On the WINGAS Website.

I. General information

1. Controller

The controller responsible for processing your personal data is:

WINGAS GmbH, Königstor 20, 34117 Kassel, Germany; Phone: +49 561 99858 0; Fax: +49 561 99858 1798; E-mail: info@wingas.de

2. Data Protection Officer

You can contact our Data Protection Officer at:

WINGAS GmbH, Datenschutzbeauftragter (Data Protection Officer), Königstor 20, 34117 Kassel, Germany; Phone: +49 561 99858 0; Fax: +49 561 99858 1798; E-mail: datenschutz@wingas.de

3. What data do we process and from what sources?

We process personal data you provide voluntarily or is gathered as part of use of our website.

You can find more information on this subject in Section II “Processing of personal data.”

4. For what purpose do we process your data and what is the legal basis for that?

We process your personal data in compliance with the relevant data protection regulations, in particular the General Data Protection Regulation (GDPR) and German Data Protection Act (BDSG), for various purposes. In principle, the purposes for which we process your data are: to perform contractual obligations (Article 6 paragraph 1 point (b) GDPR), to safeguard legitimate interests (Article 6 paragraph 1 point (f) GDPR), for processing subject to your prior consent (Article 6 paragraph 1 point (a) GDPR) and/or to comply with statutory obligations (Article 6 paragraph 1 point (c) GDPR).

You can find more information on this subject in Section II “Processing of personal data.”

5. Who obtains my data?

Service providers whom we engage to work on our behalf (termed “processors”; cf. Article 4 No. 8 GDPR) may obtain personal data. We use IT service providers as processors.

In principle, we do not pass on personal data to third parties who process personal data under their own responsibility (termed “controllers”; cf. Article 4 No. 7 GDPR). We pass on your data to controllers only if you explicitly request that by selecting an external recipient using our contact form. In such a case, we pass on the relevant personal data to the selected WINGAS company.

You can find more details on this subject in Section II “Processing of personal data.”

WINGAS can transfer personal data to affiliated companies within the meaning of Section 15 of the German Stock Corporation Act (AktG) inside the European Economic Area to a permissible extent, provided there are legitimate interests for doing so and statutory regulations are complied with. Those companies are: Gazprom Germania GmbH, Wingas Sales GmbH, Wingas Holding GmbH and Gazprom Marketing & Trading Ltd. Personal data is transferred to OOO Gazprom Export in Russia or PAO Gazprom in Russia as affiliated companies within the meaning of Section 15 of the German Stock Corporation Act (AktG) outside the European Economic Area (third country) on the basis of a standard data protection clause within the meaning of Article 46 GDPR. You can obtain a copy of that to inspect. To do so, please contact the controller or your Data Protection Officer specified in Section I, No. 1 and 2.

6. Data retention

We process your personal data only for as long as required to fulfill the purpose for which it is processed.

Moreover, we are subject to various retention and documentation obligations under legislation such as the German Commercial Code (HGB) or the German Fiscal Code (AO). The retention periods under the law may be up to 10 years.

Finally, the storage duration is also governed by the statutory limitation periods, which may be up to thirty years under Sections 195 et seq. of the German Civil Code (BGB), for example, with the standard limitation period being three years.

7. Security

WINGAS uses technical and organizational security measures to ensure that the personal data you supply us with is protected against accidental or deliberate manipulation, loss, destruction and/or access by unauthorized persons. Whenever we collect and process personal data, the information is transmitted in encrypted form to prevent misuse of this data by third parties. Our security measures are subject to continual further development in line with technical advances.

8. Your rights

Every data subject has the right to access personal data and obtain information (Article 15 GDPR), the right to rectification of data (Article 16 GDPR), the right to erasure of data (Article 17 GDPR), the right to restriction of processing (Article 18 GDPR), and the right to data portability (Article 20 GDPR). You can get in touch with us under the contact data specified in Section I “General information”, No. 1 and No. 2, to exercise the aforementioned rights.

If you have given us consent to process your data, you can revoke it at any time without using a special form. Where possible, notice of revocation should be sent to us using the contact data specified in Section I “General information”, No. 1 or No. 2.

Furthermore, you have a right to issue a complaint with a data protection supervisory authority (Article 77 GDPR). The supervisory authority responsible for WINGAS is:

The Hessian Data Protection Commissioner (HDSB)

You also have a right to object to the processing of your data, as explained in more detail at the end of this Data Privacy Statement.

II. Processing of personal data

1. Cookies

We use cookies on various pages to make your visit to our website appealing and enable you to use certain functions. Cookies are small text files that are stored on your device. They can be sent to a page when it is accessed and thus allow identification of the user. Cookies help make Internet sites more user-friendly. Some of the cookies used are deleted when the browser session is over, i.e. when you close your browser. They are termed session cookies. Other cookies remain on your device and enable us to recognize your browser again the next time you visit the website. They are termed persistent cookies.

You can set your browser so that you are notified when cookies are placed and can decide whether to accept them on a case-by-case basis or to exclude acceptance of cookies for specific cases or in general. You can delete cookies that have already been placed. If you do not accept cookies, the features of our website may be restricted.

We process the following personal data and categories of data using cookies:

• Your IP address
• The name of your Internet service provider
• The website from which you visit us
• The web pages you visit on our website

Personal data is processed using cookies on the basis of Article 6 paragraph 1 point (f) GDPR. The purpose of processing your data and our legitimate interests are to enhance the features of our website.

2. Automatic collection of access data/server log files

Whenever you visit our website, the following data record is stored each time the site or a page is called:

• Your IP address
• The name of your Internet service provider
• The website from which you visit us
• The web pages you visit on our website

Personal data in log files is processed on the basis of Article 6 paragraph 1 point (f) GDPR. The purpose of processing your data and our legitimate interests are to simplify administration of our website and to enable us to detect and prosecute hacking. The information is ultimately analyzed in anonymized form.

3. Google Analytics

This website uses Google Analytics, a web analytics service run by Google Inc. (“Google”). Google Analytics uses cookies, text files that are stored on your computer and enable analysis of how you use the website. The information on your use of this website generated by the cookie is usually transferred to a Google server in the USA and stored there.

However, if IP anonymization is activated on this website, your IP address will be abbreviated by Google beforehand within the member states of the European Union or in other countries that are party to the Agreement on the European Economic Area. The complete IP address is sent to a Google server in the U.S. and truncated there only in exceptional cases. IP anonymization is enabled on this website.

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 activities and to provide other services for the website operator relating to website and Internet use. The IP address sent from your browser as part of Google Analytics is not combined by Google with other data.

You can also prevent storage of the cookies by making the appropriate setting in your browser software; however, we point out that if you do so, you might not be able to use all the functions of this website in full. You can also prevent recording of the data relating to your use of the website and generated by the cookie (including your IP address) by Google and processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information on the terms of service for Google Analytics and data privacy at http://www.google.com/analytics/terms/de.html and www.google.com/intl/de/analytics/privacyoverview.html.

Processing of personal data using Google Analytics is based on Article 6 paragraph 1 point (f) GDPR. The purpose of processing your data and our legitimate interests are to analyze use of our website.

4. Google Maps

This Internet site uses the product Google Maps from Google. When you visit a sub-page in which Google Maps is embedded, Google is informed that you have called that sub-page on our website. Data is also collected and sent to Google by your browser. It includes your IP address, the date and time of the request, the amount of data transferred, the operating system and its interface, and the language and version of the browser software.

This is done irrespectively of whether Google offers a user account and you are logged into this account or you do not have a user account. If you are logged into Google, your data will be directly associated with your account. If you do not want Google to associate your actions with your profile, you must log out of your account before activating the button. Google stores your data as user profiles and uses it for the purposes of advertising, market research and/or designing its Internet site to suit needs. You must contact Google to exercise any rights, such as to object to creation of these user profiles.

By using Google Maps, you consent to the Google Maps Terms of Service. You can find the Google Maps Terms of Service at: [Google Maps Terms of Service]. You can find more details on processing of your personal data by Google Inc. in the Privacy Policy of Google Inc. It can be found at: [Google Privacy Policy]. Google also processes your personal data in the U.S. and participates in the EU-U.S. Privacy Shield [Link].

5. YouTube

We have integrated YouTube videos in our online offering. The videos are stored at www.youtube.com and can be played directly from our website. These videos are embedded in “extended data protection mode”, i.e. no data on you as the user will be transmitted to YouTube if you do not play the videos. The data specified in the following paragraph will only be transmitted when you play a video. We have no influence on the transmission of this data.

By playing the video, YouTube is informed that you have visited the relevant sub-page of our Internet site. Data is also collected and sent to YouTube by your browser. It includes your IP address, the date and time of the request, the amount of data transferred, the operating system and its interface, and the language and version of the browser software.

This is done irrespectively of whether YouTube offers a user account and you are logged into this account or you do not have a user account. If you are logged into Google, your data will be directly associated with your account. If you do not want YouTube to associate your actions with your profile, you must log out of your account before activating the button. YouTube stores your data as user profiles and uses it for the purposes of advertising, market research and/or designing its website to suit needs. Such an evaluation is conducted in particular (even for users who are not logged in) in order to provide advertising tailored to the user and to inform other users of the social network about your activities on our website. You must contact Google to exercise any rights, such as to object to creation of these user profiles.

You can find more information on the purpose and scope of the collection and processing of data by YouTube in the [Google Privacy Policy]. This policy also provides you with further information on your rights and the settings that you can use to protect your privacy. Google also processes your personal data in the U.S. and participates in the EU-U.S. Privacy Shield.

6. fonts.com

This website uses “fonts.com”, a font service from Monotype GmbH (“fonts.com”), Werner-Reimers-Strasse 2-4, 61352 Bad Homburg (“fonts.com”). Whenever this website is accessed, files from the “fonts.com” server are loaded to display the texts in a specific font. During this process your IP address may be transferred to a “fonts.com” server and stored as part of the usual server log. Responsibility for further processing of this information lies with “fonts.com”. Please refer to the Privacy Policy Statement (www.monotype.com/legal/privacy-policy) of “fonts.com” for the corresponding conditions and setting options.

7. Contacting us

Our Internet site contains a form that you can use to contact us electronically. You may also contact us using the e-mail addresses provided. If you contact us using one of these channels, we collect the personal data you enter and send.

The personal data recorded comprises the master data you enter in the contact form if you use it (mandatory fields: form of address, name, address, email address; voluntary fields: title, company, telephone number and fax) and possibly further personal data you enter in the “Your message” box. If you contact us directly by e-mail, we record your e-mail address and, if applicable, any personal data from the e-mail’s text.

If your contract request is addressed to a WINGAS company other than WINGAS GmbH, we pass on your request to that WINGAS company, which will then deal with it.

Data is processed on the basis of Article 6 paragraph 1 point (f) GDPR. The purpose of processing your data and our legitimate interests are to provide customer care and support, as well as to be able to answer messages and mails sent to us.

8. Newsletter

Our customers can subscribe to a newsletter containing information on the most important developments in wholesale market prices.

We process your e-mail address and your status as a customer of WINGAS as part of administering your newsletter subscription.

Data is processed on the basis of Article 6 paragraph 1 point (f) GDPR. The purpose of processing your data and our legitimate interests are to provide customer care and support, as well as to conduct direct marketing.

Ongoing development of the Internet means that we will need to amend this Data Privacy Statement from time to time. We reserve the right to make such changes at any time.