Version effective as of April 1, 2026

With this Data Protection Statement we, the companies of the 3A Composites-Group (hereinafter together “3AC”, “we” or “us”), describe how we collect and further process personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements or General Terms and Conditions, Conditions of Participation or similar documents are applicable to specific circumstances and subpages or other pages of the 3AC Group.

The term “personal data” in this Data Protection Statement shall mean any information that identifies, or could reasonably be used to identify any person. If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and such personal data is correct.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection Act («revDPA»). However, the application of these laws depends on each individual case.

1. Controller / Data Protection Officer / Representative

1.1 Controller

Unless we have informed you differently in certain cases, the “controller” of data processing as described in this data protection statement (i.e. the responsible person) is:

3A Composites GmbH
Alusingenplatz 1
78224 Singen
Germany
Phone: +49 7731 941 3500
E-Mail: 3ac.datenschutz@3acomposites.com

You can notify us of any data protection related concerns, irrespective of the concerned affiliate company of 3AC, using the above contact details.

1.2 Data Protection Officer

We have appointed an external Data Protection Officer who can be contacted using the following contact details:

Pfeil Concepts GmbH
David Pfeil
Schloßstraße 28
04425 Taucha
Germany
Phone: +49 34298 158920
E-Mail: 3ac.datenschutz@3acomposites.com

You can contact our data protection officer pursuant to art. 37 GDPR who additionally is our representative in the EEA according to article 27 GDPR (if necessary) using the above contact details.

2. Collection and Processing of Personal Data

We primarily process personal data that we obtain from our clients and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users when operating our websites, apps and other applications.

Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g., debt registers, land registries, commercial registers, press, internet) or we may receive such information from affiliated companies of 3AC, from authorities or other third parties. Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities, information about you in correspondence and discussions with third parties, credit rating information, information about you given to us by individuals associated with you, information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services, information about you found in the media or internet, your address and any interests and other socio-demographic data, and data in connection with your use of our websites (e.g., IP address, MAC address of your smartphone or computer, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).

3. Purpose of Data Processing and Legal Grounds

We primarily collect data in order to conclude and process contracts with our clients and business partners, in particular in connection with the purchase, sale or distribution as well as the development of our Composites Materials and Composites Solutions to our clients and the procurement of products and services from our partners, suppliers and subcontractors, as well as in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such a client or business partner.

In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties’) legitimate interest, such as:

• providing and developing our products, services and websites, apps and other platforms;
• communication with third parties and processing of their requests (e.g., job applications, media inquiries);
• review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
• advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose;
• market and opinion research, media surveillance;
• asserting legal claims and defense in legal disputes and official proceedings;
• prevention and investigation of criminal offences and other misconduct;
• ensuring our operation, including our IT, our websites, apps and other appliances;
• video surveillance to protect our domiciliary rights and other measures to ensure the safety of our premises and facilities as well as protection of our employees and other individuals and assets;
• acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto.

If you have given us your consent to process your personal data for certain purposes, we will process your personal data within the scope of and based on this consent, unless we have another legal basis. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

4. Cookies / Tracking and Other Techniques Regarding the Use of our Website

COOKIES

We typically use “cookies” and similar techniques on our websites and apps, which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website or install our app. If you revisit our website or use our app again, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the website (“session cookies”), we may use cookies in order to save user configurations and other information for a certain time period (e.g., two years) (“permanent cookies”). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies for the purpose of saving user configuration (e.g., language, automated log in), in order to understand how you use our services and content and to enable to show you customized offers and advertisement. Certain cookies are sent to you from us, others from business partners with which we collaborate. If you block cookies, it is possible that certain functions (such as, e.g., language settings, shopping basket, ordering processes) are no longer available to you.

By using our websites and apps and consenting to the receipt of newsletters and other marketing e-mails you agree to our use of such techniques. If you object, you must configure your browser or e-mail program accordingly or uninstall the app, should the respective setting not be available.

GOOGLE ANALYTICS

We may use Google Analytics or similar services on our website. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics, Google Ireland Ltd. (located in Ireland), which relies on Google LLC (located in the United States) as its sub-processor (both «Google»), www.google.com) and which allow us to measure and evaluate the use of our website (on an anonymized basis). For this purpose, permanent cookies are used, which are set by the service provider. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the «Data sharing» option and the «Signals» option. Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. If you have registered with the service provider, the service provider will also know your identity. In this case, the processing of your personal data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website (but not any personal information of you).

GOOGLE reCAPTCHA

We use “Google reCAPTCHA” on this website, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. reCAPTCHA is used to protect inputs on our website from abusive automated data extraction and from spam. For this purpose, reCAPTCHA analyzes various information about the behavior of the website visitor, in particular the IP address, duration of the visit, mouse movements, as well as other data required to detect bots.

The processing is carried out on the basis of Art. 6(1)(f) GDPR. Our legitimate interest lies in protecting our web services from abusive automated use and spam. Where the use of reCAPTCHA requires the storage of information on your device or access to information already stored, this is carried out solely on the basis of your consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG, provided that such consent has been obtained. The data may be transmitted to Google and processed there. A transfer to third countries cannot be ruled out. Google is certified under the EU-US Data Privacy Framework. Further information on Google reCAPTCHA can be found in Google’s terms of service and privacy information at https://cloud.google.com/terms/service-terms.

ROOMVO / PRODUCT VISUALIZATION (LEAP TOOLS)

On this website we may use “Roomvo”, a product-visualization service provided by Leap Tools Inc. (“Leap Tools”), which allows you to preview products in a room or on a surface. When you use this feature, Roomvo may use cookies and similar tracking technologies and may collect and process information such as images you upload, device and browser information, IP address, and usage data in order to provide and improve the visualization service. This data may be processed by Leap Tools in accordance with its own policies. Your use of the Roomvo feature is subject to Leap Tools’ Terms of Use, available at https://get.roomvo.com/terms_of_use, and Leap Tools’ Privacy Policy, available at https://get.roomvo.com/privacy_policy/, in each case as then in effect. We incorporate privacy and use terms for this feature that are substantially similar to, and no less protective than, Leap Tools’ Privacy Policy. If you do not agree to these terms, please do not use the Roomvo visualization feature.

SOCIAL MEDIA PLUG-INS

On this website we do not use plug-ins from social networks such as e.g. Facebook, Twitter, YouTube, Pinterest or Instagram. However, subsites, apps or other websites of 3AC may use social media plug-ins. In such case you will be informed by the respective separate data protection statement on such subsite, app or other website.

5. Data Transfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted under the applicable law and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:

• our service providers (within the 3AC group or externally, such as e.g. banks, insurances), including processors (such as e.g. IT providers);
• dealers, suppliers, subcontractors and other business partners;
• clients;
• domestic and foreign authorities or courts;
• the media;
• the public, including users of our websites and social media;
• competitors, industry organizations, associations, organizations and other bodies;
• acquirers or parties interested in the acquisition of business divisions, companies or other parts of the 3AC group;
• other parties in possible or pending legal proceedings;
• affiliates of the 3AC group (together “Recipients”).

Certain Recipients may be within Switzerland but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to any country in which the 3AC-Group is represented by affiliates, branches or other offices as well as to other countries in Europe and the USA where our service providers are located (such as Microsoft, SAP, Amazon, Salesforce.com, etc.).

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception.

6. Retention Periods for your Personal Data

We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship as well as beyond this duration in accordance with legal retention and documentation obligations under the applicable laws. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention. As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g., system logs).

7. Data Security

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as internal policies, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions and pseudonymisation.

8. Obligation to Provide Personal Data To Us

In the context of our business relationship you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations. However, without this information we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the website may not be accessible to you unless certain information is disclosed to enable data traffic (e.g. IP address).

9. Profiling and Automated Individual Decision-Making

We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about products possibly relevant for you more accurately. In establishing and carrying out a business relationship, we generally do not use any fully automated individual decision-making (such as pursuant to article 22 GDPR). Should we use such procedures in certain cases, we will inform you separately and advise you of your relevant rights if required by law.

10. Your Rights

In accordance with and as far as provided by applicable law, you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, in addition to the right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part. In general, exercising these rights requires that you are able to prove your identity. In order to assert these rights, please contact us at the addresses provided in Section 1 above. In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Amendments of this Data Protection Statement

We may amend this Data Protection Statement at any time without prior notice. The current version published on our website shall apply. If the Data Protection Statement is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.