Data Protection Declaration

  1. Information regarding the collection of personal data

1.1 Below, we will provide you with information about the collection of personal data in the case of conclusion of an employment contract as a client, professional company, supplier, business partner, or other contractual partner (for example, as part of an application or employment relationship) or when using our website. Personal data pertains to all data traceable to you personally, such as name, address, email addresses, user behavior.

1.2. The responsible party as per Art. 4 (7) EU General Data Protection Regulation (GDPR) and other national data protection laws in the member states as well as other legal provisions related to data protection in Germany is:

Arvos Ljungstrom LLC

3020 Truax Road, New York 14895, USA

President: David Breckinridge

Tel.: +1 (585) 593 2700

Fax: +1 (585) 593 3090

E-Mail: [email protected]

1.3. When you contact us via post, telephone, email or contact form, the information you provide (your email address, your name and your telephone number, if applicable) will be stored by us to answer your questions. We delete the data gathered in this context once its storage is no longer necessary or we restrict its processing should statutory retention obligations exist. Furthermore, we collect and use personal data of the data subjects and users of our website only – among others, to provide a functioning website – as far as this is necessary in the context of our contents and services or in the context of a contract fulfillment. The collection and use of personal data from the data subjects and users of our website can generally only take place once consent has been granted by the users. An exception applies in cases where prior consent cannot be given for practical reasons and/or the processing of the data is permitted by legal regulations.

1.4. Should we wish to make use of subcontracted service providers for individual features of our offer, or use your information for promotional purposes, we will subsequently inform you about the respective processes in detail. In doing so we will also indicate the fixed criteria for the storage period.

  1. Your rights – Legal grounds

2.1. You have the following rights in relation to us with regards to your personal data:

– Right to access

– Right to rectification or erasure

– Right to restriction of processing

– Right to objection to processing

– Right to data transferability.

2.2. Where we obtain consent from the data subject for processing personal data, Art. 6 (1)(a) GDPR provides the legal grounds for the processing of personal data. When processing personal data required for the performance of a contract in which the data subject is a contracting party, Art. 6 (1)(b) GDPR provides the legal grounds. This also applies to processing procedures required for the implementation of pre-contractual measures. Where the processing of personal data is required for compliance with a legal obligation to which our company is subject, Art. 6 (1)(c) GDPR provides the legal grounds. In the case that the vital interests of the data subject or another natural person render the processing of personal data necessary, Art. 6 (1)(d) GDPR provides the legal grounds. If the processing is required to safeguard a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-named interests, Art. 6 (1)(f) GDPR provides the legal grounds for processing.

2.4 We do not use any automatic decision making which is exclusively based on an automatic processing such as Profiling and which has legal effect or affects you in a similar way.

  1. Collection of personal data when visiting our website

3.1. In the event of purely informational use of the website, i.e., if you don’t register or otherwise provide us with information, we will only collect the personal data that your browser transfers to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to show you our website and to ensure stability and security (legal grounds Art. 6 (1) Clause 1 (f) GDPR):

– IP address

– Date and time of the request

– Time Zone Difference to Coordinated Universal Time (UTC)

– Content of the request (specific page)

– Access status/http status code

– Each transmitted quantity of data

– Website from which the request comes

– Browser

– Operating system and its interface

– Language and version of the browser software.

3.2. In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive and assigned to the browser that you are using and allow the site that sets the cookie (here ours) to receive certain information. Cookies cannot run programs or transfer viruses to your computer. They serve to make the internet experience more user-friendly and effective overall.

3.3. Use of cookies:

3.3.1. This website uses the following types of cookies, the scope and operation of which are explained below:

– Transient Cookies (for this 3.3.2.)

– Persistent Cookies (for this 3.3.3.)

3.3.2. Transient cookies are automatically deleted when you close the browser. In particular, these include the session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This will allow your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

3.3.3. Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

3.3.4. You can configure your browser settings according to your wishes and, for example, reject the acceptance of third-party cookies or all cookies. Please be aware that you may not be able to use all features of this website.

3.4. All data is deleted as soon as it is no longer required to fulfill the purpose of its collection. If the data is collected for the provision of the website, this is the case when the respective session is completed.

3.5. If the data is stored in log files, this is the case after seven (7) days at the latest. Further storage is possible. The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

3.6. Information about third-party provider (web host): Inmotion Hosting, Inc., 3629 Sentara Way #303, Virginia Beach, VA, USA, Phone: 23452 757-416-6575 , privacy policy: https://www.inmotionhosting.com/privacy-policy.  Innmotion Hosting, Inc. acts in accordance with the GDPR but is not certified under the Privacy-Shield-Website: https://www.inmotionhosting.com/support/community-support/general-information/what-is-your-data-protection-policy.

  1. Other features and offers of our website – external service providers

4.1. In addition to the purely informative use of our website, we offer various services that you may be interested in using. To do this, you will generally need to provide other personal information that we use to provide the service and for which the aforementioned data processing principles apply.

4.2. In some instances, we use external service providers to process your data as listed in this declaration. These have been carefully selected and commissioned by us, are bound by our instructions and are audited regularly. Your data provided will exclusively be used or processed for carrying out the services you are interested in.

4.3. Additionally it can be necessary that your data is forwarded to other entities of our group of companies. In that case we comply with applicable data protection laws. Furthermore courts, prosecution authorities or other legally competent authorities can request forwarding of your data or information about it. Your personal data can particularly be forwarded to:

  • Our mother company ARVOS Holding GmbH, or to other group companies,
  • IT-Providers, waste and disposal service providers,
  • Authorities, state agencies, banks.

4.4 Due to our global headquarter being located in Wellsville, USA we are mainly using service provider from the USA which might not have the same data protection level as required under the GDPR.

  1. Objection to or revocation of the processing of your data

5.1. Should you have granted consent for the processing of your data you may modify or completely revoke this at any time without providing reasons. You can send this revocation to us (see Clause 1.2. – Responsible Party) by post, email, fax, or in the form that was used when issuing the declaration of consent. No extra costs are incurred in such cases, other than postage costs or transmission costs in accordance with existing basic tariffs.

Such a revocation will impact the legitimacy of the processing of your personal data once you have sent it to us.

5.2. Where we support the processing of your personal data by referring to the balance of interests you can submit an objection to the processing. This is the case in particular if we do not require the processing to fulfill a contract with you. In the case of the following website uses, this will be additionally shown by us in the following description of the function. When exercising such an objection we ask that you provide the reasons for which we should not have processed your personal data as we have done. In the case that you provide an objection with reasons we will examine the situation and will either adjust or modify the data processing or indicate to you the mandatory reasons for continuing with the processing.

5.3. Of course, you may object to the processing of your personal data for marketing and data analysis purposes at any time. You may inform us about your objections to marketing by contacting us using the following contact information: [email protected]

  1. Use of Google Analytics

6.1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, due to the activation of IP anonymization on this website, your IP address will be shortened by Google beforehand within member states of the European Union or another contracting state of the Agreement on the European Economic Area (EEA). The full IP address will only be sent to a Google server in the US and shortened there in exceptional cases. 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 activity and to provide other services related to website usage and internet usage to the website operator.

6.2. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

6.3. You can prevent the storage of cookies with corresponding settings for your browser software; however, we point out that in this case you may not be able to use all features of this website in full. You may also prevent Google’s collection of data (including your IP address) generated by the cookie from your use of the website from Google and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

6.4. This website uses Google Analytics with the extension “_anonymizeIp()”. As a result, IP addresses are processed in a shortened form; a direct personal reference can be excluded. If a personal reference is contained in the data collected about you, it will be immediately excluded, and the personal data will be deleted immediately.

6.5. We use Google Analytics to analyze and regularly improve the use of our website. We can improve our offering with the statistics and make it more relevant for you as a user. For the exceptional cases in which personal data is transferred to the US, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 (1) Clause 1 (f) GDPR.

6.6. Information about third-party provider: Google LLC („Google“), Amphitheatre Parkway, Mountain View, CA 94043, USA. Terms of service: https://policies.google.com/terms?hl=de&gl=de, Overview of data protection: https://support.google.com/analytics/answer/6004245?hl=en

  1. Google Maps integration

7.1. We use Google Maps on our website. This allows us to show you interactive maps directly on the website and allows you to conveniently use the map feature.

7.2. By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. In addition, the data referred to in Clause 3 of this declaration will be transmitted. This is done regardless of whether Google provides an account that you are logged in to, or if there is no user account. If you’re logged in via Google, your data will be assigned directly to your account. If you do not wish this to be associated with your profile on Google, you must log out before activating the button. Google stores your data as usage profiles and uses them for purposes of advertising, market research and/or tailor-made website design. Such an evaluation is done in particular (even for non-logged in users) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have a right of objection to the formation of these user profiles, whereby you must contact Google to exercise them.

7.3. For more information on the purpose and scope of the data collection and its processing by the plug-in provider, please refer to the provider’s privacy policy. There, you will also find more information about your rights and settings options to protect your privacy: https://www.google.de/intl/en/policies/privacy. Google also processes personal information in the US and is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

  1. Integration of YouTube videos

8.1. We’ve included YouTube videos in our online offering, which are stored on http://www.youtube.com and are directly accessible from our website. User data is transferred when the videos are played. We have no influence on this data transfer.

8.2. By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data referred to in Clause 3 of this declaration will be transmitted. This is done regardless of whether YouTube provides an account that you are logged in to, or if there is no user account. If you are logged in via Google, your data will be assigned directly to your account. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for purposes of advertising, market research and/or tailor-made website design. Such an evaluation is done in particular (even for non-logged in users) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have a right of objection to the formation of these user profiles, whereby they must be directed to YouTube for the exercise.

8.3. Please read the privacy policy for more information on the purpose and scope of your data collection and processing through YouTube. There you will also get further information about your rights and settings options to protect your privacy: https://www.google.de/intl/en/policies/privacy. Google also processes personal information in the US and is subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

  1. Online meetings with Microsoft Teams

We use “Microsoft Teams” to hold online meetings. Microsoft Teams is a software product of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”) which is available as a desktop, web and mobile app.


The legal basis for data processing when holding meetings with Microsoft Teams is our legitimate interest in the effective holding of business meetings according to Art. 6 Para. 1, Sentence 1 lit. f of the GDPR. Insofar as the meetings are held with you as part of an existing contractual relationship, the legal basis is Article 6 Paragraph 1 Sentence 1 lit. b of the GDPR. We are not responsible for further data processing on the Microsoft product websites from which the desktop software can be downloaded and the web app can be used.

The following data may be processed during a meeting:

  • Information about the participant: display name, first name, last name, telephone number, e-mail address, password (encrypted for authentication), profile picture,
  • Metadata: topic and description of the meeting, IP address, telephone number of the participant, type of device / software (Windows / Mac / Linux / Web / iOS / Android Phone / Windows Phone), time of the last activity of the participant, number of Chat and channel messages, number of meetings attended, length of time for audio, video and screen sharing,
  • When using chat or channel messages: text data for display and, if necessary, logging,
  • When using audio: recording data of the microphone,
  • When using video: recording data of the camera,
  • When using a telephone: incoming and outgoing phone numbers, country name, start and end time, possibly other connection data such as the IP address of the device, and
  • For recordings: audio, video and screen shares for storage in the cloud.

The data is stored at Microsoft Teams for the duration in accordance with our retention guidelines.

You can register for a meeting via e-mail. Your login data will be processed by us. You will be given a calendar appointment before the meeting. To participate in a meeting, you must at least provide us with your name or – if you are using a telephone – your telephone number. If we enable anonymous participation in meetings, we will inform you of this option during the invitation.

You can deactivate your microphone (audio) and your camera (video) at any time via the corresponding settings. We will only record meetings with your consent. Microsoft uses the metadata to generate aggregated reports on the use of Microsoft Teams.

Microsoft use the above data during the meetings to enable the meetings to be carried out on our behalf. All data traffic is encrypted (MTLS, TLS or SRTP) and data is generally stored on servers in the European Economic Area (EEA). If data is still processed in the USA, we have concluded EU standard contractual clauses with Microsoft in addition to the above-mentioned measures to protect your privacy.

You can find more information in Microsoft’s privacy policy, available at: https://privacy.microsoft.com/de-de/privacystatement

  1. Contact form and email contact

10.1. There is a contact form on our web page which can be used to get in touch electronically. If you make use of this option, the data you provide will be transferred to and saved by us. This data includes:

Required fields:

– Name

– Email address


– Company name

– Phone number

– Enquiry

At the time of sending the message the following data is also saved:

  1. a) IP address
  2. b) Date and time of sending the request

For the processing of the data, your consent will be obtained within the scope of the sending process and you will be referred to the data protection declaration. Alternatively, you can get in touch via the email address provided. In this case, the user’s personal data transmitted with the email will be saved. In this connection, there is no forwarding of the data to third parties. The data is solely used for processing the conversation.

10.2. The legal grounds for data processing, in the case that consent is granted by the user, are provided by Art. 6 (1)(a) GDPR. The legal grounds for data processing, transferred as part of an email, are provided by Art. 6 (1)(f) GDPR. If the purpose of the email/mail contact is the performance of a contract, Art. 6 (1)(b) GDPR provides additional legal grounds for processing.

10.3 The processing of personal data from the input screen solely serves us for contact purposes. In the case of contact being established by email, the required justified interests in the processing of the data are also included. Other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our IT systems.

10.4. The data is deleted as soon as it is no longer required to fulfill the purpose of its collection. This is the case for the personal data from the contact form input screen and that transferred by email if the respective conversation with the user has been brought to a close. The conversation has been brought to a close if circumstances indicate that the relevant subject matter has been conclusively clarified.

10.5 You always have the possibility to withdraw your agreement with the processing of your personal data. Should you contact us via E-Mail you can either request a change for the future or entirely dissent to the filing of your personal data without giving any specific reason. You can address your dissent via courier, E-mail, Fax (see data under clause 1.2) or you can submit your dissent in the same for as you have given it. In such a case we will immediately stop such filing and delete your data.

  1. External links

If you use external links that are offered within the scope of our Internet pages, this data protection declaration does not extend to these links. We accept no responsibility for external content provided for use via links and do not adopt their content as our own.

If we offer links, we assure that at the time the links were set, no violations of applicable law were discernible on the linked Internet pages. However, we have no influence on compliance with data protection and security regulations by other providers. Therefore, please also inform yourself about the data protection declarations provided on the websites of other providers.



Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Arvos Ljungström, a division of the ARVOS Group (“LJUNGSTRÖM”), is committed to combat slavery and human trafficking.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending on March 31, 2022 and was approved by the Executive Board of the ARVOS Group on September 24, 2021.


LJUNGSTRÖM is a global technology and innovation leader, specializing in full life-cycle services and solutions for thermal power plants and industrial facilities. With a history of heat recovery advances spanning 95 years, LJUNGSTRÖM is redefining clean thermal power technologies through its deep customer and technical knowledge, worldwide.

LJUNGSTRÖM serves the thermal power plant market with three key applications: air preheaters, gas-g​as heaters and LJUNGSTRÖM AdvX™, based on our genuine Ljungström® technology platform.

LJUNGSTRÖM has under 700 employees in the USA, Germany, India, Japan, China and the Czech Republic, with approximately 30% in the USA.


Our supply chains include procurement of steel, construction and erection services, manufacturing of machined and non-machined small and major metal parts to be integrated into our products and services. Steel purchases, primarily in the USA and Canada, account for a large portion of LJUNGSTRÖM’s total supply chain spends. Although we believe that there is limited incidence of modern slavery and human trafficking in the steel industry, especially in the United States and Canada, we remain extra vigilant in our developing countries where modern slavery and human trafficking are more prevalent.


We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free, we have established a number of provisions in our Group’s Code of Conduct and in our Group’s Sourcing Policy to wit, in pertinent part:

Human Rights, Employment and Work Safety

Human Rights: ARVOS respects and supports the protection of internationally proclaimed human rights in line with the United Nations Universal Declaration of Human Rights.

International Labor Organization (ILO): ARVOS supports the principles laid down in the ILO’s Declaration on Fundamental Principles and Rights at Work. It supports the work of the ILO in formulating and enforcing international labor and social standards and creating work in conditions of human dignity as a core requirement for combating poverty.

Freedom of Association: ARVOS acknowledges and promotes the freedom of association and the right of workers to collective bargaining within the bounds of prevailing laws and statutes. ARVOS ensures that union representatives are not discriminated against.

Forced Labor: ARVOS does not tolerate any form of forced or compulsory labor.

Human Trafficking: ARVOS does not tolerate or condone or engage in any form of human trafficking or slavery in any part of its global organization.

Child Labor: ARVOS supports the elimination of exploitative child labor. It employs only workers who are at least 15 years, or if a higher age limit applies in the country, then this age limit is complied with.

ARVOS accepts only a minimum age of 14 years by way of an exception, if a statutory minimum age of 14 years applies in the country in which the work is being performed. ARVOS commits to complying with the Convention concerning the minimum age for admission to employment (Convention No 138 of the International Labour Organization) as well as the Convention concerning the prohibition and immediate action for the elimination of the worst forms of child labor (Convention No 182 of the International Labour Organization). If a national regulation concerning child labor provides for stricter measures, these shall have precedence.

Equal Employment Opportunities: ARVOS observes all regulations in the relevant countries providing for equal employment opportunities and does not tolerate any illegal discriminatory treatment of its Employees, unless national law expressly provides for selection according to specific criteria. It hires, compensates and promotes Employees on the basis of their qualifications and performance.


ARVOS’ Suppliers and Contractors shall in particular comply with the following:

  • Elimination of all forms of illegal, forced, or compulsory labor, including direct or indirect use of labor generated by human trafficking
  • Elimination of child labor: Suppliers and Contractors shall not employ persons not having reached the minimum age required for work and shall never support the use of child labor, except as part of an official government approved educational youth training scheme
  • Elimination of discrimination of any kind in respect of employment and occupation
  • Compliance with applicable laws and regulations related to maximum working hours and minimum days of rest
  • Compliance with applicable laws and regulations related to the minimum level of wage
  • Respect for freedom of association for their employees, in compliance with applicable laws
  • Compliance with applicable laws and regulations related to layoff.

Those Sections demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.


As part of our initiative to identify and mitigate risk we have made accountable the responsible LJUNGSTRÖM heads of supply chain to report any issues pertaining to modern slavery and human trafficking to the ARVOS Group Management, who in turn report any issues to the Group’s Risk Management Function for immediate action and remediation.

LJUNGSTRÖM reserves the right to audit our business partners and our supply chains to help:

  • Identify and assess potential risk areas in our supply chains
  • Identify inappropriate employment practices
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains
  • Monitor potential risk areas in our supply chains
  • Protect whistle blowers, including a world class anonymous whistle blower procedure


At LJUNGSTRÖM we have zero tolerance for slavery and human trafficking. To ensure that all those in our supply chain and contractors comply with our values, we operate in line with principles of responsible sourcing, including paying employees at the prevailing minimum wage applicable within their relevant county of operations. Also, we have in place a compliance programme, which is designed to require our suppliers and other business partners to confirm adherence to the principles set forth above or to, at least, demonstrate that they have equivalent principles and policies in place (self-certification).


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff as part of our overall Compliance Trainings. This includes all employees in a live session conducted at least every other year on adherence to our Code of Conduct.

Going Forward

Going forward, we will continue to be vigilant in this area and intend to increase our training and enforcement efforts in the LUNGSTRÖM division in developing countries where modern slavery and human trafficking have had the highest incidence.

Arvos Ljungstrom, a division of the ARVOS Group

Chattanooga, Tennessee U.S.A.

September 27, 2021


David Breckinridge