1. Data protection at a glance

What is a privacy policy and what does it cover?

Our privacy policy gives you a comprehensive insight into what information – in particular what personal data – we collect, how we use it and, if necessary, share, store and transmit it. We will also inform you about your rights.

Personal data is any data that can be used to personally identify you. It is important to us that you know how to control your privacy. We therefore recommend that you read our privacy policy. This way you can use our app however you want.

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator.

The responsible body for data processing on this website is:

WITTE:digital | flinkey
WITTE Automotive GmbH
Höferstr. 3-15
42551 Velbert
Telephone: +49 32 221 09 75 79
Email: service@flinkey.com

The responsible body is a natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

What information do we collect?

We collect the information you give us when you register for our product and create a profile, e.g. E.g. your email address or telephone number.

Information about the phone, computer or tablet on which you use our product.

What and how do we use your information?

We are always trying to improve our product. The information we collect from you in this regard helps us do this.

We use the information we collect for the following purposes:

  • To assess whether a product is functioning properly
  • To search for errors and correct them if necessary
  • To analyze user behavior

When you visit this website, your surfing behavior can be statistically evaluated. This is done primarily with so-called analysis programs.

The information we use for these purposes is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of page access.)

Your data is also collected when you provide it to us. This could, for example, be data that you enter into a contact form.

What is our legal basis?

According to current data protection law, companies need a legal basis for processing personal data.

By processing personal data we mean the way in which we collect, use and share your information. As we have described above, in previous sections of this Policy.

As a company, we rely on various legal bases to process your information for the purposes described in this privacy policy.

In addition, we may rely on different legal bases when processing the same information for different purposes.

For each of the legal bases set out below, we explain why we process your information.

Depending on the legal basis we rely on, you have certain rights.

Under the General Data Protection Regulation (GDPR) and other relevant data protection laws, you have the following rights:

Right of providing information

According to Art. 15 GDPR, you have the right to request confirmation from us as to whether we are processing relevant personal data. If this is the case, we must provide you with information about the following:

  • The processing purposes
  • The categories of personal data that are processed
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • If possible, the planned period for which your personal data will be stored or, if this is not possible, the criteria for determining that period
  • The existence of a right to rectification or deletion of personal data concerning you or to restriction of processing by the controller or a right to object to this processing
  • The existence of a right to lodge a complaint with a supervisory authority
  • If the personal data is not collected from the data subject, all available information about the origin of the data
  • The existence of automated decision-making including profiling in accordance with Article 22 paragraphs 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject

Right to rectification

Subject to applicable law in accordance with Article 16 GDPR, you have the right to receive information about your information and to have it corrected if it is incorrect.

Right to delete information

In accordance with Article 17 GDPR, you can request that the personal data concerning you be deleted immediately if one of the reasons in paragraphs 1 a-f applies.

An exception to the deletion of your personal data may result from paragraph 3.

  • To exercise the right to freedom of expression and information
  • To fulfill a legal obligation which requires processing under Union or Member State law to which the controller is subject; or to carry out a task that is in the public interest or in the exercise of official authority vested in the person responsible
  • For reasons of public interest in the field of public health in accordance with Article 9 Paragraph 2 GDPR letters h and i and Article 9 Paragraph 3 GDPR
  • For archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Article 89 Paragraph 1 GDPR to the extent that the law referred to in Paragraph 1 is likely to make the achievement of the objectives of this processing impossible or seriously impair it
  • To assert, exercise or defend legal claims

Right to restriction of processing

According to Article 18 GDPR, you have the right to request that we restrict the processing of your data. However, this only exists under the following conditions in accordance with Article 18 a)-d) GDPR.
If you have restricted the processing of your personal data, this data – apart from its storage – may only be used with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest the European Union or a member state are processed in accordance with Article 18 III GDPR .

Transfer your information

According to Article 20 GDPR, you have the right to have your personal information, which you have provided to a person responsible, handed over in a structured, common and machine-readable format. If you request the data to be transferred directly to another person responsible, this will only be done if this is technically feasible.

Right to withdraw consent

According to Article 21 GDPR, you can revoke your consent to the processing of your information, which was carried out in accordance with Article 6 I letter e) or f), at any time. This also applies to profiling based on this provision.
As a company, we no longer process personal data. Unless we can demonstrate compelling legitimate reasons for the processing that outweigh the interests, rights and freedoms of the data subject. Or the processing serves to assert, exercise or defend legal claims.
Your revocation does not affect the lawfulness of the processing that took place based on your consent before its revocation.
If your data is processed to conduct direct advertising, you also have the right to withdraw your consent in accordance with Article 21 II of the GDPR .

Right to lodge a complaint

In the event of violations of the GDPR, those affected have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedies.

Do you have any further questions?

Contact at any time:
Cornelis Friedrich
Höferstr. 3-15
42551 Velbert
E-Mail: Cornelis.Friedrich@witte-automotive.de

How long do we keep your information?

We retain your information for as long as we need it to provide our products, comply with legal obligations, or protect our interests or the interests of others.
However, if you effectively assert a legitimate reason mentioned above, the information can be deleted early.

Permanent deletion of the account

As soon as you press “Delete account”, all data we have already collected will be deleted by us. However, this does not prevent you from registering again. If you register again, we will not suggest any “old” linked data to you again, as a final deletion has previously taken place.

How do we share information with third parties (data transfer to the USA)?

Included on our website are, among other things. When these tools are active, your personal information may be transferred to the US servers of the respective companies.

We would like to point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as the person concerned being able to take legal action against this. It cannot therefore be ruled out that US authorities (e.g. secret services) process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the browser address line changing 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.


2. Hosting und Content Delivery Networks (CDN)

Externes Hosting

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the host’s servers. This can include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access and other data generated via a website.

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Article 6 Para. 1 lit. b GDPR ) and in the interest of a secure, fast and efficient provision of our online offering by a professional provider (Article 6 Para 1 lit. f GDPR ).

Our hoster will only process your data to the extent necessary to fulfill its service obligations and follow our instructions regarding this data.

We use the following host:

ALL-INKL.COM – New Media Münnich
Hauptstraße 68
02742 Friedersdorf

Conclusion of a contract for order processing

In order to ensure data protection-compliant processing, we have concluded a contract for order processing with our host


3. Data collection on this website – cookies

What are cookies?

Cookies are small text files and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser automatically deletes them.

Where do we use cookies?

Cookies have various functions. Numerous cookies are technically necessary because certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising.

Cookies that are necessary to carry out the electronic communication process (necessary cookies) or to provide certain functions you want (functional cookies, e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) are used stored on the basis of Article 6 Para. 1 lit. f GDPR , unless another legal basis is stated. The website operator has a legitimate interest in storing cookies in order to provide its services in a technically error-free and optimized manner. If consent to the storage of cookies has been requested, the relevant cookies will be stored exclusively on the basis of this consent (Article 6 Para. 1 lit. a GDPR). Consent can be revoked at any time.

How can you control your information?

You can set your browser so that you are informed about the setting of cookies or only allow cookies in individual cases, exclude or generally prohibit the acceptance of cookies for certain cases, and activate the automatic deletion of cookies when you close the browser. If cookies are deactivated, the functionality of this website may be restricted.

If cookies are used by third-party companies or for analysis purposes, we will inform you separately in this data protection declaration and, if necessary, request your consent.

Cookie consent with Borlabs Cookie

Our website uses Borlabs Cookie’s cookie consent technology to obtain your consent to store certain cookies in your browser and to document them in accordance with data protection regulations. The provider of this technology is Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg (hereinafter Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser in which the consent you have given or the revocation of this consent is stored. This data is not passed on to the provider of Borlabs Cookie.

The data collected will be stored until you request us to delete it or delete the Borlabs cookie yourself or the purpose for data storage no longer applies. Mandatory statutory retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

The Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Article 6 Paragraph 1 Sentence 1 Letter c GDPR .

Contact form

If you send us inquiries using the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us in order to process the inquiry and in case of follow-up questions. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 Para. 1 lit. b GDPR , provided that your request is related to the fulfillment of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Article 6 Para. 1 lit. f GDPR) or on your consent (Article 6 Para. 1 lit. a GDPR) if this was queried.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.

Inquiries by email, telephone or fax

If you contact us by email, telephone or fax, your request including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 Para. 1 lit. b GDPR , provided that your request is related to the fulfillment of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Article 6 Para. 1 lit. f GDPR) or on your consent (Article 6 Para. 1 lit. a GDPR) if this was queried.

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.


Analysis tools and advertising

What is Google Analytics?

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, length of stay, operating systems used and the user’s origin. Google may summarize this data in a profile that is assigned to the respective user or their device.

Google Analytics uses technologies that enable user recognition for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this analysis tool is based on Article 6 Para. 1 lit. f GDPR . The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If appropriate consent has been requested (e.g. consent to the storage of cookies), processing is carried out exclusively on the basis of Article 6 Para. 1 lit. a GDPR ; consent can be revoked at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization

We have activated the IP anonymization function on this website. This means that your IP address will be shortened by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area before it is transmitted to the USA. 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 to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data.

Preventing data processing through browser plugins

You can prevent Google from collecting and processing your data by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information about how Google Analytics handles user data in Google’s privacy policy: https://tools.google.com/dlpage/gaoptout?hl=de.

Order processing

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

Storage period

User and event-level data stored by Google that is linked to cookies, user identifiers (e.g. User ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) is anonymized after 14 months or deleted. Details can be found at the following link: https://support.google.com/analytics/answer/7667196?hl=de.


Plugins und Tools

YouTube with extended data protection

This website embeds videos from YouTube. The website is operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the extended data protection mode does not necessarily exclude the passing on of data to YouTube partners. This means that YouTube connects to the Google DoubleClick network regardless of whether you are watching a video.

As soon as you start a YouTube video on this website, a connection to YouTube’s servers is established. The YouTube server is informed which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, after starting a video, YouTube can store various cookies on your device or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can receive information about visitors to this website. This information is used, among other things, to collect video statistics, improve user experience and prevent fraud attempts.

If necessary, further data processing operations may be triggered after starting a YouTube video, over which we have no influence.

The use of YouTube is in the interest of an attractive presentation of our online offerings. This represents a legitimate interest within the meaning of Article 6 Paragraph 1 Letter f of the GDPR . If appropriate consent has been requested, processing is carried out exclusively on the basis of Article 6 Paragraph 1 Letter a of the GDPR . Consent can be revoked at any time.
Further information about data protection at YouTube can be found in their data protection declaration at: https://policies.google.com/privacy?hl=de.


Audio and video conferences

Data processing

We use online conference tools, among other things, to communicate with our customers. The specific tools we use are listed below. If you communicate with us via video or audio conference via the Internet, your personal data will be collected and processed by us and the provider of the respective conference tool.

The conference tools collect all the data that you provide/use to use the tools (email address and/or your telephone number). The conference tools also process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “contextual information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all technical data that is necessary to process online communication. This includes in particular IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker as well as the type of connection.

If content is exchanged, uploaded or made available in any other way within the tool, it will also be stored on the tool provider’s servers. Such content includes, but is not limited to, cloud recordings, chat/instant messages, photos and videos uploaded to voicemails, files, whiteboards and other information shared while using the Service.

Please note that we do not have full influence on the data processing operations of the tools used. Our options depend largely on the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, which we have listed below this text.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing business partners or to offer certain services to our customers (Article 6 Para. 1 Sentence 1 Letter b GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest within the meaning of Article 6 Para. 1 lit. f GDPR). If consent has been requested, the relevant tools will be used on the basis of this consent; consent can be revoked at any time with effect for the future.

Storage period

The data we collect directly via the video and conference tools will be deleted from our systems as soon as you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Saved cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.


Conference tools used

Microsoft Teams

If necessary, we use conference tools for exchange in online meetings. In the WITTE Group, we use the video conferencing tool “Microsoft Teams” from Microsoft Corporation (hereinafter: “Microsoft”) as standard, both for internal meetings and conferences as well as for communication with our customers, other external parties and service providers.

In this context, your personal data is processed.

Note: As soon as you access the Microsoft Teams website to download the software, Microsoft Corporation, as the provider, is responsible for data processing.

Your personal data processed in connection with Microsoft Temas will generally not be passed on to third parties. Please note, however, that Microsoft Teams, as a provider, necessarily gains knowledge of the above-mentioned data to the extent that it is intended for the order processing relationship with Microsoft Corporation.

By using Microsoft Teams, your personal data will be transmitted to Microsoft Corporation in the USA (One Microsoft Way, Redmond, WA 98052-6399, USA). For this purpose, Microsoft offers standard contractual clauses which include the specific guarantees regarding the transfer of personal data (see https://learn.microsoft.com/de-de/microsoftteams/security-compliance-overview).
Alternatively, the customer’s preferred tools can be used without any problems. E.g.

  • Google Meet
  • WebEx
  • Zoom