Privacy Policy 

Introduction Welcome to the Eberspacher Direct privacy policy. We respect your privacy and are committed to protecting your personal data. This policy informs you as to how we look after your personal data when you visit our informational website and tells you about your privacy rights and how the law protects you.

This document outlines how we handle your data and your rights regarding privacy.

Summary This policy explains how Eberspacher Direct (operated by Butlerbus Technik Ltd) collects and uses limited personal data on a non-transactional, informational website, and outlines your privacy rights. We collect identity/contact details you provide and technical/usage data via cookies; we do not collect financial, transactional, or special category data. Data is used for communication, site functionality, analytics, and support under lawful bases and may be processed by trusted third-party providers (e.g., hosting, analytics, ticketing) with appropriate security. You can manage cookies, opt out of marketing, exercise GDPR rights (access, correction, erasure, etc.), and contact our Data Privacy Manager or the ICO; data is retained only as necessary and may be disclosed when legally required.

1. Important Information and Who We Are

Purpose of this Privacy Policy This privacy policy aims to give you information on how Eberspacher Direct collects and processes your personal data through your use of this website. This includes any data you may provide when you sign up for our newsletter, download technical documents, or contact us with queries.

Controller Butlerbus Technik Ltd is the controller and responsible for your personal data (collectively referred to as “Eberspacher Direct”, “we”, “us” or “our” in this privacy policy). As Eberspacher Direct operates as an informational resource aligned with Butler Technik, your data is managed under the same high standards of security and compliance.

Contact Details If you have any questions about this privacy policy, please contact our data privacy manager:

• Full name of legal entity: Butlerbus Technik Limited
• Name of privacy manager: David Butler
• Email address: david.butler@butlertechnik.com
• Postal address: Aubourn Enterprise Centre, Bridge Road, Aubourn, Lincoln, LN5 9FD

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

2. The Data We Collect About You

Personal data means any information about an individual from which that person can be identified. Since Eberspacher Direct is an informational website and does not process direct sales, the data we collect is limited to what is necessary for communication and website optimization.

We may collect, use, store, and transfer the following kinds of personal data:

• Identity Data: Includes first name and last name (e.g., when you submit a contact form).
• Contact Data: Includes email address and telephone numbers.
• Technical Data: Includes internet protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data: Includes information about how you use our website (e.g., which technical guides or heater comparisons you view).
• Marketing and Communications Data: Includes your preferences in receiving newsletters or updates from us and your communication preferences.

What We Do NOT Collect As this is a non-transactional website, we do not collect:

• Financial Data: We do not store bank account or payment card details.
• Transaction Data: We do not process payments directly on this site.
• Special Categories of Personal Data: We do not collect data regarding race, health, religious beliefs, etc.

3. How Your Personal Data is Collected

We use different methods to collect data from and about you including through:

• Direct Interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by email. This includes personal data you provide when you:
• Subscribe to our service, newsletter, or technical publications;
• Request specific marketing or technical information be sent to you;
• Give us feedback or contact us with support queries.
• Automated Technologies (Cookies): As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and server logs.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., keeping our website updated and relevant, developing our business strategy).
• Legal Obligation: Where we need to comply with a legal obligation.
• Consent: Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

• To manage our relationship with you (e.g., notifying you about changes to our terms or privacy policy).
• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
• To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.

Marketing & Opting Out You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us directly.

5. Cookies

We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.

What is a cookie? A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

Managing Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Since we do not have a separate preference center, we recommend using your browser settings to manage these preferences.

6. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in Section 4:

• Internal Third Parties: Other companies in the Butlerbus Technik Group acting as joint controllers or processors.
• External Third Parties: Service providers acting as processors who provide IT and system administration services.
• Professional Advisers: Lawyers, bankers, auditors, and insurers.
• Regulators: HM Revenue & Customs, regulators, and other authorities who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent.

If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager at david.butler@butlertechnik.com.

No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. 2. Data Collected Data Storage Location

We are a Cyprus based company and operate web servers hosted in Germany. Our hosting provider Hetzner Online GmbH adheres to the EU/US “Privacy Shield”, ensuring that your data is securely stored and GDPR compliant. For more information on Hetzner Online GmbH privacy policy, please see here: Hetzner Data Privacy Policy Registration Data

If you register on our website, we store your chosen username and your email address and any additional personal information added to your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit this information. Purchase Data

To receive product support, you have to have one or more Envato/ThemeREX purchase codes on our website. These purchase codes will be stored together with support expiration dates and your user data. This is required for us to provide you with downloads, product support, and other customer services. Support Data

If you have registered on our website and have a valid support account, you can submit support tickets for assistance. Support form submissions are sent to our third party Ticksy ticketing system. Only the data you explicitly provided is sent, and you are asked for consent, each time you want to create a new support ticket. Ticksy adheres to the EU/US “Privacy Shield” and you can see their privacy policy here: Ticksy Privacy Policy. Comments

When you leave comments on the website we collect the data shown in the comments form, and also the IP address and browser user agent string to help spam detection. Contact Form

Information submitted through the contact form on our site is sent to our company email, hosted by Zoho. Zoho adheres to the EU/US “Privacy Shield” policy and you can find more information about this here: Zoho Privacy Policy.

These submissions are only kept for customer service purposes they are never used for marketing purposes or shared with third parties. Google Analytics

We use Google Analytics on our site for anonymous reporting of site usage. So, no personalized data is stored. If you would like to opt-out of Google Analytics monitoring your behavior on our website please use this link: Google Analytics Opt-out. Cases for Using the Personal Data

We use your personal information in the following cases:

• Verification/identification of the user during website usage;
• Providing Technical Assistance;
• Sending updates to our users with important information to inform about news/changes;
• Checking the accounts’ activity in order to prevent fraudulent transactions and ensure the security
• over our customers’ personal information;
• Customize the website to make your experience more personal and engaging;
• Guarantee overall performance and administrative functions run smoothly.

1. Embedded Content

Pages on this site may include embedded content, like YouTube videos, for example. Embedded content from other websites behaves in the exact same way as if you visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Below you can find a list of the services we use: Facebook

The Facebook page plugin is used to display our Facebook timeline on our site. Facebook has its own cookie and privacy policies over which we have no control. There is no installation of cookies from Facebook and your IP is not sent to a Facebook server until you consent to it. See their privacy policy here: Facebook Privacy Policy. X

We use the X API to display our tweets timeline on our site. X has its own cookie and privacy policies over which we have no control. Your IP is not sent to a X server until you consent to it. See their privacy policy here: X Privacy Policy. Youtube

We use YouTube videos embedded on our site. YouTube has its own cookie and privacy policies over which we have no control. There is no installation of cookies from YouTube and your IP is not sent to a YouTube server until you consent to it. See their privacy policy here: YouTube Privacy Policy. 4. Cookies

This site uses cookies — small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. Cookies generally exist to make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser. Necessary Cookies (all site visitors)

• cfduid: Is used for our CDN CloudFlare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. See more information on privacy here: CloudFlare Privacy Policy.
• PHPSESSID: To identify your unique session on the website.

Necessary Cookies (Additional for Logged in Customers)

• wp-auth: Used by WordPress to authenticate logged-in visitors, password authentication and user verification.
• wordpress_logged_in_{hash}: Used by WordPress to authenticate logged-in visitors, password authentication and user verification.
• wordpress_test_cookie Used by WordPress to ensure cookies are working correctly.
• wp-settings-[UID]: WordPress sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
• wp-settings-[UID]:WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.

1. Who Has Access To Your Data

If you are not a registered client for our site, there is no personal information we can retain or view regarding yourself. If you are a client with a registered account, your personal information can be accessed by:

• Our system administrators.
• Our supporters when they (in order to provide support) need to get the information about the client accounts and access.

1. Third Party Access to Your Data

We don’t share your data with third-parties in a way as to reveal any of your personal information like email, name, etc. The only exceptions to that rule are for partners we have to share limited data with in order to provide the services you expect from us. Please see below: Envato Pty Ltd

For the purpose of validating and getting your purchase information regarding licenses for this theme, we send your provided tokens and purchase keys to Envato Pty Ltd and use the response from their API to register your validated support data. See the Envato privacy policy here: Envato Privacy Policy. Ticksy

Ticksy provides the support ticketing platform we use to handle support requests. The data they receive is limited to the data you explicitly provide and consent to being set when you create a support ticket. Ticksy adheres to the EU/US “Privacy Shield” and you can see their privacy policy here: Ticksy Privacy Policy. 7. How Long We Retain Your Data For

When you submit a support ticket or a comment, its metadata is retained until (if) you tell us to remove it. We use this data so that we can recognize you and approve your comments automatically instead of holding them for moderation.

If you register on our website, we also store the personal information you provide in your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit that information. 8. Security Measures

We use the SSL/HTTPS protocol throughout our site. This encrypts our user communications with the servers so that personally identifiable information is not captured/hijacked by third parties without authorization.

In case of a data breach, system administrators will immediately take all needed steps to ensure system integrity, will contact affected users and will attempt to reset passwords if needed. 9. Your Data Rights General Rights

If you have a registered account on this website or have left comments, you can request an exported file of the personal data we retain, including any additional data you have provided to us.

You can also request that we erase any of the personal data we have stored. This does not include any data we are obliged to keep for administrative, legal, or security purposes. In short, we cannot erase data that is vital to you being an active customer (i.e. basic account information like an email address). If you wish that all of your data is erased, we will no longer be able to offer any support or other product-related services to you.

GDPR Rights

Your privacy is critically important to us. Going forward with the GDPR we aim to support the GDPR standard. ThemeREX permits residents of the European Union to use its Service. Therefore, it is the intent of ThemeREX to comply with the European General Data Protection Regulation. For more details please see here: EU GDPR Information Portal. 10. Third Party Websites

ThemeREX may post links to third party websites on this website. These third party websites are not screened for privacy or security compliance by ThemeREX, and you release us from any liability for the conduct of these third party websites. All social media sharing links, either displayed as text links or social media icons do not connect you to any of the associated third parties unless you explicitly click on them.

Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties or require disclosure of any personal information relating to members of the Service or Site. ThemeREX bears no responsibility for the information collected or used by any advertiser or third party website. Please review the privacy policy and terms of service for each site you visit through third party links. 11. Release of Your Data for Legal Purposes

At times it may become necessary or desirable to ThemeREX, for legal purposes, to release your information in response to a request from a government agency or a private litigant. You agree that we may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of a civil action, criminal investigation, or other legal matter. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you, and release your information to, third parties where we believe that it is prudent to do so for legal reasons, such as our belief that you have engaged in fraudulent activities. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants.

Any passing on of personal data for legal purposes will only be done in compliance with laws of the country you reside in.