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Privacy Policy

Thank you for your interest in Midel Photonics. Protecting your personal data is important to us. Below we explain which data we process in connection with your visit to this website and with the initiation of business relationships, for which purposes and on which legal basis, as well as your rights.

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Midel Photonics GmbH
Maarstraße 96
53227 Bonn
Germany
Phone: +49 228 28679710
Email: info@midel-photonics.de
Represented by the management (see Legal Notice).

Our company is not legally required to appoint a data protection officer and has therefore not appointed one. For data protection enquiries, please use the contact details above.

2. General information and legal bases

We process the personal data of our users only insofar as this is necessary to provide a functional website as well as our content and services, or where you have given your consent. Personal data means any information relating to an identified or identifiable natural person.

Where we obtain consent for processing, Art. 6 (1) (a) GDPR serves as the legal basis. For processing necessary to perform a contract or to take pre-contractual steps, Art. 6 (1) (b) GDPR applies. Where processing is necessary to comply with a legal obligation, Art. 6 (1) (c) GDPR applies. Where processing is necessary for the purposes of our legitimate interests or those of a third party and your interests, fundamental rights and freedoms do not override those interests, Art. 6 (1) (f) GDPR applies.

3. Your rights as a data subject

Subject to the statutory requirements, you have the following rights:

  • right of access to the data stored about you (Art. 15 GDPR),
  • right to rectification of inaccurate data (Art. 16 GDPR),
  • right to erasure (Art. 17 GDPR),
  • right to restriction of processing (Art. 18 GDPR),
  • right to data portability (Art. 20 GDPR),
  • right to object to processing (Art. 21 GDPR),
  • right to withdraw a given consent with effect for the future (Art. 7 (3) GDPR).

Right to object: Where we process your data on the basis of legitimate interests pursuant to Art. 6 (1) (f) GDPR, you have the right to object to such processing at any time on grounds relating to your particular situation.

You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data (Art. 77 GDPR). The authority responsible for us is: North Rhine-Westphalia State Commissioner for Data Protection and Freedom of Information (LDI NRW), Kavalleriestraße 2–4, 40213 Düsseldorf, Germany.

4. Provision of the website and server log files (hosting)

This website is hosted by an external service provider: STRATO AG, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany. Each time our website is accessed, the system automatically collects data and information from the accessing device, in particular the IP address, the date and time of access, the browser type and version, the operating system and the page accessed. This data is stored in the server log files.

The legal basis is our legitimate interest in the technical provision, stability and security of the website (Art. 6 (1) (f) GDPR). We have concluded a data processing agreement with the hosting provider pursuant to Art. 28 GDPR. Log files are deleted once they are no longer required to achieve the purpose for which they were collected.

5. Cookies and consent management

Our website uses cookies. Cookies are small text files stored on your device. We use technically necessary cookies required to operate the website on the basis of Art. 6 (1) (f) GDPR. Cookies and comparable technologies that are not strictly necessary (for example for reach measurement) are only used with your consent (Section 25 (1) TDDDG in conjunction with Art. 6 (1) (a) GDPR).

To obtain and manage your consent we use the consent management tool “Complianz” (Complianz B.V., Kalmarweg 14-5, 9723 JG Groningen, Netherlands). Your consent decision is documented; for this purpose, among other things, your IP address is stored in anonymised form in our database. You can change or withdraw your selection at any time with effect for the future via the cookie settings on our website.

6. Contact and contact form

You can use the contact form on our website to send us a question about your application. We process your name, email address and message (all mandatory). The form also transmits the date and time, your IP address, the form page and the page from which you reached the form. Alternatively, you may contact us by email.

The processing serves to handle your enquiry and to initiate a possible business relationship. The legal basis is Art. 6 (1) (b) GDPR (pre-contractual steps) and our legitimate interest in responding to enquiries (Art. 6 (1) (f) GDPR). Your enquiry is transmitted to our mailbox info@midel-photonics.de. We store the data until your enquiry has been conclusively dealt with and no statutory retention obligations apply.

To protect against misuse and spam, we use “Cloudflare Turnstile” in the contact form, a service provided by Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. This processes technical data of the accessing device, including the IP address, in order to distinguish between human users and automated access. The legal basis is our legitimate interest in security and abuse prevention (Art. 6 (1) (f) GDPR). Data may be transferred to the USA in this context (see the section “Transfer of data to third countries”).

7. Customer management and CRM (HubSpot)

To initiate, manage and process our business relationships and to communicate with customers, prospects and suppliers, we use the CRM system “HubSpot”. The provider is HubSpot Ireland Limited, 1 Sir John Rogerson’s Quay, Dublin 2, Ireland; the parent company is HubSpot, Inc., 2 Canal Park, Cambridge, MA 02141, USA. In particular, we process contact and communication data (e.g. name, company, contact details and the related correspondence).

The legal basis is Art. 6 (1) (b) GDPR insofar as the processing serves pre-contractual steps or the performance of a contract, and our legitimate interest in the efficient management of our business contacts (Art. 6 (1) (f) GDPR). A data processing agreement pursuant to Art. 28 GDPR is in place with HubSpot. A transfer of data to the USA is possible (see the section “Transfer of data to third countries”).

8. “Tech Insights” newsletter

Our “Tech Insights” newsletter brings you application examples, product information and news from Midel Photonics by email. The controller is Midel Photonics GmbH (section 1); the sender address is TechInsights@midel-photonics.de. To send the newsletter, we process your email address, name and company.

You receive the newsletter on one of these bases:

  • You have given your consent (Art. 6 (1) (a) GDPR).
  • You have bought from us, and we inform you about similar products (Section 7 (3) of the German Act against Unfair Competition, UWG; Art. 6 (1) (f) GDPR).
  • We are in business contact with you, for example after an enquiry, during a project or after a conversation at a trade fair, and have a legitimate interest in informing you about our products (Art. 6 (1) (f) GDPR).

You can unsubscribe and object to the use of your email address for advertising at any time (Art. 21 (2) GDPR), at no cost other than the transmission costs at basic rates. Use the unsubscribe link in any newsletter or write to TechInsights@midel-photonics.de. You withdraw consent the same way; processing carried out before the withdrawal remains lawful.

Our newsletters contain an invisible tracking pixel and links that are redirected via HubSpot. They show us whether and when you open an email and which links you click; your IP address, device type and email program are recorded as well. We link this information to your contact record to see which topics interest you and, where appropriate, to get in touch with you personally. If you have consented to this tracking, your consent is the legal basis (Section 25 (1) TDDDG, Art. 6 (1) (a) GDPR). Otherwise, we rely on our legitimate interest in measuring the effect of our newsletter and aligning it with the interests of our business contacts (Art. 6 (1) (f) GDPR).

You can object to the tracking or withdraw your consent at any time by writing to TechInsights@midel-photonics.de or by unsubscribing from the newsletter. You can also block the tracking pixel by turning off automatic image loading in your email program.

Links also carry campaign parameters (UTM). Our analytics tool Plausible uses them to show how often a newsletter link was clicked in total, without identifying you (section 9).

We use HubSpot (section 7) as our processor under Art. 28 GDPR for sending and tracking; data may be transferred to the USA in this context (see the section “Transfer of data to third countries”). If you have given consent, we store when and how you did so, so that we can prove it (Art. 6 (1) (f) in conjunction with Art. 7 (1) GDPR).

We use your data for the newsletter until you unsubscribe or object. We then record the unsubscription so that you receive no further newsletters (Art. 6 (1) (f) GDPR). Your other contact data in our CRM, including open and click data, is not affected (section 7).

9. Reach measurement with Plausible

We use Plausible Analytics, provided by Plausible Insights OÜ, Västriku tn 2, 50403 Tartu, Estonia, for visitor statistics. Plausible sets no cookies and stores nothing on your device. It records the pages viewed, where you came from (referrer and campaign parameters such as UTM), browser, operating system, device type, approximate location and events such as file downloads, clicks on external links, submitted forms and error pages. Your IP address is not stored: Plausible only uses it to derive the approximate location and a daily-changing visitor identifier that can no longer be linked to any visitor after 24 hours. The data reaches Plausible via our own domain and is processed exclusively in the EU.

The legal basis is our legitimate interest in measuring the reach of our website with as little data as possible (Art. 6 (1) (f) GDPR).

10. Web analytics with Google Analytics

This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Google Analytics uses cookies and similar technologies to analyse the use of our website and to enable us to improve our offering. Pseudonymous usage information is collected (e.g. pages viewed, interactions, approximate location, device and browser information). The IP address is truncated by Google Analytics 4 before it is stored.

It is used exclusively on the basis of your consent pursuant to Section 25 (1) TDDDG in conjunction with Art. 6 (1) (a) GDPR. You can withdraw your consent at any time with effect for the future via the cookie settings. Data may be transferred to the USA in this context (see the section “Transfer of data to third countries”).

11. Reach analysis with Microsoft Clarity

This website uses Microsoft Clarity, an analytics service provided by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA). Clarity records usage behaviour in pseudonymised form (including through metrics, heatmaps and session recordings) in order to understand and improve the usability of our website.

It is used exclusively on the basis of your consent pursuant to Section 25 (1) TDDDG in conjunction with Art. 6 (1) (a) GDPR. You can withdraw your consent at any time with effect for the future via the cookie settings. Data may be transferred to the USA in this context (see the section “Transfer of data to third countries”).

12. Presence on social networks

On our website we link to our company profile on LinkedIn. This is a simple link; only when you actively click it are you forwarded to LinkedIn and the provider’s data processing applies (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland). We have no influence on the nature and scope of that processing; please refer to LinkedIn’s privacy policy for details.

13. Transfer of data to third countries

Some of the services we use (in particular Cloudflare, Google and Microsoft, as well as HubSpot) may process personal data in the USA. These providers are certified under the EU-US Data Privacy Framework, for which an adequacy decision of the European Commission exists. In addition, where necessary, we base transfers on the European Commission’s Standard Contractual Clauses pursuant to Art. 46 (2) (c) GDPR. We point out that, for transfers to the USA, a level of data protection comparable to that of the EU cannot be guaranteed in every case, and in particular access by US authorities cannot be entirely ruled out.

14. Data security

We take appropriate technical and organisational measures to protect your data against manipulation, loss, destruction and unauthorised access. Our website uses TLS/SSL encryption, recognisable in your browser’s address bar.

15. Retention period

We process and store personal data only for as long as is necessary to achieve the respective processing purpose or as required by statutory retention obligations (in particular commercial and tax law periods under the German Commercial Code and Fiscal Code). Once the purpose ceases to apply and no retention obligations exist, the data is deleted.

16. Currency and amendment of this privacy policy

This privacy policy is currently valid. As our website develops or due to changed legal or regulatory requirements, it may become necessary to amend this privacy policy.

Last updated: October 2026