Data Protection Policy


This Data Protection Policy informs you of the type, extent and purpose of the processing of personal data (hereinafter referred to as "data") in the context of our online services and the associated websites, functions and contexts, as well as external online presences, such as our social media profile (hereinafter jointly referred to as "online services"). In the context of the terms used, such as "processing" or "Controller", we refer to the definitions in Article 4 of the GDPR (General Data Protection Regulations).




EFALOCK Professional Tools GmbH
Gattingerstr. 20
97076 Würzburg

Phone: +49 (0)931 6 19 05-70
Fax: +49 (0)931 6 19 05-91

Registered company office: Würzburg
Registry Court Würzburg, Commercial Register 10034
VAT ID no.: DE 813335869
Managing Director: Stefan Pokinskyj
Chairman of the Supervisory Board:
Alfred Schlembach



Types of processed data:


- Stock data (e.g. names, addresses)
- Contact data (e.g. email, phone numbers)
- Content data (e.g. text entries, photos, videos).
- Usage data (e.g. accessed websites, interest in contents, access times).
- Meta-/communication data (e.g. equipment information, IP addresses).


Categories of affected persons


Visitors and users of the online service (hereinafter the affected persons are jointly referred to as "users").


Purpose of processing


- Provision of our online services, their functions and contents
- Responding to contact requests from and communication with our users.
- Security measures
- Measuring of radius / marketing


Terms used


"Personal data": any information relating to an identified or identifiable natural person (‘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 (e.g. Cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations, which is performed on personal data or on sets of personal data, whether or not by automated means. The term is extensive and practically comprises any handling of data.

"Pseudonymisation": the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

"Controller" 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.

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


Relevant legal bases


According to Article 13 GDPR, we inform you of the legal bases of our data processing. The following applies, unless the legal basis is mentioned in the Data Protection Policy: Legal basis for the procurement of consents is Article 6 (1) lit. a and Article 7 GDPR; legal basis for processing for the fulfilment of our services and the execution of contractual measures as well as the reply to enquiries is Article 6 (1) lit. b GDPR; legal basis for processing to fulfil our statutory obligations is Article 6 (1) lit. c GDPR and legal basis for processing to maintain our legitimate interests is Article 6 (1) lit. f GDPR. Article 6 (1) lit. d DSGVO serves as legal basis if vital interests of the data subject or another natural person render the processing of personal data necessary.


Security measures


In accordance with Article 32 GDPR, under consideration of the state of the art, the implementation costs and the type, extent, circumstances and purposes of processing, as well as the various probabilities of occurrence and severity of the risk for the rights and freedoms of natural persons, we take suitable measures to provide a security level commensurate with the risk.

The measures particularly include the protection of confidentiality, integrity and availability of data by monitoring the physical access to the data, as well as the respective access, input, transmission, securing of the availability and their separation. We have furthermore established procedures, which ensure the exercising of data subject rights, erasure of data and the reaction to threats to the data. We furthermore consider the protection of personal data as early as during the development and/or selection of hardware and software, as well as procedures in accordance with the data protection principle by implementing appropriate technical measures designed to implement data protection principles (Article 25 GDPR).


Cooperation with processors and third parties


Any disclosure or transmission of data to other persons and companies (processors or third parties) in the context of processing or the provision of access to the data occurs solely based on legal consent (e.g. if the transmission of the data to third parties, such as service providers, is necessary for the fulfilment of the agreement according to Article 6 (1) lit. b GDPR), if you have consented, if prescribed by legal obligations or based on our legitimate interests (e.g. at the utilisation of representatives, web hosts, etc.).

Any commissioning of third parties with the processing data based on a so-called "order processing agreement" occurs according to Article 28 GDPR.




Transmission to third countries


Any processing of data in a third country (i.e. outside of the European Union (EU) or the European Economic Area (EEA) or in the context of utilising third party services or the disclosure and/or transmission of data to third parties, occurs only if required for the fulfilment of our (pre-) contractual obligations, based on your consent, based on a legal obligations or based on our legitimate interests. Pursuant to statutory or contractual permissions, we only process the data or have the data processed in a third country in the event of special prerequisites according to Article 44 cont. GDPR. This means, processing occurs, for example, based on special guarantees such as the officially recognised determination of a data protection level in accordance with the EU (e.g. with the "Privacy Shield" for the USA) or the compliance with officially approved special contractual obligations (so-called "Standard Contractual Clauses").


Rights of the data subjects


You have the right to demand confirmation as to whether respective data is processed and information on this data and other information, as well as copies of the data according to Article 15 GDPR.

According to Article 16 GDPR, you have the right to demand the completion as well as the rectification of incorrect personal data.

According to Article 17 GDPR, you have the right to demand that respective data is erased immediately or, alternatively according to Article 18 GDPR, the restriction of processing of the data.

According to Article 20 GDPR, you have the right to demand that you receive personal data provided to us and have it transmitted to other controllers.

According to Article 77 GDPR, you are furthermore entitled to lodge a complaint with the responsible supervisory authority.




Right of revocation


According to Article 7 (3) GDPR, you are entitled to revoke your granted consents effective for the future at any time.


Right of objection


According to Article 21 GDPR, you can object to the future processing of your personal data at any time. The objection can particularly be lodged against the processing for purposes of direct advertising.


Cookies and right of objection in case of direct advertising


"Cookies" are small files stored on the computers of the users. Different information can be stored within the Cookies. A Cookie primarily serves to store the information of a user (e.g. the device upon which the Cookie is stored) during as well as after his visit of an online service. Temporary Cookies / "Session Cookies" or "Transient Cookies" are those, which are deleted once the user leaves the online service and closes his browser. For example, such a Cookie can store the content of a shopping cart in an online shop or a login status. "Permanent" or "Persistent Cookies" are those, which remain stored also after the browser has been closed. Therefore, for example, the login status can be stored when the user returns to the website after several days. In addition, the user's interests can be stored in such a Cookie, which are used for marketing purposes or to measure the range. "Third Party Cookies" are those offered by providers other than the controller operating the online service (otherwise, they are called "First Party Cookies" if they are only his Cookies).

We can utilise temporary and permanent Cookies and shall inform you accordingly in our Data Protection Policy.

If users do not wish that these Cookies are stored on their computer, they are requested to deactivate the respective option in the systems settings of their browser. Saved Cookies can be deleted in the systems settings of the browser. The exclusion of Cookies can lead to function-limitations of this online service.

A general objection to the application of Cookies for online marketing can be explained via the US-American website or the EU website for a variety of services. The storage of Cookies can also be achieved by deactivating them in the browser settings. Please note that it is possible that not all functions of this online service will be available.


Erasure of data


The data processed by us are erased or limited in their processing according to Articles 17 and 18 GDPR. Unless explicitly specified in this Data Protection Policy, the data stored by us is deleted as soon as it is no longer required for its purpose and if the erasure is not opposed by statutory preservation obligations. If the data is not erased because it is necessary for other and statutorily admissible purposes, the processing is limited. This means, the data is blocked and not processed for other purposes. For example, this applies if the data has to be stored for commercial or tax reasons.

According to statutory specifications in Germany, the data is stored particularly for 10 years in accordance with §§ 147 (1) AO (Fiscal Code), 257 (1) no. 1 and 4, (4) HGB (German Commercial Code) (books, recordings, status reports, booking receipts, trading books, for the taxation of relevant documents, etc.) and 6 years according to § 257 (1) no. 2 and 3, (4) HGB (commercial letters).

According to statutory requirements in Austria, the storage occurs particularly for 7 years according to § 132 (1) BAO (Austrian federal fiscal code) (accounting documentation, receipts/invoices, accounts, receipts, business documents, lists of income and expenses etc.) for 22 years in connection with properties and for 10 years in case of documents in connection with electronical services, telecommunication, radio and TV services provided to non-companies in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is utilised.




Business-related processing


In addition, we process
- Contractual data (e.g. subject of agreement, term, customer category)
- Payment data (e.g. bank account, payment history)
of our customers, prospective customers and business partners to provide contractual performances, service and customer care, marketing, advertising and market research.


Establishment of contact


When contacting us (e.g. via contact form, email, phone or social media), the information of the user is processed to conclude contact enquiries and their processing, according to Article 6 (1) lit. b (in the context of contractual / pre-contractual relationships), Article 6 (1) lit. f. (other enquiries) GDPR. The information of the users can be stored in a Customer-Relationship-Management System ("CRM System") or comparable enquiry organisation.

We delete the enquiries if they are no longer required. We check their necessity every two years; furthermore, the statutory archiving obligations apply.


Hosting and email dispatch


The hosting services utilised by us serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services as well as technical maintenance, which we apply to operate this online service.

We / our hosting provider process/es inventory data, contact data, contents data, contractual data, usage data, meta and communication data of customers, potential customers and visitors of this online service based on our legitimate interests in the efficient and secure provision of this online service according to Article 6 (1) lit. f GDPR, in connection with Article 28 GDPR (conclusion of an order processing agreement).


Online presence in social media


We maintain online presences within social networks and platforms in order to communicate with customers, potential customers and users there and to inform them of our services. The general terms and conditions and data protection directives of the respective operators apply when accessing their networks and platforms.

Unless specified otherwise in the context our Data Protection Policy, we process the data of the users if they communicate with us with in the social networks and platforms, e.g. compose contributions on our online presence or send us a message.




We incorporate the videos of the platform "YouTube" of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data Protection Policy:, Opt-Out:


Established with von RA Dr. Thomas Schwenke