Data Privacy Policy

This privacy policy informs users about the nature, scope and purpose of the collection and use of personal data by the responsible provider on this website ("service").

1. Data collection on this website at a glance

Who is responsible for data collection on this website?Data processing on this website is carried out by the website operator. Their contact details can be found in the "Information about the controller" section of this privacy policy.

How do we collect your data?Your data is collected, on the one hand, by you providing it to us. This may, for example, be data you enter into a contact form. Other data is collected automatically, or after your consent, by our IT systems when you visit the website. This is mainly technical data (e.g. internet browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyse your user behaviour. If contracts can be concluded or initiated via the website, the data transmitted is also processed for contract offers, orders or other order enquiries.

What rights do you have regarding your data?You have the right at any time to receive information, free of charge, about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data.

If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority. You may contact us at any time regarding this and any further questions on the subject of data protection.

Analysis tools and third-party toolsWhen you visit this website, your browsing behaviour may be statistically evaluated. This is done primarily using what are known as analysis programs. Detailed information on these analysis programs can be found in the following privacy policy.

2. External Hosting

Webflow

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact enquiries, meta and communication data, contract data, contact details, names, website access data and other data generated via a website. External hosting is carried out for the purpose of fulfilling contracts with our potential and existing clients (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG (German Telecommunications and Telemedia Data Protection Act), insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time. Our host(s) will process your data only to the extent necessary to fulfil their contractual obligations and will follow our instructions with regard to this data.

We use the following host(s): Webflow, Inc. 398 11th Street, 2nd Floor, San Francisco, CA 94103 USA

Further information on data protection at Webflow: https://webflow.com/legal/eu-privacy-policy

Data processing agreementWe have concluded a data processing agreement (DPA) for the use of the service named above. This is a contract required by data protection law that ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Cloudflare (Security/CDN)

We use the "Cloudflare" service provided by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA, to secure and accelerate our website (content delivery network, DDoS protection, security functions). When you access our pages, traffic is routed via Cloudflare servers. In doing so, IP address, device information, browser information, referrer, accessed URLs and security-relevant event data may, among other things, be processed. Cloudflare uses technically necessary cookies for this purpose and may use fingerprinting techniques to detect malicious traffic.

The legal basis is our legitimate interest in a more secure and higher-performing provision of the website (Art. 6(1)(f) GDPR). Data transfer to the USA may take place. Cloudflare is certified under the EU-US Data Privacy Framework (DPF). We additionally use standard contractual clauses. Further information on data protection at Cloudflare can be found at: https://www.cloudflare.com/privacypolicy/

3. General Information and Mandatory Disclosures

Data protection

The operators of these pages take the protection of your personal data very seriously.

We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information about the controller

The controller responsible for data processing on this website is:

AURON GmbHRiedheimer Straße 388677 Markdorf, GermanyPhone: +49 (7544) 91387-0Email: info@auroncad.de

The controller is the 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.).

Legally required data protection officer

We have appointed a data protection officer for our company.

Michael Schwab, Managing DirectorAURON GmbHAddress and contact details as above

Storage duration

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place once these reasons cease to apply.

General information on the legal basis for data processing on this website

If you have given consent to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data are processed pursuant to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing also takes place on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g. via device fingerprinting), data processing additionally takes place on the basis of Section 25(1) TDDDG. Consent can be revoked at any time. If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if this is required to fulfil a legal obligation, on the basis of Art. 6(1)(c) GDPR. Data processing may also take place on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of personal data

In the course of our business activities, we work with various external parties. This sometimes also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the fulfilment of a contract (e.g. to shipping and payment service providers for orders), if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in the disclosure, or if another legal basis permits the disclosure of data. When using processors, we only pass on our clients' personal data on the basis of a valid data processing agreement. In the case of joint processing, an agreement on joint processing is concluded.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out up until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)

If data processing is carried out on the basis of Art. 6(1)(e) or (f) GDPR, you have the right at any time, for reasons arising from your particular situation, to object to the processing of your personal data; this also applies to profiling based on these provisions. The specific legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your affected personal data, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims (objection pursuant to Art. 21(1) GDPR).

If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing. If you object, your personal data will subsequently no longer be used for direct marketing purposes (objection pursuant to Art. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged violation. This right to lodge a complaint exists without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.

Right to information, correction and deletion

Within the scope of applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correction or deletion of this data. You may contact us at any time regarding this and any further questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing applies in the following cases:

  • If you dispute the accuracy of your personal data stored with us, we generally need time to verify this. For the duration of this verification, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of deletion.
  • If we no longer need your personal data, but you need it to assert, exercise or defend legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – with the exception of its storage – only be processed with your consent or for the assertion, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line. If SSL or TLS encryption is enabled, the data you transmit to us cannot be read by third parties.

Objection to promotional emails

The use of contact data published within the scope of the legal notice requirement to send unsolicited advertising and information materials is hereby objected to. The operators of these pages expressly reserve the right to take legal action in the event of the unsolicited sending of promotional information, such as through spam emails.

4. Data Collection on This Website

Cookies

Our websites use what are known as "cookies". Cookies are small data packets 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 (permanent 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 they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for handling payment services).

Cookies have various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies may be used to evaluate user behaviour or for advertising purposes. Cookies that are required to carry out the electronic communication process, to provide certain functions you desire (e.g. for the shopping cart function), or to optimise the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is stated.

The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies on a case-by-case basis, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be limited. You can find which cookies and services are used on this website in the following section of this privacy policy.

Cookie information and settings

Server log files

The provider of the pages automatically collects and stores information in what are known as server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be collected.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass on this data without your consent.

Our forms are provided and processed via Webflow. The provider is Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA. When you submit a form, the data you provide (e.g. name, company, email, phone, message) is stored in Webflow so that we can process your enquiry and clarify any follow-up questions.

Webflow processes the data on our behalf. Data may be transferred to the USA. Webflow is certified under the EU-US Data Privacy Framework (DPF); we additionally use the EU Commission's standard contractual clauses.

Further information on data protection at Webflow: https://webflow.com/legal/eu-privacy-policy

This data is processed on the basis of Art. 6(1)(b) GDPR, provided your enquiry is related to the fulfilment of a contract or is necessary for carrying out pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested; consent can be revoked at any time. The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage, or the purpose for storing the data no longer applies (e.g. after your enquiry has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Enquiry by email, telephone or fax

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

This data is processed on the basis of Art. 6(1)(b) GDPR, provided your enquiry is related to the fulfilment of a contract or is necessary for carrying out pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested; consent can be revoked at any time.

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

5. Analysis Tools and Advertising

Google Analytics

This website uses the web analytics service Google Analytics.

With the help of Google Analytics, we are able to collect and analyse data on the use of our website by website visitors. Among other things, this allows us to find out when which page views were made and which region they came from. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.). The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising.

If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

IP anonymisation

When analysing with Google Analytics, we use IP anonymisation. Your IP address is shortened prior to analysis, so that it can no longer be clearly assigned to you. According to Google, the IP address is shortened within the EU or the EEA; complete IP addresses are not stored.

Hosting

Google Analytics is provided and hosted by Google. Data may be transferred to the USA. Google is certified under the EU-US Data Privacy Framework (DPF); we additionally use the EU Commission's standard contractual clauses. Further information on data protection at Google can be found at: https://policies.google.com/privacy and on Google Analytics at: https://support.google.com/analytics/answer/6004245?hl=en

Google Ads Conversion

We use Google Ads Conversion Tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For this purpose, a conversion cookie or comparable recognition technology is set when you reach our website via a Google ad. This allows us to identify which ad led to which actions on the website (e.g. a completed form, an appointment booking). Google may process your IP address, browser and device information as well as the pages you visited for this purpose, and may combine this information with your Google account, should you be logged in there.

Use is exclusively based on your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. You can revoke your consent at any time via our cookie settings. Data may be transferred to the USA. Google is certified under the EU-US Data Privacy Framework; standard contractual clauses are also used. Details: https://policies.google.com/privacy and https://policies.google.com/technologies/ads

LinkedIn Insight Tag / Ads Conversion

We use the LinkedIn Insight Tag to measure the performance of our LinkedIn advertisements and to evaluate audiences. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. The Insight Tag sets a cookie which, among other things, collects IP address, device and browser characteristics, timestamps and page events.

LinkedIn provides us with aggregated reports on website audience and ad performance. LinkedIn members can object to the processing in their account settings.

Processing is exclusively based on your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. You can revoke your consent at any time via the cookie settings. Data may be transferred to the USA. LinkedIn uses standard contractual clauses and provides information on data protection at: https://www.linkedin.com/legal/privacy-policy and an opt-out at: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Leadinfo

We use the lead generation service of Leadinfo B.V., Rotterdam, Netherlands. This service identifies visits by companies to our website based on IP addresses and shows us publicly available information related to this, such as company names or addresses. In addition, Leadinfo sets two first-party cookies to evaluate user behaviour on our website and processes domains from form entries (e.g. "leadinfo.com") in order to correlate IP addresses with companies and improve its services. Further information can be found at www.leadinfo.com (https://www.leadinfo.com/). You have an opt-out option on this page: www.leadinfo.com/en/opt-out (https://www.leadinfo.com/en/opt-out). In the event of an opt-out, your data will no longer be collected by Leadinfo.

6. Email Newsletter

If you would like to subscribe to the newsletter offered on the website, we require an email address from you, as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively to send the requested information and do not pass it on to third parties.

The processing of the data entered into the newsletter subscription form is carried out exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You can revoke the consent given to store the data, the email address and its use for sending the newsletter at any time, for example via the "unsubscribe" link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

We use the "Inxmail" service provided by Inxmail GmbH, Wentzingerstraße 17, 79106 Freiburg, Germany, for managing and sending our newsletter. When you submit a subscription form, the data you provide (e.g. email address, and where applicable name, company) is stored in Inxmail so that we can manage the sending of your newsletter and clarify any follow-up questions.

Inxmail processes the data on our behalf. We have concluded a data processing agreement (DPA) with Inxmail, which ensures that the personal data of our newsletter recipients is processed only in accordance with our instructions and in compliance with the GDPR. Further information on data protection at Inxmail can be found at: https://www.inxmail.de/de/datenschutz/

The data you have provided to us for the purpose of subscribing to the newsletter will be stored by us or by the newsletter service provider until you unsubscribe from the newsletter, and will be deleted from the newsletter distribution list after unsubscribing from the newsletter or once the purpose no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion, within the scope of our legitimate interest pursuant to Art. 6(1)(f) GDPR.

Data stored with us for other purposes remains unaffected by this.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist, if this is necessary to prevent future mailings. The data in the blacklist is only used for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the statutory requirements for sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not subject to a time limit. You can object to this storage, provided your interests outweigh our legitimate interest.

7. Plugins and Tools

YouTube with extended data protection

This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of these websites on which YouTube is embedded, a connection to YouTube's servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you allow YouTube to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in extended data protection mode. According to YouTube, videos played in extended data protection mode are not used to personalise browsing on YouTube. Ads displayed in extended data protection mode are also not personalised. No cookies are set in extended data protection mode. However, so-called local storage elements are stored in the user's browser instead, which, similar to cookies, contain personal data and can be used for recognition purposes. Details on extended data protection mode can be found here: https://support.google.com/youtube/answer/171780

Depending on the case, further data processing operations may be triggered after a YouTube video is activated, over which we have no influence.

The use of YouTube is in the interest of an appealing presentation of our online services. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Further information on data protection at YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=en

The company holds a certification under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780

Google Fonts

This site uses what are known as Google Fonts, provided by Google, for the uniform display of fonts. When you access a page, your browser loads the required fonts into its browser cache in order to display texts and fonts correctly.

For this purpose, the browser you use must establish a connection to Google's servers. As a result, Google becomes aware that this website has been accessed via your IP address. The use of Google Fonts is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

If your browser does not support Google Fonts, a standard font from your computer will be used.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy at: https://policies.google.com/privacy?hl=en

The company holds a certification under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780

Google Maps

This site uses the Google Maps mapping service. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. This service enables us to embed map material on our website.

To use the functions of Google Maps, it is necessary to store your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. When Google Maps is activated, Google may use Google Fonts for the uniform presentation of fonts. When you access Google Maps, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.

The use of Google Maps is in the interest of an appealing presentation of our online services and easy findability of the places we indicate on the website. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

The transfer of data to the USA is based on the EU Commission's standard contractual clauses. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/

Further information on the handling of user data can be found in Google's privacy policy: https://policies.google.com/privacy?hl=en

The company holds a certification under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780