will send the amended version of the data protection notice to registered users by e-mail before it comes into force and publish it in the same place as this data protection notice.