As provider of the website www.bartongarnet.com we at BARTON International GmbH together with our affiliated companies (hereinafter “BARTON”) take the protection of personal data very seriously and would like to inform you at this point about data protection in our company.

Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter:”DS-GVO”) which have the aim to ensure the protection of personal data of the person affected by a data processing operation (hereinafter we refer to you as the affected person also as “customer”, “user”, “you”, “data subject”).

Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes in particular the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing of your personal data (see Articles 13 and 14 of the DS-GVO). With this statement(hereinafter: “Privacy Policy”), we inform you about the manner in which your personal data is processed by us:

Our data protection notices have a modular structure. It consists of a general part for all processing of personal data and processing situations that come into play each time a website is accessed (A. General) and a special part that comes into play in specific situations when visiting the website (B. Visit to websites).

A. General

(1) Definitions

Following the example of Art. 4 DS-GVO, this data protection notice is based on the following definitions:

“Personal data” (Art. 4 No. 1 DS-GVO) means any information relating to an identified or identifiable natural person (“Data Subject”). A person is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (even photographs, video or audio recordings can contain personal data).

“Processing” (Art. 4 No. 2 DS-GVO) means any operation which involves the handling of personal data, whether or not by automated (i.e. technology-based) means. This includes in particular the collection (i.e. acquisition), recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the modification of a purpose or objective on which a data processing was originally based.

“Controller” (Art. 4 No. 7 DS-GVO) means 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.

“Third Party” (Art. 4 No. 10 DS-GVO) means any natural or legal person, public authority, agency or other body other than the Data Subject, the Controller, the Processor and the persons who are authorized to process the Personal Data under the direct responsibility of the Controller or Processor; this also includes other group-affiliated legal entities.

“Processor” (Art. 4 No. 8 DS-GVO) is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g. IT service provider). In terms of data protection law, a processor is in particular not a third party.

“Consent” (Art. 4 No. 11 DS-GVO) of the Data Subject means any declaration of intent made voluntarily for the specific case, in an informed manner and unambiguously in the form of a statement or other unambiguous affirmative action by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

(2) Name and address of the data controller

The controller of your personal data within the meaning of Article 4 No. 7 DS-GVO is us:

Barton International GmbH
Lindenstraße 39, 61250 Usingen-Wernborn, Germany
Phone number: +49 6081 4468343
E-mail address: info@bartongarnet.com

For further information about our company, please refer to the imprint information on our website.

(3) Legal basis for data processing

By law, in principle, any processing of personal data is prohibited and only permitted if the data processing falls under one of the following justifications:

Art. 6 (1) p. 1 lit. a DS-GVO (“Consent”): if the data subject has voluntarily, in an informed manner and unambiguously indicated by means of a declaration or other unambiguous confirmatory act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;

Art. 6 para. 1 p. 1 lit. b DS-GVO: If the processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject;

Art. 6 para. 1 sentence 1 lit. c DS-GVO: If the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to keep records);

Art. 6 (1) p. 1 lit. d DS-GVO: If the processing is necessary to protect vital interests of the data subject or another natural person;

Art. 6 (1) p. 1 lit. e DS-GVO: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority transferred to the controller; or

Art. 6 (1) p. 1 lit. f DS-GVO (“Legitimate Interests”): if the processing is necessary to safeguard legitimate (in particular legal or economic) interests of the controller or a third party, unless the conflicting interests or rights of the data subject override (in particular if the data subject is a minor).

For the processing operations carried out by us, we indicate below the applicable legal basis in each case. A processing operation may also be based on several legal bases.

(4) Data erasure and storage period

For the processing operations carried out by us, we indicate below in each case how long the data will be stored by us and when it will be deleted or blocked. If no explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. Your data will be stored on our servers in the USA in accordance with the regulations in A.(7).

However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings or if storage is provided for by legal regulations to which we are subject as the responsible party (e.g. § 257 HGB, § 147 AO). If the storage period prescribed by the statutory provisions expires, the personal data will be deleted or blocked unless further storage by us is necessary and a legal basis for further storage exists.

(5) Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, implementation costs and the nature, scope, context and purpose of the processing, as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

We will be happy to provide you with more detailed information on this upon request.

(6) Cooperation with processors

As with any large company, we also use external domestic and foreign service providers (e.g. for IT, logistics, telecommunication, sales and marketing) to handle our business transactions. These service providers only act on our instructions and have been contractually obligated to comply with data protection regulations in accordance with Art. 28 DS-GVO.

If personal data from you is passed on by us to our affiliated companies or is passed on to us by our affiliated companies (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.

(7) Conditions for the transfer of personal data to third countries

Within the scope of our business relationships, your personal data may be passed on or disclosed to other affiliated companies or third party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing takes place exclusively for the fulfillment of contractual and business obligations and for the maintenance of your business relationship with us. We will inform you about the respective details of the transfer in the following at the relevant points.

Some third countries are certified by the European Commission through so-called adequacy decisions stating that these countries have data protection rules comparable to the EEA standard (a list of these countries as well as a copy of the adequacy decisions can be found here:

http://ec.europa.eu/justice/data-protection/international- transfers/adequacy/index_en.html).

However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding company regulations, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognized codes of conduct. Please contact us if you would like to receive more information on this.

(8) No automated decision making (including profiling).

We do not intend to use any personal data collected from you for any automated decision making process (including profiling).

(9) No obligation to provide personal data

We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. For you as a customer, there is basically no legal or contractual obligation to provide us with your personal data; however, it may be that we can only provide certain offers to a limited extent or not at all if you do not provide the personal data required for this. If this should exceptionally be the case in the context of the products we offer presented below, you will be informed separately.

(10) Legal obligation to transmit certain data

We may, under certain circumstances, be subject to a specific legal or statutory obligation to provide lawfully processed personal data to third parties, in particular public bodies (Art. 6 para. 1 sentence 1 lit. cDS-GVO).

(11) Your rights

You can assert your rights as a data subject regarding your processed personal data at any time by contacting us using the contact details provided at the beginning of A.(2). As a data subject, you have the right:

In accordance with Art. 15 DS-GVO, to request information about your data processed by us. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or opposition, the existence of a right of complaint, the origin of your data, if it was not collected by us, as well as the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details;

In accordance with Art. 16 DS-GVO, to demand the correction of incorrect or the completion of your data stored by us without delay;

In accordance with Art. 17 DS-GVO, to demand the deletion of your data stored by us, insofar as the processing is not necessary for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;

In accordance with Art. 18 DS-GVO, to request the restriction of the processing of your data, insofar as the accuracy of the data is disputed by you or the processing is unlawful;

In accordance with Art. 20 DS-GVO, to receive your data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller (“data portability“);

In accordance with Art. 21 DS-GVO, to object to the processing insofar as the processing is based on Art. 6 (1) p. 1 lit. e or lit. f DS-GVO. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, we ask you to explain the reasons why we should not process your data as done by us. In the event of your justified objection, we will review the situation and either discontinue or adjust the data processing or show you our compelling reasons worthy of protection on the basis of which we will continue the processing;

In accordance with Article 7 (3) of the DS-GVO, to revoke your initially given consent (also before the DS-GVO came into force, i.e. before 25.5.2018) – i.e. your voluntary will, made understandable in an informed manner and unambiguously by a declaration or other unambiguous confirming action, that you agree to the processing of the personal data in question for one or more specific purposes – at any time vis-à-vis us. This has the consequence that we may no longer continue the data processing based on this consent in the future, and

In accordance with Art. 77 DS-GVO, to complain to a data protection supervisory authority about the processing of your personal data in our company (“right of complaint”).

(12) Changes to the data protection notice

In the context of the further development of data protection law and technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes, in particular on our German website at www.bartongarnet.com. This data protection notice is current as of April 2021.

B. Visiting websites

(1)  Explanation of function

You can obtain information about our company and the services we offer in particular at www.bartongarnet.com together with the associated sub-pages (hereinafter collectively referred to as “websites”). When you visit our websites, personal data may be processed.

(2) Processed personal data

During the informational use of the Websites, the following categories of personal data are collected, stored and processed by us:

“log data”: when visiting our websites, a so-called protocol data record (so-called server log files) is stored on our web server on a temporary and anonymized basis. This consists of:

• the name and URL of the requested page
• the date and time of the request
• the IP address of the user
• the GMT time zone difference

“Contact form data”: When contact forms are used, the data transmitted through them is processed (e.g. gender, surname and first name, address, company, e-mail address and the time of transmission).

(3) Purpose and legal basis of data processing

We process the personal data described in more detail above in accordance with the provisions of the DS-GVO, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1)

1. 1 lit. f DS-GVO, the aforementioned purposes also represent our legitimate interests.

The processing of log data serves statistical purposes and aims to improve the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. f DS-GVO).

Contact form data is processed to handle customer inquiries (legal basis is Art. 6 para. 1 p. 1 lit. b or lit.f DS-GVO).

(4) Duration of data processing

Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal basis stated in the context of the processing purposes applies accordingly. With regard to the use and storage duration of cookies, please refer to point A.(4).

Third parties used by us will store your data on their systems for as long as is necessary in connection with the provision of services for us in accordance with the respective order.

For more details on the storage period, please refer to A.(4).

(5) Transfer of personal data to third parties; basis for justification

The following categories of recipients, which are usually order processors (see A.(6)), may receive access to your personal data:

Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer in this case is Art. 6 para. 1 p. 1 lit. b or lit. f DS-GVO, insofar as it does not involve order processors;

Government agencies/authorities, insofar as this is necessary for the fulfillment of a legal obligation. The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. c DS- GVO;

Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure in this case is Art. 6 para. 1 sentence 1 lit. b or lit. f DS-GVO.

For the guarantees of an adequate level of data protection in the event of a transfer of data to third countries, see A.(7).

In addition, we will only share your personal data with third parties if you have given your express consent to do so in accordance with Art. 6 para. 1 p. 1 lit. a DS-GVO.

(6) Use of cookies, plugins and other services on our website

a) Cookies

We use cookies on our websites. Cookies are small text files that are assigned to the browser you are using and stored on your hard drive by means of a characteristic string of characters, and through which the entity that sets the cookie receives certain information. Cookies cannot execute programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the Internet offer as a whole more user-friendly and effective, i.e. more pleasant for you.

Cookies can contain data that make it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that cannot be related to a specific person. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:

Technical cookies: these are mandatory in order to navigate the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which web pages you have visited;

Performance cookies: these collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you – all information collected is anonymous and is only used to improve our website and find out what interests our users;

Advertising cookies, targeting cookies: these are used to provide the website user with tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;

Sharing cookies: these are used to improve the interactivity of our website with other services (e.g.social networks); sharing cookies are stored for a maximum of 13 months.

Any use of cookies that is not absolutely technically necessary constitutes data processing that is only permitted with your explicit and active consent pursuant to Art. 6 (1) p. 1 lit. a DS-GVO. This applies in particular to the use of advertising, targeting or sharing cookies. Furthermore, we will only pass on your personal data processed by cookies to third parties if you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a DS-GVO.

b) Web analysis cookies

We create pseudonymous usage profiles with the help of Google Analytics in order to tailor our websites to your needs. Google Analytics uses targeting cookies that are stored on your device and can be read by us. In this way, we are able to recognize and count returning visitors as such and to learn how often our web pages have been accessed by different users. The data processing is based on Art. 6 para. 1 lit. a DS-GVO (consent).

The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. However, since we have activated IP anonymization on our website, your IP address will be shortened by Google beforehand within member states of the European Union. Only in exceptional cases the full IP address will be transmitted to a Google server in the USA and only shortened there (for more information on the purpose and scope of data collection, see e.g. https://policies.google.com/privacy?hl=de&gl=de). We have also concluded an order processing agreement with Google LLC (USA) in accordance with Art. 28 DS-GVO. Accordingly, Google will use all information strictly for the purpose of evaluating the use of our websites for us and compiling reports on website activity.

You can revoke your consent at any time and thus prevent the collection of your data by Google Analytics. Please use one of the following options to do so:

• You inform us that you wish to revoke your consent.
• You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you choose this option you may not be able to use the full functionality of this website.
• You can also prevent the collection of data generated by the cookie and related to your use of our websites (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link https://tools.google.com/dlpage/gaoptout?hl=de).

c) Social media plugins

We do not use social media plugins on our websites.